DDIT (IT)-4(1), MUMBAI vs. M/S. LINKLATERS, MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blelinklaters V. Ddit (International Taxation) – 4(1) Scindia House, N.M. Road C/O. Deloitte Haskins & Sells Llp Bellard Estate, Mumbai - 400001 Indiabulls Finance Centre Tower 3 28Th Floor, Senapati Bapat Marg Elphinstone Road (West) Mumbai - 400013 Pan: Aabfl2160M (Appellant) (Respondent) Ddit (International Taxation) – 4(1) V. Linklaters Scindia House, N.M. Road C/O. Deloitte Haskins & Sells Llp Bellard Estate, Mumbai - 400001 Indiabulls Finance Centre Tower 3 28Th Floor, Senapati Bapat Marg Elphinstone Road (West) Mumbai - 400013 Pan: Aabfl2160M (Appellant) (Respondent)

section 91(7) of the Income-tax Act is applicable in this case. Further, in reference to Article 5(1) and 5(2) he relied on the decision of the ITAT, in assessee’s own case, wherein the Hon’ble bench has considered the elaborate submissions from the assessee and decided the issues in favor of the revenue. 11. With

ASIA INVESTMENTS PVT.. LTD.,MUMBAI vs. DCIT ,CIRCLE 2 (1)(1), MUMBAI

In the result, all the three appeal

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

5. Without prejudice to the Grounds No 1,2 and 3 on the facts and in the Without prejudice to the Grounds No 1,2 and 3 on the facts and in the Without prejudice to the Grounds No 1,2 and 3 on the facts and in the circumstances of the case and in law the learned

JAI JALARAM CO-OPERATIVE CREDIT SOCIETY LIMITED,MUMBAI vs. THE INCOME TAX OFFICER, WARD 29(1)(5), MUMBAI

In the result appeal of the assessee is allowed partly for esult appeal of the assessee is allowed partly for esult appeal of the assessee is allowed partly for statistical purpose

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-16 Jai Jalaram Co-Operative Credit The Ito Ward 29(1)(5), Society Ltd., Kautilya Bhavan, Bandra Kurla Vs. Shop No. -2 Ground Floor, Shop Complex, No. -2 Ground Floor, Mulund Mumbai-400051. Siddhivinayak C.H.S. Near Punjab National Bank Zaver Road, Mulund West, Mumbai-400080. Pan No. Aaaaj 2603 B Appellant Respondent

disallowing the deduction of Rs 2,86,069/- claimed u/s 80P of the Act. claimed u/s 80P of the Act. Accordingly, the appeal is 'Dismissed.” 'Dismissed.” 4. We have carefully perused the orders passed by the lower We have carefully perused the orders passed by the lower We have carefully perused the orders passed by the lower authorities, material

JEEVANDEEP EDUMEDIA PRIVATE LIMITED,MUMBAI vs. PRINCIPLE CIT-6, MUMBAI

In the result, the a In the result, the appeal of the assessee is stands allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Jeevandeep Edumedia Pvt. Ltd., Pr. Cit-6, 1St Floor, Sun Paradise Business 501,5Th Floor, Aayakar Bhavan, Plaza, Senapati Bapat Marg, Vs. Maharishi Karve Road, Lower Parel (West), Mumbai-400020. Mumbai-400013. Pan No. Aabcj 0180 G Appellant Respondent

2. On the facts and circumstances of the case and in law the learned PCIT erred in disallowing the deduction of donation paid and claimed in PCIT erred in disallowing the deduction of donation paid and PCIT erred in disallowing the deduction of donation paid and accordance with the provisions of section 80G of Income tax Act of accordance with

ITO(E)-1(1), MUMBAI, MUMBAI vs. BHAVITHA FOUNDATION, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22

section 11(5)investment in shares is not a specified mode. Consequently, the dividend received there from such shares could not be therefore qualify dividend received there from such shares could not be therefore qualify dividend received there from such shares could not be therefore qualify to be an investment in specified modes us 11(5

RUSTOMJEE ASPIREE PREMISES CO-OP SOC. LTD ,MUMBAI vs. ITO, WARD 26(2)(5), MUMBAI

In the result the appeal filed by the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18 Rustomjee Aspiree Premises Co- Ito Ward 26(2)(5), Op. Soc. Ltd., Room No. 319, 3Rd Floor, Kautilya Vs. Ground Floor, Rustomjee Bhavan, C-41 To C-43, ‘G’ Block Aspiree, Cts No. 628, Ai, Pt Bandra Kurla Complex, Bandra Kurla, Eatern Express Highway, (East), Mumbai-400051. Sion, Mumbai-400022. Pan No. Aabar 4001 L Appellant Respondent

disallowed deduction claimed u/S 80P(2)(d) of the Income Tax Act and in the deduction claimed u/S 80P(2)(d) of the Income Tax Act a deduction claimed u/S 80P(2)(d) of the Income Tax Act a light of the decision of the Supreme Court with regard to the same light of the decision of the Supreme Court

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-2(1), MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

2), specific modes of investment/ deposits under section 11(5) and other related provisions of Section 13”. Satisfied with the details filed by the assessee, the Assessing Officer had no issues with respect to section 11 and 15, and he noted that the income derived from property held under trust, which included these investments, is covered by the exemption under

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. ADDITIONAL /JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, NFAC, MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

2), specific modes of investment/ deposits under section 11(5) and other related provisions of Section 13”. Satisfied with the details filed by the assessee, the Assessing Officer had no issues with respect to section 11 and 15, and he noted that the income derived from property held under trust, which included these investments, is covered by the exemption under

DY. COMMISSIONER OF INCOME-TAX, MUMBAI vs. QUANTUM ADVISORS PVT. LTD., MUMBAI

In the result, the appeal of the Revenue is allowed

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2015-16 Dcit-1(3)(1), M/S Quantum Advisors Pvt. Ltd., Room No. 535, 5Th Floor, 503, Regent Chambers, Nariman Vs. Aayakar Bhavan, Point, Mumbai-400021. M.K. Road, Mumbai-400020. Pan No. Aaacq 0281 C Appellant Respondent

2,33,69,884 out of total expenditure of Rs.2,93,69,884/ total expenditure of Rs.2,93,69,884/- was disallowed was disallowed. On further appeal, the Ld. CIT(A) deleted the addition on the ground that the Ld. CIT(A) deleted the addition on the ground that the Ld. CIT(A) deleted the addition on the ground that

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. ASST CIT CIR 5(3)(2), MUMBAI

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

Section 14A of the Act was computed at Rs. 1,14,95,165/-. 5. However, the ld. AO did not accept the assessee's computation of disallowance and proceeded to recomputed the disallowance u/s.14A r.w.r.8D. First of all, he accepted the amount liable for disallowance under clause 2

ACIT-CIRCLE-5(3)(2), MUMBAI vs. M/S GREAT EASTERN SHIPPING CO. LTD., MUMBAI

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S.RIFAUR RAHMAN (Accountant Member)

Section 14A of the Act was computed at Rs. 1,14,95,165/-. 5. However, the ld. AO did not accept the assessee’s computation of disallowance and proceeded to recomputed the disallowance u/s.14A r.w.r.8D. First of all, he accepted the amount liable for disallowance under clause 2

DCIT CIR 5(3)(2), MUMBAI vs. THE GREAT EASTERN SHIPPING CO. LTD, MUMBAI

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S.RIFAUR RAHMAN (Accountant Member)

Section 14A of the Act was computed at Rs. 1,14,95,165/-. 5. However, the ld. AO did not accept the assessee’s computation of disallowance and proceeded to recomputed the disallowance u/s.14A r.w.r.8D. First of all, he accepted the amount liable for disallowance under clause 2

JASHAN JEWELS PRIVATE LIMITED ,MUMBAI vs. PCIT -5, MUMBAI

In the result, the appeal of the assessee is stands allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Jashan Jewels Pvt. Ltd., Pcit, Mumbai-5, 301-B Aman Chambers Room No. 515, 5Th Floor, Aayakar Premises Co. Soc. Ltd., Mama Vs. Bhavan, Maharshi Karve Road, Paramand Marg, Opera House, Mumbai-400020. Girgaon, Mumbai-400 004. Pan No. Aabcj 7040 D Appellant Respondent

5,05,000/- ought also to have been disallowed under Explanation ought also to have been disallowed under Explanation ought also to have been disallowed under Explanation 2 to Section

JAN SEVA MANDAL ,MUMBAI vs. INCOME TAX OFFICER EXEMPTION WARD -1(4), MUMBAI

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2023-24 Jan Seva Mandal, Central Processing Centre Income Vinayalaya, Mahakali Caves Tax Deparment, Bengaluru, Vs. Road, Andheri (East), Income Tax Officer Exemption Mumbai-400093. Ward 1(4), Mumbai. 6Th Floor, Mtnl Te Building, Pedder Road, Mumbai-400026. Pan No. Aaatj 4868 K Appellant Respondent

2) read with section 11(5) of the Act. read with section 11(5) of the Act. Jan Seva Mandal 3. A A sum sum of of Rs.43,938/- Rs.43,938/ under under section section 11 11 read read with with Section 11(6) of the Act being the amount of capital Section 11(6) of the Act being

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

disallowed. 4. Assessee claimed deduction u/s 800(2) which is clearly in 4. Assessee claimed deduction u/s 800(2) which is clearly in 4. Assessee claimed deduction u/s 800(2) which is clearly in contravention to provisions of the Act. The income from FD contravention to provisions of the Act. The income from FD contravention to provisions

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

disallowed. 4. Assessee claimed deduction u/s 800(2) which is clearly in 4. Assessee claimed deduction u/s 800(2) which is clearly in 4. Assessee claimed deduction u/s 800(2) which is clearly in contravention to provisions of the Act. The income from FD contravention to provisions of the Act. The income from FD contravention to provisions

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

disallowed. 4. Assessee claimed deduction u/s 800(2) which is clearly in 4. Assessee claimed deduction u/s 800(2) which is clearly in 4. Assessee claimed deduction u/s 800(2) which is clearly in contravention to provisions of the Act. The income from FD contravention to provisions of the Act. The income from FD contravention to provisions

ITO-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

disallowed. 4. Assessee claimed deduction u/s 800(2) which is clearly in 4. Assessee claimed deduction u/s 800(2) which is clearly in 4. Assessee claimed deduction u/s 800(2) which is clearly in contravention to provisions of the Act. The income from FD contravention to provisions of the Act. The income from FD contravention to provisions