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

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

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

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 ()

b. Rule 8D(2)(ii) Rule 8D(2)(ii) Rs. 1,16,79,947 c Rule 8D(2)(iii) Rule 8D(2)(iii) Rs. 1,07,39,195 2. In the facts and circumstances of the case and in Law and without 2. In the facts and circumstances of the case and in Law and without 2. In the facts

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

b) of Section 5 of the BR Act, 1949, it would not be a co- operative bank. Then the definitions under the NABARD Act, 1981 operative bank. Then the definitions under the NABARD Act, 1981 operative bank. Then the definitions under the NABARD Act, 1981 would not apply. If a co would not apply. If a co-operative society

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), MUMBAI, MUMBAI vs. BLEND FINANCIAL SERVICES LIMITED, MUMBAI

In the result, appeal of the R

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal () Assessment Year: 2018-19

disallowance made by the Assessing Officer under section 40A(2)(b) of the Act in respect the Assessing Officer under section 40A(2)(b) of the Act in respect the Assessing Officer under section 40A(2)(b) of the Act in respect of payments made to directors and their relatives, which were of payments made to directors and their relatives

SHREE SAI BABA SANSTHAN TRUST (SHIRDI),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX (EXEMPTION) 2(1), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

disallowance of accumulation of income under section 11(2) of the I. T. Act, 1961 amounting to Rs. 230,68,39,506/- for non-filing of Form No. 10 with Deputy Commissioner of Income Tax within stipulated time in the absence of any specific time limit under the section 11(2) as it existed at the relevant time. 2

DY. COMMISSIONER O INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST(SHIRDI), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

disallowance of accumulation of income under section 11(2) of the I. T. Act, 1961 amounting to Rs. 230,68,39,506/- for non-filing of Form No. 10 with Deputy Commissioner of Income Tax within stipulated time in the absence of any specific time limit under the section 11(2) as it existed at the relevant time. 2

DY. COMMISSIONER O INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST(SHIRDI), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

disallowance of accumulation of income under section 11(2) of the I. T. Act, 1961 amounting to Rs. 230,68,39,506/- for non-filing of Form No. 10 with Deputy Commissioner of Income Tax within stipulated time in the absence of any specific time limit under the section 11(2) as it existed at the relevant time. 2

DY. COMMISSIONER OF INCOME TAX (EXEMPTION) 2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST (SHIRDI), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

disallowance of accumulation of income under section 11(2) of the I. T. Act, 1961 amounting to Rs. 230,68,39,506/- for non-filing of Form No. 10 with Deputy Commissioner of Income Tax within stipulated time in the absence of any specific time limit under the section 11(2) as it existed at the relevant time. 2

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

B” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) Assessment Year: 2021-22 ITO(E)-1(1), Bhavitha Foundation, 6th floor, Room No. 601, MTNL 3502, Octavius Heeranandani, Vs. Building, Cumballa Hill, DR GD Powai, Deshmukh Marg (Pedder Road) Mumbai-400076. Mumbai-400026. PAN NO. AAFCB 4096 F Appellant Respondent Assessee

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

MUMBAI KAMGAR MADHYAWARTI GRAHAK SAHAKARI SANSTHA MARYADIT,MUMBAI vs. ASST. COMMISSIONER OF INCOME TAX - CIRCLE 20(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

5(b) of the Banking regulation Act anking regulation Act, shall be considered as co shall be considered as co- operative society eligible for deduction u/s 80P(2)(d) of the Act. The operative society eligible for deduction u/s 80P(2)(d) of the Act. The operative society eligible for deduction u/s 80P(2

MUMBAI KAMGAR MADHYAWARTI GRAHAK SAHAKARI SANSTHA MARYADIT,MUMBAI vs. ASST. COMMISSIONER OF INCOME TAX - CIRCLE 20(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

5(b) of the Banking regulation Act anking regulation Act, shall be considered as co shall be considered as co- operative society eligible for deduction u/s 80P(2)(d) of the Act. The operative society eligible for deduction u/s 80P(2)(d) of the Act. The operative society eligible for deduction u/s 80P(2

MUMBAI KAMGAR MADHYAWARTI GRAHAK SAHAKARI SANSTHA MARYADIT,MUMBAI vs. ASST. COMMISSIONER OF INCOME TAX - CIRCLE 20(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

5(b) of the Banking regulation Act anking regulation Act, shall be considered as co shall be considered as co- operative society eligible for deduction u/s 80P(2)(d) of the Act. The operative society eligible for deduction u/s 80P(2)(d) of the Act. The operative society eligible for deduction u/s 80P(2

ACIT CIR 4(2), MUMBAI vs. M .M. POONJIAJI SPICES LTD, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

5. As the assessee company is engaged in the business of garlic powder, ginger powder, madras curry powder including pickles and spices et cetera, it also claimed deduction under section 10 B of the act of rupees to .27 crores being hundred percent of the profits derived from the business of preparation and export of powder, seeds, pickles, spices, paste

INCOME TAX OFFICER 4(2)(4), MUMBAI vs. M/S. M.M. POONJIAJI SPICES LTD., MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

5. As the assessee company is engaged in the business of garlic powder, ginger powder, madras curry powder including pickles and spices et cetera, it also claimed deduction under section 10 B of the act of rupees to .27 crores being hundred percent of the profits derived from the business of preparation and export of powder, seeds, pickles, spices, paste

ITO - 4(2)(2), MUMBAI vs. M/S. M.M. POONJIAJI SPICES LTD., MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

5. As the assessee company is engaged in the business of garlic powder, ginger powder, madras curry powder including pickles and spices et cetera, it also claimed deduction under section 10 B of the act of rupees to .27 crores being hundred percent of the profits derived from the business of preparation and export of powder, seeds, pickles, spices, paste