ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

1,68,31,954/- during the year ended 31.03.2017 and, out of abundant caution, disallowed 30 per cent thereof amounting to Rs. 50,49,586/- under section 40(a) of the Act in A.Y. 2017–18 (a copy of the statement of computation of income for A.Y. 2017-18 was placed on record). It was further submitted that

ICICI BANK LTD.,MUMBAI vs. THE DY CIT -2(3)(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Icici Bank Ltd. The Dy. Commissioner Of Icici Bank Towers, Income-Tax 2(3)(1) Bandra Kurla Complex, Aaykar Bhavan, Vs. 5Th Floor, Room No.552, Badra (East), Mumbai-400 051 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H

56, Mumbai filed by the Bank and hence do not come within the purview of revision under section 263. We reiterate that the order passed under section 143(3) r.w.s. 144C(3) is neither erroneous nor prejudicial and the proceedings under section 263 ought to be dropped.” ICICI Bank Ltd; A.Y. 2015-16 07. The learned PCIT after considering

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

In the result, the appeal of the Revenue Ground-3 is dismissed

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeestate Bank Of India Vs Joint Commissioner Of Income-Tax, (Erstwhile State Bank Of Large Tax Payers Unit, Bangalore Mysore Prior To Merger) Local Head Office Compliance Department, 4Th Floor, 65, St. Marks Road, Bangalore-560 001 Pan: Aaccs0155P Appellant Respondent Deputy Commissioner Of Vs State Bank Of Mysore Income-Tax, Ltu, Circle-1, Head Office, Finance & Accounts Bangalore Department, Kg Road, Bangalore- 560 009 Pan: Aaccs0155P Appellant Respondent

56,399 a) The learned CIT(A) ought to have observed that the aforementioned expenditure is related to business and is of revenue nature and accordingly. the same should have been allowed under section 37(1) of the Act.” 2.1 The revenue has raised the following grounds: - “1. The order of Ld. CIT(A) is opposed to law and facts

BANK OF INDIA,MUMBAI vs. ACIT-2(1)(2), MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

disallowance us. 144 is to be restricted to the exempt income, where as in Finance Act 2022, explanation to Section 14A has been inserted which provides for applicability of the said section even in the absence of exempt income, which being clarificatory in nature has retrospective effect? (Tax Effects: Rs. 1,56

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

disallowance us. 144 is to be restricted to the exempt income, where as in Finance Act 2022, explanation to Section 14A has been inserted which provides for applicability of the said section even in the absence of exempt income, which being clarificatory in nature has retrospective effect? (Tax Effects: Rs. 1,56

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

disallowed exemption of dividend under section 10(34). Learned Commissioner does not dispute these facts but adds that the Assessing Officer did not examine the fundamental question as to whether these shareholdings, as on 1st June 1973, were part of the corpus or not. Unless, according to the learned Commissioner, these shareholdings were held to be part of the corpus

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

disallowed exemption of dividend under section 10(34). Learned Commissioner does not dispute these facts but adds that the Assessing Officer did not examine the fundamental question as to whether these shareholdings, as on 1st June 1973, were part of the corpus or not. Unless, according to the learned Commissioner, these shareholdings were held to be part of the corpus

DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

In the result, the appeal of the Revenue Ground-3 is dismissed

56,399\na) The learned CIT(A) ought to have observed that the aforementioned\nexpenditure is related to business and is of revenue nature and accordingly. the\nsame should have been allowed under section 37(1) of the Act.”\nThe revenue has raised the following grounds: -\nITA No. 683/Bang/2015\n“1. The order of Ld. CIT(A) is opposed

BANK OF INDIA,MUMBAI vs. THE NATIONAL FACELESS ASSESSMENT CENTRE, MUMBAI

1) without appreciating that the payment was penal and punitive and was\nfor infraction of public policy? (Tax Effect: Rs.8,90,11,776/- @34.61% of\nRs.25,72,00,000/-)\n7. Whether on the facts and circumstances of the case and in law, the Ld.\nCIT(A) erred in allowing relief to the assessee relying on the decision

ACIT, MUMBAI vs. K RAHEJA CORP PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2020-21

1,45,32,176 under Section 14A r.w. Rule 8D, considering only investments from which exempt income was actually earned. The details of investments from which exempt income was actually earned. The details of investments from which exempt income was actually earned. The details of exempt dividend income exempt dividend income earned were submitted as under: Particulars Particulars Amount Amount

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

section 14A 53,98,087 - Disallowance of Prior Period Expenditure 3,92,675 Total Addition in dispute before the Tribunal 57,90,762 Tax on Income at normal rates 17,37,229 Add: Surcharge @7.5% 1,30,292 18,67,521 Add: Education Cess @3% 56

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

section 14A 53,98,087 - Disallowance of Prior Period Expenditure 3,92,675 Total Addition in dispute before the Tribunal 57,90,762 Tax on Income at normal rates 17,37,229 Add: Surcharge @7.5% 1,30,292 18,67,521 Add: Education Cess @3% 56

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

section 14A 53,98,087 - Disallowance of Prior Period Expenditure 3,92,675 Total Addition in dispute before the Tribunal 57,90,762 Tax on Income at normal rates 17,37,229 Add: Surcharge @7.5% 1,30,292 18,67,521 Add: Education Cess @3% 56

INNO vs. OURCE SERVICES PRIVATE LIMITED,MUMBAIVS.DCIT, 14(1)(1), MUMBAI

In the result, the appeal of the assessee is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22 Innovsource Services Pvt. Ltd., Dcit, 14(1)(1), 501, Jolly Board Tower 1, I-Think Aayakar Bhavan, Maharshi Karve Vs. Techno Campus Kanjurmarg-East, Road, New Marine Lines, Mumbai-400042. Churchgate, Mumbai-400020. Pan No. Aaeci 0979 D Appellant Respondent

1) of section 142 section 142, such return shall be processed in the following , such return shall be processed in the following manner, namely:— (a) the total income or loss shall be computed after making the following the total income or loss shall be computed after making the following the total income or loss shall be computed after making

VARIAN MEDICAL SYSTEMS INTERNATIONAL (INDIA) PRIVATE LIMITED,MUMBAIQQQ vs. ASSESSMENT UNIT NFAC CETNRE ITO, MINISTRY OF FINANCE DELHI, DELHI

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

Bench: Shri Narender Kumar Choudhry, Jm & Ms Padmavathy S, Am

56,75,590/-. The return was proceed under section 143(1) of the Act assessing the income at Rs. 35,84,34,480/- after making certain adjustments including the addition towards delayed remittance of employee contribution to PF/ESI. Subsequently, the case was selected for scrutiny under CASS and the statutory notices were duly served on the assessee. Since the assessee

DOW CHEMICALS INTERNATIONAL PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TA-14(1)(2), MUMBAI

In the result, the appeal by the assessee for the

56,53,581 on\ncustomer relations.\n5.2. On the facts and in the circumstances of the case and in law, the CIT(A)\nerred in upholding the contention of the Assessing Officer that the Appellant\nhas not incurred any cost for acquiring customer relations in the scheme of\nmerger.\n6. Upholding the adjustments made under section 143(1

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

1) without appreciating that the payment was penal and punitive and was\nfor infraction of public policy? (Tax Effect: Rs.8,90,11,776/- @34.61% of\nRs.25,72,00,000/-)\n7. Whether on the facts and circumstances of the case and in law, the Ld.\nCIT(A) erred in allowing relief to the assessee relying on the decision

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. ADD/JOINT/DEPUTY/ACIT, NATIONAL E-ASSESSMENT CENTRE, DELHI

disallowance to the suo-moto disallowance offered by the assessee and the\nsaid relief has not been considered by the CIT (A). 4. The Id. AR with regard to the plea that\ndisallowance should be restricted to the suo-moto disallowance, submitted that the\nassessee has investments which are in the nature of stock in trade and also are strategic