STRIDES PHARMA SCIENCE LTD.,NAVI MUMBAI vs. THE DY CIT -5(1)(2), MUMBAI

In the result ITA number 1004/M/2021 filed by the assessee for assessment year 2016 – 17 is allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Strides Pharma Science Ltd. Dcit 15(1)(2) 201, Devavrata, Sector-17, Aayakar Bhavan, M K Road, Vs. Vashi, Navi Mumbai, 400703 Mumbai 400020 (Appellant) (Respondent) Pan No. Aadcs8104P

section 115JB of the Act 7. Disallowance of weighted deduction amounting to INR 17,54,78,992 claimed under Section

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 r.w.r. 8D - Rs. 1,19,07,328/- (ii) Disallowance of Expenditure towards ESOP - Rs. 7,35,861/- (iii) Disallowance

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 r.w.r. 8D - Rs. 1,19,07,328/- (ii) Disallowance of Expenditure towards ESOP - Rs. 7,35,861/- (iii) Disallowance

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 r.w.r. 8D - Rs. 1,19,07,328/- (ii) Disallowance of Expenditure towards ESOP - Rs. 7,35,861/- (iii) Disallowance

ELARA CAPITAL (INDIA) PRIVATE LIMITED,MUMBAI vs. ACIT- CIRCLE 6(2)(2), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18 Elara Capital (India) Pvt. Ltd., The Acit-Circle 6(2)(2), Tower 3, 21St Floor, One Room No. 506, 5Th Floor, Vs. International Center, Senapati Aayakar Bhavan, Maharshi Bapat Marg, Elphinstone Karve Road, Mumbai- Road (West), Mumbai-400013. 400020. Pan No. Aabce 6487 B Appellant Respondent

7 ITA No. however relying on the CBDT Circular No. 5/2014 rejected this however relying on the CBDT Circular No 2014 rejected this d made disallowance u/s 14A of contention of the assessee an contention of the assessee and made disallowance u the Act by applying Rule 8D. On appeal, the Ld On appeal

M/S PIRAMAL ENTERPRISES LIMIITED ,MUMBSI vs. DY CIT(APPEAL)-RANGE-8(2)(1), MUMBAI

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

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2017-18 M/S Piramal Enterprises Ltd., Dy. Cit, Mumbai-8(1)(2), Or Piramal Tower, Agastya National Facelss Assessment Vs. Corporate Park, Lbs Marg, Centre, Delhi, Kamani Junction, Kurla Room No. 624, 6Th Floor, (West), Aayakar Bhavan, M.K. Road, Mumbai-400070. Mumbai-400020. Pan No. Aaacn 4538 P Appellant Respondent : Assessee By Mr. Ronak Doshi : Revenue By Mr. Rakesh Ranjan, Cit-Dr & Mr. Samuel Pitta, Dr : Date Of Hearing 17/11/2022 : Date Of Pronouncement 28/12/2022

disallowance of Rs. 23,62,21,702/ 23,62,21,702/- made made in in respect respect of of transfer transfer pricing pricing adjustment on commission on the guarantees provided be adjustment on commission on the guarantees provided be adjustment on commission on the guarantees provided be deleted or be appropriately reduced. deleted or be appropriately reduced. WITHOUT PREJUDICE

DCIT 10(1), MUMBAI vs. APL LOGISTICS (INDIA) P. LTD, MUMBAI

In the result, appeal of the assessee is partly allowed

Disallowance of interest under section 14A r.w.r 8D. FINDINGS: 7. Disallowance under section 36(1)(iii): The facts relating to the assessee

APL LOGISTICS P.LTD,MUMBAI vs. DCIT 14(1)(1), MUMBAI

In the result, appeal of the assessee is partly allowed

Disallowance of interest under section 14A r.w.r 8D. FINDINGS: 7. Disallowance under section 36(1)(iii): The facts relating to the assessee

APL LOGISTICS (INDIA) P. LTD,MUMBAI vs. ASST CIT 10(1), MUMBAI

In the result, appeal of the assessee is partly allowed

Disallowance of interest under section 14A r.w.r 8D. FINDINGS: 7. Disallowance under section 36(1)(iii): The facts relating to the assessee

APL LOGISTICS (INDIA) P.LTD,MUMBAI vs. ASST CIT 10(1), MUMBAI

In the result, appeal of the assessee is partly allowed

Disallowance of interest under section 14A r.w.r 8D. FINDINGS: 7. Disallowance under section 36(1)(iii): The facts relating to the assessee

APL LOGISTICS (INDIA) P. LTD,MUMBAI vs. ACIT 10(1), MUMBAI

In the result, appeal of the assessee is partly allowed

Disallowance of interest under section 14A r.w.r 8D. FINDINGS: 7. Disallowance under section 36(1)(iii): The facts relating to the assessee

DCIT 10(1), MUMBAI vs. APL LOGISTICS (INDIA ) P.LTD, MUMBAI

In the result, appeal of the assessee is partly allowed

Disallowance of interest under section 14A r.w.r 8D. FINDINGS: 7. Disallowance under section 36(1)(iii): The facts relating to the assessee

BAJAJ INTERNATIONAL REALTY PRIVATE LIMITED ,MUMBAI vs. DCIT-1(2), MUMBAI

In the result both the appeals of the parties are partly allowed for In the result both the appeals of the parties are partly allowed for the statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

Section 14A is directed to be deleted. Ground Nos. 7 to 11 are allowed. directed to be deleted. Ground Nos. 7 to 11 are allowed. directed to be deleted. Ground Nos. 7 to 11 are allowed. 11. The next ground in respect of the disallowance

BAJAJ INTERNATIONAL REALTY PRIVATE LIMITED ,MUMBAI vs. DCIT, 1(2)1, MUMBAI

In the result both the appeals of the parties are partly allowed for In the result both the appeals of the parties are partly allowed for the statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

Section 14A is directed to be deleted. Ground Nos. 7 to 11 are allowed. directed to be deleted. Ground Nos. 7 to 11 are allowed. directed to be deleted. Ground Nos. 7 to 11 are allowed. 11. The next ground in respect of the disallowance

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 ()

7. On the facts and in the circumstances of the case and in law, the learned On the facts and in the circumstances of the case and in law, the learned On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in confirming disallowance of UK Branch office expenses

ASST. COMMISSIONER OF INCOME-TAX-CIRCLE 6(1)(2), MUMBAI, MUMBAI vs. 360 ONE PRIME LTD., MUMBAI

In the result, the appeal of the Revenue is allowed for t, the appeal of the Revenue is allowed for t, the appeal of the Revenue is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2016-17 Asst. Cit Circle-6(1)(2), 360 One Prime Ltd., Room No. 506, 5Th Floor, Aayakar Iifl Centre, Kamala City, Senapati Vs. Bhavan, M.K. Road, Bapat Marg, Lower Parel (W), Mumbai-400020. Mumbai-400013. Pan No. Aabcc 3347 E Appellant Respondent

section 115JB of the Act and therefore, disallowance computed cannot become part of the book profit. In view of the settled cannot become part of the book profit. In view of the settled cannot become part of the book profit. In view of the settled decisions, we restore the matter back to the file of the Ld. CIT(A) decisions

INCOME TAX OFFIECER-17(3)(4), MUMBAI vs. SUGARCHEM, MUMBAI

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

Bench: Shri C.N. Prasad & Shri Manoj Kumar Aggarwalincome Tax Officer-17(3)(4) M/S. Sugarchem 1St Floor, Aayakar Bhavan Kshamalaya, 3Rd Floor Vs. M.K. Road, Mumbai 400020 Marine Lines Mumbai 400020 Pan – Aayfs3762P Appellant Respondent

disallowance under section 40(a)(ia)of the Act, in our opinion there is violation of section 194C(7) and disallowance

SICOM LTD ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1), MUMBAI

In the result, the appeal filed by the assesee is partly allow for statistical purpose and the appeal filed by the revenue is allowed for statistical purposes

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale, Judicialmember Sicom Ltd, Vs. Dy Commissioner Of Solitaire Corporate Income Tax Circle Park, Bldg No.04, 3(3)(1), Chakala, Andheri(E), 6Th Floor, Room No. Mumbai-400093. 609,Aayakar Bhavan, Maharishi Karve Road, Mumbai- 400020. "थायी लेखा सं./जीआइआर सं.Pan/Gir No. Aaacs5524J (अपीलाथ"/Applicant) (""यथ"/Respondent) Dy Commissioner Of Vs. Sicom Ltd, Income Tax Circle Solitaire Corporate Park, 3(3)(1), Bldg No.04, Chakala, 6Th Floor, Room No. Andheri(E), 609,Aayakar Bhavan, Mumbai-400093. Maharishi Karve Road, Mumbai- 400020. "थायी लेखा सं./जीआइआर सं.Pan/Gir No. Aaacs5524J (अपीलाथ"/Applicant) (""यथ"/Respondent)

section 14A of the Act in the return of income; Interest expense disallowance 7. erred in confirming the disallowance for interest