DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI , MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

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

Disallowance of deduction under section 36(1)(vii) 5. During the year under consideration, the assessee has claimed bad-debts amounting to Rs. 175,65,10,683/- under section 36(1)(vii) r.w.s. 36(2) of the Act. The assessee also claimed an amount of Rs. 81,73

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

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

Disallowance of deduction under section 36(1)(vii) 5. During the year under consideration, the assessee has claimed bad-debts amounting to Rs. 175,65,10,683/- under section 36(1)(vii) r.w.s. 36(2) of the Act. The assessee also claimed an amount of Rs. 81,73

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

73,55,929/- as provision for\ndoubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The\nAO held that the claim of bad-debts under section 36(1)(vii) is subject to the\nrestriction as per the proviso to the said section where it cannot exceed the credit\nbalance in the provision

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

73,55,929/- as provision for\ndoubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The\nAO held that the claim of bad-debts under section 36(1)(vii) is subject to the\nrestriction as per the proviso to the said section where it cannot exceed the credit\n5\nITA

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

73,55,929/- as provision for\ndoubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The\nAO held that the claim of bad-debts under section 36(1)(vii) is subject to the\nrestriction as per the proviso to the said section where it cannot exceed the credit\nbalance in the provision

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

1,160,35,01,455/- in the normal computation of total income and further same was also added to the computation of book profit under Section 115JB of the Act. iii. Disallowance of depreciation on leased assets of ₹27,31,73

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

disallowance of Rs. 54,93,734/- on account of employees’ contribution to Provident Fund was made at the stage of processing of return under section 143(1) of the Act, based on the date of payment as reflected in clause 20(b) of Form 3CD. It is also not in dispute that during the course of processing under section

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. 1,56,73

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. 1,56,73

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

disallowance against the weighted deduction claimed under Section 35(2AB) of the Act by the Appellant. 7.2 In disregarding the various other binding judgements of the ITAT and Hon'ble High Court which squarely applies to the Appellant's case with regard to allowability of weighted deduction under section 35(2AB) which are in relation to expenses incurred by DSIR

ACIT-2(1)(1), MUMBAI vs. GEECEE VENTURES LIMITED, MUMBAI

The appeal is allowed for statistical purposes

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

1. Whether on the facts and in the circumstances of the case and in law the Ld. CIT(A) erred in deleting the disallowance of deduction under Section 80IA(4) claimed in the return at Rs.1,57,73

GEECEE VENTURES LIMITED ,MUMBAI vs. DCIT, CIRCLE 2(1)(1), MUMBAI

The appeal is allowed for statistical purposes

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

1. Whether on the facts and in the circumstances of the case and in law the Ld. CIT(A) erred in deleting the disallowance of deduction under Section 80IA(4) claimed in the return at Rs.1,57,73

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

disallowance of Rs. 1,45,32,176 under Section 14A r.w. Rule 8D, considering only Rs. 1,45,32,176 under Section 14A r.w. Rule 8D, considering only Rs. 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

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

In the result, appeal of the assessee is allowed

disallowing same amount once since by charging the\nrecovery and the other by reducing allowable bad debt by such recovery.\nDeduction u/s 36(1)(viia)\n3.1 The Ld. CIT(A) ought to have noted that provision made in books of accounts in\nline with RBI auction towards loans having arrears up to 90 days (though classified\nas standard assets

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

73,89,630/-. The Assessing Officer (AO) completed the assessment by making the following disallowances: (i) Disallowance under section 14A r.w.r. 8D - Rs. 1

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

73,89,630/-. The Assessing Officer (AO) completed the assessment by making the following disallowances: (i) Disallowance under section 14A r.w.r. 8D - Rs. 1

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

73,89,630/-. The Assessing Officer (AO) completed the assessment by making the following disallowances: (i) Disallowance under section 14A r.w.r. 8D - Rs. 1

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

73, insofar as trading in sha insofar as trading in shares is concerned, with effect res is concerned, with effect from 1 April 2015. The latter amendment was intended from 1 April 2015 The latter amendment was intended to take effect from the date stipulated by Parliament to take effect from the date stipulated by Parliament to take effect from