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

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

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 ()

Section 14A r.w.r. 8D. Appellant has disallowed suo 14A r.w.r. 8D. Appellant has disallowed suo-motto an amount of motto an amount of Rs.9,08,52,583/ Rs.9,08,52,583/- but there is no proper justification for such but there is no proper justification for such disallowance. As per the appellant's admission by letter dated disallowance

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

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

89 taxmann.com 21 (Mum. Trib.). The ld. AR made a without\nprejudice plea that the disallowance under section 14A should

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 under section 14A, only those investments are to be considered for computing average value of investments are to be considered for computing average value of investments are to be considered for computing average value of investments which yielded exempt income during the year. It shall be investments which yielded exempt income during the year. It shall be investments which

DEPUTY COMMISSIONER OF INCOME TAX CC-7(3), MUMBAI vs. M/S MACROTECH DEVELOPERS LIMITED (FORMERLY KNOWN AS LODHA DEVELOPERS PVT LTD) (SUCCESSOER OF M/S BELLISSIMO CROWN BUILDMART PVT LTD ), MUMBAI

Accordingly should be allowed as a deduction

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

89 25.47 25.47 Warrants 6 ITA 2382 & 2383/Mum/2022 Macrotech Developers Ltd Less: Investment in Foreign 1,922.37 1,953.79 Companies* Investments to be considered 51,977.40 58,539.79 for 14A 8. Accordingly, the ld AR submitted that no disallowance under section

DEPUTY COMMISSIONER OF INCOME TAX, CC-7(3), MUMBAI vs. M/S MACROTECH DEVELOPERS LIMITED , MUMBAI

Accordingly should be allowed as a deduction

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

89 25.47 25.47 Warrants 6 ITA 2382 & 2383/Mum/2022 Macrotech Developers Ltd Less: Investment in Foreign 1,922.37 1,953.79 Companies* Investments to be considered 51,977.40 58,539.79 for 14A 8. Accordingly, the ld AR submitted that no disallowance under section

M/S MAFATLAL INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE-8(2), MUMBAI

In the result, appeal is partly allowed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Disallowance under section 14A Rs. 70,89,262/- (2) Disallowance under section 36(1)(iii) Rs. 1,32,49,990/- 3 ITA 881/Mum/2023

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

disallowance made by the Assessing Officer\nunder Section 40(a)(i) of the Act.\n5. The Assessee claimed deduction for the following fee\npaid/payable to the non-residents aggregating to INR\n11,21,42,029/-:\nSl.No. Name & Country of Tax Residence Status Amount (INR) Note\nRef\n1. Houthoff Buruma, Netherlands Company\n8,89

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

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

89 taxmann.com 21 (Mum. Trib.). The ld. AR made a without\nprejudice plea that the disallowance under section 14A should

DCIT 2(2), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee for assessment year 2006 – 07 and 2007 – 08 is partly allowed

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm A.Y.2006-07 [ By Assessee] &

section 14 A of ₹ 3,814,037,203/–. 25) While making such disallowance the learned assessing officer further considered the decisions of coordinate bench in Deputy Commissioner of income tax versus SG investment and industries Ltd [(2004) 89

RELIANCE RETAIL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 8(1)(1), MUMBAI

In the result, the appeal filed by the Revenue is dismissed,\nwhereas the appeal filed by the assessee is partly allowed

89,560/- while\ndisallowing Rs. 6,36,64,216/-.\niii. Disallowance under section 14A\nThe assessee made suo motu disallowance

DCIT 4(1), MUMBAI vs. DEUTSCHE EQUITIES INDIA P.LTD, MUMBAI

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance under section 40(a)(ia) on account of global overhead charges of Rs. 1,31,15,947 should be deleted. 4. The CIT(A) has erred in confirming the addition of Rs. 12,56,43,551 made by learned Assessing Officer (AO)/ Transfer Pricing Officer (IPO) and further erred in enhancing the addition by Rs. 4,19,89

HINDUSTAN PETROLEUM CORP LTD,MUMBAI vs. DCIT 1(1)(2), MUMBAI

Bench: us. 2.

89,179/- under Section 115JB of the Act. 3.1. The case of the Assessee was selected for scrutiny and the Assessing Officer passed the Assessment Order under Section 143(3) of the Act on 29/12/2017 at total income of INR 2141,19,33,648/- under normal provisions and Book profit of INR 3388,08,86,148/- under Section 115JB

INDIABULLAS HOUSING FINANCE LIMITED,MUMBAI vs. DCIT, CENTRAL CIRCLE-6(4), MUMBAI

disallowance of interest cost was warranted under Section 14A of the Act in view of the judgment of the Hon’ble Supreme Court in the case of South Indian Bank Vs. CIT [2021] 130 taxmann.com 178 (SC) and the judgment of the Hon’ble Bombay High Court in the case of HDFC bank Limited Vs. DCIT [2016] 67 taxmann.com

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CIRCLE-16(2), MUMBAI

disallowance made by the Assessing Officer\nunder Section 40(a)(i) of the Act.\n5. The Assessee claimed deduction for the following fee\npaid/payable to the non-residents aggregating to INR\n11,21,42,029/:-\nSl.No. Name & Country of Tax Residence Status Amount (INR) Note\nRef\n1. Houthoff Buruma, Netherlands Company 8,89

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. RELIANCE RETAIL LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

89,560/- while disallowing Rs. 6,36,64,216/-. iii. Disallowance under section 14A The assessee made suo motu disallowance

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

disallowance made by the Assessing Officer\nunder Section 40(a)(i) of the Act.\n5. The Assessee claimed deduction for the following fee\npaid/payable to the non-residents aggregating to INR\n11,21,42,029/-:\nSl.No. Name & Country of Tax Residence Status Amount (INR) Note\nRef\n1. Houthoff Buruma, Netherlands Company 8,89

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

disallowance made by the Assessing Officer\nunder Section 40(a)(i) of the Act.\n5. The Assessee claimed deduction for the following fee\npaid/payable to the non-residents aggregating to INR\n11,21,42,029/-\nSl.No. Name & Country of Tax Residence Status Amount (INR) Note\nRef\n1. Houthoff Buruma, Netherlands Company 8,89