HINDUSTAN UNILEVER LTD,MUMBAI vs. ITO CIR 1(1)(4), MUMBAI

In the result, both the appeal of the assessee and the revenue are partly allowed

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

House Room No.579, Aayakar Bhavan 165/166 Backbay Reclamation M.K. Road, Mumbai-400 020 Mumbai-400 020 PAN : AACH1004N APPELLANT RESPONDENT Assessee represented by Shri Nishant Thakkar, Ms Jasmin Amalsadwala Department represented by Ms. Madhu Malti Ghosh, CIT dr Date of hearing 01-08-2023 Date of pronouncement 18-08-2023 O R D E R PER : MS PADMAVATHY

STRIDES ARCOLAB LTD,NAVI MUMBAI vs. ASST CIR 10(3), MUMBAI

In the result, the appeals assessee is partly allowed for statistical purposes

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am Strides Shasun Limited The Asst. Commissioner Of (Formerly Known As Strides Income Tax Circle 10(3), Arcolab Limited) 201, Mumbai Vs. Devavrata, Sector 17, Vashi, Navi Mumbai-400 703 Appellant .. Respondent Pan No. Aadcs8104P

house R & D unit upto 31.03.2010 and extension upto 31.03.2015. 2. Copy of application made to the secretary, DSIR for certification of the expenditure under section 35(2AB) of the Act. 3. Auditors certificate certifying the R& D Expenditure 4. R & D expenses certified by Managing Director. 28. It was stated that the delay in issuing Form

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

8. In view of the above definitions the learned Counsel explained the facts that the assessee is exporting legal services based on legal database which is transmission of customized electronic data and therefore eligible for deduction u/s. 10B of the Act. According to him, the assessee is also rendering legal services, which have been notified by the board

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO, MUMBAI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

8. In view of the above definitions the learned Counsel explained the facts that the assessee is exporting legal services based on legal database which is transmission of customized electronic data and therefore eligible for deduction u/s. 10B of the Act. According to him, the assessee is also rendering legal services, which have been notified by the board

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

8. In view of the above definitions the learned Counsel explained the facts that the assessee is exporting legal services based on legal database which is transmission of customized electronic data and therefore eligible for deduction u/s. 10B of the Act. According to him, the assessee is also rendering legal services, which have been notified by the board

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

8. In view of the above definitions the learned Counsel explained the facts that the assessee is exporting legal services based on legal database which is transmission of customized electronic data and therefore eligible for deduction u/s. 10B of the Act. According to him, the assessee is also rendering legal services, which have been notified by the board

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

8. In view of the above definitions the learned Counsel explained the facts that the assessee is exporting legal services based on legal database which is transmission of customized electronic data and therefore eligible for deduction u/s. 10B of the Act. According to him, the assessee is also rendering legal services, which have been notified by the board

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

8. In view of the above definitions the learned Counsel explained the facts that the assessee is exporting legal services based on legal database which is transmission of customized electronic data and therefore eligible for deduction u/s. 10B of the Act. According to him, the assessee is also rendering legal services, which have been notified by the board

THE GEM & JEWELLERY EXPORT PROMOTION COUNCIL,MUMBAI vs. ASST CIT (E) RG 2(1), MUMBAI

In the result, all the appeals of the assessee are allowed for 10

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13 & Assessment Year: 2013-14 The Gem & Jewellery Export Acit (Exemptions) Range- Promotion Council, 2(1), Vs. Tower-A, Aw-1010, G Block, 5Th Floor, Room No. 519, Bharat Diamond Bourse, Piramal Chambers, Lalbaug, B.K.C., Bandra East, Mumbai-400012. Mumbai-400051. Pan No. Aaatt 3202 H Appellant Respondent Assessment Year: 2014-15 The Gem & Jewellery Export Dcit (Exemptions) Range- Promotion Council, 2(1), Tower-A, Aw-1010, G Block, Vs. 5Th Floor, Piramal Chambers, Bharat Diamond Bourse, Lalbaug, B.K.C., Bandra East, Mumbai-400012. Mumbai-400051. Pan No. Aaatt 3202 H Appellant Respondent

10B of Income of Income-tax Rules, 1962 (in short, short, the ‘Rules’) return of income filed by the declaring deficit of ₹8,97,94,173/ 8,97,94,173/-. The return of income filed by the assessee was selected for scrutiny assessment and the statutory assessee was selected for scrutiny assessment and the statutory assessee was selected for scrutiny

DCIT-5(2)(1),MUMBAI, AAYAKAR BHAVAN vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, appeal of the

Bench: Shri Pawan Singh & Shri Girish Agrawal

housing the operating staff of a generating station, and where electricity is generated by water-power, includes penstocks, head and tail works, main and regulating reservoirs, dams and other hydraulic works, but does not in any case include any sub-station. Whereas, "Captive generating plant" has been defined u/s. 2(8) of the Electricity Act to mean a power plant

DY. COMMISSIONER OF INCOME TAX 5(2)(1), MUMBAI, MUMBAI vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, appeal of the

Bench: Shri Pawan Singh & Shri Girish Agrawal

housing the operating staff of a generating station, and where electricity is generated by water-power, includes penstocks, head and tail works, main and regulating reservoirs, dams and other hydraulic works, but does not in any case include any sub-station. Whereas, “Captive generating plant” has been defined u/s. 2(8) of the Electricity Act to mean a power plant

SAURASHTRA TRUST,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS) , MUMBAI

In the result, the appeal of the assessee is allowed

10B declaring total income at Rs.2,20,03,230/-. In the assessment order, the AO acknowledges that he had issued notices u/s 142(1) of the Act on 01.02.2019 & 20.08.2019 calling for relevant details and raised queries. And pursuant to which the assessee had filed answers to queries and furnished details as requisitioned by him. After examining the details filed

TRENT LTD,MUMBAI vs. ADDL. C.I.T.-2(3), MUMBAI

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Trent Ltd., V. Add. Cit – 2(3) Bombay House, 2Nd Floor, 24 Aayakar Bhavan, M.K. Road Homi Mody Street, Fort Mumbai Mumbai – 400 001 Pan: Aaacl1838J (Appellant) (Respondent) Addl. Cit – 2(3) V. M/S. Trent Ltd., Room No. 556, 5Th Floor Bombay House, 2Nd Floor, 24 Aayakar Bhavan, M.K. Road Homi Mody Street, Fort Mumbai - 400 020 Mumbai – 400 001 Pan: Aaacl1838J (Appellant) (Respondent) M/S. Trent Ltd., V. Dy. Cit – 2(3) Bombay House, 2Nd Floor, 24 Aayakar Bhavan, M.K. Road Homi Mody Street, Fort Mumbai Mumbai – 400 001 Pan: Aaacl1838J (Appellant) (Respondent)

house property, the AO estimated the ALV at Rs.35,50,000/- by taking a comparable case of a government owned building meant for central government officers known as Belvedere nevertheless the building is located at a different location and after ascertaining the rent of the said property at @ Rs.60.50 per sq. ft. determined the market rate at Rs. 60.50 plus

ACC LTD.,MUMBAI vs. ADDL CIT(LTU) , MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

House, 121 World Trade Centre, Cuffe Parade M.K. Road, Churchgate Mumbai - 400005 Mumbai - 400020 PAN: AAACT1507C (Appellant) (Respondent) Assessee represented by : Shri Yogesh Thar Shri Chaitanya Joshi Ms. SukanyaJayaram Department represented by : Smt. Shailja Rai Date of Hearing : 09.01.2023 Date of Pronouncement : 28.02.2023 2 ITA NO.3137 & 3138/MUM/2019 (A.Y: 2010-11) ITA.No. 3177/MUM/2019 (A.Y. 2010-11) M/s. ACC Limited

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

House, 121 World Trade Centre, Cuffe Parade M.K. Road, Churchgate Mumbai - 400005 Mumbai - 400020 PAN: AAACT1507C (Appellant) (Respondent) Assessee represented by : Shri Yogesh Thar Shri Chaitanya Joshi Ms. SukanyaJayaram Department represented by : Smt. Shailja Rai Date of Hearing : 09.01.2023 Date of Pronouncement : 28.02.2023 2 ITA NO.3137 & 3138/MUM/2019 (A.Y: 2010-11) ITA.No. 3177/MUM/2019 (A.Y. 2010-11) M/s. ACC Limited

ACIT 17(1), MUMBAI vs. ELVE CORPORATION, MUMBAI

Bench: Shri Joginder Singh & Shri Ramit Kochar

10B sets out the meaning of computer programmes in certain cases. Section 10C contains special provision in respect of certain industrial undertakings in North Eastern region. Section 11 deals with income from property held for religious or charitable purposes. Section 12 deals with income of trust or institutions from contributions. By section 12A conditions for applicability of sections

ACIT 17(1), MUMBAI vs. ELVE CORPORATION, MUMBAI

Bench: Shri Joginder Singh & Shri Ramit Kochar

10B sets out the meaning of computer programmes in certain cases. Section 10C contains special provision in respect of certain industrial undertakings in North Eastern region. Section 11 deals with income from property held for religious or charitable purposes. Section 12 deals with income of trust or institutions from contributions. By section 12A conditions for applicability of sections

DCIT(E)-2(1), MUMBAI vs. NEHRU CENTRE, MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Bledcit (E) – 2(1) V. Nehru Centre Room No. 519, 5Th Floor Discovery Of India Building Piramal Chambers, Lalbaug 13Th Floor, Dr. Annie Besant Road Worli, Mumbai - 400018 Mumbai – 400 012 Pan: Aaatn2536J (Appellant) (Respondent) Assessee By : Shri Dilip Thakkar Department By : Shri Dilipkumar Shah

10B claiming exemption u/s 11 and declared total income at ₹.NIL. The case was selected for scrutiny and notices u/s.143(2) and 142(1) of the Act are issued and served on the assessee. In response Ld. AR of the assessee attended and submitted the details as called for. 3. During Assessment proceedings, Assessing Officer analysed the objects