ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(3)(1), MUMBAI vs. TATA SONS LIMITED, MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

8 (vi) raised in assessee’s appeal are allowed. 10. The issue arising in ground No. 9, raised in assessee’s appeal, is pertaining to disallowance of expenses while computing income from house property. 11. The brief facts of the case pertaining to this issue, as emanating from the record, are: In its computation of income from house property

THE INDIAN HOTELS CO. LTD.,MUMBAI vs. PR. CIT-1, MUMBAI

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

Bench: Shri Amarjit Singh, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.950/Mum/2021 (ननधधारण वर्ा / Assessment Years: 2014-15) बनधम/ The Indian Hotels Company Pcit-1 Room No.330, 3Rd Floor, Ltd. Vs. 9Th Floor, Express Towers, Aayakar Bhavan, Barrister Rajini Patel Marg, Maharishi Karve Road, Nariman Point, Mumbai- Mumbai-400020. 400021. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaact3957G (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. Assessee By: Shri K. K. Ved Revenue By: Shri Surendra Kumar (Dr) सुनवाई की तारीख / Date Of Hearing: 17/03/2022 घोषणा की तारीख /Date Of Pronouncement: 12/04/2022 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 31.03.2021 Passed By The Principal Commissioner Of Income Tax-01, Mumbai [Hereinafter Referred To As The “Pcit”] Relevant To The A.Y.2014-15 In Which The Principal Commissioner Of Income Tax-01 Has Invoked The Revisional Power U/S 263 Of The I.T. Act, 1961. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “Re.: Validity Of Order U/S, 263; On The Facts & In The Circumstances Of The Case & In Law, The Impugned Order Dated 31 March 2021 Passed Under Section 263 Of The Act Is Without Jurisdiction & Bad In Law. Without Prejudice To The Above, On The Facts & Circumstances Of The Case & In Law, The Principal Commissioner Of Income Tax (“Pcit”) Has Erred In Passing The Order Dated 31 March 2021 U/S. 263 Of The Act.

properties is generally provided through in room television set and the advertisement / article in the Taj magazine / Coffee Table magazine kept in the rooms of overseas hotel units. - It is further submitted that in competitive industry like hospitality, apart from retaining existing customers, it is must to reach out the customers to widen its customer base in best possible manner

HASMUKH DIPCHAND GARDI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 5(2), MUMBAI

In the result, all the above appeals are allowed

8 Years)\n2013-14, 2014-15, 2015-16, 2016-17, 2017-18, 2018-19, 2019-20,\n2020-21. Since the issues are common and interlinked, these appeals are\ntaken up together for adjudication. Appeal for the AY 2013-14 is being\ntaken up as a lead case for the sake of convenience and brevity.\nITA No. 1303/MUM/2024\n2. The grounds

EDENRED SA,MUMBAI vs. DCIT (IT) 2(1)(2), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

houses. Further, the services offered by Indian group companies need a sophisticated computer program that can monitor, track and maintain such transactions and loyalty/rewards points. The AO further observed that for this purpose the assessee is required to maintain the customer’s individual profile where the personal information, as well as their transaction track, can be kept in the assessee

EDENRED SA,MUMBAI vs. DCIT (IT) 2(1)(2), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

houses. Further, the services offered by Indian group companies need a sophisticated computer program that can monitor, track and maintain such transactions and loyalty/rewards points. The AO further observed that for this purpose the assessee is required to maintain the customer’s individual profile where the personal information, as well as their transaction track, can be kept in the assessee

EDENRED SA,MUMBAI vs. DCIT (IT) 2(2)(1), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

houses. Further, the services offered by Indian group companies need a sophisticated computer program that can monitor, track and maintain such transactions and loyalty/rewards points. The AO further observed that for this purpose the assessee is required to maintain the customer’s individual profile where the personal information, as well as their transaction track, can be kept in the assessee

EDENRED SA,MUMBAI vs. ACIT (IT) 2(2)(1), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

houses. Further, the services offered by Indian group companies need a sophisticated computer program that can monitor, track and maintain such transactions and loyalty/rewards points. The AO further observed that for this purpose the assessee is required to maintain the customer’s individual profile where the personal information, as well as their transaction track, can be kept in the assessee

M/S. LAXMI ORGANIC INDUSTRIES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(2)(1), MUMBAI

In the result, appeal of the assessee is partly allowed

Properties:\nTemperature: 170°C\nPressure: 8 kg/cm²\nLatent Heat: 489 Kcal/kg\nTotal Heat: 662 Kcal/kg\n\nMy replies to your queries are given below:\n\nQuery A: Taking into account the variations in steam pressure between the two\naforementioned examples, is the quality of steam from the utility\nperspective as described above almost similar or significantly different?\n\nICT MUMBAI

ISHARES CORE MSCI EMERGING MARKETS ETF (AS A SUCCESSOR TO ISHARES CORE EMERGING MARKETS MAURITIUS COMPANY ,MUMBAI vs. DCIT (TP) 2(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

house property, profit and gains from business of profession, capital gains and income from other sources. Section 66 to 80 deals with the aggregation of income and set off /carry forward of loss. 7.1. Hon’ble Bombay High Court in case of CIT vs. M. N. Raigi reported in (1949) 17 ITR 180 considered as to whether share income

ISHARES CORE MSCI TOTAL INTERNATIONAL STOCK ETF (AS A SUCCESSOR TO ISHARE CORE TAOTAL INTERNATIONAL STOCK MAURITIUS COMPANY ),MUMBAI vs. DY CIT (INT. TAX)-2(2)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

house property, profit and gains from business of profession, capital gains and income from other sources. Section 66 to 80 deals with the aggregation of income and set off /carry forward of loss. 7.1. Hon’ble Bombay High Court in case of CIT vs. M. N. Raigi reported in (1949) 17 ITR 180 considered as to whether share income

M/S. NICHOLAS PIRAMAL INDIA LTD,MUMBAI vs. THE ACIT CUR 7(1),

In the result, the appeal filed by the revenue is dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmanpiramal Enterprises Ltd Vs. Acit, Circle – 7(1) (Formerly Known As Aayakar Bhavan Piramal Healthcare Ltd) Mumbai – 400020. (Before Known As Nicholas Piramal Ind) Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400013. Pan/Gir No. : Aaacn4538P Appellant .. Respondent Dcit, Circle – 7(1) Vs. Piramal Enterprises Ltd Aayakar Bhyavan (Formerly Known As Mumbai – 400 020. Piramal Healthcare Ltd) (Before Known As Nicholas Piramal Ind) Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013. Pan/Gir No. : Aaacn4538P Assessee By : Mr.Ronak Doshi & Ms.Manshi Padhiyar.Ar Revenue By : Mr.S.N.Kabra.Dr

House Property, since the assessee company is not the owner of the said properties during the financial year 2003-04. Further, the assessee company is also not in the business of letting out of premises. Hence, the rental receipts can also not be taxed under the head Business Income. Such rental receipts can only be taxed under the head "Income

TATA CHEMICALS LTD,MUMBAI vs. DCIT - 2 (3)(1), MUMBAI

In the result, the appeal of the assessee is allowed

144C(5)\nof the Act) grossly erred, on fact and in law, in not taking cognizance of various\njudicial precedents relied upon by the Appellant which are of the cases where\ntransfer pricing was applicable to specified domestic transaction as defined under\nthe provisions of section 92BA of the Act.\"\n2.\nThe assessee is a company engaged in the business

DCIT IT 3 3 2 MUMBAI, MUMBAI vs. PRAMARICA ASPF II CYPRUS HOLDING LTD, CTPRUS

The appeal of the revenue is dismissed

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

House Coopers 1607, Air India Building, Pvt. Ltd., Tower C, 18th Floor, Vs. Nariman Point, Building No. 10 DLF, Cyber City, Mumbai-400021. Gurugram-122002. PAN : AAECP5087H Appellant) : Respondent) Appellant /Assessee by : Ms. Hirali Desai/ Shri Yogesh Malpani, AR Revenue / Respondent by : Shri Krishna Kumar, Sr. DR : 17.12.2024 Date of Hearing Date of Pronouncement

DCIT IT 332 MUMBAI, INCOME TAX vs. PRAMARICA ASPF II CYPRUS HOLDING LTD, CYPRUS

The appeal of the revenue is dismissed

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

House Coopers 1607, Air India Building, Pvt. Ltd., Tower C, 18th Floor, Vs. Nariman Point, Building No. 10 DLF, Cyber City, Mumbai-400021. Gurugram-122002. PAN : AAECP5087H Appellant) : Respondent) Appellant /Assessee by : Ms. Hirali Desai/ Shri Yogesh Malpani, AR Revenue / Respondent by : Shri Krishna Kumar, Sr. DR : 17.12.2024 Date of Hearing Date of Pronouncement

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

144C(1) of the Income Tax Act, 1961, which is time barred as per the provision of the Act, therefore, the impugned assessment order is bad in law and required to be quashed. 2. The respondent craves leave to add, amend, alter or delete the said ground of appeal.” 3. Rival submissions of both the parties have been heard

ISHARES MSCI EMERGING MARKETS ETF (AS A SUCCESSOR TO ISHARES EMERGING MARKETS INDEX MAURITIUS CO ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

house property,\nprofit and gains from business of profession, capital gains and income from\nother sources. Section 66 to 80 deals with the aggregation of income and set\noff /carry forward of loss.\n7. 1. Hon'ble Bombay High Court in case of CIT vs. M. N. Raigi reported in\n(1949) 17 ITR 180 considered as to whether share

ISHARES MSCI EM UCITS ETF USD DIST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

house property,\nprofit and gains from business of profession, capital gains and income from\nother sources. Section 66 to 80 deals with the aggregation of income and set\noff /carry forward of loss.\n\n7. 1. Hon'ble Bombay High Court in case of CIT vs. M. N. Raigi reported in\n(1949) 17 ITR 180 considered as to whether

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

In the result, C.O. filed by assessee is\ndismissed as infructuous

144C(1) of the Income Tax Act, 1961, which\nis time barred as per the provision of the Act, therefore, the impugned\nassessment order is bad in law and required to be quashed.\n2. The respondent craves leave to add, amend, alter or delete the said ground of\nappeal.\"\n3. Rival submissions of both the parties have been heard