SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. ADDITIONAL /JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, NFAC, MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

House, 24, National Faceless Assessment Homi Mody Street, Fort, Centre-2(1), Vs. Mumbai-400001 MTNL Tele Building, PAN : AAATS1013P Cumballa Hills, Peddar Road, Mumbai-400026. Appellant) : Respondent) Appellant/Assessee by : Shri P. J. Pardiwala a/w Shri Sukhsagar Syal, AR Revenue/Respondent by : Shri Sanyogita Nagpal, CIT-DR Date of Hearing : 22.07.2024 Date of Pronouncement 26.08.2024 : Per Padmavathy S, AM: 1. These

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-2(1), MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

House, 24, National Faceless Assessment Homi Mody Street, Fort, Centre-2(1), Vs. Mumbai-400001 MTNL Tele Building, PAN : AAATS1013P Cumballa Hills, Peddar Road, Mumbai-400026. Appellant) : Respondent) Appellant/Assessee by : Shri P. J. Pardiwala a/w Shri Sukhsagar Syal, AR Revenue/Respondent by : Shri Sanyogita Nagpal, CIT-DR Date of Hearing : 22.07.2024 Date of Pronouncement 26.08.2024 : Per Padmavathy S, AM: 1. These

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

154 (SC). The AO vide order passed under section 143(3) of the Act disagreed with the ITA No.1451, 1452, 1547 & 1548/Mum/2023 (A.Ys. 2016-17 & 2018-19) 6 submissions of the assessee and computed a disallowance of Rs.57,84,37,239 under section 14A read with Rule 8D of the Rules. 6. The learned CIT(A), vide impugned order

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

154 (SC). The AO vide order passed under section 143(3) of the Act disagreed with the ITA No.1451, 1452, 1547 & 1548/Mum/2023 (A.Ys. 2016-17 & 2018-19) 6 submissions of the assessee and computed a disallowance of Rs.57,84,37,239 under section 14A read with Rule 8D of the Rules. 6. The learned CIT(A), vide impugned order

GRASIM INDUSTRIES LTD ( CORPORATE FINANCE DIVISION),MUMBAI vs. ADDL CIT RG 6(3), MUMBAI

Bench: the CIT(A). The CIT(A) partly allowed the appeal preferred by the Assessee vide order, dated 18/05/2009. 4. Not being satisfied with the relief granted by the Id. CIT(A), the Assessee has preferred appeal before this Tribunal. The Revenue has also filed cross-appeal challenging the relief granted by the Id. CIT(A).

house property excluding the portions occupied by the Assessee for the purpose of business or profession can be computed. However, the Revenue has failed to point out corresponding provision providing for Assessment Years: 2006-2007 computation of depreciation and WDV of Block of Assets excluding the WDV of the asset let out during the relevant previous year. 7.8. We note

BANK OF INDIA,MUMBAI vs. THE NATIONAL FACELESS ASSESSMENT CENTRE, MUMBAI

154 (SC). The AO vide order passed under section 143(3) of the Act disagreed with the\nsubmissions of the assessee and computed a disallowance of Rs.57,84,37,239 under section 14A read with Rule 8D of the Rules.\n6. The learned CIT(A), vide impugned order, in principle confirmed the stand of the AO in invoking the provisions

ACIT 6(3), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

house property\nexcluding the portions occupied by the Assessee for the purpose of\nbusiness or profession can be computed. However, the Revenue has\nfailed to point out corresponding provision providing for\ncomputation of depreciation and WDV of Block of Assets excluding\nthe WDV of the asset let out during the relevant previous year.\n7. 8. We note that Section

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

154 (SC). The\nAO vide order passed under section 143(3) of the Act disagreed with the\nsubmissions of the assessee and computed a disallowance of Rs.57,84,37,239\nunder section 14A read with Rule 8D of the Rules.\n6. The learned CIT(A), vide impugned order, in principle confirmed the\nstand of the AO in invoking the provisions

ASST CIT CIR 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

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

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

property and rights of the company: (m) acquiring and undertaking the whole or an part of the business of any person or company, when such business is of a nature enumerated or described in this sub-section; (n) doing all such other things as are incidental or conducive to the promotion or advancement of the business of the company

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

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

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

property and rights of the company: (m) acquiring and undertaking the whole or an part of the business of any person or company, when such business is of a nature enumerated or described in this sub-section; (n) doing all such other things as are incidental or conducive to the promotion or advancement of the business of the company

ACIT - 14(2) (2), MUMBAI vs. PFIZER LTD, MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

property was considered at ₹ 323 million. Further fair valuation of identified intangibles of Wyeth Limited vested in Pfizer Ltd pursuant to the amalgamation of Wyeth Limited with Pfizer Ltd was prepared by Deloitte as per letter dated 9 March 2015 stated that the fair value of identified intangibles as arrived at INR 427 2 million and value attributable to goodwill

PFIZER LTD,MUMBAI vs. DCIT - 14(2) (2), MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

property was considered at ₹ 323 million. Further fair valuation of identified intangibles of Wyeth Limited vested in Pfizer Ltd pursuant to the amalgamation of Wyeth Limited with Pfizer Ltd was prepared by Deloitte as per letter dated 9 March 2015 stated that the fair value of identified intangibles as arrived at INR 427 2 million and value attributable to goodwill

MMTI'S EDUCATION & RESEARCH TRUST,MUMBAI vs. ITO (E) 2 (1), MUMBAI

In the result, the appeals of the assessee are In the result, the appeals of the assessee are allowed partly for allowed partly for statistical purposes

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-2012 Mmti’S Education & Research Trust, The Dy. Director Of Income- New Excel House, 2Nd Floor, 41-B, Tax(Exemption)-I(1), Vs. Azad Nagar Road No. 2, Off. Veera 5Th Floor, Piramal Chambers, Desai Road, Behind Icici Bank, Parel, Lalbaug, Andheri (West), Mumbai-400012. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2012-2013 Mmti’S Education & Research Trust, Ito(E)-2(1), New Excel House, 2Nd Floor, 41-B, Income-Tax Office, Piramal Vs. Azad Nagar Road No. 2, Off. Veera Chambers, Parel, Mumbai- Desai Road, Behind Icici Bank, 12. Andheri (West), Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2013-2014 Mmti’S Education & Research Trust, Ito(E)-2(1), Victor House, 2Nd Floor, End Of Veera Income-Tax Office, Piramal Vs. Desai Road, Next To Chitralekha Chambers, Parel, Mumbai- House, Andheri (W), 12. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent

House, Andheri (W), 12. Mumbai-400053. PAN No. AABTM 2192 E Appellant Respondent MMTI’s Education & Research Trust MMTI’s Education & Research Trust ITA Nos. 5866/M/2015, 451/M/2019 & 2974/M/2017 Assessee by : Ms. Arati Vissanji, Adv & Ms. Arati Vissanji, Adv & Mr. AmodPrabhudesai, Mr. AmodPrabhudesai, Revenue by : Mr. Manish Ajudiya, Date of Hearing Date of Hearing : 14/06/2023 : Date of pronouncement Date of pronouncement

MMTIS EDUCTION & RESEARCH TRUST,MUMBAI vs. DDIT (E) I(2), MUMBAI

In the result, the appeals of the assessee are In the result, the appeals of the assessee are allowed partly for allowed partly for statistical purposes

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-2012 Mmti’S Education & Research Trust, The Dy. Director Of Income- New Excel House, 2Nd Floor, 41-B, Tax(Exemption)-I(1), Vs. Azad Nagar Road No. 2, Off. Veera 5Th Floor, Piramal Chambers, Desai Road, Behind Icici Bank, Parel, Lalbaug, Andheri (West), Mumbai-400012. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2012-2013 Mmti’S Education & Research Trust, Ito(E)-2(1), New Excel House, 2Nd Floor, 41-B, Income-Tax Office, Piramal Vs. Azad Nagar Road No. 2, Off. Veera Chambers, Parel, Mumbai- Desai Road, Behind Icici Bank, 12. Andheri (West), Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2013-2014 Mmti’S Education & Research Trust, Ito(E)-2(1), Victor House, 2Nd Floor, End Of Veera Income-Tax Office, Piramal Vs. Desai Road, Next To Chitralekha Chambers, Parel, Mumbai- House, Andheri (W), 12. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent

House, Andheri (W), 12. Mumbai-400053. PAN No. AABTM 2192 E Appellant Respondent MMTI’s Education & Research Trust MMTI’s Education & Research Trust ITA Nos. 5866/M/2015, 451/M/2019 & 2974/M/2017 Assessee by : Ms. Arati Vissanji, Adv & Ms. Arati Vissanji, Adv & Mr. AmodPrabhudesai, Mr. AmodPrabhudesai, Revenue by : Mr. Manish Ajudiya, Date of Hearing Date of Hearing : 14/06/2023 : Date of pronouncement Date of pronouncement

MMTIS EDUCATION AND RESEARCH TRUST,MUMBAI vs. ITO (E) 2(1), MUMBAI

In the result, the appeals of the assessee are In the result, the appeals of the assessee are allowed partly for allowed partly for statistical purposes

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-2012 Mmti’S Education & Research Trust, The Dy. Director Of Income- New Excel House, 2Nd Floor, 41-B, Tax(Exemption)-I(1), Vs. Azad Nagar Road No. 2, Off. Veera 5Th Floor, Piramal Chambers, Desai Road, Behind Icici Bank, Parel, Lalbaug, Andheri (West), Mumbai-400012. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2012-2013 Mmti’S Education & Research Trust, Ito(E)-2(1), New Excel House, 2Nd Floor, 41-B, Income-Tax Office, Piramal Vs. Azad Nagar Road No. 2, Off. Veera Chambers, Parel, Mumbai- Desai Road, Behind Icici Bank, 12. Andheri (West), Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2013-2014 Mmti’S Education & Research Trust, Ito(E)-2(1), Victor House, 2Nd Floor, End Of Veera Income-Tax Office, Piramal Vs. Desai Road, Next To Chitralekha Chambers, Parel, Mumbai- House, Andheri (W), 12. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent

House, Andheri (W), 12. Mumbai-400053. PAN No. AABTM 2192 E Appellant Respondent MMTI’s Education & Research Trust MMTI’s Education & Research Trust ITA Nos. 5866/M/2015, 451/M/2019 & 2974/M/2017 Assessee by : Ms. Arati Vissanji, Adv & Ms. Arati Vissanji, Adv & Mr. AmodPrabhudesai, Mr. AmodPrabhudesai, Revenue by : Mr. Manish Ajudiya, Date of Hearing Date of Hearing : 14/06/2023 : Date of pronouncement Date of pronouncement

SHILPA PRABHAKAR KULKARNI,MUMBAI vs. DCIT, CPC, BENGALURU

In the result, the appeal of the assessee is allowed partly for In the result, the appeal of the assessee is allowed partly for In the result, the appeal of the assessee is allowed partly for stati...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-2018 Shilpa Prabhakar Kulkarni, Dcit Centralized Processing 3 Neel Sagar, 1280 Prabhadevi Centre, Seaface Prabhadevi, Vs. Bengaluru-560 500. Mumbai-400025. Pan No. Brhpk 8129 D Appellant Respondent Assessee By : Ms. Chandni Shah & Kinjal Patel Revenue By : Mr. A.N. Bhalekar, Dr Date Of Hearing : 03/05/2023 : Date Of Pronouncement 11/05/2023 Order

154 and upward adjustment of income are hereby dismissed. income are hereby dismissed.” 4. Before us, the Ld. Counsel of the Before us, the Ld. Counsel of the assessee filed a Paper Book assessee filed a Paper Book containing pages 1 to 156. containing pages 1 to 156. 5. We have heard rival submission of the parties on the issue

M/S. STANDARD CHARTERED BANK,MUMBAI vs. THE ACIT (IT)1(3), MUMBAI

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

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blestandard Chartered Bank V. Acit – Range-1(3) Taxation Department, 23-25 Scindia House, Ballard Estate M.G. Road, 3Rd Floor N.M. Marg, Mumbai - 400038 Fort, Mumbai - 400001 Pan: Aabcs4681D (Appellant) (Respondent) Adit (It)– 2(3) V. Standard Chartered Bank Room No. 120, 1St Floor Taxation Department, 23-25 Scindia House, Ballard Estate M.G. Road, 3Rd Floor N.M. Marg, Mumbai - 400038 Fort, Mumbai - 400001 Pan: Aabcs4681D (Appellant) (Respondent) Shri P.J. Pardiwala & Assessee Represented By : Shri Fenil Bhatt Shri Soumendu Kumar Dash Department Represented By :

property of the Housing Board. It was held that the expenditure was incurred wholly and exclusively on the welfare of the employees and, therefore, constituted legitimate business expenditure. As the assessee company acquired no ownership rights in the tenements, this Court said that the expenditure was incurred merely with a view to carry on the business of the company more

MORAJ FINANZ CORPORATION,NAVI MUMBAI vs. DCLT CENTRAL CIRLE - 5(2), MUMBAI

In the result, appeal filed by the assessee is partly allowed as per above direction

Bench: Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

154 & 155/MUM/2022 (A.Ys: 2010-11, 2011-12 & 2012-13) Moraj Finanz Corporation v. DCIT – Central Circle – 5(2) C/7 Big Splash, 1st Floor Room No. 1908, 19th Floor Turbhe Road, Vashi Air India Building Navi Mumbai-400705 Nariman Point Mumbai – 400 021 PAN: AAKFM5831H (Appellant) (Respondent) Assessee Represented by : Shri Pradip N. Kapasi Department Represented by : Smt. Mahita Nair Date