DCIT - 1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORARTION LTD., MUMBAI

housing as well as \ndevelopment of infrastructure facility in India. In aggregation, deduction \nclaimed is restricted to special reserve so created in the year. According \nto the assessee, it qualifies as a “specified entity” for the purpose of \nclause (a) of Explanation to section 36(1)(viii), falling within sub-clause \n(vi) as “any other financial corporation including

M/S. HOUSING DEVELOP,MENT FINANCE CORPN. LTD,MUMBAI vs. THE ADDL CIT RG 1(1), MUMBAI

houses in India for residential purposes. In view thereof, the ld AR\nprayed that deduction under section 36(1)(viii) of the Act may be granted in re-\nspect of all the aforesaid three categories of receipts. In this regard reliance is\nplaced on the decision of the Apex Court in the case of Standard Refinery & Dis-\ntillery

M/S. HOUSING DEVELOPMENT FINANCE CORP. LTD.,MUMBAI vs. DCIT CIR. 1(1), MUMBAI

houses in India for residential purposes. In view thereof, the ld AR\nprayed that deduction under section 36(1)(viii) of the Act may be granted in re-\nspect of all the aforesaid three categories of receipts. In this regard reliance is\nplaced on the decision of the Apex Court in the case of Standard Refinery & Dis-\ntillery

DCIT CIR 1(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPN. LTD., MUMBAI

In the result, the three appeals by the Revenue are partly\nallowed

houses in India for residential purposes. In view thereof, the ld AR\nprayed that deduction under section 36(1)(viii) of the Act may be granted in re-\nspect of all the aforesaid three categories of receipts. In this regard reliance is\nplaced on the decision of the Apex Court in the case of Standard Refinery & Dis-\ntillery

M/S. HOUSING DEVELOP,MENT FINANCE CORPN. LTD,MUMBAI vs. THE ADDL CIT RG-1(1), MUMBAI

In the result, the three appeals by the Revenue are partly\nallowed

houses in India for residential purposes. In view thereof, the ld AR\nprayed that deduction under section 36(1)(viii) of the Act may be granted in re-\nspect of all the aforesaid three categories of receipts. In this regard reliance is\nplaced on the decision of the Apex Court in the case of Standard Refinery & Dis-\ntillery

THE DY CIT CIR 1(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPN LTD, MUMBAI

In the result, the three appeals by the Revenue are partly\nallowed

houses in India for residential purposes. In view thereof, the ld AR\nprayed that deduction under section 36(1)(viii) of the Act may be granted in re-\nspect of all the aforesaid three categories of receipts. In this regard reliance is\nplaced on the decision of the Apex Court in the case of Standard Refinery & Dis-\ntillery

THE DY CIT CIR 1(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPN LTD., MUMBAI

In the result, the three appeals by the Revenue are partly\nallowed

houses in India for residential purposes. In view thereof, the ld AR\nprayed that deduction under section 36(1)(viii) of the Act may be granted in re-\nspect of all the aforesaid three categories of receipts. In this regard reliance is\nplaced on the decision of the Apex Court in the case of Standard Refinery & Dis-\ntillery

HOUSING DEVP. FIN.CORPN. LTD. vs. THE ADIT CIR. 1(1),

The appeal of the assessee is partly allowed

houses\nin India for residential purposes. In view thereof, the ld AR prayed that deduction\nunder section 36(1)(viii) of the Act may be granted in respect of all the aforesaid\nthree categories of receipts. In this regard reliance is placed on the decision of the\nApex Court in the case of Standard Refinery & Distillery

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

36(1)(viii). 15. This issue arises in the following appeals: Assessment year Ground No. in Ground No. in Assessee's appeal Revenue's appeal 2004-05 - 2 2006-07 - 3 2007-08 - 3 15.1. On this issue, ld. Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions for contingency

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

36(1)(viii). 15. This issue arises in the following appeals: Assessment year Ground No. in Ground No. in Assessee's appeal Revenue's appeal 2004-05 - 2 2006-07 - 3 2007-08 - 3 15.1. On this issue, ld. Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions for contingency

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

36(1)(viii). 15. This issue arises in the following appeals: Assessment year Ground No. in Ground No. in Assessee's appeal Revenue's appeal 2004-05 - 2 2006-07 - 3 2007-08 - 3 15.1. On this issue, ld. Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions for contingency

ADDL CIT RG 1(1), MUMBAI vs. HDFC LTD, MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

36(1)(viii). 15. This issue arises in the following appeals: Assessment year Ground No. in Ground No. in Assessee's appeal Revenue's appeal 2004-05 - 2 2006-07 - 3 2007-08 - 3 15.1. On this issue, ld. Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions for contingency

ICICI HOME FINANCE COMPANY LTD,MUMBAI vs. ADDL CIT 10(1), MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

section 36(1)(viii) of the Act for the income earned from housing finance business. 2. The appellant earns interest income from the securitization trust ('the trust') based on its purchase of units /security receipts/pass through certificates issued by the trust. The trust received interest income from the underlying assets held by it, being the housing loans. M/s. ICICI Home

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

property.\nX V. Additional claim of the Assessee with regard to inadvertent suo\nmoto disallowance made during the course of the assessment\nproceedings.\nX V I. Refund of excess dividend distribution tax (DDT).\nX V II. Transfer pricing adjustment in respect of specified domestic\ntransactions (SDT) covered by section 40A(2)(b).\nXVIII. Disallowance of year-end provisions.\nXIX. Increasing

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LTD ( MERGED ENTITY HDFC INVESTMENTS LIMITED ), MUMBAI

36(1)(viii). \nVIII. Disallowance of entrance fees and subscriptions paid to clubs. \nIX. Exemption u/s.54EC in respect of capital gains arising on \ndepreciable assets. \nX. Disallowance of FCCB issue expenses. \nXI. Set-off of short-term capital loss. \nXII. Income from India Value Fund. \n\nXIII. Addition on account of receipts as per the ITS details not found \nrecorded

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD.),MUMBAI vs. DCIT, RANGE-1(1)(2), MUMBAI

section 50(1) and (2) is restricted only \nto the mode of computation of capital gains contained in Section 48 and \n49 and does not apply to other provisions, since fiction created by the \nlegislature has to be confined to the purpose to which it is created. Also, \nthat section 54E does not make any distinction between depreciable \nassets

ADDL CIT RG 1(1), MUMBAI vs. HDFC LTD, MUMBAI

36(1)(viii). \nVIII. Disallowance of entrance fees and subscriptions paid to clubs. \nIX. Exemption u/s.54EC in respect of capital gains arising on \ndepreciable assets. \nX. Disallowance of FCCB issue expenses. \nXI. Set-off of short-term capital loss. \nXII. Income from India Value Fund.\n\n11 \nHDFC Bank Ltd. \nITA No.4315/MUM/2007 and Ors. \nAYs

HDFC BANK LIMITED (AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT 2(3)(1), MUMBAI

36(1)(viii). \nVIII. Disallowance of entrance fees and subscriptions paid to clubs. \nIX. Exemption u/s.54EC in respect of capital gains arising on \ndepreciable assets. \nX. Disallowance of FCCB issue expenses. \nXI. Set-off of short-term capital loss. \nXII. Income from India Value Fund. \nXIII. Addition on account of receipts as per the ITS details not found \nrecorded