DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

vii) or towards provision for bad and doubtful debts under section 36(1)(viia) and decide the taxability in accordance with law. Disallowance due to re-computation of deduction under section 36(1)(viia) – Ground No.2 in assessee's appeal & Ground No.2 in revenue's appeal 8. The assessee for the year under consideration has debited

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

vii) or towards provision for bad and doubtful debts under section 36(1)(viia) and decide the taxability in accordance with law. Disallowance due to re-computation of deduction under section 36(1)(viia) – Ground No.2 in assessee's appeal & Ground No.2 in revenue's appeal 8. The assessee for the year under consideration has debited

ATOS INFORMATION TECHNOLOGY HK LTD.,MUMBAI vs. DY CIT (IT)-1 (1)(2), MUMBAI

Appeals of the assessee are partly allowed for statistical purposes

vii) of the Act. Per contra, the Ld. DR appearing on behalf of the Revenue supported the order of the lower authorities and filed detailed written submissions distinguishing the appellate order/s passed for the earlier years. 10. We have heard both the parties and gone through the written submissions filed by them and perused the material placed before

ATOS INFORMATION TECHNOLOGY HK LTD.,MUMBAI vs. DCIT (INTL. TAX) RANGE 1(1)(2), MUMBAI

Appeals of the assessee are partly allowed for statistical purposes

vii) of the Act. Per contra, the Ld. DR appearing on behalf of the Revenue supported the order of the lower authorities and filed detailed written submissions distinguishing the appellate order/s passed for the earlier years. 10. We have heard both the parties and gone through the written submissions filed by them and perused the material placed before

ATOS INFORMATION TECHNOLOGY HK LTD.,MUMBAI vs. DCIT (INTL. TAX) RANGE 1(1)(2), MUMBAI

Appeals of the assessee are partly allowed for statistical purposes

vii) of the Act. Per contra, the Ld. DR appearing on behalf of the Revenue supported the order of the lower authorities and filed detailed written submissions distinguishing the appellate order/s passed for the earlier years. 10. We have heard both the parties and gone through the written submissions filed by them and perused the material placed before

DCIT 8(2)(1), MUMBAI vs. SHAMROCK PHARMACHEMI P. LTD., MUMBAI

In the result, both appeals of the revenue are dismissed

Bench: Shri Saktijit Dey & Shri M.Balaganeshita Nos. 862 & 863/Mum/2018 (Assessment Years :2013-14 & 2014-15) Dcit-8(2)(1) Vs. M/S. Shamrock Pharmachemi Room No.624, Pvt.Ltd. Aaykar Bhawan, M.K.Road Off Dr. E Moses Road Mumbai-400 020 Worli, Mumbai-400 025 Pan/Gir No.Aaacs6290H (Appellant) .. (Respondent) Assessee By Shri Bharat Gandhi, Ar Revenue By Shri V.Vinod Kumar, Sr.Ar Date Of Hearing 28/10/2020 Date Of Pronouncement 11/11/2020 आदेश / O R D E R Per M. Balaganesh (A.M): These Two Appeals Filed By Revenue In Ita Nos. 862 & 863/Mum/2018 For Assessment Years (Ay) 2013-14 & 2014-15 Arise Out Of The Order By The Ld. Commissioner Of Income Tax (Appeals)- 14, Mumbai In Appeals No.Cit(A)-14/It-170/15-16 & Cit(A)-14/It- 119/16-17, Dated 27/11/2017 (Ld. Cit(A) In Short) Against The Order Of Assessment Passed U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As Act) Dated 31/08/2016 By The Ld. Deputy Commissioner Of Income Tax-8(2)(1), Mumbai (Hereinafter Referred To As Ld. Ao).

vii) of sub-section (1) of section 9: (ia) thirty per cent of any sum payable to a resident, on which tax is deductible at source under Chapter XVIIB and such tax has not been deducted or, after deduction, has not been paid on or before the due date specified in sub-section (1) of section 139. Provided that where

ITO 3(3)2, MUMBAI vs. SHAMROCK PHARMACHEMI P.LTD, MUMBAI

In the result appeal of the Revenue in ITA No

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.1774/Mum/2013 (नििाारण वर्ा / Assessment Year: 2009-10) बिाम/ Ito 3(3)2, M/S. Shamrock R.No. 602, Pharmachemi Pvt. Ltd., Aayakar Bhavan, 83E,Hansraj Pragi Bldg., V. M.K Road, Opp. Dr. E Moses Road, Mumbai 400020 Worli, Mumbai-400018 स्थायी ऱेखा सं./ Pan: Aaacs6290H (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. Revenue By: Shri. Ashim Kumar Modi (Cit- Dr), Shri V. Justin & Ms. Chaitna Ajaria Shri. Bharat L. Gandhi Assessee By: सुनवाई की तारीख /Date Of Hearing : 01.03.2019 घोषणा की तारीख /Date Of Pronouncement : 30.05.2019 आदेश / O R D E R Per Ramit Kochar: This Appeal, Filed By Revenue, Being Ita No. 1774/Mum/2013, Is Directed Against Appellate Order Dated 29.10.2012, Passed By Learned Commissioner Of Income Tax (Appeals)-7, Mumbai (Hereinafter Called ―The Cit(A)‖) In Appeal Number Cit(A)-7/Ito-3(3)(2)/It-166/11-12, For Assessment Year 2009-10, The Appellate Proceedings Had Arisen Before Learned Cit(A) From The Assessment Order Dated 29.12.2011 Passed By Learned Assessing Officer (Hereinafter Called ―The Ao‖) U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Called ―The Act‖) For Ay 2009-10. I.T.A. No.1774/Mum/2013

vii) of sub-section (1) of section 9: (ia) thirty per cent of any sum payable to a resident, on which tax is deductible at source under Chapter XVIIB and such tax has not been deducted or, after deduction, has not been paid on or before the due date specified in sub-section (1) of section 139. Provided that where

DELOITTE HASKINS AND SELLS,MUMBAI vs. ASST CIT 11(2), MUMBAI

In the result, all the three appeals of the assessee are treated as partly allowed for statistical purposes

Bench: Shri Rajendra & Shri Amit Shukla

House, 1 Little New services Street, London EC4A3TR 3 D & T New Zealand, 61 Rs.145,290 NIL Professional Molesworth Street, PO services Box No.1490, Wellington, New Zealand 4 D & T, Canada, 98, Rs.63,658 Rs.23,249 Professional Macdonell Street, Suit 400, 29.08.2002 services Geulph, Ontario M1H431 5 D & T, New York, 1633 Rs.9,28,852 Rs.1,93,847 Professional Broadway

DELOITTE HASKINS AND SELLS,MUMBAI vs. ASST CIT 11(2), MUMBAI

In the result, all the three appeals of the assessee are treated as partly allowed for statistical purposes

Bench: Shri Rajendra & Shri Amit Shukla

House, 1 Little New services Street, London EC4A3TR 3 D & T New Zealand, 61 Rs.145,290 NIL Professional Molesworth Street, PO services Box No.1490, Wellington, New Zealand 4 D & T, Canada, 98, Rs.63,658 Rs.23,249 Professional Macdonell Street, Suit 400, 29.08.2002 services Geulph, Ontario M1H431 5 D & T, New York, 1633 Rs.9,28,852 Rs.1,93,847 Professional Broadway

DELOITTE HASKINS AND SELLS,MUMBAI vs. ASST CIT 11(2), MUMBAI

In the result, all the three appeals of the assessee are treated as partly allowed for statistical purposes

Bench: Shri Rajendra & Shri Amit Shukla

House, 1 Little New services Street, London EC4A3TR 3 D & T New Zealand, 61 Rs.145,290 NIL Professional Molesworth Street, PO services Box No.1490, Wellington, New Zealand 4 D & T, Canada, 98, Rs.63,658 Rs.23,249 Professional Macdonell Street, Suit 400, 29.08.2002 services Geulph, Ontario M1H431 5 D & T, New York, 1633 Rs.9,28,852 Rs.1,93,847 Professional Broadway

SHELL INFORMATION TECHNOLOGY INTERNATIONAL BV,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

In the result, both the appeals of assessee are allowed

Bench: Sri Mahavir Singh, Jm & Sri G. Manjunatha, Am

House, Ballard Estate, N.M. Joshi Marg, Mahalaxmi Road, Mumbai-400 038 Mumbai-400 011 Appellant .. Respondent PAN No. AAICS9091A Assessee by : Niraj Sheth, AR Revenue by : Samuel Darse, DR Date of hearing: 16 -11-2017 Date of pronouncement : 16-11-2017 O R D E R PER MAHAVIR SINGH, JM: These two appeals by the Assessee are arising

SHELL INFORMATION TECHNOLOGY INTERNATIONAL BV,MUMBAI vs. DCIT (IT) 4(1)(2), MUMBAI

In the result, both the appeals of assessee are allowed

Bench: Sri Mahavir Singh, Jm & Sri G. Manjunatha, Am

House, Ballard Estate, N.M. Joshi Marg, Mahalaxmi Road, Mumbai-400 038 Mumbai-400 011 Appellant .. Respondent PAN No. AAICS9091A Assessee by : Niraj Sheth, AR Revenue by : Samuel Darse, DR Date of hearing: 16 -11-2017 Date of pronouncement : 16-11-2017 O R D E R PER MAHAVIR SINGH, JM: These two appeals by the Assessee are arising

ASIA TODAY LTD,MUMBAI vs. ADIT (IT) 2(2), MUMBAI

In the result, Assessee's appeal is allowed

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2004-05 M/S. Asia Today Limited, Asst. Director Of Income C/O. Zee Entertainment Enterprises Tax (International Ltd., Vs. Taxation)-2(2), 135, Dr. Annie Besant Road, Scindia House, Worli, Mumbai – 400 018 Bellard Estate, Pan: Aabca0249F Mumbai - 400039 (Appellant) (Respondent) Present For: Assessee By : Shri Niraj Sheth, Ld. A.R. Revenue By : Shri Krishna Kumar, Ld. Sr. D.R. Date Of Hearing : 10.10.2025 Date Of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.01.2007, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2004-05. 2. The Relevant Facts For Adjudication Of This Appeal Are As Under: The Assessee, Being A Foreign Telecasting Company Incorporated In Mauritius & Having Tax Residency Certificate Of Mauritius , During The Ay Under Consideration Was Engaged In The Production & Acquiring Rights Of Various Television Films Including Feature Films, As A Copy Right Owner/Holder Of Various Hindi Feature Films Produced & Censored In India, As Mentioned In Schedule ‘C’ Annexed With The ‘Agreement Of 2 M/S Asia Today Ltd. Vs Asst. Dit (Int. Taxation)-2(2)

House, Worli, Mumbai – 400 018 Bellard Estate, PAN: AABCA0249F Mumbai - 400039 (Appellant) (Respondent) Present for: Assessee by : Shri Niraj Sheth, Ld. A.R. Revenue by : Shri Krishna Kumar, Ld. Sr. D.R. Date of Hearing : 10.10.2025 Date of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry, Judicial Member: This appeal has been preferred by the Assessee against the order

M/S. SATELITE TELEVISION ASIAN REGION LTD.,MUMBAI vs. DDIT (INT. I.T) 2(1), MUMBAI

In the result, all the appeals by the assessee and the Revenue are partly

Bench: Shri Shamim Yahya, Am & Shri Ram Lal Negi, Jm

House Hunghom, Kowloon Ballard Pier Hongkong Mumbai – 400 001 Mumbai Address: M/s. Satellite Television Asian Region Ltd., C/o. DSK Legal 4th Floor, Express Towers Nariman Point Mumbai – 400 021 (Appellant) .. (Respondent) & Deputy Director of Vs. M/s. Satellite Television Asian Income-Tax (International Region Ltd., Taxation)-2(1) Mumbai – 400 021 Mumbai – 400 001 (Appellant) .. (Respondent) Assessee by Shri Porus Kaka

ATOS INFORMATON TECHNOLOGY HK LTD,MUMBAI vs. DCIT (IT) 1(1)(2), MUMBAI

In the result, appeal of assessee is allowed in the manner indicated above

Bench: Shri Amit Shukla & Shri Ashwani Taneja

property or information) finds place in clause (i), (ii) (iii), (iv) and (v) only and not in clause (iva) of Explanation 2 of Section 9. Therefore, one can reasonably interpret that the Explanation 5 was sought to be introduced to explain clauses (i) to (v) and not clause (iva).  Explanation 5 has been inserted with retrospective effect from June 1

ATOS INFORMATON TECHNOLOGY HK LTD,MUMBAI vs. DCIT (IT) 1(1)(2), MUMBAI

In the result, appeal of assessee is allowed in the manner indicated above

Bench: Shri Amit Shukla & Shri Ashwani Taneja

property or information) finds place in clause (i), (ii) (iii), (iv) and (v) only and not in clause (iva) of Explanation 2 of Section 9. Therefore, one can reasonably interpret that the Explanation 5 was sought to be introduced to explain clauses (i) to (v) and not clause (iva).  Explanation 5 has been inserted with retrospective effect from June 1

ATOS INFORMATON TECHNOLOGY HK LTD,MUMBAI vs. DCIT (IT) 1(1)(2), MUMBAI

In the result, appeal of assessee is allowed in the manner indicated above

Bench: Shri Amit Shukla & Shri Ashwani Taneja

property or information) finds place in clause (i), (ii) (iii), (iv) and (v) only and not in clause (iva) of Explanation 2 of Section 9. Therefore, one can reasonably interpret that the Explanation 5 was sought to be introduced to explain clauses (i) to (v) and not clause (iva).  Explanation 5 has been inserted with retrospective effect from June 1

ATOS INFORMATON TECHNOLOGY HK LTD,MUMBAI vs. DCIT (IT) 1(1)(2), MUMBAI

In the result, appeal of assessee is allowed in the manner indicated above

Bench: Shri Amit Shukla & Shri Ashwani Taneja

property or information) finds place in clause (i), (ii) (iii), (iv) and (v) only and not in clause (iva) of Explanation 2 of Section 9. Therefore, one can reasonably interpret that the Explanation 5 was sought to be introduced to explain clauses (i) to (v) and not clause (iva).  Explanation 5 has been inserted with retrospective effect from June 1