UNION BANK OF INDIA,MUMBAI vs. DCIT, CIR - (LTU)-2, MUMBAI

Penalty proceedings u/s 271 (1) (C)\nare initiated for furnishing inaccurate particulars of income\"\n11. We heard the parties and perused the material on record. The ld. AR brought\nto our attention that a similar issue in assessee's own case for AY 2013-14 (ITA\nNo. 1439/Mum/2023 dated 13.03.2024) was considered by the Co-ordinate Bench\nwhere

UNION BANK OF INDIA,MUMBAI vs. DCIT, CIR - (LTU)-2, MUMBAI

Penalty proceedings u/s 271 (1) (C)\nare initiated for furnishing inaccurate particulars of income\"\n11. We heard the parties and perused the material on record. The ld. AR brought\nto our attention that a similar issue in assessee's own case for AY 2013-14 (ITA\nNo. 1439/Mum/2023 dated 13.03.2024) was considered by the Co-ordinate Bench\nwhere

DCIT-3(4), MUMBAI vs. M/S UNION OF BANK OF INDIA, MUMBAI

Penalty proceedings u/s 271 (1) (C)\nare initiated for furnishing inaccurate particulars of income\"\n11.\nWe heard the parties and perused the material on record. The ld. AR brought\nto our attention that a similar issue in assessee's own case for AY 2013-14 (ITA\nNo. 1439/Mum/2023 dated 13.03.2024) was considered by the Co-ordinate Bench\nwhere

DCIT-3(4), MUMBAI vs. M/S UNION OF BANK OF INDIA, MUMBAI

Penalty proceedings u/s 271 (1) (C)\nare initiated for furnishing inaccurate particulars of income\"\n11.\nWe heard the parties and perused the material on record. The ld. AR brought\nto our attention that a similar issue in assessee's own case for AY 2013-14 (ITA\nNo. 1439/Mum/2023 dated 13.03.2024) was considered by the Co-ordinate Bench\nwhere

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

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

Penalty 41 2866/Mum/2012 CIT(A)-I/IT- 06.02.2012 DCIT, Cir-1(1), 08.10.2010 271(1)(c) 2005-06 Order 682/2010-11 Mumbai passed 42 2867/Mum/2012 CIT(A)-I/IT- 07.02.2012 DCIT, Cir-1(1), 08.10.2010 271(1)(c) 2006-07 u/s. 731/2010-11 Mumbai 271(1)(c)] 2. Except for appeals mentioned at Sr. Nos. 24 and 39 to 42 in the above table

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

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

Penalty 41 2866/Mum/2012 CIT(A)-I/IT- 06.02.2012 DCIT, Cir-1(1), 08.10.2010 271(1)(c) 2005-06 Order 682/2010-11 Mumbai passed 42 2867/Mum/2012 CIT(A)-I/IT- 07.02.2012 DCIT, Cir-1(1), 08.10.2010 271(1)(c) 2006-07 u/s. 731/2010-11 Mumbai 271(1)(c)] 2. Except for appeals mentioned at Sr. Nos. 24 and 39 to 42 in the above table

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

Penalty 41 2866/Mum/2012 CIT(A)-I/IT- 06.02.2012 DCIT, Cir-1(1), 08.10.2010 271(1)(c) 2005-06 Order 682/2010-11 Mumbai passed 42 2867/Mum/2012 CIT(A)-I/IT- 07.02.2012 DCIT, Cir-1(1), 08.10.2010 271(1)(c) 2006-07 u/s. 731/2010-11 Mumbai 271(1)(c)] 2. Except for appeals mentioned at Sr. Nos. 24 and 39 to 42 in the above table

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

Penalty 41 2866/Mum/2012 CIT(A)-I/IT- 06.02.2012 DCIT, Cir-1(1), 08.10.2010 271(1)(c) 2005-06 Order 682/2010-11 Mumbai passed 42 2867/Mum/2012 CIT(A)-I/IT- 07.02.2012 DCIT, Cir-1(1), 08.10.2010 271(1)(c) 2006-07 u/s. 731/2010-11 Mumbai 271(1)(c)] 2. Except for appeals mentioned at Sr. Nos. 24 and 39 to 42 in the above table

DCIT-2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which is part of the lending activity . The CIT(A) placed reliance on the decision of the Delhi High Court

DCIT 2(3)(1), MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which is part of the lending activity . The CIT(A) placed reliance on the decision of the Delhi High Court

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which is part of the lending activity . The CIT(A) placed reliance on the decision of the Delhi High Court

DCIT 2(3)(1), MUMBAI vs. HDFC BANK LIMITED , MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which is part of the lending activity . The CIT(A) placed reliance on the decision of the Delhi High Court

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which is part of the lending activity . The CIT(A) placed reliance on the decision of the Delhi High Court

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which is part of the lending activity . The CIT(A) placed reliance on the decision of the Delhi High Court

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

Section 57(iii) and find that ld.\nUnder the said section, Assessing Officer has no power to bifurcate on\npro-rata basis and deduct a part of it from the gross dividend income.\nThere is no scope for any estimation of expenditure and hence no scope\n53\nHDFC Bank Ltd.\nITA No.4315/MUM/2007 and Ors.\nAYs

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

271(1)(c) 2006-07 \n\n2. Except for appeals mentioned at Sr. Nos. 24 and 39 to 42 in the \nabove table, all the appeals arise out of assessment orders passed u/s. \n143(3) of the Income-tax Act, 1961 (‘the Act’) for assessment years 2002- \n03 up to 2020-21. Since, similar issues are arising in several years

CREDIT AGRICOLE CORPORATE & INVESTMENT BANK,MUMBAI vs. THE DY.CIT OF INCOME TAX (INTERNATIONSL TAXATION) -2(1) (1) , MUMBAI

Accordingly these grounds are dismissed as not pressed

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

36(1)(viia)(b) of the Act. Accordingly, the ground raised by the Revenue is dismissed. ITA No. 1273/Mum/2016-Assessee's appeal- AY 2011-12 44. The issues contended by the assessee and the revenue in the appeal for AY 2011-12 which are identical to the issues contended in AY 2010-11 are tabulated below – Issue

ADIT (IT) 1(2), MUMBAI vs. CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK, MUMBAI

Accordingly these grounds are dismissed as not pressed

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

36(1)(viia)(b) of the Act. Accordingly, the ground raised by the Revenue is dismissed. ITA No. 1273/Mum/2016-Assessee's appeal- AY 2011-12 44. The issues contended by the assessee and the revenue in the appeal for AY 2011-12 which are identical to the issues contended in AY 2010-11 are tabulated below – Issue