MR. HIRJIPARBAT GADA,MUMBAI vs. ITO-WARD 24(1), MUMBAI

In the result, In the result, the appeal of the assesse bearing ITA No

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar- A.Y. 2014-15 - A.Y. 2014-15 - A.Y. 2016-17

Penalty proceedings u/s 271(1)(c) is being initiated separately for filing inaccurate particulars and concealment of income.” 5. After getting the rectification order, the demand U/s 143(3) of the Act was reduced, but the said order was duly challenged before the Ld.CIT(A) and the Ld.CIT(A) took an observation that the issue is already settled

SCHWAB FUNDAMENTAL EMERGING MARKETS EQUITY ETY ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-4(2)(1), MUMBAI

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

55A of the Act whilst sections 111A and 115AD only provide for determination of tax in certain cases and therefore, gains arising on transactions subjected to STT and those not subjected to STT are no different and satisfy the 'similar computation' condition specified in section 70(2) of the Act. 3. The learned DCIT failed to appreciate that section

MR. HIRJIPARBAT GADA,MUMBAI vs. ITO-WARD 24(1), MUMBAI

In the result, In the result, the appeal of the assesse bearing ITA No

Penalty proceedings u/s 271(1)(c) is being initiated separately for\nfiling inaccurate particulars and concealment of income.\nITA No.526/Mum/2024\n5. After getting the rectification order, the demand U/s 143(3) of the Act was\nreduced, but the said order was duly challenged before the Ld.CIT(A) and the\nLd.CIT(A) took an observation that the issue is already settled

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

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

u/s. 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 Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions

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

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

u/s. 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 Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions

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

u/s. 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

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

u/s. 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

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

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 \n54 \nHDFC Bank Ltd. \nITA No.4315/MUM/2007 and Ors. \nAYs 2002-03 to 2020-21 \nfor allocation of notional expenditure. The deductions contemplated are \nthe

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

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

u/s.\n36(1)(viii).\n15. This issue arises in the following appeals:\n Assessment year\nGround No. in\nAssessee's appeal\nGround No. in\nRevenue's appeal\n2004-05\n-\n2\n2006-07\n-\n3\n2007-08\n-\n3\n15. 1. On this issue, ld. Assessing Officer noted that assessee had\nwithdrawn a sum of Rs.50 Crores from Special Reserve

DCIT CIR 1(1), MUMBAI vs. M/S HOUSING DEVELOPEMENT FINANCE CORPORATION LTD, MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

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, \nbefore

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

section 54EC in respect of capital gains \narising on depreciable assets. \n\n17. This issue arises in the following appeals: \n\n Assessment year \nGround No. in \nAssessee's appeal \n\nGround No. in \nRevenue's appeal \n2006-07 \n- \n2 \n\n17. 1. Assessee had claimed deduction of Rs.54,49,21,366/- u/s.54EC \nin respect of short-term capital

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

section along with corresponding amendment \nu/s.41(1A) which are effective from Assessment Year 1998-99. \nAssessee had explained this aspect before the ld. Assessing Officer by \nclarifying that special reserve had been created over the years out of the \nprofits and “Special Reserve No. I Account” relates to amount which had \nbeen transferred up to financial year 1997-98. Thus

DCIT RANGE-1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORATION LTD, 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, \nbefore

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

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\n| Sr

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, \nbefore

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

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

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, \nbefore

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

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

u/s. \n36(1)(viii). \n\n15. This issue arises in the following appeals: \n\n Assessment year \nGround No. in \nAssessee's appeal \nGround No. in \nRevenue's appeal \n2004-05 \n- \n2 \n2006-07 \n- \n3 \n2007-08 \n- \n3 \n\n15. 1. On this issue, ld. Assessing Officer noted that assessee had \nwithdrawn a sum of Rs.50 Crores

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

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\n\n53\nHDFC Bank Ltd.\nITA No.4315/MUM/2007 and Ors.\nAYs