PROCTER & GAMBLE HYGIENE AND HEALTHCARE LTD,MUMBAI vs. DCIT CIRCLE-8(2), MUMBAI

In the result, both the appeals of the assessee are allowed

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.1373/Mum/2015 (A.Ys. 2006-07 & 2008-09) Procter & Gamble Hygiene Vs. Dcit, Circle 10(3)(2) & Healthcare Limited Aaykar Bhavan, P & G Plaza Cardinal Mumbai Gracias Road, Chakkala, Andheri (East) Mumbai – 400099 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

801B from 100% to 30% in respect of Vicks Vaporub Tin Line & Whisper E-Line, on the alleged ground that such excess claim represented concealment of income and / or furnishing of inaccurate particulars of income 2. The Appellant prays that the penalty u/s 271(1)(c) of the Act be deleted GROUND III: 1. On the facts and circumstances

PROCTER & GAMBLE HYGIENE AND HEALTH CARE LTD,MUMBAI vs. DCIT 8(2), MUMBAI

In the result, both the appeals of the assessee are allowed

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.1373/Mum/2015 (A.Ys. 2006-07 & 2008-09) Procter & Gamble Hygiene Vs. Dcit, Circle 10(3)(2) & Healthcare Limited Aaykar Bhavan, P & G Plaza Cardinal Mumbai Gracias Road, Chakkala, Andheri (East) Mumbai – 400099 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

801B from 100% to 30% in respect of Vicks Vaporub Tin Line & Whisper E-Line, on the alleged ground that such excess claim represented concealment of income and / or furnishing of inaccurate particulars of income 2. The Appellant prays that the penalty u/s 271(1)(c) of the Act be deleted GROUND III: 1. On the facts and circumstances

ASST CIT CC 38, MUMBAI vs. UNIPHOS ENTERPRISES LTD, MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

penalty levied u/s 271(1)(c)) ACIT, CC-38, Room no. M/s. United Phosphorous Ltd. 32(1), Ayakar Bhavan, Vs. Uniphos House, Madhu Park, 11th Road, Khar (W), Mumbai. Maharishi Karve Rd., Mumbai-400020. PAN: AAACU 3440 P (Appellant) .. (Respondent) Assessee by Ms. Vasanti Patel Advocate Revenue by Shri. Kiran Unavekar, Sr. DR Date of Hearing 18/03/2025 Date of Pronouncement

M/S. UNITED PHOSPHORUS LTD(NOW KNOWN AS UNIPHOS ENTERPRISES LTD),MUMBAI vs. THE DCIT CEN CIR-38, MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

penalty levied u/s 271(1)(c)) ACIT, CC-38, Room no. M/s. United Phosphorous Ltd. 32(1), Ayakar Bhavan, Vs. Uniphos House, Madhu Park, 11th Road, Khar (W), Mumbai. Maharishi Karve Rd., Mumbai-400020. PAN: AAACU 3440 P (Appellant) .. (Respondent) Assessee by Ms. Vasanti Patel Advocate Revenue by Shri. Kiran Unavekar, Sr. DR Date of Hearing 18/03/2025 Date of Pronouncement

ADDL CIT CEN RG IX, MUMBAI vs. UNIPHOS ENTERPRISES LTD ( FORMLERY KNOWN AS UNITED PHOSPHORUS LTD), MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

penalty levied u/s 271(1)(c)) ACIT, CC-38, Room no. M/s. United Phosphorous Ltd. 32(1), Ayakar Bhavan, Vs. Uniphos House, Madhu Park, 11th Road, Khar (W), Mumbai. Maharishi Karve Rd., Mumbai-400020. PAN: AAACU 3440 P (Appellant) .. (Respondent) Assessee by Ms. Vasanti Patel Advocate Revenue by Shri. Kiran Unavekar, Sr. DR Date of Hearing 18/03/2025 Date of Pronouncement

UNIPHOS ENTERPRISES LTD ( FORMERLY KNOWN AS UNITED PHOSPHORUS LTD),MUMBAI vs. ADDL CIT CEN RG IX, MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

penalty levied u/s 271(1)(c)) ACIT, CC-38, Room no. M/s. United Phosphorous Ltd. 32(1), Ayakar Bhavan, Vs. Uniphos House, Madhu Park, 11th Road, Khar (W), Mumbai. Maharishi Karve Rd., Mumbai-400020. PAN: AAACU 3440 P (Appellant) .. (Respondent) Assessee by Ms. Vasanti Patel Advocate Revenue by Shri. Kiran Unavekar, Sr. DR Date of Hearing 18/03/2025 Date of Pronouncement

THE ACIT CC-38, MUMBAI vs. M/S. UNITED PHOSPHOROUS LTD, MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

penalty levied u/s 271(1)(c)) ACIT, CC-38, Room no. M/s. United Phosphorous Ltd. 32(1), Ayakar Bhavan, Vs. Uniphos House, Madhu Park, 11th Road, Khar (W), Mumbai. Maharishi Karve Rd., Mumbai-400020. PAN: AAACU 3440 P (Appellant) .. (Respondent) Assessee by Ms. Vasanti Patel Advocate Revenue by Shri. Kiran Unavekar, Sr. DR Date of Hearing 18/03/2025 Date of Pronouncement

DCIT 22(2), NAVI MUMBAI vs. RAJESH BUILDERS, MUMBAI

In the result, appeals of assessee in ITA Nos

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

271(1)(c) of the Act cannot be levied and hence, we confirm the order of CIT(A) deleting the penalty. This appeal of revenue is dismissed. Page 17 of 33 ITA No.2954 & 2955, 6131 & 3454/Mum/2012 Rajesh Builder s (AYs:04-05,05-06,07-08,08-09) 21. The only issue in ITA No. 2954/Mum/2012

RAJESH BUILDER,MUMBAI vs. CIT 22, MUMBAI

In the result, appeals of assessee in ITA Nos

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

271(1)(c) of the Act cannot be levied and hence, we confirm the order of CIT(A) deleting the penalty. This appeal of revenue is dismissed. Page 17 of 33 ITA No.2954 & 2955, 6131 & 3454/Mum/2012 Rajesh Builder s (AYs:04-05,05-06,07-08,08-09) 21. The only issue in ITA No. 2954/Mum/2012

RAJESH BUILDER,MUMBAI vs. DCIT 22(2), MUMBAI

In the result, appeals of assessee in ITA Nos

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

271(1)(c) of the Act cannot be levied and hence, we confirm the order of CIT(A) deleting the penalty. This appeal of revenue is dismissed. Page 17 of 33 ITA No.2954 & 2955, 6131 & 3454/Mum/2012 Rajesh Builder s (AYs:04-05,05-06,07-08,08-09) 21. The only issue in ITA No. 2954/Mum/2012

SEZAL GLASS LTD.,MUMBAI vs. ACIT-9(3), MUMBAI

Bench: Sh. R. C. Sharma, Am & Sh. Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 2553/Mum/2014 (निर्धारणवर्ा / Assessment Year: 2007-08)

801B was not allowed by the Hon'ble ITAT were debatable in nature as on the date when the appellant filed its return of income. 3 I.T.A. No. 2553/Mum/2014 M/s Sejal Glass Ltd. THE APPELLANT CRAVES LEAVE TO ADD TO ALTER AMEND AND OR DELETE ANY OR ALL OF THE ABOVE GROUNDS OF APPEAL 2. As per the facts

PROCTER & GAMBLE HYGINE & HEALTH CARE LTD,MUMBAI vs. ADDL CIT RG 7(1), MUMBAI

In the result, appeal of the assessee is allowed

u/s 80HHC by invoking the provisions of Section 801B(13) r.w.s 801A(9). GROUND IV: The CIT(A) erred in upholding the penalty levied by the AO under Section 271

ASST CIT CC 43, MUMBAI vs. ROHA DYECHEM LTD, MUMBAI

In the result, the appeals filed by the assessee are allowed

Bench: Shri Joginder Singh & Shri Ashwani Taneja

u/s 263 setting aside the Assessment Order without appreciating the fact that the order passed by the AO was neither erroneous nor prejudicial to the interest of the revenue. Without prejudice to above ground, IV. 1. The CIT-(Central) erred in setting aside the order of the Assessing officer and directing him to reframe the assessment in accordance with

ACIT-24(1), MUMBAI vs. M/S.ATUL PROPERTIES, MUMBAI

In the result, the appeals of revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. Nos. 4393 & 4394/Mum/2018 (निर्धारण वर्ा / Assessment Years:2010-11 & 2011-12) Acit-24(1) बिधम/ M/S. Atul Properties Room No.604, Piramal 501-502, Trade Avenue, Off Vs. Chambers, Lalbaug, Parel, Suren Road, Western Express Mumbai-400012. Highway, Andheri (E), Mumbai-400093. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aamfa3756F (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Shri Rajesh Damor (Dr) Assessee By: Shri Naresh Jain/Mahaveer Jain & Ms. Carmi Shroff सुनवाई की तारीख / Date Of Hearing: 13/05/2022 घोषणा की तारीख /Date Of Pronouncement: 30/06/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: These Are Appeal Preferred By Revenue Against The Order Of The Ld. Cit(A)-36, Mumbai Dated 29.12.2017 For A.Y.2010-11 & 2011- 12 Respectively.

penalty u/s 271(1)(c) of the Act; and even though the assessee withdrew the claim by filing the revised return and offered for taxation the profit from Blue Meadow project Rs 23,32,39,561/-, the AO completed the scrutiny assessment based on the original return of income and disallowed the deduction claimed u/s 80IB

ACIT-24(1), MUMBAI vs. M/S.ATUL PROPERTIES, MUMBAI

In the result, the appeals of revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. Nos. 4393 & 4394/Mum/2018 (निर्धारण वर्ा / Assessment Years:2010-11 & 2011-12) Acit-24(1) बिधम/ M/S. Atul Properties Room No.604, Piramal 501-502, Trade Avenue, Off Vs. Chambers, Lalbaug, Parel, Suren Road, Western Express Mumbai-400012. Highway, Andheri (E), Mumbai-400093. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aamfa3756F (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Shri Rajesh Damor (Dr) Assessee By: Shri Naresh Jain/Mahaveer Jain & Ms. Carmi Shroff सुनवाई की तारीख / Date Of Hearing: 13/05/2022 घोषणा की तारीख /Date Of Pronouncement: 30/06/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: These Are Appeal Preferred By Revenue Against The Order Of The Ld. Cit(A)-36, Mumbai Dated 29.12.2017 For A.Y.2010-11 & 2011- 12 Respectively.

penalty u/s 271(1)(c) of the Act; and even though the assessee withdrew the claim by filing the revised return and offered for taxation the profit from Blue Meadow project Rs 23,32,39,561/-, the AO completed the scrutiny assessment based on the original return of income and disallowed the deduction claimed u/s 80IB

MORESHWAR KRUSHNA BARIA,VIRAR vs. ACIT, CENTRAL CIRCLE 3, THANE, THANE

In the result, appeal of the assessee is partly allowed

801B(10) has been claimed in respect of income offered to tax for projects entitled for such deduction." 7.6 The submission of the assessee was carefully considered vis a vis the details available on record. It is seen these loose paper bundles evidence that the assessee is accepting cash as 'on money' over and above the sale agreement value

DCIT (LTU)-2, MUMBAI vs. M/S RELIANCE INDUSTRIES LTD., MUMBAI

In the result, the ITA No

Penalty proceedings u/s 271(1)(c) of the Act for furnishing inaccurate particulars are initiated separately. 5.1.3 Further, during the assessment proceedings, it is also noted that has claimed depreciation under "Oil and Gas division" in respect of KG-D6 basin/Block of Rs 726,75,62,145/-. As has been discussed in detail under subsequent paragraphs (para 14.7) of this

RELIANCE INDUSTRIES LIMITED,MUMBAI vs. ACIT , MUMBAI

In the result, the ITA No

Penalty proceedings u/s 271(1)(c) of the Act for furnishing inaccurate particulars are initiated separately. 5.1.3 Further, during the assessment proceedings, it is also noted that has claimed depreciation under "Oil and Gas division" in respect of KG-D6 basin/Block of Rs 726,75,62,145/-. As has been discussed in detail under subsequent paragraphs (para 14.7) of this