BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

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

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. Rule 8D - Method for determining amount of expenditure in relation to income not includible in total income

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

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

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. Rule 8D - Method for determining amount of expenditure in relation to income not includible in total income

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned\nissue back to the AO with similar directions. The grounds raised by the assessee in\nthis regard are allowed for statistical purposes

reassess under section 147 or pass an order enhancing the assessment or\nreducing a refund already made or otherwise increasing the liability of the assessee\nunder section 154, for any assessment year beginning on or before the 1st day of\nApril, 2001.\nRule 8D - Method for determining amount of expenditure in relation to income not\nincludible in total income

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned\nissue back to the AO with similar directions. The grounds raised by the assessee in\nthis regard are allowed for statistical purposes

reassess under section 147 or pass an order enhancing the assessment or\nreducing a refund already made or otherwise increasing the liability of the assessee\nunder section 154, for any assessment year beginning on or before the 1st day of\nApril, 2001.\nRule 8D - Method for determining amount of expenditure in relation to income not\nincludible in total income

DCIT(CC)-8(3) , MUMBAI vs. SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED, MUMBAI

In the result, the cross-objection of the assessee is partly\nallowed, whereas the appeal of the Revenue is dismissed

reassessment proceedings cannot survive.\n9.1 The brief facts relevant to the issue are that in the\nreassessment order passed under section 143(3) read with section\n147 of the Act dated 09.12.2019, the Assessing Officer made\naddition of Rs.80,73,86,524 comprising of two additions:\n(i) disallowance of interest expenditure under section 14A

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LIMITED,MUMBAI vs. ITO CIRCLE 14(1)(1), MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

14A of the Act read with Rule 8D of the Rules. Accordingly, Ground No.1 and 2 raised by the Assessee are allowed. Ground No.3 to 8 11. Ground No.3 to 8 raised by the Assessee pertain to the addition of INR.1,00,19,00,000/- made in respect of Delayed Payment Charges. 11.1. During the assessment proceedings the Assessing Officer

JCIT(OSD)-14(1)(1), MUMBAI vs. MAHARASHTRA STATE ELECTRICITY TRANSMISSION CO. LTD., MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

14A of the Act read with Rule 8D of the Rules. Accordingly, Ground No.1 and 2 raised by the Assessee are allowed. Ground No.3 to 8 11. Ground No.3 to 8 raised by the Assessee pertain to the addition of INR.1,00,19,00,000/- made in respect of Delayed Payment Charges. 11.1. During the assessment proceedings the Assessing Officer

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

reassessment was beyond four years, and that notice under section 148 should have beyond four years, and that notice under section 148 should have beyond four years, and that notice under section 148 should have been issued by the Faceless Assessing Officer rather than the been issued by the Faceless Assessing Officer rather than the been issued by the Faceless

DCIT CEN 5 3, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

reassessment was beyond four years, and that notice under section 148 should have beyond four years, and that notice under section 148 should have beyond four years, and that notice under section 148 should have been issued by the Faceless Assessing Officer rather than the been issued by the Faceless Assessing Officer rather than the been issued by the Faceless

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

reassessment was beyond four years, and that notice under section 148 should have beyond four years, and that notice under section 148 should have beyond four years, and that notice under section 148 should have been issued by the Faceless Assessing Officer rather than the been issued by the Faceless Assessing Officer rather than the been issued by the Faceless

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

reassessment was beyond four years, and that notice under section 148 should have beyond four years, and that notice under section 148 should have beyond four years, and that notice under section 148 should have been issued by the Faceless Assessing Officer rather than the been issued by the Faceless Assessing Officer rather than the been issued by the Faceless

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

In the result the appeal filed by the assessee in ITA No

section 14A to Rs.2,16,33,239/- as disallowed by the\nAppellant in Return of Income\n10.\nWithout Prejudice to the above, AO be directed to restrict the disallowance u/s\n14A r.w. Rule 8D(2)(ii) only w.r.t. those investments which have yielded exempt income\nduring the year and exclude those investments which have not yielded exempt income\nduring

ACIT 14(I)(2), MUMBAI, MUMBAI vs. GODREJ PROPERTIES LIMITED, MUMBAI

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyal1. Ita No. 3880/Mum/2024 (A.Y.2017-18)

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. Explanation.—For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. ADD/JOINT/DEPUTY/ACIT, NATIONAL E-ASSESSMENT CENTRE, DELHI

Section 14A(2) of the Act, read\n40\nITA Nos.4056/Mum/2023 & Others\nM/s. Kotak Mahindra Bank Ltd.\nwith Rule 8D of the Rules, before applying the theory of apportionment, the AO needs to\nrecord satisfaction that having regard to the kind of the assessee, suo moto disallowance\nunder Section 14A was not correct. It will be in those cases where

DCIT 2(2), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee for assessment year 2006 – 07 and 2007 – 08 is partly allowed

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm A.Y.2006-07 [ By Assessee] &

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001." 12. The sub-section (2) and (3) were introduced to the main section by the Finance

DCIT 3(1), MUMBAI vs. BAJAJ HINDUSTAN TD, MUMBAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] Rule 8D. (1) Where the Assessing Officer, having regard to the accounts of the assessee of a previous

BAJAJ HINDUSTAN LTD,MUMBAI vs. DCIT 3(1), MUMBAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] Rule 8D. (1) Where the Assessing Officer, having regard to the accounts of the assessee of a previous

ADITYA BIRLA NUVO LTD (SINCE AMALGAMATED WITH GRASIM INDUSTRIES LIMITED),MUMBAI vs. ASST CIT (LTU) 1, MUMBAI

reassess under section 147 or pass an order enhancing the\nassessment or reducing a refund already made or otherwise increasing the\nliability of the assessee under section 154, for any assessment year beginning\non or before the 1st day of April, 2001.]\nRule 8D. (1) Where the Assessing Officer, having regard to the accounts of\nthe assessee of a previous