NAVNIDHI STEEL AND ENGG CO. P.LTD,MUMBAI vs. DCIT 5(2)(1), MUMBAI

The appeal of the assessee is dismissed

Bench: Shri Joginder Singh, Assessment Year: 2007-08

1) and section 143(3) of the Act. 20. Learned counsel for the respondent submitted that other points are available to be raised. Since no other point was urged before the High Court, we find no reason to examine if any other point was available. The appeal is allowed without any orders as to costs.” 2.5. In the light

ICICI BANK LTD.,MUMBAI vs. THE DY CIT -2(3)(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Icici Bank Ltd. The Dy. Commissioner Of Icici Bank Towers, Income-Tax 2(3)(1) Bandra Kurla Complex, Aaykar Bhavan, Vs. 5Th Floor, Room No.552, Badra (East), Mumbai-400 051 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H

section 36(1)(viia) to be reduced ought to be Rs. 1313,68,58,216 as per assessment order

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed, as indicated above

Bench: Sri Mahavir Singh, Vp & Sri G Manjunatha, Am आयकर अपील सुं./ Ita No. 3644/Mum/2016 (ननर्ाारण वर्ा / Assessment Year 2008-09) State Bank Of India The Dy. Commissioner Of 3Rd Floor, Corporate Centre Income Tax, Circle -2(2)(1) बनाम/ Madam Cama Road Mumbai Vs. Nariman Point Mumbai-400021 (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा सुं./Pan No. Aaacs8577K

section 36(1)(vii) of the Act being the amount of bad debts written off (other than in respect of rural advances). This issue of assessee appeal is allowed. 60. The next issue in this appeal of assessee is as regards to the order of CIT(A) confirming the action of AO in disallowing deduction claimed by assessee

DUCK CREEK TECHNOLOGIES INDIA LLP,MUMBAI vs. ACIT- CIRCLE 26 (1), MUMBAI

In the result, the appeal is allowed

1) of the Act under section 43B of the Act amounting to INR 68,05,543 without even any mentioning

M/S JR FIBER GLASS INDUSTRIES PVT LTD,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE, MUMBAI

The appeal is allowed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.2848/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2009-10) M/S. Jr Fiber Glass Industries Pvt. Ltd.

section 68 of the Act by the addition of proviso thereto took place with effect from April 1, 2013. Therefore

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

1,56,73,70,902/- of Rs. Rs.452,89,26,555/-) 3. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in allowing deduction of taxes paid abroad from business income even though the provisions of section 40aii) of the Act are pery clear for not granting

BANK OF INDIA,MUMBAI vs. ACIT-2(1)(2), MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

1,56,73,70,902/- of Rs. Rs.452,89,26,555/-) 3. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in allowing deduction of taxes paid abroad from business income even though the provisions of section 40aii) of the Act are pery clear for not granting

INCOME TAX OFFICER (INTERNATIONAL TAXATION) 3(2)(1), KAUTILYA BHAWAN MUMBAI vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

Bench: Shri Amit Shukla & Shri Girish Agrawal

68 of the Act in the order under section 147 of the Act without appreciating the facts of the case. CO. No. 153/MUM/2025 1

INCOME TAX OFFICER (IT)-3(2)(1), KAUTILYA BHAWAN vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawal

68 of the Act in the order under section 147 of the Act without appreciating the facts of the case. CO. No. 153/MUM/2025 1

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

1. "Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition of Rs.1,68,19,775/- without appreciating the fact that as per amended provision of section

ILJIN ELECTRIC CO. LTD,MUMBAI vs. DCIT (IT) CIR 2(2)(1), MUMBAI

In the result, appeal for A

Bench: Shri Jason P. Boaz, Accoutant Member & Shri Saktijit Dey

68,12,549 USD one million two hundred fifty nine thousand four hundred 5. Total payable forty five only And Rupees five crore sixty eight lakh twelve thousand five hundred forty nine only 21. Schedule–1(A) specified the goods / equipment to be supplied from abroad; Schedule–1(B) specified the goods / equipments to be supplied from employer‟s country

INNO vs. OURCE SERVICES PRIVATE LIMITED,MUMBAIVS.DCIT, 14(1)(1), MUMBAI

In the result, the appeal of the assessee is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22 Innovsource Services Pvt. Ltd., Dcit, 14(1)(1), 501, Jolly Board Tower 1, I-Think Aayakar Bhavan, Maharshi Karve Vs. Techno Campus Kanjurmarg-East, Road, New Marine Lines, Mumbai-400042. Churchgate, Mumbai-400020. Pan No. Aaeci 0979 D Appellant Respondent

1 is against CPC restricting the claim under Section 80JJAA of the Act amounting to IN Section 80JJAA of the Act amounting to INR 30,10,31,823 to R 30,10,31,823 to the of Rs 6,22,44,207/ the of Rs 6,22,44,207/- and not restricting the claim under and not restricting

ITO(IT)-3(2)(1), MUMBAI vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

Bench: Shri Amit Shukla & Shri Girish Agrawal

68 of the Act in the order under section 147 of the Act without appreciating the facts of the case. CO. No. 153/MUM/2025 1

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).

68,19,755.00 13. 75% 2009-10 16,93,05,845.00 1,05,30,824.00 6.22% 2010-11 6,00,73,432.00 12,01,469.00 2%. The assessee had duly submitted copies of agency agreement/contract and exclusivity agreement pertaining to 4 major overseas agents based in USA & Europe as well copies of ledger account of these agents. The four foreign

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 6(1)(1), MAHARASHTRA

section 40(a) of the Act was confirmed. 54. The learned AR submitted that the assessee had created a year-end provision on ad hoc basis of Rs. 1,68

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6 (1)(1), MAHARASHTRA

Accordingly, this ground is allowed

section 40(a) of the Act was confirmed. 54. The learned AR submitted that the assessee had created a year-end provision on ad hoc basis of Rs. 1,68

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1), MAHARASHTRA

Accordingly, this ground is allowed

section 40(a) of the Act was confirmed. 54. The learned AR submitted that the assessee had created a year-end provision on ad hoc basis of Rs. 1,68

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

section 40(a) of the Act was confirmed. 54. The learned AR submitted that the assessee had created a year-end provision on ad hoc basis of Rs. 1,68