DCIT - CC - 1(4), MUMBAI vs. ULTRATECH CEMENT LTD., MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

68. In summary, prior to insertion of sub-section (12) in section 80IA, the deduction was allowed to the amalgamating and the amalgamated companies on a pro-rata basis for the year in which the amalgamation took place. Sub-section (12), although allowed the benefit to the successor entity to which the undertaking was transferred, it changed

DCIT- CC- 1(4), MUMBAI vs. ULTRATECH CEMENT LTD., MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

68. In summary, prior to insertion of sub-section (12) in section 80IA, the deduction was allowed to the amalgamating and the amalgamated companies on a pro-rata basis for the year in which the amalgamation took place. Sub-section (12), although allowed the benefit to the successor entity to which the undertaking was transferred, it changed

ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CEN CIR 1(4), MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

68. In summary, prior to insertion of sub-section (12) in section 80IA, the deduction was allowed to the amalgamating and the amalgamated companies on a pro-rata basis for the year in which the amalgamation took place. Sub-section (12), although allowed the benefit to the successor entity to which the undertaking was transferred, it changed

ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CEN CIR 1(4), MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

68. In summary, prior to insertion of sub-section (12) in section 80IA, the deduction was allowed to the amalgamating and the amalgamated companies on a pro-rata basis for the year in which the amalgamation took place. Sub-section (12), although allowed the benefit to the successor entity to which the undertaking was transferred, it changed

ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CEN CIR 1(4), MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

68. In summary, prior to insertion of sub-section (12) in section 80IA, the deduction was allowed to the amalgamating and the amalgamated companies on a pro-rata basis for the year in which the amalgamation took place. Sub-section (12), although allowed the benefit to the successor entity to which the undertaking was transferred, it changed

DCIT -CC-1(4), MUMBAI vs. ULTRATECH CEMENT LTD. , MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

68. In summary, prior to insertion of sub-section (12) in section 80IA, the deduction was allowed to the amalgamating and the amalgamated companies on a pro-rata basis for the year in which the amalgamation took place. Sub-section (12), although allowed the benefit to the successor entity to which the undertaking was transferred, it changed

JT. CIT (OSD)- CC - 1(4), MUMBAI vs. ULTRATECH CEMENT LTD., MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

68. In summary, prior to insertion of sub-section (12) in section 80IA, the deduction was allowed to the amalgamating and the amalgamated companies on a pro-rata basis for the year in which the amalgamation took place. Sub-section (12), although allowed the benefit to the successor entity to which the undertaking was transferred, it changed

ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CEN CIR 1(4), MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

68. In summary, prior to insertion of sub-section (12) in section 80IA, the deduction was allowed to the amalgamating and the amalgamated companies on a pro-rata basis for the year in which the amalgamation took place. Sub-section (12), although allowed the benefit to the successor entity to which the undertaking was transferred, it changed

VODAFONE INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(3), MUMBAI

In the result, the appeal of the assessee is allowed

Section 68 of the Act in case of investee is totally against the settled principle of law and hence the order passed is bad in law. 2.11 It was also submitted by the ld. AR of the assesee that during the course of hearing before the AO, following documents were filed. For identity and genuineness  Financial Statements (attached

TATA EDUCATION TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX , MUMBAI

In the result, the appeal is allowed

12A registration are to be taxed at MMR. The CPC has followed the provisions of the ACT only and the order u/s 143(1) is correct and requires no interference. Ground 1 is dismissed. Ground 2 and 3 are consequential in nature and as ground 1 is dismissed these grounds are also dismissed.\n5.6 Ground 4 is against Refund adjusted

SILA FOR CHANGE FOUNDATION ,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

In the result appeals filed by the assessee stand dismissed

Bench: Smt Beena Pillai & Shri Prabhash Shankar & Sila For Change Foundation Commissioner Of Income-Tax A-301, 3Rd Floor, (Exemption) Neelam Centre, 601, 6Th Floor, Plot 249A, Worli, Cumballa Hill, Mumbai- 400030. Mtnl Building, Pan: Abgcs5333L Vs. Peddar Road, Dr. Gopalrao Deshmukh Marg, Cumballa Hill, Maharashtra- 400026. (Appellant) (Respondent)

68 ITD 95, wherein it is submitted that an organisation carrying out with exhibition and promotional activities outside India and money is spent outside India but nevertheless the ‘charitable purpose’ is served in India . He also placed reliance on the following decision in support of his arguments:- “1. CIT V/s. Dawoodi Bohara Jamat [2014] 43 Taxmann.com

SILA FOR CHANGE FOUNDATION ,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

In the result appeals filed by the assessee stand dismissed

Bench: Smt Beena Pillai & Shri Prabhash Shankar & Sila For Change Foundation Commissioner Of Income-Tax A-301, 3Rd Floor, (Exemption) Neelam Centre, 601, 6Th Floor, Plot 249A, Worli, Cumballa Hill, Mumbai- 400030. Mtnl Building, Pan: Abgcs5333L Vs. Peddar Road, Dr. Gopalrao Deshmukh Marg, Cumballa Hill, Maharashtra- 400026. (Appellant) (Respondent)

68 ITD 95, wherein it is submitted that an organisation carrying out with exhibition and promotional activities outside India and money is spent outside India but nevertheless the ‘charitable purpose’ is served in India . He also placed reliance on the following decision in support of his arguments:- “1. CIT V/s. Dawoodi Bohara Jamat [2014] 43 Taxmann.com

ADITYA BIRLA EDUCATION TRUST,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

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

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

12A(1)(ac)(v) on December 24, 2024. The Ld. CIT(E) has by order dated June 30, 2025, being the impugned order, rejected the application of the assessee and has held that “grant of registration stands rejected”. Being aggrieved the appeal is filed by the assessee challenging such rejection of grant of registration. 4. The Ld.AR argued and filed

TATA EDUCATION TRUST ,MUMBAI vs. ASSISTANT COMMISSIIONER OF INCOME TAX CIRCLE 17(3), MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

12A of the Act and for alleged violation in conditions of Sections 13(1)(d) and 13(2)(h) of the Act have not only denied exemption u/s. 11 of the Act but have also rejected assessee’s claim of exemption u/s. 10(34) and 10(35) of the Act. We find, while considering identical nature of dispute

TATA EDUCATION TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-CIRCLE 2(1), MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

12A of the Act and for alleged violation in conditions of Sections 13(1)(d) and 13(2)(h) of the Act have not only denied exemption u/s. 11 of the Act but have also rejected assessee’s claim of exemption u/s. 10(34) and 10(35) of the Act. We find, while considering identical nature of dispute

ASSISTANT COMMISSIONER OF INCOME TAX, KAUTILYA BHAVAN, BKC, MUMBAI vs. TATA EDUCATION TRUST, MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

12A of the Act and for alleged violation in conditions of Sections 13(1)(d) and 13(2)(h) of the Act have not only denied exemption u/s. 11 of the Act but have also rejected assessee’s claim of exemption u/s. 10(34) and 10(35) of the Act. We find, while considering identical nature of dispute

MEDIA RESEARCH USERS COUNCIL,MUMBAI vs. ADIT (E) 1(1), MUMBAI

Appeal of the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble & Media Research Users Council V. Addl. Dit(E)– 1(1) 128, Tv Industrial Estate Piramal Chambers, Lalbaug S.K. Ahire Marg, Worli Mumbai – 400 012 Mumbai – 400012 Pan: Aaatm5433F (Appellant) (Respondent) Media Research Users Council V. Addl. Dit(E)– Range 1 128, Tv Industrial Estate Piramal Chambers, Lalbaug S.K. Ahire Marg, Worli Mumbai – 400 012 Mumbai – 400012 Pan: Aaatm5433F (Appellant) (Respondent)

12A of the Income-tax Act, 1961 ("the Act") vide certificate dated 7th June 1994 and claims benefit under section 11 of the Act. Ground 1: Denial of benefit of section 11 by invoking section 13 4. During the previous year ended 31st March 2007, the assessee entered into an agreement with Hansa Research Group

MEDIA RESEARCH USERS COUNCIL,MUMBAI vs. ADDL DIT (E) RG 1, MUMBAI

Appeal of the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble & Media Research Users Council V. Addl. Dit(E)– 1(1) 128, Tv Industrial Estate Piramal Chambers, Lalbaug S.K. Ahire Marg, Worli Mumbai – 400 012 Mumbai – 400012 Pan: Aaatm5433F (Appellant) (Respondent) Media Research Users Council V. Addl. Dit(E)– Range 1 128, Tv Industrial Estate Piramal Chambers, Lalbaug S.K. Ahire Marg, Worli Mumbai – 400 012 Mumbai – 400012 Pan: Aaatm5433F (Appellant) (Respondent)

12A of the Income-tax Act, 1961 ("the Act") vide certificate dated 7th June 1994 and claims benefit under section 11 of the Act. Ground 1: Denial of benefit of section 11 by invoking section 13 4. During the previous year ended 31st March 2007, the assessee entered into an agreement with Hansa Research Group