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

3).  On the above reasoning, the ld. CIT(A) held that there was no infirmity in the approach of the Assessing Officer in adopting the income as per the intimation under section 143(1), declined to adjudicate the issue on merits, and dismissed the grounds raised by the assessee. Consequently, the appeal was dismissed. 68

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

68,378/- . In the 143(3) order the claim under Section 80JJAA itself is . In the 143(3) order

ESSEL MINING & INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), MUMBAI

In the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12 & Assessment Year: 2012-13 Essel Mining & Industries Ltd., Dy. Cit, Central Circle-1(4), Industry House, 18Th Floor, 10, 9Th Floor, Old Cgo Building, Camac Street, Vs. Mk Road, Kolkata-700017. Mumbai-400020. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 & Assessment Year: 2012-13 Jcit, Central Circle-1(4), M/S Essel Mining & Industries Room No. 902, Pratishtha Ltd., Bhavan, 9Th Floor, Old Cgo Vs. Industry House, 18Th Floor, 10, Building Annexe, Camac Street, Mumbai-400020. Kolkata-700017. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 M/S Essel Mining & Industries Dy. Cit, Central Circle-1(4), Ltd., 9Th Floor, Old Cgo Building, Vs. Industry House, 18Th Floor, 10, Mk Road

143(3) read with Section 153A of the IT Act Section 153A of the IT Act is both, bad in law and on is both, bad in law and on facts. No addition could have been made while facts. No addition could have been made while facts. No addition could have been made while completing assessment under Section

ESSEL MINING & INDUSTRIES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE 1(4), MUMBAI

In the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12 & Assessment Year: 2012-13 Essel Mining & Industries Ltd., Dy. Cit, Central Circle-1(4), Industry House, 18Th Floor, 10, 9Th Floor, Old Cgo Building, Camac Street, Vs. Mk Road, Kolkata-700017. Mumbai-400020. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 & Assessment Year: 2012-13 Jcit, Central Circle-1(4), M/S Essel Mining & Industries Room No. 902, Pratishtha Ltd., Bhavan, 9Th Floor, Old Cgo Vs. Industry House, 18Th Floor, 10, Building Annexe, Camac Street, Mumbai-400020. Kolkata-700017. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 M/S Essel Mining & Industries Dy. Cit, Central Circle-1(4), Ltd., 9Th Floor, Old Cgo Building, Vs. Industry House, 18Th Floor, 10, Mk Road

143(3) read with Section 153A of the IT Act Section 153A of the IT Act is both, bad in law and on is both, bad in law and on facts. No addition could have been made while facts. No addition could have been made while facts. No addition could have been made while completing assessment under Section

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

143(3) did not grant\ncredit of Dividend Distribution Tax paid and also did not grant\nrefund of excess DDT.\n43. Reference was made to the Tax Audit Report placed at page\n12 of the factual paper book and to Form 26AS, wherein such\nDDT was reflected. It was submitted that relevant supporting\ndocuments were enclosed as Annexure

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

143(3) did not grant\ncredit of Dividend Distribution Tax paid and also did not grant\nrefund of excess DDT.\n43. Reference was made to the Tax Audit Report placed at page\n12 of the factual paper book and to Form 26AS, wherein such\nDDT was reflected. It was submitted that relevant supporting\ndocuments were enclosed as Annexure

ITO 3(1)(4), MUMBAI vs. EVERLON SYNTHETICS P.LTD, MUMBAI

In the result, the appeal filed by the Revenue in ITA N0

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 6965/Mum/2013 ("नधा"रण वष" / Assessment Year : 2006-07) Income Tax Officer 3(1)(4), M/S Everlon Synthetics बनाम/ R. No. 666, Pvt. Ltd., V. Aayakar Bhawan,M.K. Road, 67, Regent Chambers, Mumbai – 400 020. 208 Nariman Point, Mumbai – 400 021 "थायी लेखा सं./Pan : Aaace0860H (अपीलाथ" /Appellant) .. (""यथ" / Respondent)

Section 143(2) of the Act, which material had been duly considered by the A.O. while framing the original assessment order dated 24.11.2008 u/s 143(3) of the Act by the AO. The said ITA 6965/Mum/2013 9 information with respect to the one time bank settlement and relief received by the assessee company had already been disclosed

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Section 115JB of the I.T.Act, 1961 are not \napplicable in the case of the assessee. \n9. Whether on the facts and circumstances of the case and in \nlaw, the Ld. CIT(A) was right in deleting the disallowance \nof Rs.776,13,61,000/- on account of reserve for \nunexpired risk without appreciating the fact the said \nreserved was created

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

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 of the aforesaid discussion

M/S. CIFCO FINANCE LTD.,MUMBAI vs. ACIT (OSD-II) CR-7, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed

CIFCO FINANCE LTD.,MUMBAI vs. ACIT (OSD II) CIR.7, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed

CIFCO FINANCE LTD,MUMBAI vs. DCIT (OSD-II) CR-7, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed

CIFCO FINANCE LTD,MUMBAI vs. ACIT (OSD-II) CR 7, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed

CIFCO FINANCE LTD,MUMBAI vs. ACIT (OSD II), CR 7,, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed

CIFCO FINANCE LTD,MUMBAI vs. ASST CIT (OSD-II) CIR 7, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed

CIFCO FINANCE LTD,MUMBAI vs. DCIT (OSD-II) CR-7, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed

M/A. CIFCO FINANCE LTD,MUMBAI vs. THE ACIT (OSD II) CR-7, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed

THE ACIT (OSD-II) CEN RG-7, MUMBAI vs. M/S. CIFCO FINANCE LTD, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed

CIFCO FINANCE LTD,MUMBAI vs. DCIT (OSD-II) CR-7, MUMBAI

In the result all 16 appeals related to the assessee are disposed off

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 147 490/M/2008 2004 – 2005 Assessee 143 (3) 488/M/2013 2004 – 2005 Assessee penalty u/s 271 (1) (C) 67. ITA number 490/M /2006 is filed by assessee for assessment year 2004 – 05 against the order of the Commissioner of income tax (appeals) – Central – V, Mumbai dated 23/11/2007 wherein appeal filed against the order u/s 143 (3) on 19/12/2006 passed