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

II – Employees’ contribution to PF under section 36(1)(va) of Rs. 41,05,801/- 50. We also have already adjudicated the issue relating to deduction under section 80G while deciding the corresponding ground for A.Y. 2017–18. Since the facts and the applicable legal principles for the year under consideration are identical, we do not consider

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

ii) of clause (a) of f clause (a) of sub-section (1) of section 143 has been applied in the present case, section (1) of section 143 has been applied in the present case, section (1) of section 143 has been applied in the present case, the quantum of deduction claimed by the appellant

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

ii) undisclosed income or property discovered in the course of search." income or property discovered in the course of search." income or property discovered in the course of search." 20.5 The Hon'ble Bombay High Court has examined this 20.5 The Hon'ble Bombay High Court has examined this 20.5 The Hon'ble Bombay High Court has examined this issue

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

ii) undisclosed income or property discovered in the course of search." income or property discovered in the course of search." income or property discovered in the course of search." 20.5 The Hon'ble Bombay High Court has examined this 20.5 The Hon'ble Bombay High Court has examined this 20.5 The Hon'ble Bombay High Court has examined this issue

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

II – Employees' contribution to PF under section\n36(1)(va) of Rs. 41,05,801/-\n50. We also have already adjudicated the issue relating to\ndeduction under section 80G while deciding the corresponding\nground for A.Y. 2017–18. Since the facts and the applicable legal\nprinciples for the year under consideration are identical, we do\nnot consider

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

II – Employees' contribution to PF under section\n36(1)(va) of Rs. 41,05,801/-\n50. We also have already adjudicated the issue relating to\ndeduction under section 80G while deciding the corresponding\nground for A.Y. 2017–18. Since the facts and the applicable legal\nprinciples for the year under consideration are identical, we do\nnot consider

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

GRASIM INDUSTRIES LTD ( CORPORATE FINANCE DIVISION),MUMBAI vs. ADDL CIT RG 6(3), MUMBAI

Bench: the CIT(A). The CIT(A) partly allowed the appeal preferred by the Assessee vide order, dated 18/05/2009. 4. Not being satisfied with the relief granted by the Id. CIT(A), the Assessee has preferred appeal before this Tribunal. The Revenue has also filed cross-appeal challenging the relief granted by the Id. CIT(A).

Section 43B of the Act was inserted by the Finance Act, 1987 with effect from 01/04/1988. The First Proviso made it clear that Section 43B shall not apply in relation to any sum which is actually paid by the assessee in the next accounting year if it is paid on or before the due date for furnishing

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

ii) Further, on perusal of the bank statement period 21/09/2006 to 30/09/2006, it reveals that on 25/09/2006 the closing bank balance of Rs.51912/- only. ON 29/09/2006, there is a deposits of Rs.23,00,000/- and Rs.2,00,000/- and on the same day the advances given to the assessee company. 5 Navnidhi Steel & Engg. Co. Pvt. Ltd. (iii) On perusal

THE ACIT CENT. CIR -5(4) , MUMBAI vs. SHRI NITAN CHHATWAL, MUMBAI

In the result, the both the appeals of the revenue are dismissed

143(3) r.w.s 153A of the Act determining total income of the assessee at Rs.43.41 crores by making various additions. The main addition made by the AO was in respect of Capital gains declared by the assessee, i.e., the AO held that the capital gains declared by the assessee are bogus in nature and accordingly assessed them u/s 68

ACIT CENT. CIR -5(4) , MUMBAI vs. SHRI NITAN CHHATWAL , MUMBAI

In the result, the both the appeals of the revenue are dismissed

143(3) r.w.s 153A of the Act determining total income of the assessee at Rs.43.41 crores by making various additions. The main addition made by the AO was in respect of Capital gains declared by the assessee, i.e., the AO held that the capital gains declared by the assessee are bogus in nature and accordingly assessed them u/s 68

OLEANDER FARMS P.LTD,NAVI MUMBAI vs. DCIT CC 47, MUMBAI

In the result, appeal of the assessee is allowed in terms indicated hereinabove

Bench: Transfer Of File To The Ao Of The Assessee. 3. Rival Contentions Have Been Heard & Record Perused.

3) had been annulled by higher authorities on the ground of legality of notice under section 143(2), re-opening under section 147 on that very ground would mean nothing else but abuse of process of law. Hence, the contention of the revenue that as the return was processed under section 143(1), it was a mere

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

ii. the CIT (A) failed to appreciate that the appellant was governed by Prudential norms issued by the reserve bank of India and was deducted any bound by these guidelines and thereby erred in confirming disallowance of reversal of lease rentals of ₹ 1,730,586 iii. the CIT (A) failed to appreciate that even though the appellant was following accrual

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

ii. the CIT (A) failed to appreciate that the appellant was governed by Prudential norms issued by the reserve bank of India and was deducted any bound by these guidelines and thereby erred in confirming disallowance of reversal of lease rentals of ₹ 1,730,586 iii. the CIT (A) failed to appreciate that even though the appellant was following accrual

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

ii. the CIT (A) failed to appreciate that the appellant was governed by Prudential norms issued by the reserve bank of India and was deducted any bound by these guidelines and thereby erred in confirming disallowance of reversal of lease rentals of ₹ 1,730,586 iii. the CIT (A) failed to appreciate that even though the appellant was following accrual

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

ii. the CIT (A) failed to appreciate that the appellant was governed by Prudential norms issued by the reserve bank of India and was deducted any bound by these guidelines and thereby erred in confirming disallowance of reversal of lease rentals of ₹ 1,730,586 iii. the CIT (A) failed to appreciate that even though the appellant was following accrual

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

ii. the CIT (A) failed to appreciate that the appellant was governed by Prudential norms issued by the reserve bank of India and was deducted any bound by these guidelines and thereby erred in confirming disallowance of reversal of lease rentals of ₹ 1,730,586 iii. the CIT (A) failed to appreciate that even though the appellant was following accrual

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

ii. the CIT (A) failed to appreciate that the appellant was governed by Prudential norms issued by the reserve bank of India and was deducted any bound by these guidelines and thereby erred in confirming disallowance of reversal of lease rentals of ₹ 1,730,586 iii. the CIT (A) failed to appreciate that even though the appellant was following accrual

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

ii. the CIT (A) failed to appreciate that the appellant was governed by Prudential norms issued by the reserve bank of India and was deducted any bound by these guidelines and thereby erred in confirming disallowance of reversal of lease rentals of ₹ 1,730,586 iii. the CIT (A) failed to appreciate that even though the appellant was following accrual