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

15. Section 147 prior to its substitution by the Direct Tax Laws (Amendment) Act, 1987, stood as follows : "147. Income escaping assessment.—If— he may, subject to the provisions of sections 148 to 153, assess or reassess such income or recompute the loss or the depreciation allowance, as the case may be, for the assessment year concerned (hereafter

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

15) of the Act. In the original computation of total income, the assessee suo-moto made a disallowance of Rs. 201 crore in terms of rule 8D(2)(ii) and Rs. 20.37 crore in terms of rule 8D(2)(iii). In the revised computation of total income, the suo-moto disallowance was restricted to Rs. 20.37 crore in terms

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

15 provides the breakup as given in para 2.7 above. The Note 1 to Schedule 18(38) on page 167 clearly specifies that Amount of Rs. 3023,25,00,000 is part Rs. 3141,26,87,071. 2.9 We reiterate that presentation of figures of provision for bad debts, write off of bad debts etc, in the books of accounts

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

In the result, the appeal is allowed

68,05,543 without even any mentioning the clause of section 143(1) wherein the disallowance is alleged to fall while the Appellant contends that the disallowance is outside the scope of that section. 3. The Learned CIT(A) has erred in giving overriding effect to the procedural provision of section 143(1) disregarding the substantive

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

In the result, the appeal of the assessee is allowed

1)\nCentre\nRoom No. 649, M. K.\nRoad, Aayakar Bhavan,\nMumbai.\nस्थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAACJ6312K\n(अपीलार्थी / Appellant)\n(प्रत्यर्थी / Respondent)\nAssessee by:\nShri Satyaprakash Singh\nRevenue by:\nMs. Kavitha Kaushik (Sr. AR)\nसुनवाई की तारीख / Date of Hearing:\n24/01/2024\nघोषणा की तारीख /Date of Pronouncement:\n31/01/2024\nआदेश / ORDER\nPER ABY T. VARKEY, JM:\nThis

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

15 (1) it will clearly reveal that the transaction is clearly covered under the said notification and D.T.A.A. agreement entered by India with U.K. and the non resident commission agent is not required to pay the taxes in India, I.T.A. No.1774/Mum/2013 b) On perusal of circular No. 786 dated 07.02.2000 reported in 241 ITR (St.) 132 where it is been

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

1. If Ground No 1 is allowed and it is held that Appellant is entitled to exemption u/s. 11 of the Act engaged in charitable activities, the amount expended/incurred be allowed as application of income. Under the circumstances, if the ground number one is being allowed, the only prayer of the Appellant is to give a direction to the Assessing

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

1. If Ground No 1 is allowed and it is held that Appellant is entitled to exemption u/s. 11 of the Act engaged in charitable activities, the amount expended/incurred be allowed as application of income. Under the circumstances, if the ground number one is being allowed, the only prayer of the Appellant is to give a direction to the Assessing

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

1. If Ground No 1 is allowed and it is held that Appellant is entitled to exemption u/s. 11 of the Act engaged in charitable activities, the amount expended/incurred be allowed as application of income. Under the circumstances, if the ground number one is being allowed, the only prayer of the Appellant is to give a direction to the Assessing

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

1. If Ground No 1 is allowed and it is held that Appellant is entitled to exemption u/s. 11 of the Act engaged in charitable activities, the amount expended/incurred be allowed as application of income. Under the circumstances, if the ground number one is being allowed, the only prayer of the Appellant is to give a direction to the Assessing

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

1. If Ground No 1 is allowed and it is held that Appellant is entitled to exemption u/s. 11 of the Act engaged in charitable activities, the amount expended/incurred be allowed as application of income. Under the circumstances, if the ground number one is being allowed, the only prayer of the Appellant is to give a direction to the Assessing

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

68,424/-) 7. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was right in deleting the disallowance of losses written off of Rs 8,22,59,119/, without appreciating the fact that the same did not fulfill the conditions of deduction of s.36(1)(vii) r.w.s

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

68,424/-) 7. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was right in deleting the disallowance of losses written off of Rs 8,22,59,119/, without appreciating the fact that the same did not fulfill the conditions of deduction of s.36(1)(vii) r.w.s

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 that there is profit of Rs.2,57,97,824/- from transaction in derivatives at BSE and the same is already offered to tax by the Assessee. 3. It is brought to the notice of the Bench that Revenue has inadvertently filed

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

68,31,954/- during\nthe year ended 31.03.2017 and, out of abundant caution,\ndisallowed 30 per cent thereof amounting to Rs. 50,49,586/-\nunder section 40(a) of the Act in A.Y. 2017–18 (a copy of the\nstatement of computation of income for A.Y. 2017-18 was placed\non record). It was further submitted that

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

15. As far as applicability of CBDT instruction no.1829 of 1989, dated 21st September 2989 is concerned, the learned Authorised Representative submitted that such instruction did not form basis of the decision rendered in Ishikawajima Harima Heavy Industries (supra), therefore, withdrawal of the said instruction will not alter the precedentiary value of the said decision. He submitted, even otherwise also

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

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

15, 2021 prescribed under the relevant Provident Fund Act.  In clause 20(b) of Form 3CD, the date of payment was inadvertently mentioned as July 04, 2020 instead of July 04, 2021, which resulted in the erroneous adjustment under section 143(1).  Documentary evidence in the form of payment challans was placed on record to substantiate the actual date