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

Accordingly, this ground is allowed

23 - (ITA No. 6702/Mum/2025) Ground No. I - Disallowance of employees' contribution to Provident Fund under section 36(1)(va) of the Act amounting to Rs. 54,93,734/- 64. During the processing of the return of income under section 143(1) of the Act, an adjustment was proposed in respect of employees' contribution to Provident Fund amounting

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

Accordingly, this ground is allowed

23 - (ITA No. 6702/Mum/2025) Ground No. I - Disallowance of employees' contribution to Provident Fund under section 36(1)(va) of the Act amounting to Rs. 54,93,734/- 64. During the processing of the return of income under section 143(1) of the Act, an adjustment was proposed in respect of employees' contribution to Provident Fund amounting

VARIAN MEDICAL SYSTEMS INTERNATIONAL (INDIA) PRIVATE LIMITED,MUMBAIQQQ vs. ASSESSMENT UNIT NFAC CETNRE ITO, MINISTRY OF FINANCE DELHI, DELHI

In the result, the appeal of the assessee is partially allowed

Bench: Shri Narender Kumar Choudhry, Jm & Ms Padmavathy S, Am

68 2. Disallowance of finance cost under section 37(1) Rs. 31,97,466/- 3. Disallowance of installation support service charges Rs. 1,43,72,205/- and warranty services 4. Addition towards recovery of warranty support Rs. 12,81,24,990/- services charges from AE 5. Disallowance of warranty support charges under Rs. 3,22,33,056/-. section

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

23 - (ITA No. 6702/Mum/2025) Ground No. I - Disallowance of employees' contribution to Provident Fund under section 36(1)(va) of the Act amounting to Rs. 54,93,734/- 64. During the processing of the return of income under section 143(1) of the Act, an adjustment was proposed in respect of employees' contribution to Provident Fund amounting

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).

va)) was maintained - and continues to be maintained. On the other hand, section 43B covers all deductions that are permissible as expenditures, or out-goings forming part of the assessees' liability. These include liabilities such as tax liability, cess duties etc. or interest liability having regard to the terms of the contract. Thus, timely payment of these alone entitle

INCOME TAX OFFICER 8(3)(3), MUMBAI vs. M/S.VIBGYOR TEXOTECH PRIVATE LIMITED, MUMBAI

In the result, the appeal of the assessee is partly allowed, whereas appeal of the Revenue is allowed

Bench: Shri Amarjit Singh () & Shri Om Prakash Kant () Assessment Year: 2009-10 Income Tax Officer-8(3)(3), M/S Vibgyor Texotech Pvt. Ltd., Room No. 616, 6Th Floor, Aayakar 309, Navyug, T.J. Road, Sewree, Bhavan, M.K. Road, Vs. Mumbai-400015. Mumbai-400020. Pan No. Aaccv 0752 D Appellant Respondent Assessment Year: 2009-10 M/S Vibgyor Texotech Pvt. Ltd., The Asst. Commissioner Of 309, Navyug, T.J. Road, Sewree, Income Tax-8(3)(2), Mumbai-400015. Vs. Mumbai. Pan No. Aaccv 0752 D Appellant Respondent

Va’ to ‘Vn’ having returned income or loss of upto Rs.30 lakh under jurisdiction of Principal Commissioner of Income-Tax-1 to 5 and 16 and in case of return income exceeding Rs.30 lakh, the jurisdiction lied with ACIT/DCIT 8(3)(2). The Ld. DR submitted that in view of the no regular return of income filed by the assessee

M/S.VIBGYOR TEXOTECH PRIVATE LIMITED,MUMBAI vs. ACIT-8(3)(2), MUMBAI

In the result, the appeal of the assessee is partly allowed, whereas appeal of the Revenue is allowed

Bench: Shri Amarjit Singh () & Shri Om Prakash Kant () Assessment Year: 2009-10 Income Tax Officer-8(3)(3), M/S Vibgyor Texotech Pvt. Ltd., Room No. 616, 6Th Floor, Aayakar 309, Navyug, T.J. Road, Sewree, Bhavan, M.K. Road, Vs. Mumbai-400015. Mumbai-400020. Pan No. Aaccv 0752 D Appellant Respondent Assessment Year: 2009-10 M/S Vibgyor Texotech Pvt. Ltd., The Asst. Commissioner Of 309, Navyug, T.J. Road, Sewree, Income Tax-8(3)(2), Mumbai-400015. Vs. Mumbai. Pan No. Aaccv 0752 D Appellant Respondent

Va’ to ‘Vn’ having returned income or loss of upto Rs.30 lakh under jurisdiction of Principal Commissioner of Income-Tax-1 to 5 and 16 and in case of return income exceeding Rs.30 lakh, the jurisdiction lied with ACIT/DCIT 8(3)(2). The Ld. DR submitted that in view of the no regular return of income filed by the assessee

J KUMAR INFRAPROJECTS LIMITED,MUMBAI vs. THE DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -5(1), MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails

DCIT CC 5-1, MUMBAI, MUMBAI vs. J KUMAR INFRAPROJECTS LIMITED , MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails

J KUMAR INFRAPROJECTS LIMITED,MUMBAI vs. THE DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -5(1), MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails

J KUMAR INFRAPROJECTS LIMITED,MUMBAI vs. THE DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -5(1), MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails

DCIT, MUMBAI vs. J KUMAR INFRAPROJECTS LIMITED, MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails

ACIT-2(2)(1), MMUMBAI vs. M/S. JICS LOGISTIC LIMITED , MUMBAI

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

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

section 143(3) of the 10/03/2014, the Assessing Officer made t 10/03/2014, the Assessing Officer made two additions. o additions. Firstly, addition was made made made disallowing disallowing disallowing depreciation depreciation depreciation amounting amounting amounting to to to ₹3,38,42,112/- claimed on intangible assets claimed on intangible assets in the form of form of ‘business right

ACIT-2(2)(1), MMUMBAI vs. M/S. JICS LOGISTIC LIMITED , MUMBAI

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

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

section 143(3) of the 10/03/2014, the Assessing Officer made t 10/03/2014, the Assessing Officer made two additions. o additions. Firstly, addition was made made made disallowing disallowing disallowing depreciation depreciation depreciation amounting amounting amounting to to to ₹3,38,42,112/- claimed on intangible assets claimed on intangible assets in the form of form of ‘business right

ACIT-2(2)(1), MMUMBAI vs. M/S. JICS LOGISTIC LIMITED , MUMBAI

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

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

section 143(3) of the 10/03/2014, the Assessing Officer made t 10/03/2014, the Assessing Officer made two additions. o additions. Firstly, addition was made made made disallowing disallowing disallowing depreciation depreciation depreciation amounting amounting amounting to to to ₹3,38,42,112/- claimed on intangible assets claimed on intangible assets in the form of form of ‘business right

ACIT-2(2)(1), MMUMBAI vs. M/S. JICS LOGISTIC LIMITED , MUMBAI

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

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

section 143(3) of the 10/03/2014, the Assessing Officer made t 10/03/2014, the Assessing Officer made two additions. o additions. Firstly, addition was made made made disallowing disallowing disallowing depreciation depreciation depreciation amounting amounting amounting to to to ₹3,38,42,112/- claimed on intangible assets claimed on intangible assets in the form of form of ‘business right

ACIT-2(2)(1), MMUMBAI vs. M/S. JICS LOGISTIC LIMITED , MUMBAI

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

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

section 143(3) of the 10/03/2014, the Assessing Officer made t 10/03/2014, the Assessing Officer made two additions. o additions. Firstly, addition was made made made disallowing disallowing disallowing depreciation depreciation depreciation amounting amounting amounting to to to ₹3,38,42,112/- claimed on intangible assets claimed on intangible assets in the form of form of ‘business right

ACIT-2(2)(1), MMUMBAI vs. M/S. JICS LOGISTIC LIMITED , MUMBAI

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

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

section 143(3) of the 10/03/2014, the Assessing Officer made t 10/03/2014, the Assessing Officer made two additions. o additions. Firstly, addition was made made made disallowing disallowing disallowing depreciation depreciation depreciation amounting amounting amounting to to to ₹3,38,42,112/- claimed on intangible assets claimed on intangible assets in the form of form of ‘business right

ACIT-2(2)(1), MMUMBAI vs. M/S. JICS LOGISTIC LIMITED , MUMBAI

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

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

section 143(3) of the 10/03/2014, the Assessing Officer made t 10/03/2014, the Assessing Officer made two additions. o additions. Firstly, addition was made made made disallowing disallowing disallowing depreciation depreciation depreciation amounting amounting amounting to to to ₹3,38,42,112/- claimed on intangible assets claimed on intangible assets in the form of form of ‘business right