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

234B of the Act amounting to Rs. 3,31,027/- being consequential in nature. GROUND NO. IV: EXCESS LEVY OF INTEREST U/S 234C OF THE ACT AMOUNTING TO RS. 15,763/- 1. On the facts and circumstances of the case and in law, CIT(A) erred in confirming the action of the AO in levying excess interest u/s 234C

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

Accordingly, this ground is allowed

234B of the Act amounting to Rs. 3,31,027/- being consequential in nature. GROUND NO. IV: EXCESS LEVY OF INTEREST U/S 234C OF THЕ АСТ AMOUNTING TO RS. 15,763/- 1. On the facts and circumstances of the case and in law, CIT(A) erred in confirming the action of the AO in levying excess interest u/s 234C

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

Accordingly, this ground is allowed

234B of the Act amounting to Rs. 3,31,027/- being consequential in nature. GROUND NO. IV: EXCESS LEVY OF INTEREST U/S 234C OF THE ACT AMOUNTING TO RS. 15,763/- 1. On the facts and circumstances of the case and in law, CIT(A) erred in confirming the action of the AO in levying excess interest u/s 234C

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

234B of the Act amounting to Rs. 3,31,027/- being consequential in nature. GROUND NO. IV: EXCESS LEVY OF INTEREST U/S 234C OF THE ACT AMOUNTING TO RS. 15,763/- 1. On the facts and circumstances of the case and in law, CIT(A) erred in confirming the action of the AO in levying excess interest u/s 234C

M/S THE STATE BANK OF PATIALA,PATIALA vs. ACIT, PATIALA

In the result, the appeals of the assessee are partly allowed for In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2013-14 & Assessment Year: 2014-15 & Assessment Year: 2015-16 The State Bank Of India Asst. Cit Circle-Patiala, (Successor To State Bank Of Aayakar Bhavan, Vs. Patiala), Patiala-147001 Dgm & Cfo, Sbi, Local Head Office – Chandigarh, 2Nd Floor, Sector 17A, Chandigarh- 160017. Pan No. Aaccs 0143 D Appellant Respondent Assessee By : Mr. Ketan Ved & Mr. Ninadpatade, Ars Revenue By : Dr. Kishor Dhule, Cit-Dr : Date Of Hearing 09/03/2023 Date Of Pronouncement : 31/03/2023

1)(viia) of the Act. This ground of appeal deduction u/s 36(1)(viia) of the Act. This grou deduction u/s 36(1)(viia) of the Act. This grou is, therefore, dismissed. is, therefore, dismissed.” 12. We have heard rival submission of the parties on the issue in We have heard rival submission of the parties on the issue

M/S.BALAJI BULLION & COMMODITIES (INDIA) PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE-40, MUMBAI

In the result, both the appeals are allowed

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm Balaji Bullion & Commodities The Dy. Commissioner Of (India) Private Limited Income–Tax, 118/120, 3Rd Floor, Ashoka Central Circle–40, Vs. House Zavri Baazar, Mumbai Mumbai-400 002 (Appellant) (Respondent) Pan No. Aadcbo236F Balaji Universal Tradelinks P. The Dy. Commissioner Of Ltd. Income–Tax, 118/120, 3Rd Floor, Ashoka Central Circle–40, Vs. House Zavri Baazar, Mumbai Mumbai-400 002

1. The order of the assessing officer is erroneous on the facts and in the law. On the facts and in the circumstances of the case he ought to have accepted the returned income. 2. The Ld. Assessing officer has erred in initiating the proceedings under section 153A of the IT Act, 1961 and the assessment order is without

BALAJI UNIVERSAL TRADELINK P.LTD,MUMBAI vs. DCIT CEN CIR 40, MUMBAI

The appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri Sanjay Arora

68 taxmann.com368(SC) has held that limitation provisions for completing assessments are to be strictly construed as under: The counsel for the appellants are justified in their contention that the provision relating to limitation need to be strictly construed. In the case of K.M. Sharma v. ITO [2002] 254 ITR 772/122 Taxman 426 (SC), this principle is laid down

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhan

68 taxmann.com368(SC) has held that limitation provisions for completing assessments are to be strictly construed as under: The counsel for the appellants are justified in their contention that the provision relating to limitation need to be strictly construed. In the case of K.M. Sharma v. ITO [2002] 254 ITR 772/122 Taxman 426 (SC), this principle is laid down

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhan

68 taxmann.com368(SC) has held that limitation provisions for completing assessments are to be strictly construed as under: The counsel for the appellants are justified in their contention that the provision relating to limitation need to be strictly construed. In the case of K.M. Sharma v. ITO [2002] 254 ITR 772/122 Taxman 426 (SC), this principle is laid down

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhan

68 taxmann.com368(SC) has held that limitation provisions for completing assessments are to be strictly construed as under: The counsel for the appellants are justified in their contention that the provision relating to limitation need to be strictly construed. In the case of K.M. Sharma v. ITO [2002] 254 ITR 772/122 Taxman 426 (SC), this principle is laid down

ANIL MAHAVIR GUPTA,MUMBAI vs. ACIT CEN CIR 45, MUMBAI

In the result, appeal of the assessee allowed

Bench: Shri G.S.Pannu & Shri Sanjay Garg.

1. That on the facts and in the circumstances of the appellant's case and in law learned CIT (Appeal) has erred in sustaining, in part, the addition made by the assessing officer on the basis of maximum credit standing in the accounts of the Sundry Creditors of Rs.76,50,46,685/- u/s. 68 of the Act to the extent

ACIT CC-45, MUMBAI vs. ANIL M. GUPTA, MUMBAI

In the result, appeal of the assessee allowed

Bench: Shri G.S.Pannu & Shri Sanjay Garg.

1. That on the facts and in the circumstances of the appellant's case and in law learned CIT (Appeal) has erred in sustaining, in part, the addition made by the assessing officer on the basis of maximum credit standing in the accounts of the Sundry Creditors of Rs.76,50,46,685/- u/s. 68 of the Act to the extent

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

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings