ACIT 6(3), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

244A(1) would be assessable in the\nyear in which it is granted and not in the year in which\nproceedings under section 143(1)(a) attain finality.\n16. The matter will now go to the regular Bench for decision on\nmerits.” (Emphasis Supplied)\n10. 4. We note that the CIT(A) has decided the issue in the following

BAJAJ HOLDINGS & INVESTMENT LTD (FORMERLY KNOWN AS BAJAJ AUTO LTD),MUMBAI vs. DCIT (LTU) 1, MUMBAI

In the result, both the appeals of the assessee are allowed

Bench: Shri C.N. Prasad & Shri Rajesh Kumar

68,714/- pertinent to A.Y. 2007-08 and balance related to the two assessment years i.e. 2003-04 & 2003-04. The TDS pertaining to A.Y. 2003-04 was Rs.1,31,76,602/-. However, while computing the interest under section 244A

UNION BANK OF INDIA,MUMBAI vs. ACIT LTU, MUMBAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla & Shri Ashwani Tanejaassessment Year: 2008-09 Union Bank Of India, Acit Ltu, Central Accounts 29Th Floor, World बनाम/ Department, Vi Floor, 239 Trade Centre, Cuff Vs. Vidhan Bhavan Marg, Parade Nariman Point Mumbai -400 021 Mumbai-400005 (Revenue) (Respondent ) P.A. No.Aaacu0564G Assessee By Shri C. Naresh (Ar) Revenue By Shri G.M. Doss (Dr)

section (1) has been increased or reduced, as the case may be, the interest shall be increased or reduced accordingly. In the present context interest u/s 244A was calculated by the AO as a first step upto June 2009 which amounted to Rs 18,51,43,880/-. The refund due at that point of time was arrived at Rs.246

TATA CHEMICALS LTD,MUMBAI vs. DCIT CIR 2(2), MUMBAI

Bench: Shri M. Balaganesh & Shri Ravish Soodtata Chemicals Limited Commissioner Of Income Tax-2 Bombay House, 24, 384, Aayakar Bhavan, M.K. Road, Vs. Homi Mody, Street, Fort, Mumbai – 400 020 Mumbai – 400 001 Pan – Aaact4059M (Appellant) (Respondent) Appellant By: Shri Nitesh Joshi & Shri Atul Suraiya, A.Rs Respondent By: Shri R. Manjunatha Swami, Cit D.R Date Of Hearing: 18.09.2019 Date Of Pronouncement: 30.09.2019

section (2) of Sec. 244A would be invoked only if the assessee had caused any delay in completion of the assessment proceeding under which the refund is granted. Accordingly, drawing support from the aforesaid judicial pronouncement, it was submitted by the Ld. A.R that as the assesse in the present case had not caused any delay in the completion

M/S CHEMET,MUMBAI vs. ASSTT.COMMISSIONER OF INCOME TAX, CIRCLE 19(2) , MUMBAI

Bench: Shri Prashant Maharishi & Shri Kuldip Singhassessment Year: 1996-97 M/S. Chemet, Asst. Commissioner Of 2Nd Floor, Income Tax, Span Centre, 556, Circle-19(2), Vs. Ramkrishna Mission Road, Aayakar Bhavan, Santacruz (West), Maharishi Karve Road, Mumbai – 400 054 Mumbai - 400020 Pan: Aaafc0996P (Appellant) (Respondent) Present For: Assessee By : Shri M. Subramanian, A.R. Revenue By : Shri B. Bagchi, D.R.

68,749/- interest u/s 244A of the act. 2 On the facts and in the circumstances of the case & in law, the learned CIT(A) erred in not directing the granting of interest u/s 244A of the act on the refund of Self-Assessment tax payment. 2 M/s. Chemet 3. On the facts and in the circumstances of the case

TATA MOTORS LTD,MUMBAI vs. DCIT LTU 2, MUMBAI

In the result, appeal of the assessee is allowed

68,40,27,967 70,55,000 70,55,00,000 32,90,44,20,857 44,38,13,92,393 31,53,10,17,212 1285,03,75,181 6.4. During the course of the assessment proceeding, after examination of the aforesaid details submitted vide letter dated 28.10.2015. the Ld. AO vide Order Sheet Entry, further called for evidences

TATA MOTORS LTD,MUMBAI vs. DCIT LTU 2, MUMBAI

Bench: Shri C. N. Prasad, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 3424/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2013-14)

244A 3 I.T.A. No. 3424/Mum/2019 Tata Motors Ltd already provided and MAT credit of Rs. 71,72,17,877/- also needed to be withdrawn. Accordingly, assessee was asked to submit the submission in this regard and in response, assessee filed a detail written submission on this matter and we are reproducing only relevant paragraphs:- 3. Exercise of powers

GENERAL REINSURANCE AG,COLOGNE, GERMANY vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION) CIRCLE - 2(3)(2), MUMBAI

244A of the Act granted to the Appellant while computing the tax payable\nby the Appellant in the income-tax computation sheet.\n17. Without prejudice to Ground No. 1 above, the learned AO has on the facts and\ncircumstances of the case, and i and in law, erred in initiating penalty\nproceedings under section 270A of the Act.”\nITA

MAPE ADVISORY GROUP PRIVATE LIMITED,MUMBAI vs. DCIT CIRCLE 5.2.1, MUMBAI

In the result, appeal of the assessee is allowed

section 244A of the\nAct, on refund, up to the date of refund cheque.\n(b) On the facts and in the circumstances of the case and in law,\nthe Hon'ble CIT (A) erred in confirming the withdrawal of interest\namounting to Rs 5,68

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

M/S PIRAMAL ENTERPRISES LIMIITED ,MUMBSI vs. DY CIT(APPEAL)-RANGE-8(2)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2017-18 M/S Piramal Enterprises Ltd., Dy. Cit, Mumbai-8(1)(2), Or Piramal Tower, Agastya National Facelss Assessment Vs. Corporate Park, Lbs Marg, Centre, Delhi, Kamani Junction, Kurla Room No. 624, 6Th Floor, (West), Aayakar Bhavan, M.K. Road, Mumbai-400070. Mumbai-400020. Pan No. Aaacn 4538 P Appellant Respondent : Assessee By Mr. Ronak Doshi : Revenue By Mr. Rakesh Ranjan, Cit-Dr & Mr. Samuel Pitta, Dr : Date Of Hearing 17/11/2022 : Date Of Pronouncement 28/12/2022

244A of the Act. 2. Briefly stated, facts of the case are that the assessee Briefly stated, facts of the case are that the assessee Briefly stated, facts of the case are that the assessee-company was engaged in the business of manufacturing was engaged in the business of manufacturing of of pharmaceutical formulations as well as trading in pharmaceutical

INDIAN OIL CORPORATION LTD,MUMBAI vs. DCIT 14(2)(1), MUMBAI

In the result, the appeal of the assessee is partly allowed and that of the revenue is dismissed

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriindian Oil Corporation V/S. Dcit-14(2)(1), Mumbai Ltd. बनाम Aaykar Bhavan, G-9, Ali Yavar Jung Marg, M.K.Road, Bandra (East), Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaci1681G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Dcit-14(2)(1), Mumbai V/S. Indian Oil Corporation Ltd. Aaykar Bhavan, बनाम G-9, Ali Yavar Jung Marg, M.K.Road, Bandra (East), Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaci1681G Appellant/अपीलार्थी .. Respondent/प्रतिवादी

68 months from December 2014 to July 2020 in granting refund due to the assessee. Accordingly, he argued that the assessee is entitled to additional interest @3% per annum u/s 244A(1)(b) for the entire period. Ld. AR further placed reliance on the following decisions in support of its claim. (i) Stock Holding Corporation of India v/s N.C. Tewari

DCIT-14(1)(1), MUMBAI vs. INDIAN OIL CORPORATION LTD, MUMBAI

In the result, the appeal of the assessee is partly allowed and that of the revenue is dismissed

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriindian Oil Corporation V/S. Dcit-14(2)(1), Mumbai Ltd. बनाम Aaykar Bhavan, G-9, Ali Yavar Jung Marg, M.K.Road, Bandra (East), Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaci1681G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Dcit-14(2)(1), Mumbai V/S. Indian Oil Corporation Ltd. Aaykar Bhavan, बनाम G-9, Ali Yavar Jung Marg, M.K.Road, Bandra (East), Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaci1681G Appellant/अपीलार्थी .. Respondent/प्रतिवादी

68 months from December 2014 to July 2020 in granting refund due to the assessee. Accordingly, he argued that the assessee is entitled to additional interest @3% per annum u/s 244A(1)(b) for the entire period. Ld. AR further placed reliance on the following decisions in support of its claim. (i) Stock Holding Corporation of India v/s N.C. Tewari

ORIENT OVERSEAS CONTAINER LINE LIMITED ,MUMBAI vs. DCIT (INT) TAX CIRCLE 3(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailorient Overseas Container Line Limited, C/O Oocl (India) Private Limited, Icc Chambers, 5Th Floor, Saki Vihar Road, Opp. Santogen Silk Mills, Powai, ............... Appellant Mumbai - 400072 Pan : Aaaco5679E V/S Deputy Commissioner Of Income Tax (International Taxation), Circle – 3(2)(2), ……………… Respondent 6Th Floor, Kautilya Bhavan, Bandra Kurla Complex, Mumbai - 400051

244A of the Act 11. On the facts and circumstances of the case, Ld. AO has erred in raising the outstanding demand on the e-filing portal of the Appellant vide Demand Identification Number 2025202337363986854C. Initiation of penalty proceedings under section 270A 12. The Ld. AO has erred in initiating penalty proceedings under section 270A

GENERAL REINSURANCE AG,MUMBAI vs. ASSISTANT COMM. OF INCOME TAX (INTERNATIONAL TAXATION)-RANGE 2(3)(2), MUMBAI

In the result, all the four appeals of the assessee are partly\nallowed

244A of the Act granted to the Appellant while computing the tax payable\nby the Appellant in the income-tax computation sheet.\n17. Without prejudice to Ground No. 1 above, the learned AO has on the facts and\ncircumstances of the case, and i and in law, erred in initiating penalty\nproceedings under section 270A of the Act.”\nITA

GENERAL REINSURANCE AG,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATONAL TAXATION)-RANGE 2(3)(2), MUMBAI

244A of the Act granted to the Appellant while computing the tax payable\nby the Appellant in the income-tax computation sheet.\n17. Without prejudice to Ground No. 1 above, the learned AO has on the facts and\ncircumstances of the case, and i and in law, erred in initiating penalty\nproceedings under section 270A of the Act.”\nITA

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. PR CIT 3, MUMBAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Shri Pawan Singh (Jm) & Shri G Manjunatha (Am) M/S Small Industries Vs Pr. Commissioner Of Income- Development Bank Of India Tax-3, Mumbai C-22, ‘G’Block, Msme Development Centre, Bandra Kurla Complex, Bandra (E), Mumbai Pan : Aabcs3480N Appellant Respondednt

68,83,899/- determined vide order dated 19.02.2010. Accordingly vide order dated 11.03.2013 assessed income has been revised to 1 a reduced figure of Rs. 19,75,00,563/- which has resulted into refund of tax 1 plus interest on Rs. 11,74,25,616/-. Therefore, assessee has not received any I interest on interest u/s 244A. The resultant refund

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

244A of the Act. GENERAL The Appellant craves leave to add, amend, modify, rescind, supplement or alter any of the Grounds stated hereinabove, either before or at the time of hearing of this appeal. A.Y. 2023–24 (ITA No. 6703/Mum/2025) GROUND NO. I: SHORT-TERM CAPITAL GAINS U/S 111A OF THE ACT AMOUNTING