EKTA SAHAKARI PATPEDHI MARYADIT,VIRAR vs. INCOME TAX OFFICER, ASSESSMENT UNIT, NEW DELHI

In the result, both the above appeals are allowed

68,52,014/- thereby wrongly treating the Appellant a Cooperative Bank instead of Cooperative Society and overlooking the fact that the deduction u/s Section 80P(2)(a)(i) was allowed in the previous years including AY 2017-18.\n2. In the facts and circumstances of the case and in law, the learned A.O. erred in denying deduction u/s Section

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT 3(1)(1),MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD, MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

MORGAN STANLEY MAURITIUS COMPANY LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-CIRCLE 3(2)(2), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Morgan Stanley Mauritius Company Dy. Cit (International Taxation) – Ltd., Circle 3(2)(2), Vs. C/O S R B C & Associates Llp, 14Th 16Th Floor, Room No. 1615, Air India Floor, The Ruby, 29, Senapati Bapat Building Nariman Point, Marg, Dadar (West), Mumbai-400021. Mumbai-400028. Pan No. Aadcm 5927 G Appellant Respondent

section 270A of the Act for under- reporting of income. reporting of income. The Appellant craves leave to add, alter, vary, omit, substitute, amend The Appellant craves leave to add, alter, vary, omit, substitute, amend The Appellant craves leave to add, alter, vary, omit, substitute, amend or withdraw any or all of the above grounds of appeal

SEADRILL INTERNATIONAL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-INTERNATIONAL TAXATION-4(2)(1), MUMBAI

The appeal of the assessee is allowed

68 relates to\npayment of service tax.\nSub-section (1) thereof\nstipulates that every\nperson,\nproviding\ntaxable service to any\nperson, shall pay service\ntax at the rate specified\nin section 66B\nof\nFinance Act 2012 in\nsuch manner, and within\nsuch period, as may be\nprescribed.\nNotwithstanding\nanything contained in\nsub-section (1), in\nrespect

OCEANEERING INTERNATIONAL GMBH,MUMBAI vs. DCIT(INT. TAXATION)RANGE-3(2)(2), MUMBAI

In the result, ground no. 4 of the appeal is allowed for statistical\npurposes

68 of erstwhile Service\nTax law and Section 49 of CGST Act, the comparison is given herein below.\n\nService Tax\n\nGST\n\nSection\n68 relates\nto CGST Act,\n2017\n(1) Every deposit made\ntowards tax, interest,\npenalty, fee or any other\namount by a person by\ninternet banking or by\nusing credit or debit cards

EKTA SAHAKARI PATPEDHI MARYADIT,VIRAR vs. INCOME TAX OFFICER, ASSESSMENT UNIT, NEW DELHI

In the result, both the above appeals are allowed

68,52,014/- thereby wrongly treating the Appellant a Cooperative Bank instead of Cooperative Society and overlooking the fact that the deduction u/s 80P(2)(a)(i) was allowed in the previous years including AY 2017-18.\n2. In the facts and circumstances of the case and in law, the learned A.O. erred in denying deduction u/s 80P(2

RITESH SINGH ACIT CIRCLE 3 3 1 MUMBAI, MUMBAI vs. TREND ELECTRONICS LIMITED, MUMBAI

In the result, all result, all the three appeals are allowed for three appeals are allowed for statistical purpose statistical purpose

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

270A of the Income-tax Act, 1961 (in short the ‘Act’) (in short the ‘Act’) for AY 2018-19. 2. The core issue The core issue arising in these appeals is narrow and legal arising in these appeals is narrow and legal in character, namely, in character, namely, whether the learned CIT(A) CIT(A) was justified in not adjudicating

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

68,81,654 under the head 'Profits and gains of business of profession' as\nclaimed by the Appellant in its return of income.\n13. Without prejudice to ground nos. 1 to 7, ground no. 10 and 12 above, the\nlearned AO has on the facts and in the circumstances of the case, and in law,\nand based on the directions

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

2 2006-07 - 3 2007-08 - 3 15.1. On this issue, ld. Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions for contingency” as reported in Schedule II of the balance sheet for the year under consideration. According to him, Section 36(1)(viii) speaks only of special reserve

ADDL CIT RG 1(1), MUMBAI vs. HDFC LTD, MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

2 2006-07 - 3 2007-08 - 3 15.1. On this issue, ld. Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions for contingency” as reported in Schedule II of the balance sheet for the year under consideration. According to him, Section 36(1)(viii) speaks only of special reserve

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

2 2006-07 - 3 2007-08 - 3 15.1. On this issue, ld. Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions for contingency” as reported in Schedule II of the balance sheet for the year under consideration. According to him, Section 36(1)(viii) speaks only of special reserve

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

2 2006-07 - 3 2007-08 - 3 15.1. On this issue, ld. Assessing Officer noted that assessee had withdrawn a sum of Rs.50 Crores from Special Reserve No. 1 towards “provisions for contingency” as reported in Schedule II of the balance sheet for the year under consideration. According to him, Section 36(1)(viii) speaks only of special reserve

HDFC BANK LIMITED (AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT 2(3)(1), MUMBAI

2 | As at \nMarch 31, 2004 | As at \nMarch 31, 2005 \nRupees | Rupees | Rupees \n---|---|---\nSPECIAL RESERVE No. I | 194,35,94,700 | 934,35,94,700\nLess: Transfer to Provision for Contingencies | 50,00,00,000 | 40,00,00,000 \nSPECIAL RESERVE No. II | 144,35,94,700 | 194,35,94,700 \nOpening Balance