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

VIA) and an amount not exceeding ten per cent of the aggregate average advances made by the rural branches of such bank computed in the prescribed manner : Provided that a scheduled bank or a non-scheduled bank referred to in this sub-clause shall, at its option, be allowed in any of the relevant assessment years, deduction in respect

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

VIA) and an amount not exceeding ten per cent of the\naggregate average advances made by the rural branches of such bank\ncomputed in the prescribed manner :\nProvided that a scheduled bank or a non-scheduled bank referred to in this\nsub-clause shall, at its option, be allowed in any of the relevant assessment\nyears, deduction in respect

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

via) is also entitled for deduction under section 36(1)(vii) towards actual write off. The legislature restricts double deduction by proviso to section 36(1)(vii) where it is stated that the deduction under section 36(1)(vii) cannot exceed the credit balance in the provision under section 36(1)(viia). On perusal

DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

via) is also entitled for deduction under section 36(1)(vii) towards actual write off. The legislature restricts double deduction by proviso to section 36(1)(vii) where it is stated that the deduction under section 36(1)(vii) cannot exceed the credit balance in the provision under section 36(1)(viia). On perusal

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

VIA and an amount not exceeding 10% of the aggregate average advances made by the rural branches. Thus the deduction under section 36(1)(viia) being a deduction linked to the total income computed it is subject to revision each time the total income changes viz. increases /decreases subject to the provision created in the books of accounts

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

36(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

ASST CIT 19(3), MUMBAI vs. PAHILAJRAI JAIKISHIN, MUMBAI

In the result, the appeal is allowed

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

68,778 Average value of Investment related to Tax free income Opening Investment 5,22,02,950.00 Closing Investment 4,74,88,371.17 4,98,45,660 Average Total Assets in Balance Sheet Opening Total Assets 50,37,32,643 Closing Total Assets 58,77,80,214 54,57,56,428 Interest Expenses 12,66,679 C Deemed Expenses

PAHILAJRAI JAIKISHAN,MUMBAI vs. DCIT 19(3), MUMBAI

In the result, the appeal is allowed

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

68,778 Average value of Investment related to Tax free income Opening Investment 5,22,02,950.00 Closing Investment 4,74,88,371.17 4,98,45,660 Average Total Assets in Balance Sheet Opening Total Assets 50,37,32,643 Closing Total Assets 58,77,80,214 54,57,56,428 Interest Expenses 12,66,679 C Deemed Expenses

M/S THE MAHARASHTRA STATE CO. OP BANK LTD.,MUMBAI vs. ITO-1(3)(3), MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

section (6), section (6),— (b) any income is excluded from the total income of one (b) any income is excluded from the total income of one (b) any income is excluded from the total income of one person and held to be the income of another person, person and held to be the income of another person, person

DY CIT-1(3)(2), MUMBAI vs. MAHARASHTRA STATE CO-OPERATIVE BANK LIMITED, MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

section (6), section (6),— (b) any income is excluded from the total income of one (b) any income is excluded from the total income of one (b) any income is excluded from the total income of one person and held to be the income of another person, person and held to be the income of another person, person

ASST CIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

Bench: Smt. Beena Pillai () & Shri Jagadish ()

1,44,74,298 and it will thus be appreciated that out of the total interest expenditure of Rs. 3,93,69,566, interest expenditure at the most of Rs. 1,44,74,298 could be relatable to earning dividend income. We do not agree with the alternative contention of the learned counsel of the assessee. It is established clearly

STATE BANK OF INDIA,MUMBAI vs. ASST CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

Bench: Smt. Beena Pillai () & Shri Jagadish ()

1,44,74,298 and it will thus be appreciated that out of the total interest expenditure of Rs. 3,93,69,566, interest expenditure at the most of Rs. 1,44,74,298 could be relatable to earning dividend income. We do not agree with the alternative contention of the learned counsel of the assessee. It is established clearly

DCIT-2(3)(1), MUMBAI vs. INDUSIND BANK LTD., MUMBAI

via) the rural advances given by Bharat Financial Inclusion Ltd.\n(BFIL) an NBFC which got amalgamated with the assessee company from the\nappointed date 01.01.2018 should be included. The CIT(A) gave partial relief to the\nassessee with regard to the various disallowances made by the AO. With regard to\nfresh claim made towards deduction under section 36

INDUSIND BANK LTD,MUMBAI vs. THE DCIT-2(3)(1), MUMBAI

In the result, the Income Tax Appeal is\ndismissed

via) the rural advances given by Bharat Financial Inclusion Ltd.\n(BFIL) an NBFC which got amalgamated with the assessee company from the\nappointed date 01.01.2018 should be included. The CIT(A) gave partial relief to the\nassessee with regard to the various disallowances made by the AO. With regard to\nfresh claim made towards deduction under section 36

INNO vs. OURCE SERVICES PRIVATE LIMITED,MUMBAIVS.DCIT, 14(1)(1), MUMBAI

In the result, the appeal of the assessee is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22 Innovsource Services Pvt. Ltd., Dcit, 14(1)(1), 501, Jolly Board Tower 1, I-Think Aayakar Bhavan, Maharshi Karve Vs. Techno Campus Kanjurmarg-East, Road, New Marine Lines, Mumbai-400042. Churchgate, Mumbai-400020. Pan No. Aaeci 0979 D Appellant Respondent

68,378/- or is to be restricted to the e restricted to the business income of Rs 6,22,44,207/ business income of Rs 6,22,44,207/- will be relevant if the will be relevant if the appellate authority in the appeal filed against the 143(3) order appellate authority in the appeal filed against

ICICI SECURITIES LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI -4, MUMBAI

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

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

36, also makes it clear that there is no bar regarding the admissibility of CSR expenditure under any other provision of the Act, except under section 37(1). In other words, the intention of the legislature is not to restrict the right of the assessee to claim deduction towards the CSR spend if the payment is otherwise allowable under

GLITCH MEDIA PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - 1(3)(1), MUMBAI

In the result the appeal filed by the assessee stands partly\nallowed

1) of the Act, they are specifically excluded\nin clarification issued. There is no restriction on an expenditure being\nclaimed under above sections to be exempt, as long as it satisfies\nnecessary conditions under section 30 to 36 of the Act, for computing\nincome under the head, "Income from Business and Profession".\n17. For claiming benefit under section

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).

68,71,018, as a dividend from M/s Alexandria Carbon Black Company S.A.E., a company incorporated and registered under the laws of Egypt (U.A.R.). It is the plea of the assessee that the aforesaid dividend received from the Egyptian company is not taxable in India. 48. We find that the coordinate bench, vide order dated 23/06/2023, passed in assessee