DEUTSCHE INDIA PVT. LTD.(EARLIER KNOWN AS 'DBOI GLOBAL SERVICES PVT. LTD.),MUMBAI vs. ACIT-1(3)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for 16

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

68,149/- as CSR expenditure in its books of accounts however, for the purpose of claiming deduction u/s 80G of the Income-tax, Act, 1961, the assessee is treating the same expenses as Donation. The amount has not been paid by the a ssessee voluntarily to become eligible for entity specified under Section 80G

SHREE SAI BABA SANSTHAN TRUST (SHIRDI),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX (EXEMPTION) 2(1), MUMBAI

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

5% of the total expenses of the Trust. In such a case, the trust may be eligible for certificate u/s 80G of the Act and at the same time would not be liable to be taxed for the anonymous donations received by virtue of Section 115BBC(2)(b) of the Act. We thus find merit in the submission

DY. COMMISSIONER O INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST(SHIRDI), MUMBAI

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

5% of the total expenses of the Trust. In such a case, the trust may be eligible for certificate u/s 80G of the Act and at the same time would not be liable to be taxed for the anonymous donations received by virtue of Section 115BBC(2)(b) of the Act. We thus find merit in the submission

DY. COMMISSIONER O INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST(SHIRDI), MUMBAI

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

5% of the total expenses of the Trust. In such a case, the trust may be eligible for certificate u/s 80G of the Act and at the same time would not be liable to be taxed for the anonymous donations received by virtue of Section 115BBC(2)(b) of the Act. We thus find merit in the submission

DY. COMMISSIONER OF INCOME TAX (EXEMPTION) 2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST (SHIRDI), MUMBAI

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

5% of the total expenses of the Trust. In such a case, the trust may be eligible for certificate u/s 80G of the Act and at the same time would not be liable to be taxed for the anonymous donations received by virtue of Section 115BBC(2)(b) of the Act. We thus find merit in the submission

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)

5. After giving thoughtful consideration to the material placed on record and the submissions of the learned Departmental Representative, it is evident that the sole controversy centres upon the allowability of deduction under section 80G in respect of donations made out of CSR funds, which the assessee had already disallowed while computing income under section 37. This precise

THE RUBY MILLS LIMITED,MUMBAI vs. PCIT (CENTRAL) - 8, MUMBAI

In the result, appeals of the revenue are dismissed

Bench: Shri Pawan Singh & Shri Prabhash Shankar(Physical Hearing) The Ruby Mills Limited Pr. Commissioner Of Income Tax 11Th Floor, Ruby House A, Vs (Central)-5, Aayakar Bhawan, J.K. Sawant Marg, Dadar West, Mumbai-400020. Mumbai – 400028. [Pan No. Aaact0220G] Appellant / Assessee Respondent / Revenue

68 and addition under head income from business and profession. The assessment was revised, ld. Pr. CIT by exercising jurisdiction under section 263 on 10.03.2025. Before passing the order under section 263, the ld. Pr. CIT issued show cause notice dated 28.02.2025. In the show cause notice, the ld. Pr. CIT noted that on perusal of assessment record

NAV CONSEC P.LTD,MUMBAI vs. ITO 9(2)(3), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Aby T. Varkey, Jm & Shri. Gagan Goyal, Am आयकर अपील सं/ I.T.A. No.3258/Mum/2016 (निर्धारण वर्ा / Assessment Year: 2011-12) M/S Nav Consec Pvt Ltd बिधम/ Income Tax Officer, Ward 9(2)(3) Mumbai. Vs. C/O Sanjay Shah, 108, 1St Floor Sujata Niketan, Rani Sati Marg Malad East, Mumbai-400097 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcn1435A (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Shri Anil Surana, Ca (Written Submission) Assessee By: Dr Mahesh Akhade, Cit Dr

5. For that the Ld. CIT(A) erred in drawing adverse inference on account of high share premium charged -wherein the share premium is a capital receipt. The issue is squarely covered by the decision of jurisdictional Dombatj High Coxirt in the case of Vodafone Services India Pvt. Ltd. reported in 6. For that the Ld. CIT(A) erred

PRUDENT INSURANCE BROKERS PRIVATE LIMITED ,MUMBAI vs. PCIT-8 , MUMBAI

In the result, the appeal of the assessee stands allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

68,44,440/–. In the said return, the assessee claimed deduction under section 80G of ₹10,50,000/– in respect of donations aggregating to ₹10,00,000/– to KK Birla Memorial, ₹6,00,000/– to St. Krishna Public Charitable Trust, and ₹5

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. RELIANCE RETAIL LIMITED, MUMBAI

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

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

80G to meet Corporate Social Responsibility. Additional claim of foreign tax credit not granted: Rs. 78,67,620 5. Erred in disallowing the additional claim of foreign tax credit of Rs. 78,67,620 on the ground that the Appellant did not file the Form 67 before the due date of filing the Return of Income (‘ROI’); 6. Erred

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

5. We heard the parties and perused the material on records. The\nassessee during the year disallowed a sum of Rs.33,85,00,000 under\nsection 37 of the Act towards the CSR Spend in compliance with section\n135 of the Act. Since the institutions to which the said amounts are\ngiven are registered under section 80G

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

5,26,845/- consequentially on the alleged ground that no refund is due on regular assessment. 2. The Appellant submits that the interest u/s 234D of the Act ought to be deleted. 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

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

SOLA HAKIM MEDICAL RESEARCH TRUST, MUMBAI vs. DIT (E), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri M.Balaganesh, Am & Shri Amarjit Singh, Jm Sola Hakim Medical Vs. The Director Of Income- Research Trust Tax(Exemption), Mumbai 9, Hamton Court Colaba, Mumbai – 400 005 Pan/Gir No.Aacts2195J (Appellant) .. (Respondent)

80G(5) of the Act which says that the approval u/s.80G be rejected if any institution accepts anonymous donations. Finally, it held that these factors are not relevant for granting approval u/s.80G of the Act and the same could very well be taken care at the time of assessment proceedingd by the ld. AO. 7.1. The ld. AR also placed

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 LIFE INSURANCE CORPORATION OF INDIA,MUMBAI-400021 vs. DY COMMISSIONER OF INCOME TAX-3(2)(1), MUMBAI

Appeal is disposed off as being partly allowed

68. Ground No. 4 pertains to deduction of INR 10,00,00,000/- claimed under 80G of the Act. 69. In view of paragraph 28 to 31 above, we do not find any reason to interfere with the order passed by CIT(A) and confirm the order of the Assessing Officer to the extent the Assessing Officer held that

DCIT-13(2)(2), MUMBAI vs. M/S.SHUBHAM MOTIWALA & JEWELLERS PRIVATE LIMITED, MUMBAI

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Bledcit – 13(2)(2) V. M/S. Shubham Motiwala & Jewellers Pvt. Ltd., Shop No. 5, Unity Heights, Chincholi Jn, 1St Floor, Room No. 146 Aayakar Bhavan, M.K. Road Sv Road, Malad, Mumbai – 400064 Mumbai - 400020 Pan: Aahcs1597A

80G and 80GGB of Income-tax Act, 1961 (in short “Act”) and the return was processed u/s. 143(1) of the Act. The case was selected for scrutiny and notices u/s. 143(2) and 142(1) were issued and served on the assessee. In response, Authorised Representative attended and filed relevant information as called for. 3. Assessee is engaged

WNS GLOBAL SERVICES PRIVATE LIMITED,MUMBAI vs. ASESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, NEW DELHI, NEW DELHI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

68,243/-on account of disallowance of depreciation. We are in any case going to consider the whole amount of depreciation of Rs.52,04,37,398/- at the time of adjudicating ground No.(5) and, hence, the adjustment proposed by the TPO would also be required to be dealt with accordingly. Hence, dealing with the same separately at this juncture