POLYNOVA INDUSTRIES LIMITED,MUMBAI vs. DCIT 14(1)(1), MUMBAI

In the result, the appeal of the assessee stands allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2020-21 Polynova Industries Limited Dcit 14(1)(1) 159, Cst Road, Kalina, Aayakar Bhavan,4Th Floor, Santacruz East, Vs. Mumbai- 400001 Mumbai- 400098 Pan No. Aabcl 0864 D Appellant Respondent

68,94,980/-. The said return was processed under section 143(1) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), and the total income was adjusted to ₹14,69,27,010/-. Thereafter, a scrutiny assessment under section 143(3) of the Act was completed on 27.09.2022, wherein the income as determined under section

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

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)

vi) of the Act, in accordance with Rule 3 of the Income-tax Rules, 1962. The assessee duly deducted tax at source under section 192 of the Act on the value of such perquisite. 18. During the relevant previous year, the assessee debited a total ESOP expenditure of ₹12,64,77,536/- to its statement of profit and loss

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

vi) or any hospital or other institution referred to in sub-clause (iiiae) or sub- clause (via) or any fund or institution referred to in sub-clause (iv) or any trust or institution referred to in sub-clause (v) of clause (23C) of section 10 or any trust or institution referred to in section 11, includes any income

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

vi) or any hospital or other institution referred to in sub-clause (iiiae) or sub- clause (via) or any fund or institution referred to in sub-clause (iv) or any trust or institution referred to in sub-clause (v) of clause (23C) of section 10 or any trust or institution referred to in section 11, includes any income

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

vi) or any hospital or other institution referred to in sub-clause (iiiae) or sub- clause (via) or any fund or institution referred to in sub-clause (iv) or any trust or institution referred to in sub-clause (v) of clause (23C) of section 10 or any trust or institution referred to in section 11, includes any income

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

vi) or any hospital or other institution referred to in sub-clause (iiiae) or sub- clause (via) or any fund or institution referred to in sub-clause (iv) or any trust or institution referred to in sub-clause (v) of clause (23C) of section 10 or any trust or institution referred to in section 11, includes any income

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

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)

5,94,89,516/- relating to Assessment Year 2019–20 and Rs. 6,36,64,216/- relating to Assessment Years 2017–18 and 2018– 19.The learned AR submitted that section 80JJAA(1) clearly provides that deduction equal to 30 percent of the additional employee cost is allowable for three assessment years including the assessment year in which the employment

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

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)

vi) of sub-section (5) of section 80G shall be in Form No. 10G and shall be made in triplicate. (2) The application shall be accompanied by the following documents, namely :— (i) Copy of registration granted under section 12A or copy of notification issued under section 10(23) or 10(23C) ; (ii) Notes on activities

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

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

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

Accordingly, this ground is allowed

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

Accordingly, this ground is allowed

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

RELIANCE RETAIL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 8(1)(1), MUMBAI

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

5,94,89,516/- relating to Assessment Year 2019-20 and Rs. 6,36,64,216/- relating to Assessment Years 2017–18 and 2018– 19.The learned AR submitted that section 80JJAA(1) clearly provides that deduction equal to 30 percent of the additional employee cost is allowable for three assessment years including the assessment year in which the employment

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

80G of the Act. M/s Piramal Enterprises Ltd. 7 WITHOUT PREJUDICE TO GROUND I, WITHOUT PREJUDICE TO GROUND I, II, III AND VI AS II, III AND VI AS MENTIONED ABOVE: MENTIONED ABOVE: GROUND NO. VIII: DEDUCTION UNDER SECTION SOGGB GROUND NO. VIII: DEDUCTION UNDER SECTION SOGGB GROUND NO. VIII: DEDUCTION UNDER SECTION SOGGB

MARTIN AND HARRIS LABORATORIES LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX (PCIT), AAYKAR BHAWAN,MUMBAI-400020

In the result, the present appeal by the Assessee is allowed

68,54,840/- after claiming accounting MAT Credit brought forward from earlier years. The case of the Appellant was selected for scrutiny and assessment was completed on 16.12.2019 under Section 143(3) of the Act determining the total income at INR 30,25,86,600/- after making the addition/disallowance on account of advertisement and promotion expenses

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

vi) 3. Disallowance of legal & professional fees - 1 1 - - - - - - - - - 4. Disallowance of Dep. On Delhi Guest - 2 2 - - - - - - House 5. Disallowance of Dep. On KK Square office - 3 3 - - - - - - bldg. 6. Addition of deemed rent - 4 4 - - - - - - - - - 7. Disallowance of office and adm - 5 5 - - - - - - - - - expenditure of Delhi Guest House 8. Disallowance of electricity expenditure of - 6 6 - - - - - - - - - Delhi Guest