ISARC-14/2010-11 TRUST,MUMBAI vs. ITO 23(1)(2), MUMBAI

In the result the Appeal is dismissed

Bench: Shri M.Balaganesh, Am & Shri Amarjit Singh, Jm M/S. Isarc 14/2010-11 Vs. Ito 23(1)(2), Trust Room No.108, C-11, G Block, Sme Matru Mandir, Tardeo Road Development Centre Grant Road, Bandra Kurla Complex Mumbai – 400 007 Bandra (East) Mumbai – 400 051 Pan/Gir No.Aaati8646N (Appellant) .. (Respondent) Ito 23(1)(2), Vs. M/S. Isarc 14/2010-11 Room No.108, Trust Matru Mandir, Tardeo Road C-11, G Block, Sme Grant Road, Development Centre Mumbai – 400 007 Bandra Kurla Complex Bandra (East) Mumbai – 400 051 Pan/Gir No.Aaati8646N (Appellant) .. (Respondent) M/S. Isarc-12/2010-11 Vs. Ito 23(1)(2), Trust Room No.108, C-11, G Block, Sme Matru Mandir, Tardeo Road Development Centre Grant Road, Bandra Kurla Complex Mumbai – 400 007 Bandra (East) Mumbai – 400 051 Pan/Gir No.Aaati8644Q Isarc Sidbi 2/2009-10 Trust

167B of the IT Act is applicable on the assessee instead of section 164(1) of the IT Act. b)On the facts and circumstances of the case and in law, the Ld. CIT (A) has ignored the fact that in this case investors/contributors are also the beneficiaries and at the date of creation of trust, beneficiaries were not identifiable

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal of the Revenue is dismissed and the cross objection of the Assessee is allowed in part in terms indicated herein above

Bench: Shri C.N. Prasad & Shri Ashwani Taneja

167B r.w.s. 86 of the Act. A further without prejudice submission is that the company has substantial own funds by way of capital reserves aggregating Rs. 12,936 lacs which is more than 5.50 times of the balance in such JV / partnership firm. The sale proceeds of the appellant are deposited in the cash credit account and the debit balance

ACIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, cross objection filed by the assessee is partly allowed

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

transfer by the appellant but solely on account of the appellant's income and share of profit generated from such JV/firm. When no funds whatsoever, borrowed or otherwise, have been invested in JVs/firms, the applicability of section 14A does not arise. When there is no expenditure incurred in relation to income not includable in the total income, the applicability

ACIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, cross objection filed by the assessee is partly allowed

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

transfer by the appellant but solely on account of the appellant's income and share of profit generated from such JV/firm. When no funds whatsoever, borrowed or otherwise, have been invested in JVs/firms, the applicability of section 14A does not arise. When there is no expenditure incurred in relation to income not includable in the total income, the applicability

ASST CIT CEN CIR 25, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal of revenue is dismissed, whereas cross objection of the assessee is allowed in part, in terms indicated hereinabove

section 80lA. As the assessee being directly under contract to the concern for the work done and also directly dealing with the Government on whose behalf the assessee are doing the work, they can be & CO No.9/15 considered as main contractors alongwith PEC and are not simply sub contractors vie-a-vis the work undertaken by them. As such

ESTATE OF NALINI MANILAL ,MUMBAI vs. ITO WARD 20(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2024-25 Estate Of Nalini Manilal, Ito 20(1)(1), 57, Naiman Bhavan, Vinay Shah Piramal Chambers, Vs. Marg, Nariman Point, S.O. Mumbai-400012. Mumbai-400021. Pan No. Aaaae 0475 E Appellant Respondent

167B of the Act are not applicable in the case of the Appellant. the case of the Appellant. c) Neglecting that the Appellant is regarded as an AOP u/s ing that the Appellant is regarded as an AOP u/s ing that the Appellant is regarded as an AOP u/s 168(1)(b) merely for statistical purpose whereas for discharging