JEWELEX INDIA PRIAVTE LIMITED,MUMBAI vs. DCIT CIRCLE-14(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarjewelex India Private V/S. Deputy Commissioner Of Limited बनाम Income Tax, Circle – 401 Trade Centre, Bandra 14(1)(1), Aayakar Bhavan, Kurla Complex, Bandra Maharishi Karve Marg, (East), Mumbai – 400 098, Mumbai – 400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcj4523H Appellant/अपीलार्थी .. Respondent/प्रतिवादी

5) of the Companies Act are also eligible for deduction/s 80G of Ericsson India Global Services Pvt. Ltd. v. DCIT the Act subject to satisfying the requisite conditions prescribed for deduction u/s 80G of the Act. For this purpose, the issue is remanded to the file of AO to examine the same whether the payments satisfy the claim of donation

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)

price of shares and did not result in any real outflow or accrued liability. The failure of the Assessing Officer to examine the factual and legal sustainability of the claim under section 37(1) was treated as a serious lapse. (4) In so far as the deduction under section 80G amounting to ₹7,22,00,000/- was concerned, the learned

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

Bench: Shri Pawan Singh & Shri Girish Agrawal

5 & 9 of the income- tax Act, 1961, thus establishing that the liability to deduct tax at source under section 195 arase which the assessee failed to discharge?" 13. "Whether on facts and in circumstances of the case and in law, the Ld. CITIA) erred in deleting the disallowance of claim of deduction under section 10AA in respect of interest

FIRMENICH AROMATICS PRODUCTION (INDIA) PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(3)(1), MUMBAI

In the result, both the appeals of the assessee are partly allowed

Transfer Pricing\nOfficer has compared the price charged to non-AEs located in India with\nthe price charged to AEs in foreign countries. Therefore, the AEs and non-\nAEs being situated in different geographical locations, there may be\nvarious factors/reasons which could have influenced the price charged\nby the assessee to the AEs and non-AEs. Hence, the price charged

DCIT-3(4), MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

80G of the Act in respect of donations given under Corporate Social Responsibility. e) Disallowance under section 42(1)(b) in respect of KG-DWN-98/3 (KGD6 bloc) and Coal Bed Methane Sohagpur (CBM). 28 Reliance Industries Ltd. AY 2017-18 & 2018-19 f) Disallowance of foreign tax credit u/s 90(1)(a)(ii) relating to income eligible for deduction

RELIANCE INDUSTRIES LTD.,MUMBAI vs. ACIT CIRCLE 3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

80G of the Act in respect of donations given under Corporate Social Responsibility. e) Disallowance under section 42(1)(b) in respect of KG-DWN-98/3 (KGD6 bloc) and Coal Bed Methane Sohagpur (CBM). 28 Reliance Industries Ltd. AY 2017-18 & 2018-19 f) Disallowance of foreign tax credit u/s 90(1)(a)(ii) relating to income eligible for deduction

RELIANCE INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE-3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

80G of the Act in respect of donations given under Corporate Social Responsibility. e) Disallowance under section 42(1)(b) in respect of KG-DWN-98/3 (KGD6 bloc) and Coal Bed Methane Sohagpur (CBM). 28 Reliance Industries Ltd. AY 2017-18 & 2018-19 f) Disallowance of foreign tax credit u/s 90(1)(a)(ii) relating to income eligible for deduction

DCIT- 3(4) , MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

80G of the Act in respect of donations given under Corporate Social Responsibility. e) Disallowance under section 42(1)(b) in respect of KG-DWN-98/3 (KGD6 bloc) and Coal Bed Methane Sohagpur (CBM). 28 Reliance Industries Ltd. AY 2017-18 & 2018-19 f) Disallowance of foreign tax credit u/s 90(1)(a)(ii) relating to income eligible for deduction

SOU DWARKABAI SHASTRI PATWARDHAN TRUST,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI , MUMBAI

Appeal is allowed for statistical purposes

Bench: Shri Satbeer Singh Godara & Shri Omkareshwar Chidaraassessment Year: 2025-26

Section 80G(5) of the Act. This will be the harmonious interpretation. 11. If we agree with the interpretation of the ld.CIT(E), then say a trust which was formed in the year 2000, performed charitable activities since 2000, but did not applied for registration u/s.80G, the said trust will never be able to apply for registration now. This

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)

Transfer Pricing Officer under section 92CA of the Act on 16.07.202, who passed an order dated 27.01.2022 without proposing any adjustment to the arm’s length price. 3. The assessment was completed under section 143(3) read with section 144B of the Act vide order dated 27.09.2022. During following additions and disallowances: i. Disallowance of deduction under section 80G

ACIT, CIRCLE - 3 3 1, MUMBAI vs. JAMNAGAR UTILITIES AND POWER PVT LTD, MUMBAI

In the result, both the appeals of the Revenue are allowed\npartly

price to NIL arbitrarily and MTM loss arising out of\nrevaluation/fair value adjustment is not applicable as\nthere is no market?\"\n6. \"Whether on the facts and in the circumstances of the case and in\nlaw, the Ld.CIT(A) has justified in deleting the addition of fair value\nadjustment on asset being redeemable preference shares(RPS) in\nbook profit, without

ACIT, CIRCLE - 3 3 1, MUMBAI vs. JAMNAGAR UTILITIES AND POWER PVT LTD, MUMBAI

In the result, both the appeals of the Revenue are allowed\npartly

price to NIL arbitrarily and MTM loss arising out of\nrevaluation/fair value adjustment is not applicable as\nthere is no market?\"\n6. \"Whether on the facts and in the circumstances of the case and in\nlaw, the Ld.CIT(A) has justified in deleting the addition of fair value\nadjustment on asset being redeemable preference shares(RPS) in\nbook profit, without

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

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

price.\n3. The assessment was completed under section 143(3) read\nwith section 144B of the Act vide order dated 27.09.2022. During\nthe course of assessment proceedings, the Assessing Officer\nexamined various claims made by the assessee and made the\nfollowing additions and disallowances:\ni. Disallowance of deduction under section 80G\nThe Assessing Officer observed that the assessee had incurred

ABM KNOWLEDGEWARE LIMITED,MUMBAI vs. ASSESSING OFFICER CIRCLE 4(1)(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 given\nare registered under section 80G

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly\nallowed for all the three

section 80HHC /80HHE etc. there is\nspecific provision to exclude from the \"Profit of the Business\", the other\nincome such as commission, brokerage, interest, rent etc. However,\nthere is no specific exclusion while computing deduction under section\n10A/10AA/10B of the Act. Therefore, in view of the aforesaid provisions,\nit is clear that, what is exempted is not merely the profits

FIRMENICH AROMATICS PRODUCTION (INDIA) PRIVATE LIMITED,MUMBAI vs. ASSESSING OFFICER, NEW DELHI

In the result, both the appeals of the assessee are partly allowed

Transfer Pricing\nOfficer has compared the price charged to non-AEs located in India with\nthe price charged to AEs in foreign countries. Therefore, the AEs and non-\nAEs being situated in different geographical locations, there may be\nvarious factors/reasons which could have influenced the price charged\nby the assessee to the AEs and non-AEs. Hence, the price charged

B. ARUNKUMAR CAPITAL & CREDIT SERVICES PVT LTD ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX 3, 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

TATA MOTORS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.631/मुं/2013 (िन.व. 2008-09) Tata Motors Limited Bombay House, 24,Homi Mody Street, Hutama Chowk, Mumbai – 400001. Pan: Aaact-2727-Q ...... अपीलाथ"/Appellant बनाम Vs. The Addl. Commissioner Of Income Tax Circle -2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri J.D.Mistry, Sr.Advocate With Shri Nikhil Tiwari,Advocate "ितवादी "ारा/Respondent By : Ms. Vatsala Jha, Cit-Dr & Shri Manoj Kumar Singh, Sr.Ar सुनवाई की ितिथ/ Date Of Hearing : 10/11/2023 घोषणा की ितिथ/ Date Of Pronouncement : 05/02/2024 आदेश/Order Per Vikas Awasthy, Jm:

Pricing. The name of Shri Vatsalya Saxena figures in the list of ‘Officers who are being posted to other station/region’ at Sl.No.11. Thus, he was transferred in the charge of Director General of Income Tax (International Taxation) by the Board and the DGIT(IT) posted Shri Vatsalya Saxena vide office order dated 05/04/2011 as TPOII(2). Thus posting orders