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

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

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

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

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

transfer pricing adjustment under section 92CA amounting to Rs.11,26,24,233/-. In addition, disallowances were made as follows: Disallowance under section 80G: Rs. 2,05,58,406/- Disallowance of depreciation on intangible assets: Rs.12,42,89,747/- Being aggrieved by the final assessment order, the assessee has preferred an appeal before this Tribunal. 3. The Ld.AR argued and filed

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

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

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 the course of assessment proceedings, the Assessing Officer examined various claims made

PASHUPATI CAPITAL SERVICES PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX OFFICER, MUMBAI - 4, MUMBAI

In the result, appeal filed by the assessee is allowed in above\nterms

Pricing Officer, as\nthe case may be,] shall be deemed to be erroneous in so far as it is\nprejudicial to the interests of the revenue, if, in the opinion of the Principal\n[Chief Commissioner or Chief Commissioner or Principal] Commissioner or\nCommissioner,—\n(a) the order is passed without making inquiries or verification which should\nhave been made

NATIONAL ASSOCIATION FOR THE BLIND,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI, MUMBAI

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

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2026-27

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 apply for registration u/s.80G, the said trust will never be able to apply for registration now. This

GOLDMAN SACHS (INDIA) SECURITEIS PRIVATE LIMITED,MUMBAI vs. ADD/JT/DY/ASST/CIT/ITO/NFAC, DELHI

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

5,96,20,000 under Chapter VI-A of the Act on account of the donations made under section 80G of the Act and disregarding the donation receipts submitted by the Appellant evidencing the eligibility for deduction under section 80G of the Act. Further, the learned AO failed to appreciate the fact that voluntary contribution is not a mandatory requirement