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

iv) Allegis Services (India) Pvt. Ltd. (ITA No. 1693 /Bang/ 2019) Ld. Counsel further submitted that if the intention was to deny deduction of CSR expenses under section 80G, appropriate amendments on lines of section 37(1) should also have been made under section 80G of the Act. In the absence of any such amendment, CSR expenses should

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

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 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

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

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

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

iv) of the first proviso, rejecting such application, after affording it a reasonable opportunity of being heard;] (iii) ……. 5. The Commissioner of Income Tax (Exemption),Pune in the case of the Assessee held that the Activities of the Assessee had commenced in 18/01/2014, hence the assessee was liable to make application for Approval u/s 80G of the Act to file

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

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

iv) FNF India (P) Ltd. v. ACIT [133 taxmann.com 251 (Bang.)]\n(υ) JMS Mining (P) Ltd. v. Pr.CIT [130 taxтапп.com 118 (Kol.)]”\n3.2 The assessee also placed reliance on the decision of\ncoordinate bench of this Tribunal in case of Naik Sea Foods Pvt.\nLtd. Vs. PCIT in ITA no. 490/Mum/2021 dated 26/11/2021 and\ndecision of Inter Gold

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:

iv) disposal of appeals, (v) representing Departmental cases in the Appellate Tribunal, (vi) handling search and seizure matters, etc. The above shows that some of the Deputy Commissioners and Deputy Directors have been assigned duties of higher responsibility. Therefore, there is need to recognize 13 the aforesaid distinction in responsibility by making an appropriate change in the designation of such

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

IV\nand the only Explanation 2 to section 37 prohibits the allowance of CSR\nexpenditure as business expenditure. This scope of the restriction imposed\nin section 37 does not extend to Chapter VI-A of the Act which is\nindependent of section 37 of the Act. It is further claimed by the assessee\nthat CSR expenditure is eligible for deduction

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

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

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

IV: ADDITION TO ARM'S LENGTH PRICE IN RELATION TO INTERNATIONAL LENGTH PRICE IN RELATION TO INTERNATIONAL LENGTH PRICE IN RELATION TO INTERNATIONAL TRANSACTIONS AMOUNTING TO RS. 23,62,21,702/ TRANSACTIONS AMOUNTING TO RS. 23,62,21,702/ TRANSACTIONS AMOUNTING TO RS. 23,62,21,702/-: 1. On the facts and in ci 1. On the facts

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

IV), Mumbai and since then has been enjoying exemption u/s 11 and the benefit of the 80G of the Act. However, pursuant to the Amendment vide Finance Act, 2022, the Assessee had applied and got provisional approval u/s 80G(5) of the Act on dated 04.10.2022 which is valid up to A.Y. 2025-26. 9. As the Assessee established