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Documents citing Ima Pg India Ltd ( Formerly M.S, ... vs Addl Cit Rg 5(2), Mumbai on 26 April, 2017

Dcit Rg. - 3(1), Mumbai vs M/S. Bajaj Auto Ltd., Mumbai on 23 February, 2024

66. In the given case, assessee has acquired a new technique in order to assist in manufacture / assemble of multi model in the same manufacturing / assembly line. This is a new information or technique acquired by the assessee from M/s.Kawasaki Heavy Industries Limited, Japan. This clearly shows that assessee has acquired a new method of manufacturing of multi models of scooters in one dedicated manufacturing or assembly line instead of several dedicated lines for each model. This shows that it is not an Page No.| 55 ITA NO.4236 & 4372/MUM/2005 (A.Y: 2001-02) M/s. Bajaj Auto Limited improvement of existing manufacturing process. Certain improvements can also be made in the existing line or may be certain process were readjusted to improve the efficiency of the manufacturing line. However, in this case it is completely new process technique acquired by the assessee and it is relevant to note that assessee also paid a huge sum to acquire the above technique and in books of accounts also assessee has recognized that assessee has a new technique and claimed as deferred revenue expenditure. Further, as held in the case of M/s.Bharat Gears Limited v. CIT (supra), the expenses incurred by the assessee is nothing but capital expenditure and assessee has an option to claim either differed revenue expenditure or depreciation as allowed by the Assessing Officer. After considering the overall facts on record, we do not find any reason to disturb the findings of the Ld. CIT(A). Accordingly, Ground No. 6 raised by the assessee is dismissed.
Income Tax Appellate Tribunal - Mumbai Cites 46 - Cited by 0 - Full Document

M/S. Bajaj Auto Ltd., Mumbai vs Dcit Rg. - 3(1), Mumbai on 23 February, 2024

66. In the given case, assessee has acquired a new technique in order to assist in manufacture / assemble of multi model in the same manufacturing / assembly line. This is a new information or technique acquired by the assessee from M/s.Kawasaki Heavy Industries Limited, Japan. This clearly shows that assessee has acquired a new method of manufacturing of multi models of scooters in one dedicated manufacturing or assembly line instead of several dedicated lines for each model. This shows that it is not an Page No.| 55 ITA NO.4236 & 4372/MUM/2005 (A.Y: 2001-02) M/s. Bajaj Auto Limited improvement of existing manufacturing process. Certain improvements can also be made in the existing line or may be certain process were readjusted to improve the efficiency of the manufacturing line. However, in this case it is completely new process technique acquired by the assessee and it is relevant to note that assessee also paid a huge sum to acquire the above technique and in books of accounts also assessee has recognized that assessee has a new technique and claimed as deferred revenue expenditure. Further, as held in the case of M/s.Bharat Gears Limited v. CIT (supra), the expenses incurred by the assessee is nothing but capital expenditure and assessee has an option to claim either differed revenue expenditure or depreciation as allowed by the Assessing Officer. After considering the overall facts on record, we do not find any reason to disturb the findings of the Ld. CIT(A). Accordingly, Ground No. 6 raised by the assessee is dismissed.
Income Tax Appellate Tribunal - Mumbai Cites 46 - Cited by 0 - Full Document

M/S Dell International Services India ... vs Deputy Commissioner Of Income Tax Ltu , ... on 24 June, 2020

50. We have considered the submissions and are of the view that the plea of the assessee that the aforesaid company should not be treated as comparables was considered by the Tribunal in Capegemini India Ltd. (supra) where the assessee was software developer. The Tribunal, in the said decision referred to by the ld. counsel for the assessee, has accepted that this company was not comparable in the case of assessee engaged in software development services business. Accepting the argument of the ld. counsel for the assessee, we hold that the aforesaid company should be excluded as comparables."
Income Tax Appellate Tribunal - Bangalore Cites 29 - Cited by 4 - Full Document

Nuvama Wealth Management ... vs Deputy Commissioner Of Income ... on 27 February, 2026

Fur Further, ther, the Spl Bench decision has been followed in a numberr of other judgements such as (i (i)) Sajjan India Ltd. vs. Addi.CIT (2018) 89 Taxmann.com 21 (Mum Tribunal), (ii) DCIT vs. Bombay Oxygen Corporation Ltd. (2017) 86 Taxmann 88 (Mum Tribunal), (iii) Tata Power Co Ltd. vs PCIT, Mumbai (2020), 121 Taxmann.com 127 (Mum Tribunal) 10.3 With thee Spl. Bench decision in the case of Vireet Investment Ltd. (supra), law with respect to computation of disallowance under Rule 8D(2)(ii 8D(2)(iii) of the Act is settled and the qu quantum antum of disallowance has to be limited to the extent of investments yielding exempt income. Further, the Spl Bench decision has been followed in several cases by the jurisdictional Mumbai Tribunal in several cases quoted in the previous paragraph. Hence, following the judgement of the Spl Bench Delhi Tribunal and jurisdictional Tribunal, it is held that disallowance u/u/s s 14A of the Act has to be limited to the value of investments inve yielding exempt income.
Income Tax Appellate Tribunal - Mumbai Cites 24 - Cited by 0 - Full Document

Nuvama Wealth Management ... vs Deputy Commissioner Of Income ... on 27 February, 2026

Fur Further, ther, the Spl Bench decision has been followed in a numberr of other judgements such as (i (i)) Sajjan India Ltd. vs. Addi.CIT (2018) 89 Taxmann.com 21 (Mum Tribunal), (ii) DCIT vs. Bombay Oxygen Corporation Ltd. (2017) 86 Taxmann 88 (Mum Tribunal), (iii) Tata Power Co Ltd. vs PCIT, Mumbai (2020), 121 Taxmann.com 127 (Mum Tribunal) 10.3 With thee Spl. Bench decision in the case of Vireet Investment Ltd. (supra), law with respect to computation of disallowance under Rule 8D(2)(ii 8D(2)(iii) of the Act is settled and the qu quantum antum of disallowance has to be limited to the extent of investments yielding exempt income. Further, the Spl Bench decision has been followed in several cases by the jurisdictional Mumbai Tribunal in several cases quoted in the previous paragraph. Hence, following the judgement of the Spl Bench Delhi Tribunal and jurisdictional Tribunal, it is held that disallowance u/u/s s 14A of the Act has to be limited to the value of investments inve yielding exempt income.
Income Tax Appellate Tribunal - Mumbai Cites 24 - Cited by 0 - Full Document

Dcit, Cir-12(1), Kolkata, Kolkata vs M/S Bengal Ambuja Housing Development ... on 20 November, 2019

7.3. I have considered these findings in the light of detailed submissions made by the AR. From the audited accounts it is apparent that the average cost of investments during the relevant year was ₹914,85 lacs whereas the appellant's net owned funds in the form of share capital & reserves were ₹10,318,.27 lacs. As such it is apparent that the assessee's net owned funds both at the beginning and at the closing of the relevant year were substantially higher than the cost of investments. Ono these facts therefore I find merit in the submissions of the AR that when the assessee has both own funds and borrowed funds then the presumption would be that the investments were acquired out of own funds. This proposition finds support in the decision of the ITAT, Kolkata in the case of H S I L Limited Vs Addl. CIT (ITA 83/KoIl2012) dated 05.08.2014.
Income Tax Appellate Tribunal - Kolkata Cites 34 - Cited by 0 - Full Document

M/S.Venkatachala Iyer & Co., ... vs Dcit,Cir-1,, Trivandrum on 1 March, 2019

legal heirs of the deceased partners would be paid part of the income of the assessee-firm for the services rendered by them. Hence, it was concluded by the Mumbai Bench of the Tribunal that it was a case of diversion of income by way of overriding title. Similar view was taken by the Mumbai Tribunal in the cases of A.F.Ferguson & Co. v. ACIT [ITA No.663/Mum/2010 - order dated 10.08.2011] and R.S.M. & Co. v. Addl.CIT [(2010) 10 ITR (Trib.) 0614].
Income Tax Appellate Tribunal - Cochin Cites 6 - Cited by 0 - Full Document
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