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Documents citing Dcit Cc 6(4), Mumbai vs Dhani Services Ltd (Previously Known As ... on 8 September, 2023

Assistant Director Of Income-Tax, Cpc, ... vs M/S Goldy Precision Stampings P Ltd, ... on 7 March, 2025

5. LD AR appearing virtually from the side of the assessee relied on decision passed by Mumbai Bench of the Tribunal in the case of DCIT vs. ANI Integrated Services Ltd., 162 taxmann.com 889 (Mumbai - Trib.) wherein under identical facts it has been held that there was no mistake in the order passed by the Tribunal since the Judgement of Hon'ble Supreme Court was delivered subsequent to the impugned order of the Tribunal. Therefore, it was submitted that the claim of the department that there is mistake in the order of the Tribunal is not correct since on the date of passing of the order by the Tribunal no such order of Hon'ble Apex Court was there but it was delivered subsequently. It was therefore submitted that there was no mistake in the impugned order of the Tribunal & accordingly it was prayed to dismiss the MA filed by the Revenue.
Income Tax Appellate Tribunal - Pune Cites 23 - Cited by 0 - Full Document

Circle-11(2)(1), Mumbai-400020 vs Seven S Banking Management Consultancy ... on 25 October, 2024

3. The ld. Counsel filed the decision of the Co-ordinate Bench in the case of DCIT vs. ANI Integrated Services Ltd. in MA No.167/Mum/2023. The Tribunal after discussing various judgments of the Hon'ble Supreme Court have held that order passed earlier by the Tribunal cannot be recalled based on subsequent judgment of the Hon'ble Supreme Court once the order has attained finality earlier. For the sake of ready reference, the order of the Tribunal is reproduced as under:-
Income Tax Appellate Tribunal - Mumbai Cites 34 - Cited by 0 - Full Document

Vaibhav Maruti Dombale vs The Assistant Registrar Income Tax ... on 12 September, 2025

The Tribunal by its decision dated 29 May 2024 [ANI Integrated Services Limited (Supra)] did not accept the contentions as urged on behalf of the Revenue and rejected the Miscellaneous Applications filed by the Revenue, also considering the decision in Beghar Foundation (Supra) and the scope of its limited jurisdiction under Section 254(2) of the IT Act.
Bombay High Court Cites 31 - Cited by 0 - B P Colabawalla - Full Document

Dcit Cir 3(1), Mumbai vs Icici Bank Ltd, Mumbai on 30 April, 2025

The Ld.AR submitted that this company is functionally not similar with the assessee as it is engaged in development of software products. She further emphasized that, there is not segmental details available in its audited balance sheet. The Ld.AR placed reliance on the decision of Hon'ble Bombay High Court in the case of PCIT vs BNY Mellon International Operations (India) Pvt. Ltd. reported in (2018) 93 taxmannc.com 363, wherein this company was upheld for exclusion by placing reliance on the decision of coordinate bench of Hon'ble High Court in case of DCIT vs Bills Processing Services India Pvt. Ltd. in ITA No. 2152/M/2014 vide dated 10.10.2014. Hon'ble High Court noted that this company is a high end KPO and this cannot be compared with captive service provider.
Income Tax Appellate Tribunal - Mumbai Cites 52 - Cited by 0 - Full Document

Icici Bank Ltd,Mumbai vs Addl Cit Rg 3 (1), Mumbai on 30 April, 2025

The Ld.AR submitted that this company is functionally not similar with the assessee as it is engaged in development of software products. She further emphasized that, there is not segmental details available in its audited balance sheet. The Ld.AR placed reliance on the decision of Hon'ble Bombay High Court in the case of PCIT vs BNY Mellon International Operations (India) Pvt. Ltd. reported in (2018) 93 taxmannc.com 363, wherein this company was upheld for exclusion by placing reliance on the decision of coordinate bench of Hon'ble High Court in case of DCIT vs Bills Processing Services India Pvt. Ltd. in ITA No. 2152/M/2014 vide dated 10.10.2014. Hon'ble High Court noted that this company is a high end KPO and this cannot be compared with captive service provider.
Income Tax Appellate Tribunal - Mumbai Cites 52 - Cited by 0 - Full Document

Vaibhav Maruti Dombale vs Deputy Commissioner Of Income Tax ... on 12 September, 2025

The Tribunal by its decision dated 29 May 2024 [ANI Integrated Services Limited (Supra)] did not accept the contentions as urged on behalf of the Revenue and rejected the Miscellaneous Applications filed by the Revenue, also considering the decision in Beghar Foundation (Supra) and the scope of its limited jurisdiction under Section 254(2) of the IT Act.
Bombay High Court Cites 31 - Cited by 0 - B P Colabawalla - Full Document
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