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Documents citing Sodexo India Services Private Limited, ... vs Pcit, Mumbai 5, Circle 13(2)(2), Mumbai on 23 February, 2023

M/S Cleartrip Pvt Ltd. (Fprmerly Known ... vs Dcit 6(2)(1), Mumbai on 13 April, 2023

The Tribunal firstly held in the case of CAE Flight Training (I) Pvt. Ltd. (supra) that Thin Capitalisation principle was not applicable till such time those principles were recognised by way of statutory provisions. Thereafter, the Tribunal examined whether the question, interest paid on CCDs should be allowed as a deduction. The Tribunal held as follows:-
Income Tax Appellate Tribunal - Mumbai Cites 44 - Cited by 0 - Full Document

Asst Cit 6 (2)(1), Mumbai vs M/S Chiripal Poly Films Ltd., Mumbai on 11 October, 2023

4.12 It is seen that the said monies received by it from M/s. Platinummic FZE, UAE were computed in accordance with DCF valuation arrived at by an independent Chartered Accountant in compliance with the Foreign Exchange Management Act and the rules and regulations framed there under. This being an approved method for the purpose of FEMA, was an acceptable method for the valuation of shares. Hon'ble Mumbai Tribunal (jurisdictional) in case of Finproject India Private Ltd. v. PCIT (supra), held that the DCF technique of valuation is appropriate method for determining the value of shares, given that the same was in accordance with the 27 ITA No.258Mum/2020 (Assessment Year 2014-15) CO No.152/Mum/2022 (Assessment Year: 2014-15) FEMA provisions. Thus, the appellant cannot be considered to be in default for compliance with something that was merited by law.
Income Tax Appellate Tribunal - Mumbai Cites 13 - Cited by 0 - Full Document

Seamec Limited ,Mumbai vs Dcit, Circe 5(3)(1), Mumbai on 5 May, 2026

"9. We have considered the submissions of both sides and perused the material available on record. In the present case, the assessee incurred expenditure of ₹ 1,55,000/- towards CSR and disallowed the same while computing its income under the head "income from business" in terms of provisions of Explanation - 2 to section 37(1) of the Act. However, while computing the deduction under section 80G of the Act, the assessee claimed a deduction of ₹ 77,500/- (50% of ₹ 1,55,000/-) being the CSR 7 ITA No. 1586/Mum/2026 expenditure covered under the provisions of section 80G of the Act. Thus, undisputedly, the assessee has not claimed the CSR expenditure under section 37(1) of the Act, and its claim is only restricted to section 80G of the Act. It is evident from the record that the learned PCIT, on the basis that the said expenditure was incurred voluntarily and therefore cannot be called a donation, initiated the revisionary proceedings under section 263 of the Act. We find that while disagreeing with the submissions of the assessee and setting aside the assessment order, the learned PCIT, vide impugned order, placed reliance upon the decision of the Delhi Bench of the Tribunal in Agilent technologies (International) Pvt. Ltd. and held that for a payment to be considered for deduction under section 80G of the Act, the same should be voluntary in nature, unlike in the present case where the payment was made in compliance of the provisions of the Companies Act, 2013.
Income Tax Appellate Tribunal - Mumbai Cites 27 - Cited by 0 - Full Document
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