SC) (ii) Sassoon J David & Co. P. Ltd. v. CIT (1975) 98 ITR 50 (Bom.) (iii) CIT v. Parmanand Makhan Lal

61 ITR 23High Court1966#18202 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2024.

Issues it is cited on

credit for tdsdirections of the drparm's length priceassociated enterprisestransfer pricing adjustmentsection 92casection 92csection 144c(13)associated enterprisedispute resolution panelsection 92international transaction

Judgments citing SC) (ii) Sassoon J David & Co. P. Ltd. v. CIT (1975) 98 ITR 50 (Bom.) (iii) CIT v. Parmanand Makhan Lal

METAL CLOSURES PVT LTD,BANGALORE vs. ACIT, CIRCLE 4(1)(2), BANGALORE, BANGALORE

In the result, the appeal of the Revenue is treated as allowed for statistical purpose

ITA 941/BANG/2024[2014-15]Status: DisposedITAT Bangalore29 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Year: 2014-15

For Appellant: Sri R.E. Balasubramanyam, A.RFor Respondent: Sri Subramanian S., D.R
Section 148Section 28Section 36(2)(i)

…f fact recorded by the Income-tax Officer which are affirmed by the first appellate authority. 13. Learned counsel appearing for the assessee, relying on Associated Banking Corporation of India Ltd. v. CIT [1965] 56 ITR 1 (SC), Kothari and Sons v. CIT [1966] 61 ITR 23 (Mad) and Hopkin and Williams (Travancore) Ltd. v. CIT [1967] 64 ITR 76 (Ker), contended that the deduction claimed by the assessee was an admissible deduction as it was not possible to recover the loss from Sri Somani. 14. There are no two opinions about the proposition of law laid down in the aforesaid cases relied upon by learned counsel, but,…

M/S. UNITED SPIRITS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BENGALURU

In the result, the appeal filed by the assessee is partly allowed

ITA 2701/BANG/2017[2013-14]Status: DisposedITAT Bangalore04 Apr 2022AY 2013-14

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2701/Bang/2017 : Asst.Year 2013-2014 M/S.United Spirits Limited The Deputy Commissioner Of Ub Towers, Income-Tax, Circle 7(1)(1) V. No.24 Vittal Mallya Road Bangalore. Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Senior Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 05.04.2022 Date Of Hearing : 24.03.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 12.10.2017 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In The Manufacture & Sale Of Alcoholic Beverage. The Assessee Filed Its Return Of Income For The Assessment Year 2013-2014 On 28.11.2013 Which Was Selected For Scrutiny Assessment. During The Course Of Assessment, The Assessee’S Case Was Also Referred To The Transfer Pricing Officer (Tpo). The Tpo Vide Order Dated 26.10.2016, Recommended Transfer Pricing Adjustments. The A.O., Thereafter, Passed A Draft Assessment Order Dated 30.12.2016. 2 It(Tp)A No.2701/Bang/2017 M/S.United Spirits Limited.

For Appellant: Sri.Percy Pardiwala, Senior AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR
Section 143(3)Section 14ASection 234BSection 234CSection 36(1)(iii)

…as highlighted in the following judicial pronouncements:- (i) Baridas Daga v. CIT (34 ITR 10 (SC) (ii) Sassoon J David & Co. P. Ltd. v. CIT (1975) 98 ITR 50 (Bom.) (iii) CIT v. Parmanand Makhan Lal (1983) 15 Taxman 12 (Patna) (iv) Kothari & Sons v. CIT (1966) 61 ITR 23 (Madras) (v) Ramchandar Shivnarayan v. CIT (1978) 111 ITR 263 (SC) (vi) Khaitan & Co. v. CIT (1979) 1 Taxman 280 (Calcutta) (vii) Churakulam Tea Estates (P) Ltd. v. CIT (1995) 81 Taxman 214 (Kerala) (viii) CIT v. India United Mills Ltd. (1978) 112 ITR 129 (Bombay).  The CBDT vide its undernoted circular (Circular No.35-D (Xivii- 20) (F.No.10/48/65…

SAN DISK INDIA DEVICE DESIGN CENTRE PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 543/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 154Section 92C

…placed by the Assessee on the following decisions in support of its claim that the loss incurred due to misappropriation of its funds by its ex-employee ought to be allowed as a deduction: Badridas Daga v. C/T (1958) 34 ITR 10  Kothari & Sons v. CIT (1966) 61 ITR 23  Gothamchand Galada v. C/T (1961) 42 ITR 418.  Without prejudice to the above, if the disallowance of the aforesaid loss incurred due to misappropriation of its funds by its ex-employee were to be upheld by this Hon'ble Tribunal, then it is submitted that since the loss related to its Unit which is eligible for deduction under Section 10A of the…

DCIT, BANGALORE vs. M/S SANDISK INDIA DEVICE DESIGN CENTRE PRIVATE LIMITED, BANGALORE

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 341/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 154Section 92C

…placed by the Assessee on the following decisions in support of its claim that the loss incurred due to misappropriation of its funds by its ex-employee ought to be allowed as a deduction: Badridas Daga v. C/T (1958) 34 ITR 10  Kothari & Sons v. CIT (1966) 61 ITR 23  Gothamchand Galada v. C/T (1961) 42 ITR 418.  Without prejudice to the above, if the disallowance of the aforesaid loss incurred due to misappropriation of its funds by its ex-employee were to be upheld by this Hon'ble Tribunal, then it is submitted that since the loss related to its Unit which is eligible for deduction under Section 10A of the…

DCIT 8(2), MUMBAI vs. HEXAWARE TECHNOLOGIES LTD, NAVI MUMBAI

In the result appeal filed by revenue is dismissed whereas Cross objection filed by assessee is allowed in part for statistical purposes

ITA 4688/MUM/2013[2008-09]Status: DisposedITAT Mumbai17 Oct 2016AY 2008-09
For Appellant: Shri Vijay MehtaFor Respondent: Shri Rahul Raman

…oss so incurred as business loss. i) Badridas Oaga vs CIT [1958] (34 ITR 10) (SC) ii) Pandyan Builders Vs. Inspecting Assistant Commissioner (45TTJ 524)(Mad) iii) Eveready Industries India Ltd. Vs. DCIT (78 ITD 175)(Cal)(TM) iv) Kothari & Sons Vs. CIT (1996) (61 ITR 23)(Mad.) However, the AO did not accept the assessee’s contention and held that the assessee had itself stated that these transactions were unauthorized and outside the companies normal hedging programme. AO stated that as per the copy of FIR dated January 30, 2008 it has been mentioned that the said employee had submitted forged resolutions to the t…

SC) (ii) Sassoon J David & Co. P. Ltd. v. CIT (1975) 98 ITR 50 (Bom.) (iii) CIT v. Parmanand Makhan Lal (61 ITR 23) — Cited in 5 Judgments | BharatTax