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“liable to tax”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(29A)2,645 judgments

The decision most relied on for liable to tax is DIT v. NGC Network Asia LLC (313 ITR 187), cited in 144 judgments on BharatTax.

Leading authorities on liable to tax

DIT v. NGC Network Asia LLC
313 ITR 187 · 2009 · High Court
144
citing judgments

Where a duty is cast on the payer to deduct and pay tax at source under Section 195, the payee-assessee cannot be levied interest under Section 234B for failure to pay advance tax if the payer defaults on its TDS obligation. This principle may also extend to interest under Section 234C.

CIT v. Nestle India Ltd.
14 Taxmann 99 · 1983 · High Court
125
citing judgments

Club entrance fees, if incurred wholly and exclusively for business purposes, are allowable as revenue expenditure under Section 37(1). Furthermore, an order holding a deductor liable for TDS defaults under Section 201 must be preceded by an inquiry into the deductee's actual tax payment.

CIT v. Karnataka Power Corporation
247 ITR 268 · 2001 · Supreme Court
124
citing judgments

Income earned during the project construction stage, which has a direct nexus or is inextricably linked to the project's setting up, constitutes a capital receipt not liable to tax and reduces the project cost.

CIT v. Rasoi Ltd.
335 ITR 438 · 2011 · High Court
107
citing judgments

Sales tax subsidies and Industrial Promotion Assistance received under the West Bengal Incentive Scheme are capital receipts and therefore not liable to tax. The ruling clarifies the inapplicability of the Sahney Steel judgment to such subsidies.

(supra), Rama Bai v. CIT
181 ITR 408 · 1990 · Supreme Court
84
citing judgments

Interest received on delayed payment or enhanced compensation awarded under compulsory acquisition is a revenue receipt and is liable to income tax.

Bank Vs. ACIT (2005) 142 Taxman 98 (Kerala) (v) CIT(TDS) v. Director, DPS
115 ITD 411 · ITAT
81
citing judgments

The case is an authority regarding the conditions under which an assessee can be held liable, and orders confirmed, under Section 201(1) of the Income-tax Act for failure to deduct tax at source (TDS). It clarifies the circumstances for deeming an assessee to be in default for non-deduction or non-payment of TDS.

CIT v. Chaphalkar Brothers
351 ITR 309 · 2013 · High Court
77
citing judgments

A subsidy or incentive provided by the government for meeting capital expenditure, to achieve a national objective or public interest, is a capital receipt and thus not liable to income tax. The nature of the subsidy is determined by applying the 'purpose test'.

CIT v. Wipro Ltd. (
70 Taxmann.com 129 · Reported
77
citing judgments

Payments are liable for deduction of tax at source when they are in the nature of royalty. The withholding tax liability can be worked out by applying a proportion to the total remittance.

Judgments citing liable to tax

Addl CIT Ltu, Mumbai vs. Bajaj Holding & Investment Ltd ( Foremerly Known As Bajaj Auto Ltd), Mumbai

In the result, appeal filed by the revenue is dismissed and appeal filed by the assessee stands partly allowed as indicated hereinabove

ITA 5510/MUM/2012[2007-08]Status: DisposedITAT Mumbai26 Aug 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 14ASection 80

purposes. During the assessment proceedings it was claimed by the Assessee that the aforesaid receipts were in the nature of capital receipts not liable to tax. However, the Assessing Officer rejected the aforesaid contention of the Assessee and held that the aforesaid receipts were liable to tax in the hands

Metso Oyj, Finland vs. Assistant Commissioner of Income Tax, (International Taxation), Circle-1(2), Kolkata

In the result, the appeal filed by the assessee is dismissed and the order of the Ld

ITA 616/KOL/2025[2022-23]Status: DisposedITAT Kolkata25 Aug 2025AY 2022-23

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270ASection 56Section 9

resident to charge in India is laid out in section 5(2) of the Act. The following incomes derived by them are liable to tax in India:- • Income received/deemed to be received in India in the previous year by or on behalf of such person; or • Income accruing or arising

M/S. Biobuild Developers, Mumbai vs. Income Tax Officer Ward 24(1)(3), Mumbai

ITA 4011/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Aug 2025AY 2013-14

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Sameer DalalFor Respondent: Shri Pravin Salunkhe
Section 143(3)Section 147Section 148Section 250

Assessing Officer made an addition of INR.33,82,946/- in the hands of the Assessee holding the same to be interest income liable to tax in the hands of the Assessee. 5. Being aggrieved, the Assessee challenged the above Assessment Order in appeal before Learned CIT(A) raising the following

Dy CIT (Int Tax) 4(1)(2) Mumbai, Mumbai vs. Trans Union Llc, Usa

In the result, the appeals by the Revenue are dismissed

ITA 1475/MUM/2025[2022-23]Status: DisposedITAT Mumbai25 Aug 2025AY 2022-23

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am

Section 9(1)(vi)

DCIT [2023] 154 taxmann.com 372 (Mumbai Trib.) has held that the same shall not amount to copyright infringement and therefore not be liable to tax as royalty. Basis the above discussions, reading of the agreements and on perusal of the relevant paragraphs in the Apex Court's decision

Dy CIT (Int Tax) 4(1)(2) Mumbai, Mumbai vs. Trans Union Llc, Usa

In the result, the appeals by the Revenue are dismissed

ITA 1474/MUM/2025[2021-22]Status: DisposedITAT Mumbai25 Aug 2025AY 2021-22

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am

For Appellant: Shri Rajan Vora &For Respondent: Shri Krishna Kumar
Section 9(1)(vi)

DCIT [2023] 154 taxmann.com 372 (Mumbai Trib.) has held that the same shall not amount to copyright infringement and therefore not be liable to tax as royalty. Basis the above discussions, reading of the agreements and on perusal of the relevant paragraphs in the Apex Court's decision

Dy CIT (Int. Tax) 4(1)(2) Mumbai, Mumbai vs. Trans Union Llc, Usa

In the result, the appeals by the Revenue are dismissed

ITA 1473/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Aug 2025AY 2020-21

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am

For Appellant: Shri Rajan Vora &For Respondent: Shri Krishna Kumar
Section 9(1)(vi)

DCIT [2023] 154 taxmann.com 372 (Mumbai Trib.) has held that the same shall not amount to copyright infringement and therefore not be liable to tax as royalty. Basis the above discussions, reading of the agreements and on perusal of the relevant paragraphs in the Apex Court's decision

Harpreet Kaur, Bhopal vs. Income-Tax Officer, 5(2), Bhopal

ITA 730/IND/2024[2009-10]Status: DisposedITAT Indore22 Aug 2025AY 2009-10

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 131Section 133(6)Section 142(1)Section 143(2)Section 147Section 148Section 54Section 69A

आयकरअपीलीयअधिकरण,इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND

Sri Someshwara Laxmi Narasimha Swamy Temple Palakurthy, Warangal vs. CIT (Exemptions), Hyderabad

In the result, all the four appeals of the assessee are allowed for statistical purpose

ITA 141/HYD/2025[2024-25]Status: DisposedITAT Hyderabad22 Aug 2025AY 2024-25

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1408/Hyd/2024 To 1410/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2015-16, 2016-17 & 2018-19) Sri Someshwara Laxmi Vs. Income Tax Officer, Narasimha Swamy Temple Exemption Palakurthy Ward-1(4) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.141/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2024-25) Sri Someshwara Laxmi Vs. Commissioner Of Narasimha Swamy Temple Income Tax Palakurthy (Exemptions) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 19/08/2025 घोर्णध की तधरीख/ 22/08/2025 Date Of Pronouncement: आदेश / Order Per Bench : These Four Appeals Filed By The Assessee Are Directed Against Three Separate Orders Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre, Delhi, All Dated 08.10.2024 For The A.Y.2015-16, 2016-17 & 2018-19 Respectively & Order Dated 26.02.2024 Of Commissioner Of Income Tax (Exemptions) [“Ld.Cit(E)”], Whereby The Application Of The Assessee For Registration U/S 12Ab Of The Income Tax Act, 1961 (“The Act”) Was Rejected.

For Appellant: Shri K.A.Sai Prasad, ARFor Respondent: Dr.Sachin Kumar, DR
Section 12A

administration of the assessee temple was taken over by the Government under the Endowment Act, the income of the assessee is not liable to tax, in view of the provisions of section 10(23BBA) of the Act, and therefore, the assessee did not file the return of income for these

Adp Private Limited, Hyderabad vs. DCIT., Circle 1(1), Hyderabad

In the result, appeal of the Assessee is partly allowed

ITA 975/HYD/2024[2020-21]Status: DisposedITAT Hyderabad22 Aug 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, Sriram SeshadriFor Respondent: MS. U Mini Chandran, CIT-DR
Section 143(3)Section 144C(1)Section 144C(5)Section 153Section 195Section 234ASection 40Section 92C

Services” [in short “FTS”] as defined u/sec.9(1)(vii) of the Income Tax Act, 1961 and consequently, income of ADP, Australia, is not liable to tax in India. Further, assuming for a moment, payment made by the appellant-company to ADP, Australia falls under the definition of “FTS” as defined

Sri Someshwara Laxmi Narasimha Swamy Temple Palakurthy, Warangal vs. ITO., Exemption Ward-1(4), Hyderabad

In the result, all the four appeals of the assessee are allowed for statistical purpose

ITA 1410/HYD/2024[2018-19]Status: DisposedITAT Hyderabad22 Aug 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1408/Hyd/2024 To 1410/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2015-16, 2016-17 & 2018-19) Sri Someshwara Laxmi Vs. Income Tax Officer, Narasimha Swamy Temple Exemption Palakurthy Ward-1(4) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.141/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2024-25) Sri Someshwara Laxmi Vs. Commissioner Of Narasimha Swamy Temple Income Tax Palakurthy (Exemptions) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 19/08/2025 घोर्णध की तधरीख/ 22/08/2025 Date Of Pronouncement: आदेश / Order Per Bench : These Four Appeals Filed By The Assessee Are Directed Against Three Separate Orders Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre, Delhi, All Dated 08.10.2024 For The A.Y.2015-16, 2016-17 & 2018-19 Respectively & Order Dated 26.02.2024 Of Commissioner Of Income Tax (Exemptions) [“Ld.Cit(E)”], Whereby The Application Of The Assessee For Registration U/S 12Ab Of The Income Tax Act, 1961 (“The Act”) Was Rejected.

For Appellant: Shri K.A.Sai Prasad, ARFor Respondent: Dr.Sachin Kumar, DR
Section 12A

administration of the assessee temple was taken over by the Government under the Endowment Act, the income of the assessee is not liable to tax, in view of the provisions of section 10(23BBA) of the Act, and therefore, the assessee did not file the return of income for these

Sri Someshwara Laxmi Narasimha Swamy Temple Palakurthy, Warangal vs. ITO., Exemption, Ward-1(4), Hyderabad

In the result, all the four appeals of the assessee are allowed for statistical purpose

ITA 1409/HYD/2024[2016-17]Status: DisposedITAT Hyderabad22 Aug 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1408/Hyd/2024 To 1410/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2015-16, 2016-17 & 2018-19) Sri Someshwara Laxmi Vs. Income Tax Officer, Narasimha Swamy Temple Exemption Palakurthy Ward-1(4) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.141/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2024-25) Sri Someshwara Laxmi Vs. Commissioner Of Narasimha Swamy Temple Income Tax Palakurthy (Exemptions) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 19/08/2025 घोर्णध की तधरीख/ 22/08/2025 Date Of Pronouncement: आदेश / Order Per Bench : These Four Appeals Filed By The Assessee Are Directed Against Three Separate Orders Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre, Delhi, All Dated 08.10.2024 For The A.Y.2015-16, 2016-17 & 2018-19 Respectively & Order Dated 26.02.2024 Of Commissioner Of Income Tax (Exemptions) [“Ld.Cit(E)”], Whereby The Application Of The Assessee For Registration U/S 12Ab Of The Income Tax Act, 1961 (“The Act”) Was Rejected.

For Appellant: Shri K.A.Sai Prasad, ARFor Respondent: Dr.Sachin Kumar, DR
Section 12A

administration of the assessee temple was taken over by the Government under the Endowment Act, the income of the assessee is not liable to tax, in view of the provisions of section 10(23BBA) of the Act, and therefore, the assessee did not file the return of income for these

Sri Someshwara Laxmi Narasimha Swamy Temple Palakurthy, Warangal vs. ITO., Exemption, Ward-1(4), Hyderabad

In the result, all the four appeals of the assessee are allowed for statistical purpose

ITA 1408/HYD/2024[2015-16]Status: DisposedITAT Hyderabad22 Aug 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1408/Hyd/2024 To 1410/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2015-16, 2016-17 & 2018-19) Sri Someshwara Laxmi Vs. Income Tax Officer, Narasimha Swamy Temple Exemption Palakurthy Ward-1(4) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.141/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2024-25) Sri Someshwara Laxmi Vs. Commissioner Of Narasimha Swamy Temple Income Tax Palakurthy (Exemptions) Pan : Aagas8382Q Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 19/08/2025 घोर्णध की तधरीख/ 22/08/2025 Date Of Pronouncement: आदेश / Order Per Bench : These Four Appeals Filed By The Assessee Are Directed Against Three Separate Orders Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre, Delhi, All Dated 08.10.2024 For The A.Y.2015-16, 2016-17 & 2018-19 Respectively & Order Dated 26.02.2024 Of Commissioner Of Income Tax (Exemptions) [“Ld.Cit(E)”], Whereby The Application Of The Assessee For Registration U/S 12Ab Of The Income Tax Act, 1961 (“The Act”) Was Rejected.

For Appellant: Shri K.A.Sai Prasad, ARFor Respondent: Dr.Sachin Kumar, DR
Section 12A

administration of the assessee temple was taken over by the Government under the Endowment Act, the income of the assessee is not liable to tax, in view of the provisions of section 10(23BBA) of the Act, and therefore, the assessee did not file the return of income for these

Bain and Company, Usa vs. DCIT, Gurgoan

In the result, appeal of assessee in ITA Nos

ITA 3056/DEL/2023[2021-22]Status: DisposedITAT Delhi22 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Ms. Ekta Jain, CIT- DR
Section 143(3)

that reimbursements made by Bain India to the Appellant on account of third-party vendors are not taxable in India and thus not liable to tax deduction. GROUNDS PERTAINING TO REIMBURSEMENT OF MISCELLANEOUS EXPENSES 10. That the Ld. AO/DRP erred on facts and in law in holding that the reimbursements ... Ground No. 21-23 with respect to receipt of INR 14,57,058 as subscription fee is not liable to tax in India as royalty income under Section 9(i)(vi) of the Act and Article 12 of the DTAA, submitted that during the relevant year, the Appellant had entered

Bain & Company, Inc., Usa vs. DCIT Intl. Taxation Circle, New Delhi

In the result, appeal of assessee in ITA Nos

ITA 1677/DEL/2023[2020-21]Status: DisposedITAT Delhi22 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Ms. Ekta Jain, CIT- DR
Section 143(3)

that reimbursements made by Bain India to the Appellant on account of third-party vendors are not taxable in India and thus not liable to tax deduction. GROUNDS PERTAINING TO REIMBURSEMENT OF MISCELLANEOUS EXPENSES 10. That the Ld. AO/DRP erred on facts and in law in holding that the reimbursements ... Ground No. 21-23 with respect to receipt of INR 14,57,058 as subscription fee is not liable to tax in India as royalty income under Section 9(i)(vi) of the Act and Article 12 of the DTAA, submitted that during the relevant year, the Appellant had entered

The Dy. Commr. of Income Tax, Cir.-3(1), Rajkot-Gujarat vs. M/S. Sonpal Exports Pvt. Ltd., Rajkot-Gujarat

In the result, appeal filed by the revenue is dismissed

ITA 29/RJT/2018[2012-13]Status: DisposedITAT Rajkot21 Aug 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 29/Rjt/2018 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) The Dcit, Circle – 3(1), Vs. M/S. Sonpal Exports Pvt. Ltd. Rajkot Aayakar Bhavan, Room Dhari Bagsara Road, Nr. Ice No. 114, 1St Floor, Race Course Factory, Amreli Ring Road, Rajkot Pan No.: Aajcs0177N (Assessee) (Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Praveen Verma, Ld. Cit(Dr) Date Of Hearing : 24/06/2025 Date Of Pronouncement : 21/08/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am; By Way Of This Appeal, The Revenue, Has Challenged Correctness Of The Order Dated 16.11.2017, Passed By The Learned Cit(A), In The Matter Of Assessment Under Section 143(3) Of The Income Tax Act 1961, For The Assessment Year 2012-13. Grievances Raised By The Revenue, Which Are Interconnected & Will Be Taken Up Together, Are As Follows: “1. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 13,96,33,023/- Holding That Provision Of Section 195 Will Not Be Applicable. 2. On The Facts Of The Case & In Law, The Ld. C.I.T. (A) Erred In Ignoring The Facts That The Assessee Has Failed To Prove The Genuineness Of Foreign Commission Expenses Before The A.O. 3. It Is, Therefore, Prayed That The Order Of The C.I.T. (A) May Be Set Aside & That Of The A.O. Be Restored To The Above Extent. Dcit Vs. M/S. Sonpal Export Pvt. Ltd.

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Praveen Verma, Ld. CIT(DR)
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 195

will also be not applicable. Now, if the payments to the foreign agents are not a receipt (in agent's hand) which is liable to tax in India, then there is no question of deduction of tax at source. The ld. CIT(A) therefore, noted that foreign commissions ... liable to tax in India and therefore provision of section 195 of the Act, will not be applicable and therefore the disallowance made by assessing officer u/s 40(a) (ia) cannot be upheld. The ld. CIT(A) also noted that assessing officer has raised another issues that assessee can make

Popular Motorworld Private Limited, Ernakulam vs. Income Tax Officer, Corporate Ward 2(5), Kochi

ITA 538/COCH/2025[2014-15]Status: DisposedITAT Cochin21 Aug 2025AY 2014-15

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri P.M. Veeramani, CAFor Respondent: Ms. Neetu S, Sr. DR
Section 143(3)Section 147Section 148Section 250

examining the material which already formed part of the assessment record. Per contra, the stand taken by the Revenue is that the income liable to tax had escaped assessment and, therefore, the Assessing Officer was justified in initiating the re-assessment proceedings. The reassessment proceedings were initiated on the basis ... assessment records and there was no fresh tangible material was available with the Assessing Officer to form a belief that income liable to tax had escaped assessment. In this regard, we note that the original assessment proceedings, the issue of difference between the turnover recorded in service tax return

Jewels Emporium A Legacy, Jaipur vs. ACIT, CC-1, Jaipur

In the result, the appeal of the assessee stands allowed

ITA 1215/JPR/2024[2009-10]Status: DisposedITAT Jaipur21 Aug 2025AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT,Sr.-DR a
Section 143(3)Section 145(3)

questions of fact — tribunal finding assessee did purchase cloth and sell finished fabrics — not entire purchase price but profit element embedded in purchases liable to tax — Income-Tax Act, 1961 In this case, of BholanathPolyfab Limited (supra), Tribunal was of the opinion that the purchases might have been made from

Laggisetty Manohar Karthik, Chennai vs. ITO Non Corporate Ward 15(2), Chennai

In the result the appeal of the assessee is allowed

ITA 746/CHNY/2025[2012-13]Status: DisposedITAT Chennai21 Aug 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 746/Chny/2025 िनधा$रण वष$ / Assessment Year: 2012-13

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 147Section 54Section 80C

Land Acquisition Collector created by Section 194A of the Income-tax Act, 1961. According to the petitioners, the amount of interest being not liable to tax, the Land Acquisition Collector was not justified in deducting the tax at source. :-10-: ITA. No: 746/Chny/2025 4. The issue is no more

Somabhai M Bhoi, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 2101/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri Parin Shah, ARFor Respondent: Shri Sudhakar Verma, DR
Section 148Section 250

participation in the proceedings before the authorities below, he was unable to demonstrate that the capital gains earned by him was not liable to tax since the lands were rural agricultural lands. In view of the same, we consider it to be a fit case to condone the delay

ACIT, Circle-61(1), New Delhi vs. Subramaniam Hariharan, New Delhi

ITA 600/DEL/2020[2013-14]Status: DisposedITAT Delhi20 Aug 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Ms Tanya Sharma, Sr. Advocate
Section 143(3)Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: D : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI MANISH