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“Section 36(1)(xii)”

Section References (mined)Section 36Section 36(1)(xii)26 judgments

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 545/PUN/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable in the case of Corporation or Body Corporate. He further noted that

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable in the case of Corporation or Body Corporate. He further noted that

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable in the case of Corporation or Body Corporate. He further noted that

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable in the case of Corporation or Body Corporate. He further noted that

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable in the case of Corporation or Body Corporate. He further noted that

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1153/MUM/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable in the case of Corporation or Body Corporate. He further noted that

DCIT 3(2)(1), MUMBAI vs. THE NATIONAL BANK FOR AGRICULTURE AND RURAL DEVELOPMENT, MUMBAI

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

ITA 3006/MUM/2024[2020-21]Status: DisposedITAT Mumbai06 Dec 2024AY 2020-21

Bench: Shri Amarjit Singh, Hon’Ble & Shri Rahul Chaudhary, Hon’Bleassessment Year: 2020-21

For Appellant: Shri J.D. Mistry, Sr. Advocate &For Respondent: Shri Kailash C. Kanojiya, CIT, DR &
Section 143(3)Section 250Section 36(1)(xii)

IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH ‘B’, MUMBAI BEFORE SHRI AMARJIT SINGH, HON’BLE ACCOUNTANT MEMBER AND SHRI

THE NATIONAL BANK FOR AGRICULTURE AND RURAL DEVELOPMENT,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 3(2)(1), MUMBAI, MUMBAI

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

ITA 2522/MUM/2024[2020-21]Status: DisposedITAT Mumbai06 Dec 2024AY 2020-21
Section 143(3)Section 36(1)(xii)

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH ‘B', MUMBAI\nBEFORE SHRI AMARJIT SINGH, HON'BLE ACCOUNTANT MEMBER

DCIT CIRCLE-52(1), NEW DELHI vs. OIL INDUSTRY DEVELOPMENT BOARD, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 1847/DEL/2023[2014-15]Status: HeardITAT Delhi13 Jun 2024AY 2014-15

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Subhra Jyoti Chakraborty, Sr. DR
Section 14ASection 36(1)(xii)

vide order dated 23.11.2012 in ITA Nos. 1128 to 1130/DEL/2012 wherein the issue of applicability of provisions of section 36(1)(xii) of the Act in respect of expenses claimed by the assessee towards grant released to the institutions and royalty paid has been quite extensively deliberated by placing reliance

NATIONAL DAIRY DEVELOPMENT BOARD,,ANAND vs. THE ASSTT. COMMISSIONER OF INCOME TAX, ANAND CIRCLE,, ANAND

In the result, Ground No. 7 of the assessee’s appeal is allowed for statistical purposes

ITA 2994/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad17 May 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Shri Yogesh Shah & Ms. Aparna Parlekr A.RsFor Respondent: Shri Sudhendu Das, CIT DR
Section 14ASection 36(1)(viii)Section 36(1)(xii)

accordingly. Ground No. 3 & 3.1:- CIT(A) erred in setting-aside the matter regarding grant of disallowance of Rs. 54,71,000/- under Section 36(1)(xii) of the Act. 7. The brief facts in relation to this ground of appeal are that the assessee claimed expenditure ... crores in the Profit & Loss Account under Section 36(1)(xii) of the Act. 8. During the course of assessment proceedings, the Assessing officer asked the assessee to provide a break-up of the expenses and on analysis of the details provided by the assessee, the Assessing Officer observed that

THE DY.COMMISSIONER OF INCOME TAX.,ANAND CIRCLE,, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, Ground No. 7 of the assessee’s appeal is allowed for statistical purposes

ITA 2954/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad17 May 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Shri Yogesh Shah & Ms. Aparna Parlekr A.RsFor Respondent: Shri Sudhendu Das, CIT DR
Section 14ASection 36(1)(viii)Section 36(1)(xii)

accordingly. Ground No. 3 & 3.1:- CIT(A) erred in setting-aside the matter regarding grant of disallowance of Rs. 54,71,000/- under Section 36(1)(xii) of the Act. 7. The brief facts in relation to this ground of appeal are that the assessee claimed expenditure ... crores in the Profit & Loss Account under Section 36(1)(xii) of the Act. 8. During the course of assessment proceedings, the Assessing officer asked the assessee to provide a break-up of the expenses and on analysis of the details provided by the assessee, the Assessing Officer observed that

NATIONAL DAIRY DEVELOPMENT BOARD,,ANAND vs. THE ACIT.,ANAND CIRCLE,, ANAND

In the result, Ground No. 7 of the assessee’s appeal is allowed for statistical purposes

ITA 2004/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad17 May 2024AY 2010-11

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Shri Yogesh Shah & Ms. Aparna Parlekr A.RsFor Respondent: Shri Sudhendu Das, CIT DR
Section 14ASection 36(1)(viii)Section 36(1)(xii)

accordingly. Ground No. 3 & 3.1:- CIT(A) erred in setting-aside the matter regarding grant of disallowance of Rs. 54,71,000/- under Section 36(1)(xii) of the Act. 7. The brief facts in relation to this ground of appeal are that the assessee claimed expenditure ... crores in the Profit & Loss Account under Section 36(1)(xii) of the Act. 8. During the course of assessment proceedings, the Assessing officer asked the assessee to provide a break-up of the expenses and on analysis of the details provided by the assessee, the Assessing Officer observed that

THE ACIT,ANAND CIRCLE,, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, Ground No. 7 of the assessee’s appeal is allowed for statistical purposes

ITA 1873/AHD/2014[2010-11]Status: PendingITAT Ahmedabad17 May 2024AY 2010-11

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Shri Yogesh Shah & Ms. Aparna Parlekr A.RsFor Respondent: Shri Sudhendu Das, CIT DR
Section 14ASection 36(1)(viii)Section 36(1)(xii)

accordingly. Ground No. 3 & 3.1:- CIT(A) erred in setting-aside the matter regarding grant of disallowance of Rs. 54,71,000/- under Section 36(1)(xii) of the Act. 7. The brief facts in relation to this ground of appeal are that the assessee claimed expenditure ... crores in the Profit & Loss Account under Section 36(1)(xii) of the Act. 8. During the course of assessment proceedings, the Assessing officer asked the assessee to provide a break-up of the expenses and on analysis of the details provided by the assessee, the Assessing Officer observed that

DCIT, CIRCLE-52(1), NEW DELHI vs. OIL INDUSTRY DEVELOPMENT BOARD, NEW DELHI

In the result, the appeal of the Revenue in ITA No

ITA 1305/DEL/2023[2013-14]Status: DisposedITAT Delhi25 Apr 2024AY 2013-14

Bench: Shri Saktijit Dey & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Subhra Jyoti Chakraborty, Sr. DR
Section 14ASection 36(1)(xii)

vide order dated 23.11.2012 in ITA Nos. 1128 to 1130/DEL/2012 wherein the issue of applicability of provisions of section 36(1)(xii) of the Act in respect of expenses claimed by the assessee towards grant released to the institutions and royalty paid has been quite extensively deliberated by placing reliance

DCIT 3(2)(2), MUMBAI vs. NATIONAL BANK OF AGRICULTURE AN RURAL DEVELOPMENT, MUMBAI

In the result, all the appeals of assessee as well as revenue are partly\nallowed

ITA 4010/MUM/2018[2015-16]Status: DisposedITAT Mumbai03 Apr 2024AY 2015-16

revenue in A.Y. 2014-15, 2015-16 and\n2019-10 relates to the disallowance of expenditure incurred on promotional\nactivities claimed under section 36(1)(xii) of the Act. The assessee has also\nraised this issue in 2011-12, 2012-13 and 2019-20. We notice that the\nassessee ... expenditure of NABARD. The amounts were diverted at source and did not belong to the assessee.", "result": "Allowed", "sections": [ "Section 2(24)", "Section 36(1)(xii)", "Section 37(1)", "Section 45 of NABARD Act" ], "issues": "Whether the interest income attributable to funds managed by NABARD in a fiduciary capacity

DCIT 3(2)(2), MUMBAI vs. NATIONAL BANK OF AGRICULTURE AN RURAL DEVELOPMENT, MUMBAI

In the result, all the appeals of assessee as well as revenue are partly\nallowed

ITA 4009/MUM/2018[2014-15]Status: DisposedITAT Mumbai03 Apr 2024AY 2014-15

revenue in A.Y. 2014-15, 2015-16 and\n2019-10 relates to the disallowance of expenditure incurred on promotional\nactivities claimed under section 36(1)(xii) of the Act. The assessee has also\nraised this issue in 2011-12, 2012-13 and 2019-20. We notice that the\nassessee ... addressed issues related to promotional expenses and prior period expenses, remanding some matters for fresh examination.", "result": "Partly Allowed", "sections": [ "Section 2(24)", "Section 36(1)(xii)", "Section 37(1)", "Section 45 of NABARD Act" ], "issues": "Whether interest income and expenditure related to funds managed by NABARD on behalf

DCIT 3(2)(2), MUMBAI vs. NATIONAL BANK OF AGRICULTURE AN RURAL DEVELOPMENT, MUMBAI

In the result, all the appeals of assessee as well as revenue are partly\nallowed

ITA 4008/MUM/2018[2013-14]Status: DisposedITAT Mumbai03 Apr 2024AY 2013-14

revenue in A.Y. 2014-15, 2015-16 and\n2019-10 relates to the disallowance of expenditure incurred on promotional\nactivities claimed under section 36(1)(xii) of the Act. The assessee has also\nraised this issue in 2011-12, 2012-13 and 2019-20. We notice that the\nassessee ... Government of India are taxable/allowable in the hands of the assessee. 2. Whether promotional expenses are allowable as a deduction under Section 36(1)(xii) or Section 37(1) of the Income

DCIT 3(2)(2), MUMBAI vs. NATIONAL BANK OF AGRICULTURE AN RURAL DEVELOPMENT, MUMBAI

ITA 4007/MUM/2018[2012-13]Status: DisposedITAT Mumbai03 Apr 2024AY 2012-13

revenue in A.Y. 2014-15, 2015-16 and\n2019-10 relates to the disallowance of expenditure incurred on promotional\nactivities claimed under section 36(1)(xii) of the Act. The assessee has also\nraised this issue in 2011-12, 2012-13 and 2019-20. We notice that the\nassessee ... expenditure incurred out of interest income from funds held on behalf of GOI was upheld.", "result": "Partly Allowed", "sections": ["Section 2(24)", "Section 36(1)(xii)", "Section 37(1)", "Section 45"], "issues": "1. Whether interest income attributable to Rural Infrastructure Development Fund (RIDF) and Short Term Co-operative Rural Credit

DCIT 3(2)(2), MUMBAI vs. NATIONAL BANK OF AGRICULTURE AN RURAL DEVELOPMENT, MUMBAI

In the result, all the appeals of assessee as well as revenue are partly\nallowed

ITA 4006/MUM/2018[2011-12]Status: DisposedITAT Mumbai03 Apr 2024AY 2011-12

revenue in A.Y. 2014-15, 2015-16 and\n2019-10 relates to the disallowance of expenditure incurred on promotional\nactivities claimed under section 36(1)(xii) of the Act. The assessee has also\nraised this issue in 2011-12, 2012-13 and 2019-20. We notice that the\nassessee

DCIT 3(2)(2), MUMBAI vs. NATIONAL BANK FOR AGRICULTURE AND RURAL DEVELOPMENT, MUMBAI

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

ITA 3650/MUM/2016[2010-11]Status: DisposedITAT Mumbai24 Aug 2022AY 2010-11

THE INCOME TAX APPELLATE TRIBUNAL “B” Bench, Mumbai Shri B.R. Baskaran (AM) & Shri Kuldip Singh (JM) I.T.A. No. 3650/Mum/2016 (A.Y

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