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191 results for “disallowance”+ Section 119clear

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Key Topics

Section 1184Section 14A68Addition to Income61Section 143(1)60Section 26358Disallowance54Section 14748Section 143(3)43Section 14841Exemption

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1) (1) AHMEDABAD, VEJALPUR AHMEDABAD vs. INDUCTOTHERM (INDIA) PRIVATE LIMITED, AHMEDABAD

Appeal are dismissed

ITA 598/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad21 Oct 2024AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Ms. Chandni Shah, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 115JSection 143(2)Section 143(3)Section 144C(3)Section 14ASection 195Section 40Section 92C

119/-. Accordingly, notice under Section 143(2) of the Act was issued on 22.08.2017. During the course of assessment, the case was referred to the Transfer Pricing Officer (TPO) under Section 92CA(1) of the Act for determining the Arm’s Length Price (ALP) of the international transactions. The TPO, in his order dated 30.10.2018, made an upward adjustment

Showing 1–20 of 191 · Page 1 of 10

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33
Deduction31
Section 12A30

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

ITA 303/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

disallowance under section 14A of the Act can be made for that year. Such an interpretation is not in line with the intention of the Legislature. To illustrate, if during a previous year, an assessee incurs an expense of Rs. 1 lakh to earn non-exempt income of Rs. 1.5 lakh and also incurs an expense

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

ITA 198/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

disallowance under section 14A of the Act can be made for that year. Such an interpretation is not in line with the intention of the Legislature. To illustrate, if during a previous year, an assessee incurs an expense of Rs. 1 lakh to earn non-exempt income of Rs. 1.5 lakh and also incurs an expense

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

ITA 199/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

disallowance under section 14A of the Act can be made for that year. Such an interpretation is not in line with the intention of the Legislature. To illustrate, if during a previous year, an assessee incurs an expense of Rs. 1 lakh to earn non-exempt income of Rs. 1.5 lakh and also incurs an expense

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

ITA 302/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

disallowance under section 14A of the Act can be made for that year. Such an interpretation is not in line with the intention of the Legislature. To illustrate, if during a previous year, an assessee incurs an expense of Rs. 1 lakh to earn non-exempt income of Rs. 1.5 lakh and also incurs an expense

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LIMITED, AHMEDABAD

ITA 2047/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad28 Dec 2022AY 2013-14
For Appellant: Shri Vartik Choksi, A.RFor Respondent: Shri Ritesh Parmar, CIT. D.R
Section 14ASection 36Section 80

section 80-IA of the Act. 64.1 However, the AO was of the view that no benefit of bad debts recovery can be granted by allowing deduction under section 80IA of the Act for the reason that the amount of bad debt was recognized by the assessee when its unit was not eligible for deduction under section

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LTD.,, AHMEDABAD

ITA 14/AHD/2018[2012-13]Status: DisposedITAT Ahmedabad28 Dec 2022AY 2012-13
For Appellant: Shri Vartik Choksi, A.RFor Respondent: Shri Ritesh Parmar, CIT. D.R
Section 14ASection 36Section 80

section 80-IA of the Act. 64.1 However, the AO was of the view that no benefit of bad debts recovery can be granted by allowing deduction under section 80IA of the Act for the reason that the amount of bad debt was recognized by the assessee when its unit was not eligible for deduction under section

ADANI ENTERPRISES LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD

Appeal of the Revenue is hereby dismissed

ITA 2035/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad15 Jul 2022AY 2011-12

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedasstt. Sr.No.

For Appellant: Shri S.N. Soparkar, Sr. Advocate with Shri Vartik Choksi, A.RFor Respondent: Shri Mohd. Usman, C.I.T.DR
Section 143(3)Section 28Section 35Section 92C

Section 37(1) of the Income-tax Act, 1961, read with sections 198 and 309 of the Companies Act, 1956 - Business expenditure - Allowability of - Assessment year 1979-80 - Whether when vehicles belonging to an assessee-company are used by its directors, for personal or other purposes, it would be wrong to hold that vehicles are personally used by company, because

CORRTECH INTERNATIONAL PVT. LTD.,AHMEDABAD vs. THE ADDL. CIT, TDS RANGE,, AHMEDABAD

ITA 2408/AHD/2017[2015-16]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2015-16

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 14ASection 26(1)(iii)

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

CORRTECH INTERNATIONAL PVT.LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)RANGE-1,, AHMEDABAD

ITA 1785/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2009-10

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 14ASection 26(1)(iii)

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

THE DCIT(OSD) RANGE-1,, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT.LTD.,, AHMEDABAD

ITA 2578/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2010-11

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 14ASection 26(1)(iii)

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

CORRTECH INTERNATIONAL PVT.LTD.,,AHMEDABAD vs. THE ACIT.,(OSD) RANGE-1,, AHMEDABAD

ITA 2652/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2010-11

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 14ASection 26(1)(iii)

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT. LTD.,, AHMEDABAD

ITA 1358/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2010-11

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 14ASection 26(1)(iii)

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

CORRTECH INTERNATIONAL PVT. LTD.,AHMEDABAD vs. THE ADDL. CIT, TDS RANGE,, AHMEDABAD

ITA 2406/AHD/2017[2014-15]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2014-15

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 14ASection 26(1)(iii)

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

THE DCIT(OSD)RANGE-1,, AHMEDABAD vs. CORRTECH INTERNATIONAL PVT.LTD.,, AHMEDABAD

ITA 1871/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2009-10

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 14ASection 26(1)(iii)

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

CORRTECH INTERNATIONAL PVT.LTD.,,AHMEDABAD vs. DY. COMMISSIONER OF INCOME TAX,(OSD),, AHMEDABAD

ITA 821/AHD/2015[2008-09]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2008-09

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 14ASection 26(1)(iii)

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

THE DCIT(OSD) RANGE-1,, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT.LTD.,, AHMEDABAD

ITA 1129/AHD/2015[2008-09]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2008-09

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 14ASection 26(1)(iii)

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

VOLARK LEASING IFSC PVT. LTD,GUJARAT vs. ACIT/DCIT, CIRCLE, GANDHINAGAR, GUJARAT, GUJARAT

In the result, the appeal of the assessee is allowed

ITA 357/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2023-24

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Shri Pancham Sethi, ARFor Respondent: Date of Hearing
Section 143Section 143(1)Section 234BSection 250Section 80Section 80JSection 80L

disallow the appellant's claim for deduction under Section 80LA(3) of the Act, when processing the return under Section 143(1) of the Act. 4.4 Further, Section 119

THE DCIT, CIRCLE-1,, AHMEDABAD vs. AIA ENGINEERING LTD.,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

ITA 1766/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad04 Jan 2021AY 2008-09
For Appellant: Shri T.P. Hemani, Sr. A.R. &For Respondent: Shri Vinod Tanwani, Sr. D.R
Section 143(2)Section 143(3)

Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92 B defines the expression 'international transaction

AIA ENGINEERING LTD.,,AHMEDABAD vs. THE DY.CIT.,CIRCLE-1,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

ITA 1757/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad04 Jan 2021AY 2008-09
For Appellant: Shri T.P. Hemani, Sr. A.R. &For Respondent: Shri Vinod Tanwani, Sr. D.R
Section 143(2)Section 143(3)

Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92 B defines the expression 'international transaction