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95 results for “disallowance”+ Section 270A(10)clear

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Key Topics

Section 14A87Section 270A83Addition to Income66Section 143(3)58Disallowance58Penalty57Deduction39Section 271A38Section 54F30Section 68

GELOT AGRI EXPORTS,DEESA vs. ITO WD 1 PALANPUR, BANASKANTHA

The appeal of the assessee is allowed, while that of the Revenue is dismissed

ITA 1739/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad19 Dec 2024AY 2018-19

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Ito, Ward-1 Vs. Gelot Agri Exports Palanpur, Banaskantha At 13, Aditya Complex Gujarat. Opp: Jalaram Temple Deesa 385 535. Pan : Aapfg 5455 N Assessment Year : 2018-19 Gelot Agri Exports Vs. Ito, Ward-1 At 13, Aditya Complex Palanpur, Banaskantha Opp: Jalaram Temple Gujarat. Deesa 385 535. Pan : Aapfg 5455 N

Section 143(3)Section 250(6)Section 270ASection 270A(1)Section 270A(8)Section 40

10. Thereafter, the ld.counsel for the assessee contended that in terms of provisions of section 270A sub-section (2) of the Act, no penalty was leviable on the addition/disallowance which were of the nature to be adjusted in the intimation made under section 143(1)(a) of the Act. He drew our attention to section 270A(1) sub-section

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Section 92C27
Section 12A25

ITO, WARD-1, PALANPUR, PALANPUR vs. GELOT AGRI EXPORTS, PALANPUR

The appeal of the assessee is allowed, while that of the Revenue is dismissed

ITA 225/AHD/2024[2018]Status: DisposedITAT Ahmedabad19 Dec 2024

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Ito, Ward-1 Vs. Gelot Agri Exports Palanpur, Banaskantha At 13, Aditya Complex Gujarat. Opp: Jalaram Temple Deesa 385 535. Pan : Aapfg 5455 N Assessment Year : 2018-19 Gelot Agri Exports Vs. Ito, Ward-1 At 13, Aditya Complex Palanpur, Banaskantha Opp: Jalaram Temple Gujarat. Deesa 385 535. Pan : Aapfg 5455 N

Section 143(3)Section 250(6)Section 270ASection 270A(1)Section 270A(8)Section 40

10. Thereafter, the ld.counsel for the assessee contended that in terms of provisions of section 270A sub-section (2) of the Act, no penalty was leviable on the addition/disallowance which were of the nature to be adjusted in the intimation made under section 143(1)(a) of the Act. He drew our attention to section 270A(1) sub-section

INFOANALYTICA CONSULTING PRIVATE LIMITED,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, the penalty u/s

ITA 1592/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad30 Jan 2025AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Sunil Talati, ARFor Respondent: Shri Nitin Kulkarni, Sr. DR
Section 143(3)Section 270ASection 270A(2)Section 270A(8)Section 270A(9)Section 40

disallowance made by the AO provision of section 270A(9)(a) or 270A(a)(c) of the Act are not attracted. Therefore, to conclude looking into the facts of the assessee’s case, it is not a fit case for levy of penalty u/s.270(A) of the Act, on account of failure on the part of the AO in giving

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. GUJARAT URJA VIKAS NIGAM LIMITED, VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 178/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad15 Mar 2024AY 2018-19

Bench: Smt. Annapurna Gupta & Ms. Madhumita Roy

For Appellant: Respondent by : Shri Akhilendra Pratap Yadaw, CIT DRFor Respondent: Shri Akhilendra Pratap Yadaw, CIT DR
Section 143(3)Section 14ASection 234ASection 270A

270A of the I T Act. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming the charging of interest under section 234A, 234B, 234C and 234D of the Income Tax Act, 1961. 4.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before

GUJARAT URJA VIKAS NIGAM LIMITED,VADODARA vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 139/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad15 Mar 2024AY 2018-19

Bench: Smt. Annapurna Gupta & Ms. Madhumita Roy

For Appellant: Respondent by : Shri Akhilendra Pratap Yadaw, CIT DRFor Respondent: Shri Akhilendra Pratap Yadaw, CIT DR
Section 143(3)Section 14ASection 234ASection 270A

270A of the I T Act. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming the charging of interest under section 234A, 234B, 234C and 234D of the Income Tax Act, 1961. 4.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before

SHREE SWATI TEXDYES PVT. LTD.,AHMEDABAD vs. THE DY. CIT, CIRCLE-4(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 2222/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rameshwar P Meena, Sr. DRFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 14ASection 270ASection 40

10. Subsequently, by the Finance Act, 2022 an Explanation was inserted in section 40(a)(ii) of the Act with retrospective effect from 01.04.2005 clarifying that the expression “tax” shall include surcharge and cess. As a consequence of the retrospective amendment, the deduction claimed by the assessee towards Health and Education Cess became statutorily disallowable. However, the material on record

KOSHAMBH MULTITRED PRIVATE LIMITED,VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed

ITA 1031/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad21 Aug 2025AY 2020-21

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar

For Appellant: Respondent byFor Respondent: Shri Rohit Aasudani, Sr. DR
Section 155(18)Section 250Section 270A(2)Section 270A(7)Section 270A(9)Section 40

10. As per the said sub section, such claims of education cess not allowable on account of the retrospective amendment but allowed earlier, were deemed to be under reported income for purposes of levy of penalty u/s 270A of the Act. However, the proviso to the sub section carved an exception providing immunity from the levy of penalty, subject

PARULBEN VIJAYKUMAR PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 164/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad22 May 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Sanjay R. Shah, A.RFor Respondent: Shri Ravindra, Sr. DR
Section 139Section 147Section 148Section 270ASection 270A(10)Section 270A(8)Section 270A(9)

10. The issue for consideration before us is that whether penalty under Section 270A of the Act can be levied in the instant set of facts, when as per the assessee, she was under the genuine belief that since taxes has been deducted at source on such sale of property then there was no occasion to file return of income

GUJARAT ENERGY DEVELOPMENT AGENCY,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

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

ITA 1180/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

disallowance of “Impairment of Assets” of Rs.9,35,16,377/- and “Abnormal loss” on account of the spares of Rs.1,07,10,358/-, as made by the AO, is upheld. The grounds raised by the assessee in this respect are accordingly dismissed. ITA Nos.1179 & 1180/Ahd/2025 (Assessment Year: 2017-18 (for both)) Gujarat Energy Development Agency vs. DCIT Page

GUJARAT ENERGY DEVELOPMENT AGENCY,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

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

ITA 1179/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

disallowance of “Impairment of Assets” of Rs.9,35,16,377/- and “Abnormal loss” on account of the spares of Rs.1,07,10,358/-, as made by the AO, is upheld. The grounds raised by the assessee in this respect are accordingly dismissed. ITA Nos.1179 & 1180/Ahd/2025 (Assessment Year: 2017-18 (for both)) Gujarat Energy Development Agency vs. DCIT Page

GUJARAT URJA VIKAS NIGAM LTD.,VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, the appeal filed by the Revenue in ITA No

ITA 231/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad08 Aug 2024AY 2020-21

Bench: Shri Ramit Kochar (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 10Section 115JSection 143(3)Section 14A

10(34/35) of Rs.12,07,96,095/- (vi) Adjustment in Book Profit under 115JB including the disallowance u/s. 14A. 4. Aggrieved against the assessment order, the assessee filed an appeal before Ld. CIT(A). Regarding the first issue of disallowance u/s. 14A, the Ld. CIT(A) considered the appellate orders passed by his predecessors for the Asst. years

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1), VADODARA vs. GUJARAT URJA VIKAS NIGAM LIMITED, VADODARA

In the result, the appeal filed by the Revenue in ITA No

ITA 293/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad08 Aug 2024AY 2020-21

Bench: Shri Ramit Kochar (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 10Section 115JSection 143(3)Section 14A

10(34/35) of Rs.12,07,96,095/- (vi) Adjustment in Book Profit under 115JB including the disallowance u/s. 14A. 4. Aggrieved against the assessment order, the assessee filed an appeal before Ld. CIT(A). Regarding the first issue of disallowance u/s. 14A, the Ld. CIT(A) considered the appellate orders passed by his predecessors for the Asst. years

GUJARAT URJA VIKAS NIGAM LTD.,VADODARA vs. THE ACIT, CIRCLE-1(1)(1), VADODARA

In the result, the appeal filed by the Revenue in ITA No

ITA 166/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad08 Aug 2024AY 2017-18

Bench: Shri Ramit Kochar (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 10Section 115JSection 143(3)Section 14A

10(34/35) of Rs.12,07,96,095/- (vi) Adjustment in Book Profit under 115JB including the disallowance u/s. 14A. 4. Aggrieved against the assessment order, the assessee filed an appeal before Ld. CIT(A). Regarding the first issue of disallowance u/s. 14A, the Ld. CIT(A) considered the appellate orders passed by his predecessors for the Asst. years

THE JT.CIT, (OSD)CIRCLE-1(1)(1), VADODARA vs. GUJARAT URJA VIKAS NIGAM LTD., VADODARA

In the result, the appeal filed by the Revenue in ITA No

ITA 223/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad08 Aug 2024AY 2017-18

Bench: Shri Ramit Kochar (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 10Section 115JSection 143(3)Section 14A

10(34/35) of Rs.12,07,96,095/- (vi) Adjustment in Book Profit under 115JB including the disallowance u/s. 14A. 4. Aggrieved against the assessment order, the assessee filed an appeal before Ld. CIT(A). Regarding the first issue of disallowance u/s. 14A, the Ld. CIT(A) considered the appellate orders passed by his predecessors for the Asst. years

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION - THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 913/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 915/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

DCIT, CIRCLE-2(1)(1) AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCE LIMITED SHIVARTH AMBIT, AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 847/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

DCIT CIRCLE-2(1)(1), AHMEDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 850/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

DCIE CIRCLE-2(1)(1), AHEMDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 849/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY.CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 912/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order