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91 results for “disallowance”+ Section 270A(9)clear

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Key Topics

Section 270A96Section 14A85Addition to Income62Disallowance59Section 143(3)58Penalty55Section 271A42Deduction35Section 14730Section 54F

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

disallowance of such expenses now made in assessment framed under section 143(3) of the Act would tantamount to under reporting of the income as per the provisions of section 270A(2) of the Act. The provision of section are reproduced by us above , and are being reproduced again for clarity: ITA No.1739 and 225/Ahd/2024 11 270A. (1) The Assessing

Showing 1–20 of 91 · Page 1 of 5

29
Section 12A24
Section 92C22

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

disallowance of such expenses now made in assessment framed under section 143(3) of the Act would tantamount to under reporting of the income as per the provisions of section 270A(2) of the Act. The provision of section are reproduced by us above , and are being reproduced again for clarity: ITA No.1739 and 225/Ahd/2024 11 270A. (1) The Assessing

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

9– income and the Ld. Counsel for the assessee submitted before us that the assessee had not made disallowance in anticipation of submission of certificate u/s.201 of the Act from the deductee. Accordingly, even with respect to second disallowance made by the AO provision of section 270A

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

section 270A of the Act on account of disallowance of deduction claimed towards Health and Education Cess. 9. It is an undisputed

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)

9), Parulben Vijakumar Patel vs. ITO Asst.Year –2017-18 - 5– penalty at two hundred per cent, of tax payable on such income]. Penalty under sub Section (8) is independent of levy of penalty under sub Section (7) even if there is no under reported income. Under sub Section (1), the AO, Commissioner, Principal Commissioner or the Appellate Commissioner may direct

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

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 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 9

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 9

KRUNAL SANGHVI,AHMEDABAD vs. INCOME TAX OFFICER , WARD-5(3)(1), AHMEDABAD

In the result, appeal filed by the assessee is allowed

ITA 1285/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri Chintan Shah, ARFor Respondent: Shri Abhijit, Sr.DR
Section 253Section 270A(9)Section 5

disallowance of deduction u/s.54F of the Act to the extent of excess claimed by the assessee, penalty for mis-reporting of income as a consequence of under reporting in terms of Section 270A(9

NARAYANBHAI SHIVABHAI PATEL,MEHSANA vs. THE ITO, WARD-1, MEHSANA

In the result, the appeal of the assessee is allowed

ITA 1357/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2020-21

Section 143(3)Section 270ASection 270A(6)Section 270A(6)(a)Section 270A(6)(b)Section 56(2)(x)

disallowance; (d) the amount of under-reported income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction

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

disallowance of the same and accordingly, Koshambh Multitred Pvt. Ltd. vs. DCIT Asst.Year –2020-21 the impugned sum was added to the returned income of the assessee. Thereafter, penalty proceedings for misreporting of income were initiated in terms of section 270A(9

THE AHMEDABAD DISTRICT CO.OP. BANK LTD.,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1108/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad24 Apr 2025AY 2020-21
For Appellant: \nShri Sanjay R. Shah, ARFor Respondent: \nShri B.P. Srivastava, Sr.DR
Section 139(1)Section 143(3)Section 155(18)Section 270ASection 40

disallowance of a bona fide claim.\n6. 2. Alternatively, it was submitted that the penalty levied by the Assessing\nOfficer @ 200% was not sustainable in view of section 270A(7) of the Act, and\nthat the learned CIT(A) rightly restricted it to 50% by treating the case as one\nof under-reporting and not misreporting. However, even such reduced

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

270A of the IT 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 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

270A of the IT 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

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

270A of the IT 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

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

270A of the IT 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

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

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

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