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972 results for “disallowance”+ Section 10(6)(vii)clear

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Key Topics

Section 143(3)75Addition to Income62Section 153A52Disallowance51Deduction46Section 4042Section 36(1)(vii)32Section 10A30Section 14A23Section 148

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

ITA 161/PAN/2019[2015-16]Status: DisposedITAT Bangalore30 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

For Appellant: Shri Ananthan S. & Smt. Lalitha Rameswaran, CAsFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 14ASection 234BSection 36(1)(vii)Section 36(1)(viia)Section 40Section 41(4)

10% of the aggregate average advance made by the rural branches of such banks. This limit is 5% of gross total income (before deduction under this clause) under sections 36(1)(viia)(b) and 36(1)(viia)(c) for a bank incorporated outside India and certain financial institutions. Provisions of clause (vii) of section 36(1) of the Act provides

Showing 1–20 of 972 · Page 1 of 49

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Section 25019
Depreciation17

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

ITA 1107/BANG/2019[2015-16]Status: DisposedITAT Bangalore30 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

For Appellant: Shri Ananthan S. & Smt. Lalitha Rameswaran, CAsFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 14ASection 234BSection 36(1)(vii)Section 36(1)(viia)Section 40Section 41(4)

10% of the aggregate average advance made by the rural branches of such banks. This limit is 5% of gross total income (before deduction under this clause) under sections 36(1)(viia)(b) and 36(1)(viia)(c) for a bank incorporated outside India and certain financial institutions. Provisions of clause (vii) of section 36(1) of the Act provides

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU, BENGALURU vs. INFOSYS LIMITED, BENGALURU

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

ITA 245/BANG/2024[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt. Srinandini Das – CIT - DR
Section 1Section 10ASection 155Section 250

vii) Incentive from airlines amounting to Rs.7,63,88,054 viii) Rental income from BSNL amounting to Rs.12,000 3.2. On facts and circumstances of the case and law applicable, the appellant is entitled for the claim of deduction under section 10AA of the Act on the above incomes included in the profits of eligible SEZ units. 4. Foreign

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

ITA 528/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 Apr 2023AY 2015-16

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

For Appellant: Shri Ananthan, CA&For Respondent: Shri G. Manoj Kumar, CIT-DR
Section 115JSection 14ASection 194JSection 36Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

disallowance of bad debts written off under Section 36(1)(vii) of the Act. The facts are that the assessee has claimed a sum of Rs.14.96 crores as bad debts written off in the computation of income u/s. 36(1)(vii) of the Act. It was noticed from the P&L account that nowhere the bad debt was debited

M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

ITA 321/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 Apr 2023AY 2015-16

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

For Appellant: Shri Ananthan, CA&For Respondent: Shri G. Manoj Kumar, CIT-DR
Section 115JSection 14ASection 194JSection 36Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

disallowance of bad debts written off under Section 36(1)(vii) of the Act. The facts are that the assessee has claimed a sum of Rs.14.96 crores as bad debts written off in the computation of income u/s. 36(1)(vii) of the Act. It was noticed from the P&L account that nowhere the bad debt was debited

THE KARNATAKA BANK LTD,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), MANGALURU

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

ITA 1907/BANG/2018[2014-15]Status: DisposedITAT Bangalore26 May 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranthe Karnataka Bank Ltd. Dcit, Circle - 2(1) Head Office, Mahaveera Circle Mangalore Vs. Kankanady Mangalore 575002 Pan – Aabct5589K Appellant Respondent Dcit, Circle – 2(1) The Karnataka Bank Ltd. Mangalore Head Office, Mahaveera Circle Vs. Kankanady Mangalore 575002 Pan – Aabct5589K Appellant Respondent Assessee By: Shri S. Ananthan, Ca & Smt. Lalitha Rameswaran, Ca Revenue By: Shri Mudavathu Harish Chandra Naik, Ca Date Of Hearing: 22.03.2022 Date Of Pronouncement: 26.05.2022 O R D E R Per: B.R. Baskaran, A.M. These Cross Appeals Are Directed Against The Order Dated 27-03-2018 Passed By Ld Cit(A), Mangaluru & They Relate To The Assessment Year 2014-15. 2. The Assessee Is A Banking Company Carrying On Banking Business. The Karnataka Bank Ltd.

For Appellant: Shri S. Ananthan, CA &For Respondent: Shri Mudavathu Harish
Section 14A

6. The next issue urged by the revenue relates to the relief granted by Ld CIT(A) in respect of disallowance made u/s 36(1)(viia) of the Act. During the year under consideration, the assessee had claimed deduction towards Provision for bad and doubtful debts (PBDD) u/s 36(1)(viia) of the Act as detailed below:- The Karnataka Bank

M/S INFOSYS LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

Section 10ASection 14ASection 2Section 2(24)Section 40

6% No satisfaction recorded by the AO Infosys BPM Ltd v DCIT – ITA No 493/B/2018 decision dated 23.8.2021 ITAT Bangalore deleted the 14A disallowance in the absence of Disallowance under section 14A read 10 to 13 satisfaction by the AO with rule 8D(2)(iii) Without prejudice, ACIT v Vireet Investment (P) Ltd [2017] 82 taxmann.com 415 – only actual dividend

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE vs. M/S INFOSYS LIMITED , BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 809/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R
Section 11Section 14ASection 194JSection 234BSection 40Section 80J

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

M/S INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 735/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R
Section 11Section 14ASection 194JSection 234BSection 40Section 80J

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

M/S UNITED BREWERIES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, the appeal filed by the assessee is partly allowed

ITA 481/BANG/2018[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR
Section 115JSection 143(2)Section 143(3)Section 14ASection 40Section 43B

vii) as these are not received at all. 6. Grounds related to addition on account of Brand Promotion Expenses: 6.1 The learned CIT{A) has erred in confirming the action of the AO in making addition of Rs 13,76,00,000 in respect of the payment made towards Brand Promotion expenses to Force 6 M/s.United Breweries Limited. India Formula

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, LTU, CIRCLE-2, BANGALORE

In the result, the appeals are partly allowed for statistical purposes

ITA 229/BANG/2023[2013-14]Status: DisposedITAT Bangalore28 Apr 2023AY 2013-14

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Ananthan S. & Smt. Lalitha R., AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 36(1)(vii)

vii) for the current year after write off pertaining to rural branches is at Rs.413,94,00,446/-. Since the available provision exceeds the claim, the entire claim of deduction u/s. 36(1)(viia) is hereby disallowed (901,62,96,579 – 474,24,85,753). Total disallowance : Rs.427,38,10,826.” 25. On appeal before the CIT(Appeals), the assessee

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeals are partly allowed for statistical purposes

ITA 228/BANG/2023[2012-13]Status: DisposedITAT Bangalore28 Apr 2023AY 2012-13

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Ananthan S. & Smt. Lalitha R., AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 36(1)(vii)

vii) for the current year after write off pertaining to rural branches is at Rs.413,94,00,446/-. Since the available provision exceeds the claim, the entire claim of deduction u/s. 36(1)(viia) is hereby disallowed (901,62,96,579 – 474,24,85,753). Total disallowance : Rs.427,38,10,826.” 25. On appeal before the CIT(Appeals), the assessee

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeals are partly allowed for statistical purposes

ITA 227/BANG/2023[2011-12]Status: DisposedITAT Bangalore28 Apr 2023AY 2011-12

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Ananthan S. & Smt. Lalitha R., AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 36(1)(vii)

vii) for the current year after write off pertaining to rural branches is at Rs.413,94,00,446/-. Since the available provision exceeds the claim, the entire claim of deduction u/s. 36(1)(viia) is hereby disallowed (901,62,96,579 – 474,24,85,753). Total disallowance : Rs.427,38,10,826.” 25. On appeal before the CIT(Appeals), the assessee

M/S. A. SHAMA RAO FOUNDATION,MANGALORE vs. THE CHIEF COMMISSIONER OF INCOME TAX, PANAJI, GOA

In the result, the appeal by the assessee is allowed

ITA 628/BANG/2020[2017-18]Status: DisposedITAT Bangalore23 Jul 2021AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2017-18

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR), ITAT, Bengaluru
Section 10Section 12A

6] the approval granted shall be subject to the provision of proviso to section 143[3]; [7] the approval shall be void if it is subsequently found that it has been obtained fraud or misappropriation of fact; [8] the above approval is given only for the purpose of sec. 10[23][vi] of the Income

INTERGARDEN INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-11(3), BANGALORE

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

ITA 2199/BANG/2017[2010-11]Status: DisposedITAT Bangalore15 Mar 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumarassessment Year : 2010-11 M/S. Intergarden (India) Private Limited, The Deputy No. 447, Sri Sai Heights, Commissioner Of 17Th Cross, 17Th Main, Vs. Income Tax, 4Th Sector, Hsr Layout, Circle 11 (3), Bangalore, Bangalore. Karnataka – 560 102. Pan: Aaaci7692H Appellant Respondent

For Appellant: Shri Veenu Aggarwal, CAFor Respondent: Shri Muzaffar Hussain, CIT (DR)
Section 250(5)Section 28Section 36(1)(vii)Section 36(2)Section 37

6 to 8 of his order. It is submitted by ld. AR of assessee that the decision of CIT(A) is on the basis of provisions of section 36(1)(vii) and section 36(2) of IT Act but for the purpose of deciding the issue in respect of write off of advances, these sections are not applicable and this

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), CIRCLE-1, BENGALURU vs. M/S. MAHATMA GANDHI VIDYAPEETHA TRUST, BENGALURU

In the result, appeal of the Revenue is dismissed while cross objection by the Assessee is allowed

ITA 2707/BANG/2017[2012-13]Status: DisposedITAT Bangalore15 Feb 2019AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Jason P Boaz

For Appellant: Shri S Sukumar, AdvocateFor Respondent: Shri Pradeep Kumar, CIT
Section 11Section 12ASection 143(3)

vii) It will, therefore, be more appropriate to hold that funds received from the Government contemplated under Section 10(23c)(iiiab) of the Act must be direct grants/contributions from governmental sources and not fees collected under the statute. The view of the Delhi High Court in Mother Diary Fruit & Vegetable Private Limited vs. Hatim

INCOME TAX OFFICER WARD-1(2)(1), BANGALORE vs. M/S TRUE NORTH FUND IIIA , BANGALORE

In the result, the appeal of the revenue is dismissed and the cross objection of the assessee is treated as allowed

ITA 486/BANG/2019[2015-16]Status: DisposedITAT Bangalore29 Jan 2020AY 2015-16

Bench: Shri B.R Baskaran & Smt. Beena Pillaiassessment Year : 2015-16

For Appellant: Shri Manish Malik, AdvocateFor Respondent: Shri Pradeep Kumar, CIT (DR)
Section 10Section 10(38)Section 2Section 47

disallowed by the AO. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in not considering the fact that the assessee did not sell the unlisted shares of VCU to claim exemption 10(23FB) of the Act. 6. On the facts and in the circumstances of the case

M/S. SYNDICATE BANK,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, UDUPI

In the result, grounds 6 and 9 are allowed for statistical purposes

ITA 1885/BANG/2018[2014-15]Status: DisposedITAT Bangalore23 Feb 2022AY 2014-15

Bench: Shri George George K, Jm & Ms.Padmavathy S, Jm

For Appellant: Sri. S.Ananthan, CA & Smt.Lalitha Rameshwaran, CAFor Respondent: Pradeep Kumar, CIT-DR
Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 36(1)(vii)Section 36(1)(viia)Section 40

vii) 1008,00,06,232 6. The CIT(A) in relation to applicability of provisions of section 115JB of the Act, did not allow ground that section M/s.Canara Bank (Erstwhile Syndicate Bank) 115JB is not applicable to the assessee. The first appellate authority allowed the appeal of the assessee-bank in respect of additions made to the book profit

M/S SYNDICATE BANK,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, UDUPI

In the result, appeal of the revenue in ITA No

ITA 1219/BANG/2019[2015-16]Status: DisposedITAT Bangalore08 Aug 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Shri S. Ananthan, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115JSection 36(1)(vii)Section 36(1)(viia)

6. Ground No.3 is with regard to deduction u/s 36(1)(vii)(a) of the Act. 6.1 Facts of the case are that the assessee bank had claimed a deduction of Rs. 1702,94,76,906/- u/s 36(1)(vii)(a) being the amount eligible as calculated under the section. The assessee had calculated the deduction based on the Aggregate

M/S. UNITED SPIRITS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BENGALURU

In the result, the appeal filed by the assessee is partly allowed

ITA 2701/BANG/2017[2013-14]Status: DisposedITAT Bangalore04 Apr 2022AY 2013-14

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2701/Bang/2017 : Asst.Year 2013-2014 M/S.United Spirits Limited The Deputy Commissioner Of Ub Towers, Income-Tax, Circle 7(1)(1) V. No.24 Vittal Mallya Road Bangalore. Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Senior Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 05.04.2022 Date Of Hearing : 24.03.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 12.10.2017 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In The Manufacture & Sale Of Alcoholic Beverage. The Assessee Filed Its Return Of Income For The Assessment Year 2013-2014 On 28.11.2013 Which Was Selected For Scrutiny Assessment. During The Course Of Assessment, The Assessee’S Case Was Also Referred To The Transfer Pricing Officer (Tpo). The Tpo Vide Order Dated 26.10.2016, Recommended Transfer Pricing Adjustments. The A.O., Thereafter, Passed A Draft Assessment Order Dated 30.12.2016. 2 It(Tp)A No.2701/Bang/2017 M/S.United Spirits Limited.

For Appellant: Sri.Percy Pardiwala, Senior AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR
Section 143(3)Section 14ASection 234BSection 234CSection 36(1)(iii)

10,00,000/-, in the present case, consists merely in facilitating the assessee's business operations, enabling the management to conduct their Hotel business more efficiently and profitably. We are, therefore, satisfied that the view taken by the Tribunal in answering this question in favour of Assessee and against the Revenue is correct and deserve no interference by this Court