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544 results for “disallowance”+ Section 10B(4)clear

Sorted by relevance

Mumbai919Delhi826Bangalore544Kolkata398Chennai304Ahmedabad223Pune198Hyderabad157Chandigarh97Jaipur62Cochin51Karnataka46Lucknow38Indore33Visakhapatnam32Cuttack32Rajkot30Surat27Nagpur15Amritsar14Jodhpur13Agra10Telangana9Dehradun8Guwahati8Varanasi7Ranchi6Panaji6Raipur4Patna4Jabalpur3Calcutta1Allahabad1Kerala1SC1Himachal Pradesh1

Key Topics

Section 143(3)78Section 10A54Addition to Income52Transfer Pricing48Section 92C47Section 1145Disallowance44Comparables/TP41Deduction36Section 143(1)

DINESH KUMAR SINGHI,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2011-12 is partly allowed

ITA 699/BANG/2015[2005-06]Status: DisposedITAT Bangalore10 Apr 2018AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri K.R. Pradeep, C.AFor Respondent: Shri K.V. Arvind, Standing Counsel for Dept
Section 10BSection 132Section 143(3)Section 148Section 153ASection 154

disallowance in the denial of the assessee's claim for deduction under Section 10B of the Act; which is not based on incriminating material seized in the case on hand. It is seen that the seized material referred to in the assessment order pertains to seizures effected elsewhere and if they pertained to this assessee, these proceedings under Section 153C

Showing 1–20 of 544 · Page 1 of 28

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29
Section 80J28
Section 9026

BHARAT MINE AND MINERALS,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals of Revenue for Assessment Years 2008-09

ITA 738/BANG/2015[2008-09]Status: DisposedITAT Bangalore10 Apr 2018AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri K.R. Pradeep, C.AFor Respondent: Shri K.V.Arvind, Standing Counsel for Dept
Section 10BSection 132Section 132(4)Section 143(3)Section 153ASection 37(1)Section 69

10B : Assessment Years 2008-09 to 2011-12. (ii) Unexplained investment u/s. 69 : A.Y. 2008-09. (iii) Unexplained payments/unexplained expenditure : A.Y. 2008-09 to 2011-12. (iv) Unexplained investment in land : A.Y. 2009-10. (v) Disallowance under Section 37(1) : Belekere Port Export : A.Y. 2010- 11. (vi) Disallowance of loss on Forward Exchange Contracts

M/S. ALLSTATE INDIA PRIVATE LIMITED ,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BENGALURU

In the result, the appeal of the assessee is allowed

ITA 257/BANG/2023[2018-19]Status: DisposedITAT Bangalore31 May 2023AY 2018-19

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year: 2018-19

For Appellant: Shri Prakash Shridhar Hegde, A.RFor Respondent: Shri Gudimella VP Pavan Kumar, D.R
Section 10ASection 139

disallowance of deduction under section 10AA of the Act for interest income earned by the Appellant. 4. That the learned CIT(A) has erred in the facts and circumstances of the case by - passing the impugned Order without following the judicial Precedence on this matter. 2. The brief facts of the case are that the assessee filed return of income

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

section 10AA of the Act. Accordingly these grounds raised by the assessee stands partly allowed. 16. Ground nos. 41 & 42 - Reduction of deduction under section 10AA in respect of pure onsite revenue 16.1 It was submitted that a software development project typically goes through the stages of requirement analysis, prototyping, design, pilots, programming, testing and installation and maintenance. A software

M/S INTERNATIONAL STONES I P LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE

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

ITA 1475/BANG/2014[2011-12]Status: DisposedITAT Bangalore20 Jan 2016AY 2011-12

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Rao

For Appellant: Shri C. Ramesh, CAFor Respondent: Dr. P.K. Srihari, Addl. CIT(DR)
Section 10BSection 143(1)Section 143(3)

disallowed this claim for a reason that exports were effected by the merchant exporters, who alone had received the foreign exchange. AO also noted that assessee had received the consideration for sale from such merchant exporters only in Indian rupee and there was no concept of "deemed exports" in section 1OB of the Act. Learned CIT(A), accepted the claim

DCIT, BANGALORE vs. M/S INTERNATIONAL STONES INDIA PVT. LTD.,, BANGALORE

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

ITA 608/BANG/2014[2009-10]Status: DisposedITAT Bangalore20 Jan 2016AY 2009-10

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Rao

For Appellant: Shri C. Ramesh, CAFor Respondent: Dr. P.K. Srihari, Addl. CIT(DR)
Section 10BSection 143(1)Section 143(3)

disallowed this claim for a reason that exports were effected by the merchant exporters, who alone had received the foreign exchange. AO also noted that assessee had received the consideration for sale from such merchant exporters only in Indian rupee and there was no concept of "deemed exports" in section 1OB of the Act. Learned CIT(A), accepted the claim

M/S |NTERNATIONAL STONES I P LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE

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

ITA 1474/BANG/2014[2010-11]Status: DisposedITAT Bangalore20 Jan 2016AY 2010-11

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Rao

For Appellant: Shri C. Ramesh, CAFor Respondent: Dr. P.K. Srihari, Addl. CIT(DR)
Section 10BSection 143(1)Section 143(3)

disallowed this claim for a reason that exports were effected by the merchant exporters, who alone had received the foreign exchange. AO also noted that assessee had received the consideration for sale from such merchant exporters only in Indian rupee and there was no concept of "deemed exports" in section 1OB of the Act. Learned CIT(A), accepted the claim

DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S INTERNATIONAL STONES INDIA P LTD, BANGALORE

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

ITA 1332/BANG/2014[2009-10]Status: DisposedITAT Bangalore20 Jan 2016AY 2009-10

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Rao

For Appellant: Shri C. Ramesh, CAFor Respondent: Dr. P.K. Srihari, Addl. CIT(DR)
Section 10BSection 143(1)Section 143(3)

disallowed this claim for a reason that exports were effected by the merchant exporters, who alone had received the foreign exchange. AO also noted that assessee had received the consideration for sale from such merchant exporters only in Indian rupee and there was no concept of "deemed exports" in section 1OB of the Act. Learned CIT(A), accepted the claim

M/S INTERNATIONAL STONE INDIA PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

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

ITA 539/BANG/2014[2009-10]Status: DisposedITAT Bangalore20 Jan 2016AY 2009-10

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Rao

For Appellant: Shri C. Ramesh, CAFor Respondent: Dr. P.K. Srihari, Addl. CIT(DR)
Section 10BSection 143(1)Section 143(3)

disallowed this claim for a reason that exports were effected by the merchant exporters, who alone had received the foreign exchange. AO also noted that assessee had received the consideration for sale from such merchant exporters only in Indian rupee and there was no concept of "deemed exports" in section 1OB of the Act. Learned CIT(A), accepted the claim

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

ITA 517/BANG/2015[2010-11]Status: DisposedITAT Bangalore01 Apr 2021AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri Muzaffar Hussain, CIT (DR)For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143Section 144CSection 144C(13)Section 194JSection 40Section 9(1)(iv)

disallowance by the Ld. AO under section 10A regarding the voluntary income offered by assessee for computing the transfer pricing adjustment. 39. On one hand, it is the assessee’s contention that provisions of section 92(4) will not be applicable in this case as the transfer Page 24 of 55 IT(TP)A No.517 & 570/Bang/2015 pricing adjustment has been

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

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

disallowance made under section 10AA of the Act ignoring that since no new master service agreement was made, the benefit of claim u/s 10AA from the old SEZ cannot be allowed. 5. The CIT(A) erred in remitting the matter to assessing officer on issue relating to section 80G of the Act ignoring that in instant case assessee

ASST.C.I.T., BELLARY vs. M/S HOTHUR TRADERS 100% EOU, BELLARY

In the result, Revenue’s appeals for asst

ITA 32/BANG/2016[2011-12]Status: DisposedITAT Bangalore19 Jan 2018AY 2011-12

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazita No.32/Bang/2016 (Asst. Years 2010-11 & 2011-12) The Asst. Commissioner Of Income-Tax, Circle-1, Bellary. . Appellant Vs. M/S Hothur Traders 100% Eou, No.85,6,7&8, Infantry Road, Cantonment, Bellary. . Respondent Pan –Aaefh7705H. Co No.55/Bang/2016 (By Assessee) Appellant By : Shri Nagendra Prasad, Cit Respondent By : Shri B.S Balachandran, Advocate Date Of Hearing : 22-11-2017 Date Of Pronouncement : 19-01-2018

For Appellant: Shri Nagendra Prasad, CITFor Respondent: Shri B.S Balachandran, Advocate
Section 10ASection 10BSection 143(3)Section 40

10B of I.T. Act for claiming exemption under the said section. The CIT(Appeals) ought to have appreciated the facts that the assessee has failed to fulfill the conditions as laid down In Section 10A/10B of IT. Act, which ultra vires of the Income-Tax Act. 4. For these and other grounds that may be urged at the time

M/S K. MOHAN & COMPANY (EXPORTS) PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

In the result, ITA 1057/B/12 is partly allowed and ITA 1103/B/12 is dismissed

ITA 1057/BANG/2012[2008-09]Status: DisposedITAT Bangalore24 Apr 2015AY 2008-09

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

For Appellant: Shri V. Srinivasan, C.AFor Respondent: Shri P. Dhivahar, Jt. CIT(DR)
Section 10BSection 10B(3)

4. Without prejudice, the CIT(Appeals) ought to have appreciated that the requirement of Section 10B was not the income derived from export of goods or merchandise as concluded by the assessing officer and the same being contrary to the requirement of Section 10B, ought to have sustained the disallowance

ACIT, BANGALORE vs. M/S K. MOHAN & COMPANY (EXPORTS) PVT. LTD.,, BANGALORE

In the result, ITA 1057/B/12 is partly allowed and ITA 1103/B/12 is dismissed

ITA 1103/BANG/2012[2008-09]Status: DisposedITAT Bangalore24 Apr 2015AY 2008-09

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

For Appellant: Shri V. Srinivasan, C.AFor Respondent: Shri P. Dhivahar, Jt. CIT(DR)
Section 10BSection 10B(3)

4. Without prejudice, the CIT(Appeals) ought to have appreciated that the requirement of Section 10B was not the income derived from export of goods or merchandise as concluded by the assessing officer and the same being contrary to the requirement of Section 10B, ought to have sustained the disallowance

M/S. K. MOHAN & COMPANY (EXPORTS) PVT. LTD.,,BANGALORE vs. ACIT, BANGALORE

In the result, ITA 1057/B/12 is partly allowed and ITA 1103/B/12 is dismissed

ITA 1266/BANG/2010[2007-08]Status: DisposedITAT Bangalore24 Apr 2015AY 2007-08

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

For Appellant: Shri V. Srinivasan, C.AFor Respondent: Shri P. Dhivahar, Jt. CIT(DR)
Section 10BSection 10B(3)

4. Without prejudice, the CIT(Appeals) ought to have appreciated that the requirement of Section 10B was not the income derived from export of goods or merchandise as concluded by the assessing officer and the same being contrary to the requirement of Section 10B, ought to have sustained the disallowance

M/S K. MOHAN & COMPNAY (EXPORTS) PVT. LTD.,,BANGALORE vs. ACIT, BANGALORE

In the result, ITA 1057/B/12 is partly allowed and ITA 1103/B/12 is dismissed

ITA 1093/BANG/2009[2006-07]Status: DisposedITAT Bangalore24 Apr 2015AY 2006-07

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

For Appellant: Shri V. Srinivasan, C.AFor Respondent: Shri P. Dhivahar, Jt. CIT(DR)
Section 10BSection 10B(3)

4. Without prejudice, the CIT(Appeals) ought to have appreciated that the requirement of Section 10B was not the income derived from export of goods or merchandise as concluded by the assessing officer and the same being contrary to the requirement of Section 10B, ought to have sustained the disallowance

GE MEDICAL SYSTEMS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 332/BANG/2011[2004-05]Status: DisposedITAT Bangalore30 Jun 2015AY 2004-05

Bench: Smt. P. Madhavi Devi & Shri Abraham P George

For Appellant: Shri K.R.Vasudevan, AdvocateFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 10ASection 143(3)Section 92C

section 10B(4) of the Act. ” 16. We find that the co-ordinate bench of the Tribunal in the case of GE BE Pvt. Ltd., has considered the decision of the Special Bench in coming to the conclusion that the Tribunal’s order in the assessee’s own case for assessment year 2002-03 is not applicable for the assessment

GE MEDICAL SYSTEMS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 333/BANG/2011[2005-06]Status: DisposedITAT Bangalore30 Jun 2015AY 2005-06

Bench: Smt. P. Madhavi Devi & Shri Abraham P George

For Appellant: Shri K.R.Vasudevan, AdvocateFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 10ASection 143(3)Section 92C

section 10B(4) of the Act. ” 16. We find that the co-ordinate bench of the Tribunal in the case of GE BE Pvt. Ltd., has considered the decision of the Special Bench in coming to the conclusion that the Tribunal’s order in the assessee’s own case for assessment year 2002-03 is not applicable for the assessment