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3,268 results for “disallowance”+ Section 11(1)(c)clear

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Mumbai10,035Delhi8,481Bangalore3,268Chennai2,702Kolkata2,612Ahmedabad2,056Pune1,430Jaipur1,376Hyderabad1,118Chandigarh798Indore682Surat587Cochin438Raipur431Visakhapatnam373Amritsar333Rajkot299Karnataka299Cuttack285Lucknow220Nagpur216Panaji150Agra136Jodhpur129Guwahati113SC98Telangana85Allahabad84Ranchi73Calcutta68Dehradun58Kerala43Patna36Varanasi36Jabalpur27Punjab & Haryana12Rajasthan8Orissa7Himachal Pradesh6A.K. SIKRI ROHINTON FALI NARIMAN4A.K. SIKRI N.V. RAMANA1ANIL R. DAVE AMITAVA ROY L. NAGESWARA RAO1ASHOK BHAN DALVEER BHANDARI1RANJAN GOGOI PRAFULLA C. PANT1H.L. DATTU S.A. BOBDE1Gauhati1Uttarakhand1Andhra Pradesh1

Key Topics

Section 143(3)76Addition to Income58Disallowance47Section 153A43Deduction39Section 10A35Section 25027Section 143(2)25Section 80P(2)(a)21

ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

ITA 290/BANG/2024[2017-18]Status: DisposedITAT Bangalore03 Dec 2024AY 2017-18

Bench: Shri George George K & Shri Waseem Ahmed

For Appellant: Shri Narendra Kumar Jain, AdvocateFor Respondent: Shri D.K Mishra, CIT (DR)
Section 1Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)

1)(c) of the Act had been violated, as the assessee trust had extended benefits to specified persons. Consequently, the AO denied the exemption claimed by the assessee under Section 11 of the Act and computed the assessee’s income in accordance with the normal provisions applicable to an assessee. Furthermore, while computing the assessee’s income, the AO disallowed

Showing 1–20 of 3,268 · Page 1 of 164

...
Section 4019
Section 139(1)19
Penalty14

ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

ITA 291/BANG/2024[2018-19]Status: DisposedITAT Bangalore03 Dec 2024AY 2018-19

Bench: Shri George George K & Shri Waseem Ahmed

For Appellant: Shri Narendra Kumar Jain, AdvocateFor Respondent: Shri D.K Mishra, CIT (DR)
Section 1Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)

1)(c) of the Act had been violated, as the assessee trust had extended benefits to specified persons. Consequently, the AO denied the exemption claimed by the assessee under Section 11 of the Act and computed the assessee’s income in accordance with the normal provisions applicable to an assessee. Furthermore, while computing the assessee’s income, the AO disallowed

M/S. GARUDA SECURITY SERVICES,BANGALORE vs. ITO, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee are dismissed

ITA 1051/BANG/2022[2018-19]Status: DisposedITAT Bangalore15 Dec 2022AY 2018-19

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1051 & 1052/Bang/2022 Assessment Year: 2018-19 & 2019-20

For Appellant: Shri Raghavendra Chakravarthy, A.RFor Respondent: Smt. Priyadarshini Besaganni, D.R
Section 143(1)Section 154Section 36Section 36(1)(va)

c) A claim made/ backed by judicial pronouncements as on the date of filing return was correct and legal cannot be brought within the purview of adjustments u/s 143(1) of the Act. However, it may be noted that even on the date of making a claim as is in the present case, it was a settled law which again

M/S. GARUDA SECURITY SERVICES,BANGALORE vs. ITO, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee are dismissed

ITA 1052/BANG/2022[2019-20]Status: DisposedITAT Bangalore15 Dec 2022AY 2019-20

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1051 & 1052/Bang/2022 Assessment Year: 2018-19 & 2019-20

For Appellant: Shri Raghavendra Chakravarthy, A.RFor Respondent: Smt. Priyadarshini Besaganni, D.R
Section 143(1)Section 154Section 36Section 36(1)(va)

c) A claim made/ backed by judicial pronouncements as on the date of filing return was correct and legal cannot be brought within the purview of adjustments u/s 143(1) of the Act. However, it may be noted that even on the date of making a claim as is in the present case, it was a settled law which again

DODDABALLAPUR PLANNING AUTHORITY,BANGALORE vs. ITO, EXEMPTION, WARD-3, BANGALORE

In the result appeal of the assessee is hereby dismissed

ITA 2115/BANG/2024[2019-20]Status: DisposedITAT Bangalore25 Jun 2025AY 2019-20

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Appellant: Sri Dinesh Kumar Joshi, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 11Section 11(1)Section 11(1)(d)Section 12ASection 143(1)Section 250

disallowed as the appellant assessee failed to file Form 9A within the due date. (ii) Section 11(1) explicitly mandates the filing of Form 9A for the accumulation of income for the charitable purpose to ensure transparency and accountability in the utilization of fund for charitable activities. ITA Nos.2115 & 2116/Bang/2024 Doddaballapur Planning Authority, Doddaballapur Page

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)

11(vii) relating to allowance of the bad debt(s). In other words, the scheduled commercial banks continue to get the full benefit of the write off of the irrecoverable debt(s) under Section 36(1)(vii) in addition to the benefit of deduction for the provision made for bad and doubtful debt(s) under section 36(1)(viia

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)

11(vii) relating to allowance of the bad debt(s). In other words, the scheduled commercial banks continue to get the full benefit of the write off of the irrecoverable debt(s) under Section 36(1)(vii) in addition to the benefit of deduction for the provision made for bad and doubtful debt(s) under section 36(1)(viia

M/S. MOBILY INFOTECH INDIA PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD-4(1)(3), BANGALORE

In the result, the appeal by the assessee is allowed

ITA 313/BANG/2022[2017-18]Status: FixedITAT Bangalore07 Jul 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2016-17

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sankarganesh K. Jt.CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 36(1)(iii)Section 40

c) assuming without admitting that the impugned interest expenditure is disallowed under section 40(a)(ia) in AY 2016-17, the same should be allowed as a deduction in AY 2017-18. Page 5 of 17 3.3 On facts and in circumstance of the case and law applicable, the disallowance under section 40(a)(ia) should be deleted

M/S. HICAL INFRA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (OSD), RANGE- 1, BANGALORE

In the result, the appeal by the assessee is allowed

ITA 313/BANG/2020[2016-17]Status: DisposedITAT Bangalore07 Jul 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2016-17

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sankarganesh K. Jt.CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 36(1)(iii)Section 40

c) assuming without admitting that the impugned interest expenditure is disallowed under section 40(a)(ia) in AY 2016-17, the same should be allowed as a deduction in AY 2017-18. Page 5 of 17 3.3 On facts and in circumstance of the case and law applicable, the disallowance under section 40(a)(ia) should be deleted

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)

11 of 46 provision made for bad and doubtful debt(s) under section 36(1)(viia). A reading of the Circulars issued by CBDT indicates that normally a deduction for bad debt(s) can be allowed only if the debt is written off in the books as bad debt(s). No deduction is allowable in respect of a mere provision

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)

11 of 46 provision made for bad and doubtful debt(s) under section 36(1)(viia). A reading of the Circulars issued by CBDT indicates that normally a deduction for bad debt(s) can be allowed only if the debt is written off in the books as bad debt(s). No deduction is allowable in respect of a mere provision

SHRI. MUNINAGA REDDY,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal for A

ITA 859/BANG/2012[2006-07]Status: DisposedITAT Bangalore12 Jan 2015AY 2006-07

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

For Appellant: Shri P. Dinesh, AdvocateFor Respondent: Dr. P.K. Srihari, Addl. CIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 54BSection 80C

disallowed these claims which resulted in addition to the assessee's income. The Assessing Officer simultaneously initiated penalty proceedings u/s. 271(1)(c) of the Act and proceeded to levy penalty on the assessee thereunder. 8.3 On appeal, the learned CIT (Appeals) confirmed the levy of penalty. 8.4 Before us, it was contended that the assessee was under the bona

M/S. NIRMAL ENVIRO SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

ITA 1154/BANG/2022[2019-20]Status: DisposedITAT Bangalore18 Jan 2023AY 2019-20

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

For Appellant: Miss Sunaiana Bhatia, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 139(1)Section 143Section 143(1)Section 234ASection 36Section 36(1)(va)

C of the Act, as computed in the intimation u/s.143[1] of the Act, which under the facts and Nirmal Enviro Solutions P. Ltd. in the circumstances of the appellant's case deserves to be cancelled. 6. For the above and other grounds that may be urged at the time of hearing of the appeal, your appellant humbly prays that

SRI PANATI VIDYANATH REDDY ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

ITA 1148/BANG/2022[2019-20]Status: DisposedITAT Bangalore18 Jan 2023AY 2019-20

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

For Appellant: Miss Sunaiana Bhatia, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 139(1)Section 143Section 143(1)Section 234ASection 36Section 36(1)(va)

C of the Act, as computed in the intimation u/s.143[1] of the Act, which under the facts and Nirmal Enviro Solutions P. Ltd. in the circumstances of the appellant's case deserves to be cancelled. 6. For the above and other grounds that may be urged at the time of hearing of the appeal, your appellant humbly prays that

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

c) Disallowance made u/ 36(1)(viia) 4. The first issue relates to the disallowance of depreciation claimed on Investments held to Maturity. The AO noticed that the assessee has revalued the investments held to maturity as at the yearend and the fall in the value was claimed as depreciation in their value amounting to Rs.436.81 crores as deduction

SRI SRINIVASA TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

ITA 1076/BANG/2024[2021-2022]Status: DisposedITAT Bangalore18 Feb 2025AY 2021-2022

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Siva Prasad Reddy & Shri BalachandranFor Respondent: Ms. Nandini Das, CIT (DR)
Section 11Section 11(1)Section 11(1)(a)Section 12ASection 2(45)Section 80G

c) The statement referred to in clause (a) is furnished at least two months prior to the due date specified under sub-section (1) of section 139 for furnishing the return of income for the previous year. 23.3 It is clear that there are three conditions. The authorities below have not doubted the condition of furnishing the documents i.e. intimation

SRI SRINIVASA TRUST,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

ITA 1075/BANG/2024[2020-21]Status: DisposedITAT Bangalore18 Feb 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Siva Prasad Reddy & Shri BalachandranFor Respondent: Ms. Nandini Das, CIT (DR)
Section 11Section 11(1)Section 11(1)(a)Section 12ASection 2(45)Section 80G

c) The statement referred to in clause (a) is furnished at least two months prior to the due date specified under sub-section (1) of section 139 for furnishing the return of income for the previous year. 23.3 It is clear that there are three conditions. The authorities below have not doubted the condition of furnishing the documents i.e. intimation

MASS FAB TECHNOLOGIES,BANGALORE vs. CIT(APPEALS), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

ITA 1079/BANG/2022[2019-20]Status: DisposedITAT Bangalore28 Dec 2022AY 2019-20

Bench: Shri Chandra Poojariassessment Year: 2020-21

For Appellant: Shri S.V. Ravishankar, A.RFor Respondent: Shri Ganesh R. Gale, Standing Counsel for Department
Section 139(1)Section 143(1)Section 244ASection 250Section 36(1)(va)

11 of 20` 5. We are conscious of the fact that the issue on merits is decided against the assessee by the recent decision of the Hon’ble Supreme Court in the case of Checkmate Services Pvt Ltd vs CIT reported in 143 taxmann.com 178 (SC) dated 12/10/2022. This decision was rendered in the context where assessment was framed under

ITEK PACKZ,BANGALORE vs. INCOME TAX OFFICER, WARD-3(2)(4), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

ITA 995/BANG/2022[2020-21]Status: DisposedITAT Bangalore28 Dec 2022AY 2020-21

Bench: Shri Chandra Poojariassessment Year: 2020-21

For Appellant: Shri S.V. Ravishankar, A.RFor Respondent: Shri Ganesh R. Gale, Standing Counsel for Department
Section 139(1)Section 143(1)Section 244ASection 250Section 36(1)(va)

11 of 20` 5. We are conscious of the fact that the issue on merits is decided against the assessee by the recent decision of the Hon’ble Supreme Court in the case of Checkmate Services Pvt Ltd vs CIT reported in 143 taxmann.com 178 (SC) dated 12/10/2022. This decision was rendered in the context where assessment was framed under

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

ITA 294/BANG/2023[2018-19]Status: DisposedITAT Bangalore01 Jun 2023AY 2018-19

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Sandeep Chalapathy, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 139(1)Section 143(1)(a)Section 250Section 36(1)(va)Section 43BSection 44A

11. In a result, this appeal is allowed” 5. We are conscious of the fact that the issue on merits is decided against the assessee by the recent decision of the Hon’ble Supreme Court in the case of Checkmate Services Pvt Ltd vs CIT reported in 143 taxmann.com 178 (SC) dated 12/10/2022. This decision was rendered in the context