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546 results for “disallowance”+ Section 144Cclear

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Key Topics

Section 143(3)111Transfer Pricing70Addition to Income70Section 92C68Comparables/TP51Disallowance44Section 14A32Section 10A29Deduction26

M/S. ACER INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, both the appeals of the assessee are partly allowed

ITA 502/BANG/2017[2012-13]Status: DisposedITAT Bangalore10 May 2019AY 2012-13

Bench: Shri B.R Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri Ajay Vohra, Sr. Advocate & Shri Niranjan, AdvocateFor Respondent: Dr. Pradeep Kumar, CIT (DR)
Section 143(3)Section 144C(13)Section 153Section 234BSection 271(1)(c)Section 40

Section 144C(13) gives extension of further period of one month from the date of receipt of direction from the DRP. In view of the above, the date of receipt of direction of DRP by the Assessing Officer becomes crucial......” 8. We notice that various benches of Tribunal are taking the view that the provisions of sec.144C(13) give extension

Showing 1–20 of 546 · Page 1 of 28

...
Section 4024
Section 26320
Section 143(2)19

YOKOGAWA INDIA LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, the appeal is allowed

ITA 1715/BANG/2016[2012-13]Status: DisposedITAT Bangalore11 Mar 2021AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Nageshwar Rao, AOvocateFor Respondent: Shri Pradeep Kumar, CIT (DR)
Section 143Section 144Section 234BSection 253

disallowance made under section 37(1) of the Act. 6. Upon receipt of the DRP directions, the Ld.AO failed to follow the directions in computing the transfer pricing adjustment, as well as the corporate tax additions. Instead of passing the final assessment as required by law, the Ld.AO passed impugned order dated 28/01/2016 identical to the draft assessment order passed

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. GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

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

ITA 2355/BANG/2019[2015-16]Status: DisposedITAT Bangalore15 Jun 2020AY 2015-16

Bench: Shri A.K. Garodia & Shri Pavan Kumar Gadaleit(Tp)A No.2355/Bang/2019 (Assessment Year: 2015-16) M/S. Goldman Sachs Services Pvt. Ltd., Wing A, B & C, Helios Business Park, 150, Orr, Kadubeesanahalli, Bangalore-560103 ….Appellant Pan Aaccg 2435N Vs. Joint Commissioner Of Income Tax, Special Range 3, Bangalore. ……Respondent.

For Appellant: Shri Sharath Rao, C.AFor Respondent: Ms. Neera Malhotra, CIT (D.R)
Section 143(3)Section 144CSection 144C(5)Section 92CSection 92C(3)

Section 143(3) r.w.s. 144C dt.24.12.2018, with Transfer Pricing Adjustment of Rs.171,04,84,800/- and disallowance under Section 14A of the Act of Rs.1

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

ITA 2846/BANG/2017[2013-14]Status: DisposedITAT Bangalore07 Aug 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 133(6)Section 143(3)Section 144CSection 144C(5)Section 92C(3)

144C(5). On the facts and in the circumstances of the case and in law, the Ld. c) Panel and Ld. AO/ Ld. TPO erred in not demonstrating that the motive of the Appellant was to shift profits outside India by manipulating the prices charged in the international transaction, which is a pre- requisite condition to make any adjustment under

M/S VOLVO INDIA PVT. LTD. vs. ACIT, BANGALORE

In the result, appeal of the Assessee is partly allowed

ITA 1537/BANG/2012[2008-09]Status: DisposedITAT Bangalore08 May 2019AY 2008-09

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

For Appellant: Shri Ajay Vohra, Sr. Advocate &For Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 139Section 143Section 143(3)Section 144Section 153(1)Section 18

144C gives a complete go bye to section 153; and (ii) The Act does not contemplate any limitation for passing of draft assessment order, which can be passed within a reasonable time. 14. Though arguments were advanced that the aforesaid decision does not lay down the correct law, we are of the view that a co-ordinate Bench decision

M/S ALTISOURCE BUSINESS SOLUTIONS PVT. LTD.,,BANGALORE vs. ACIT, BANGALORE

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

ITA 208/BANG/2016[2011-12]Status: DisposedITAT Bangalore02 Jul 2021AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.208/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Shri Shishir Srivastava, CIT
Section 143Section 144C(13)Section 144C(5)Section 92C

144C(13) of the Act, for assessment year 2011-12 on following grounds of appeal: The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer ("learned TPO") and the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 15,17,38,598/- of the Appellant's international transactions with its Associated Enterprises

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

ITA 1539/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore09 May 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 234ASection 270A

disallowance of Rs. 5,13,01,761/- for gratuity under section 43B of the Act was made in the . IT(TP)A No.1539/Bang/2024 Page 23 of 37 intimation under section 143(1) of the Act and was not a variation proposed by the AO in the draft assessment order passed under section 144C

ASTRAZENECA PHARMA INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BANGALORE

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

ITA 460/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Smt. Beena Pillai & Ms. Padmavathy S.It(Tp)A No. 460/Bang/2016 (Assessment Year: 2011-12)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 144C(11)

disallowance considering the provisions of Section 144C(8) of the Act and sustained the disallowance. Since the AO has not verified

DCIT, BANGALORE vs. M/S ASTRA ZENCA PHARMA INDIA LTD.,, BANGALORE

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

ITA 446/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Smt. Beena Pillai & Ms. Padmavathy S.It(Tp)A No. 460/Bang/2016 (Assessment Year: 2011-12)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 144C(11)

disallowance considering the provisions of Section 144C(8) of the Act and sustained the disallowance. Since the AO has not verified

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)

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 and 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

NDS LIMITED - INDIA BRANCH OFFICE,BANGALORE vs. DDIT INTERNATIONAL TAXATION, BANGALORE

In the result, the assessee's appeal for Assessment Year 2006-07 is partly allowed

ITA 1515/BANG/2010[2006-07]Status: DisposedITAT Bangalore20 Mar 2015AY 2006-07

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazi.T(T.P) A. No.1515/Bang/2010 (Assessment Year : 2006-07) Nds Limited – India Branch Office, Vs. Dy. Director Of Income Tax, No.9, Ashford Park View, (International Taxation), 80 Ft Road, Koramangala Iii Block, Circle 1 (1), Bangalore. Bangalore-560 034 Pan Aabcn 2524L Appellant Respondent.

For Appellant: Smt. Shreya Loyalka, C.AFor Respondent: Shri C.H. Sundar Rao, CIT (D.R)
Section 10ASection 143(1)Section 143(3)Section 144CSection 144C(5)Section 92C

Section 143(3) rws 144C(5) & 144C(8) of the Act wherein the income of the assessee was determined at Rs.6,11,40,278 in view of – (i) T.P. Adjustment u/s.92CA : Rs.5,65,66,531. and (ii) Disallowance

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

ITA 298/BANG/2021[2016-17]Status: DisposedITAT Bangalore24 Apr 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri Madhur Agarwal, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 144C(10)Section 92CSection 92C(3)

144C(13) of the Act and hence liable to be quashed. IT(TP)A No.298/Bang/2024 Goldman Sachs Services Pvt. Ltd., Bangalore Page 2 of 14 1.2 Complete effect not given to the DRP's direction 1.2.1 The learned AO has made the following apparent error while giving effect of the order of the Hon'ble DRP: • The learned AO/TPO erred

IBM INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal by the assessee stands allowed as indicated hereinabove

ITA 289/BANG/2021[2015-16]Status: DisposedITAT Bangalore14 Feb 2022AY 2015-16

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 289/Bang/2021 Assessment Year : 2015-16 M/S. Ibm India Pvt. Ltd., The Deputy No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 12-01-2022 Date Of Pronouncement : 14-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Final Assessment Order Dated 30.04.2021 U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Act Passed By The National Faceless Assessment Centre, Delhi Relating To Assessment Year 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Assessment Order Bad In Law 1.1. At The Outset, M/S Ibm India Private Limited (Hereinafter Referred To As 'The Appellant' Or 'The Company') Prays That The Order Dated April 30. 2021

For Appellant: Shri Ajay Roti, CAFor Respondent: Shri Pradeep Kumar, CIT DR
Section 10ASection 143(3)Section 144BSection 144C(13)

144C(13) read with section 144B of the Income-tax Act. 1961 ('the Act'), by the National e-Assessment Centre ('the NeAC'), be struck down as invalid, as the order is bad in law and on facts. 1.2. The Hon'ble Dispute Resolution Panel ('ORP') has erred in completing the proceedings in undue haste and in violation of the principles

M/S SAP LABS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 561/BANG/2015[2010-11]Status: DisposedITAT Bangalore28 Jul 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 561/Bang/2015 Assessment Year : 2010-11 M/S. Sap Labs India Pvt. Ltd., The Deputy No. 138, Export Promotion Commissioner Of Industrial Park, Income Tax, Whitefield, Circle – 6 (1)(1), Bangalore – 560 066. Bangalore. Vs. Pan: Aafcs3649P Appellant Respondent & It(Tp)A No. 437/Bang/2015 (By Revenue) : Shri Aliasgar Rampurawala, Assessee By Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 20-06-2022 Date Of Pronouncement : 28-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee As Well As Revenue Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Consolidated Grounds Of Appeal. Assessee’S Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another.

For Respondent: Shri Arun Kumar, CIT DR
Section 92D

disallowing deduction under section 8oJJAA of the Act amounting to INR 13,07,42,470/-. The learned AO and the learned Panel failed to appreciate the fact that deduction under section 8oJJAA of the Act is assessee specific and not undertaking / unit specific. (corresponding to revised ground no. 8 & original ground no. 8) 9. On the facts

D.C.I.T., BANGALORE vs. M/S SAP LABS INDIA PVT. LTD.,, BANGALORE

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

ITA 437/BANG/2015[2010-11]Status: DisposedITAT Bangalore28 Jul 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 561/Bang/2015 Assessment Year : 2010-11 M/S. Sap Labs India Pvt. Ltd., The Deputy No. 138, Export Promotion Commissioner Of Industrial Park, Income Tax, Whitefield, Circle – 6 (1)(1), Bangalore – 560 066. Bangalore. Vs. Pan: Aafcs3649P Appellant Respondent & It(Tp)A No. 437/Bang/2015 (By Revenue) : Shri Aliasgar Rampurawala, Assessee By Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 20-06-2022 Date Of Pronouncement : 28-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee As Well As Revenue Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Consolidated Grounds Of Appeal. Assessee’S Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another.

For Respondent: Shri Arun Kumar, CIT DR
Section 92D

disallowing deduction under section 8oJJAA of the Act amounting to INR 13,07,42,470/-. The learned AO and the learned Panel failed to appreciate the fact that deduction under section 8oJJAA of the Act is assessee specific and not undertaking / unit specific. (corresponding to revised ground no. 8 & original ground no. 8) 9. On the facts

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

ITA 725/BANG/2018[2013-14]Status: DisposedITAT Bangalore31 Jul 2020AY 2013-14

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Percy Pardiwala, Sr. Advocate along with Ajay Roti, C.AFor Respondent: Shri K.V Arvind, Advocate
Section 10ASection 143Section 143(3)Section 144C(1)Section 92C

disallowance for non-deduction of tax at source as the corresponding amendment has not been made under section 40(a)(i) of the Act. 5.6. The Honble DRP has erred in law in directing the learned ACIT to carry out further verification which is not permissible in view of section 144C

ANALOG DEVICES INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 38/BANG/2015[2010-11]Status: DisposedITAT Bangalore14 Jun 2021AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.38/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: Shri Kannan Narayanan, JCIT
Section 250

144C of the Act on 11/04/2014 by making following additions in th ct on 11/04/2014 by making following additions in the hands ct on 11/04/2014 by making following additions in th of assessee: 9. Adjustment Adjustment Adjustment as as as per per per order order order under under under section section section 92CA: 92CA: 92CA: Rs.5,27,12,412/-; Disallowance

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)

144C(1) of the Act. In the draft assessment order so passed the Ld.AO:- • disallowed depreciation on computer software at Rs.7,46,162/- for non-deduction of TDS; • disallowed payments on which TDS was not deducted under section

PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 1(3), BENGALURU, BANGALORE

In the result the appeal of the assessee is allowed

ITA 311/BANG/2024[AY 2015-16]Status: DisposedITAT Bangalore20 Feb 2025

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)

For Appellant: Sri Padam Chand Khincha, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 143(2)Section 144Section 144C(10)Section 144C(5)Section 147Section 148Section 153

disallowances under section 14A and section 37 of the Act. It may be noted that the draft assessment order was passed post the date of condonation of delay in e-verification of the return. 3.9 The Assessee filed its objections with the Dispute Resolution Panel ('DRP') in Form 35A, as per section 144C