DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

disallowance under Section 14A was permissible. The cross objections challenging the reopening of assessment were dismissed.", "result": "Allowed", "sections": [ "Section 14A", "Rule 8D", "Section 132", "Section 148", "Section 153A", "Section 143(3)", "Section 154", "Section 234B", "Section 234D", "Section 32(1)(iia)", "Section 2(29A)", "Section 147

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

disallowance under section 14A can be made, citing a High Court ruling. The Tribunal also addressed issues related to additional depreciation and the scope of section 153A in cases of search.", "result": "Allowed", "sections": [ "14A", "8D", "132", "148", "153A", "143(3)", "154", "234B", "234D", "32(1)(iia)", "2(29A)", "147

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

disallowance under Section 14A was permissible. The reopening of assessment grounds were dismissed based on a jurisdictional High Court decision. Regarding additional depreciation, the conversion of raw coffee beans to liquid coffee was considered a manufacturing activity, allowing for additional depreciation.", "result": "Allowed/Dismissed", "sections": ["14A", "32(1)(iia)", "143(3)", "147

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

section 147 of the Act\nas there was escapement of income due to wrong claim of\ndisallowance u/s 14A of the Act.\n10. We have heard the rival submissions and perused the\nmaterials available on record. The main contention of the ld. A.R. is\nthat the ld. AO made disallowance

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY GLOBAL LIMITED, BANGALORE

In the result, all the COs by assessee in CO\nNos

sections": [ "14A", "Rule 8D", "143(3)", "147", "148", "153A", "234B", "234D", "32(1)(iia)" ], "issues": "Whether disallowance under Section 14A is permissible

DEPUTY COMMISSIONER OF INCOME-TAX, , BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 147 of the Act as there was escapement of income due to wrong claim of disallowance u/s 14A of the Act. 10. We have

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY ENTERPRISES, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 147 of the Act as there was escapement of income due to wrong claim of disallowance u/s 14A of the Act. 10. We have

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BANGALORE

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 147 of the Act as there was escapement of income due to wrong claim of disallowance u/s 14A of the Act. 10. We have

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 147 of the Act as there was escapement of income due to wrong claim of disallowance u/s 14A of the Act. 10. We have

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

section 147 of the Act\nas there was escapement of income due to wrong claim of\ndisallowance u/s 14A of the Act.\n10.\nWe have heard the rival submissions and perused the\nmaterials available on record. The main contention of the ld. A.R. is\nthat the ld. AO made disallowance

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

section 147 of the Act\nas there was escapement of income due to wrong claim of\ndisallowance u/s 14A of the Act.\n10. We have heard the rival submissions and perused the\nmaterials available on record. The main contention of the ld. A.R. is\nthat the ld. AO made disallowance

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, the appeals filed by the assessee for all the four A

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER\nAND\nSHRI SOUNDARARAJAN K. (Judicial Member)

disallowance made by the Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n Assessment Years 2018-19 to 2020-21:\n1.\nIt is submitted that the Assessee's Appeal in ITA Nos.645

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

disallowance made by the Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n Assessment Years 2018-19 to 2020-21:\n1.\nIt is submitted that the Assessee's Appeal

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, all the appeals filed by the assessee are allowed

disallowance made by the Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n\n Assessment Years 2018-19 to 2020-21:\n\n1.\nIt is submitted that the Assessee's Appeal

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Disallowance under section 40(a)(ia) of the Act for short deduction of tax — Rs. 17,562,147 a) The Ld. AO has erred

M/S. TOYOTA KIRLOSKAR MOTOR PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, , BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2011-12 M/S. Toyota Kirloskar Motor Pvt. Ltd. Plot No.1, Bidadi Industrial Area So Bidadi Acit Vs. Ramanagar Ltu, Circle-1 Bengaluru 562 109 Banalore Pan No : Aaact5415B Appellant Respondent Appellant By : Sri Padam Chand Kincha, A.R. Respondent By : Smt. Kumutha D., D.R. Date Of Hearing : 24.09.2024 Date Of Pronouncement : 20.12.2024

section 147 of the Act. Ground relating to Corporate Tax 4. The learned CIT(A) has erred in confirming the action of the AO in: a. Disallowing

EUROFINS PEENYA RESOURCES PRIVATE LIMITED (FORMERLY KNOWN AS EUROFINS ADVINUS LIMITED) ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1) , BANGALORE

In the result, the appeal for AY 2013-14 is partly allowed

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadav

disallowance made vide the order under section 143(3) were settled under the Direct Tax Vivad se Vishwas Act, 2020. The learned assessing officer has erred in reopening assessment under section 147

M/S. EUROFINS PEENYA RESOURCES PRIVATE LIMITED(FORMERLY KNOW AS EUROFINS ADVINUS LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal for AY 2013-14 is partly allowed

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadav

disallowance made vide the order under section 143(3) were settled under the Direct Tax Vivad se Vishwas Act, 2020. The learned assessing officer has erred in reopening assessment under section 147