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193 results for “disallowance”+ Section 194C(6)clear

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Key Topics

Section 40137Section 143(3)69Disallowance66Addition to Income59Section 194C56Deduction53Section 20149TDS36Section 26334Section 40A(3)

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1), DAVANGERE vs. M/S MUURUGARAJENDRA OIL INDUSTRY PVT LTD , CHITRADURGA

In the result, appeal filed by the Revenue is dismissed

ITA 2094/BANG/2017[2012-13]Status: DisposedITAT Bangalore26 Apr 2019AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazassessment Year : 2012-13

For Appellant: Shri Pradeep Kumar, CITFor Respondent: Shri V. Srinivasan, Advocate
Section 194(6)Section 194(7)Section 194CSection 194C(6)Section 194C(7)Section 40

section 194C(6), disallowance under section 40(a)(ia) does not arise just because there is violation of provisions of section

Showing 1–20 of 193 · Page 1 of 10

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30
Transfer Pricing22
Comparables/TP22

SOUTH INDIA FREIGHT CARRIERS ,BANGALORE vs. THE INCOME TAX OFFICER WARD-3(2)(4), BANGALORE

In the result, the appeal of the assessee is allowed

ITA 2586/BANG/2018[2015-16]Status: DisposedITAT Bangalore27 Nov 2019AY 2015-16

Bench: Shri B.R Baskaran & Shri Pavan Kumar Gadaleassessment Years : 2015-16

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Sunil Kumar Agarwal, Addl. CIT
Section 194CSection 194C(6)Section 40Section 44A

6) are independent of section 194C(7), and just because there is violation of provisions of section 194C (7), disallowance

SRI. K R SANTHOSH KUMAR,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE- 3(2)(1), BANGALORE

In the result appeal filed by assessee stands allowed

ITA 20/BANG/2020[2013-14]Status: DisposedITAT Bangalore04 Dec 2020AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013 – 14

For Appellant: Shri S Ramsubramanian, C.AFor Respondent: Shri Elamurugu, JCIT (DR)
Section 143Section 194CSection 194C(6)Section 194C(7)Section 263Section 40Section 44A

disallowance of the same under section 40(a)(ia) of the Act. In response, assessee vide letter dated 19/07/2018 filed details of transportation to whom the pavements were made and declaration from such transporters under section 194C (6

SRI. SINGONAHALLI CHIKKAREVANNA GANGADHARAIAH,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(1), BENGALURU

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

ITA 785/BANG/2018[2014-15]Status: DisposedITAT Bangalore24 Feb 2020AY 2014-15

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri. Narendra Sharma, AdvocateFor Respondent: Ms.Neera Malhotra, CIT-DR
Section 194CSection 194C(3)Section 201Section 28Section 30Section 40

disallowance under section 40[a][ia] is not warranted under the facts and circumstances of the case. 6. Without prejudice the learned authorities below failed to appreciate that by virtue of the provisions of section 194C

M/S FINE BLANKING PVT. LTD.,,HUBLI vs. JCIT, HUBLI

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

ITA 393/BANG/2016[2012-13]Status: DisposedITAT Bangalore15 Feb 2019AY 2012-13

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year : 2012-13

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Dr. P.V. Pradeep Kumar, Addl.CIT(DR)(ITAT), Bengaluru

disallowance under section 40(a)(ia) is permissible, Page 10 of 10 even though there is violation of provisions of section 194C(7) - Held, yes - Whether since assessee had submitted PAN and addresses of transporters before Assessing Officer and thus complied with provisions of section 194C(6

M/S. SRI BALAJI PRASANNA TRAVELS,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 6(3)(1), BENGALURU

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

ITA 2078/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 Nov 2020AY 2015-16

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2015-16

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Priyadarshi Mishra, D.R
Section 143(2)Section 194Section 194CSection 194ISection 234ASection 40

disallowance made requires to be deleted. 5. On the other hand, Ld. D.R. submitted that assessee has paid the hire charges to the vehicle owners which falls under the purview of section 194C of the Act on which payment, assessee is liable to deduct TDS, which is not deducted by the assessee mainly the applicability of section

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)

194C to 194J so as to raise TDS demand again under section 201 and levy of interest under section 201(1A). Therefore, assessee's ground on this issue are to be allowed as the entire amount has been disallowed under the provisions of section 40(a)(i)/(ia) in the computation of income on the reason that

ASHOK IRAPPA BANNUR ,BAGALKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX , BELAGAVI

In the result appeal filed by assessee stands allowed

ITA 903/BANG/2019[2014-15]Status: DisposedITAT Bangalore29 Dec 2021AY 2014-15
For Respondent: Shri S.V. Ravishankar
Section 143(3)Section 194C(6)Section 263Section 4o

section 194C(6) and (7) of the Act, and in view of the above, the order of assessment was not erroneous, on the facts and circumstances of the case. 6. The learned CIT was not justified on facts, in appreciating that the details filed demonstrate that the information was available before the completion of the assessment proceedings and no disallowance

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIAVTE LIMITED ,BANGALORE vs. INCOME TAX OFFICER (TDS) /OSD LTU , BANGALORE

In the result, both the appeals filed by assessee stands allowed for statistical purposes

ITA 1690/BANG/2017[2013-14]Status: DisposedITAT Bangalore31 Jan 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Percy Padiwala, Sr
Section 201Section 201(1)Section 40

194C to 194J so as to raise TDS demand again under section 201 and levy of interest under section 201(1A). Therefore, assessee's ground on this issue are to be allowed as the entire amount has been disallowed under the provisions of section 40(a)(i)/(ia) in the computation of income on the reason that

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT LTD ,BANGALORE vs. INCOME TAX OFFICER (TDS) /OSD , BANGALORE

In the result, both the appeals filed by assessee stands allowed for statistical purposes

ITA 1689/BANG/2017[2012-13]Status: DisposedITAT Bangalore31 Jan 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Percy Padiwala, Sr
Section 201Section 201(1)Section 40

194C to 194J so as to raise TDS demand again under section 201 and levy of interest under section 201(1A). Therefore, assessee's ground on this issue are to be allowed as the entire amount has been disallowed under the provisions of section 40(a)(i)/(ia) in the computation of income on the reason that

DELL INDIA P LTD,BANGALORE vs. INCOME TAX OFFICER(TDS), LTU, BANGALORE

In the result the appeals filed by assessee and revenue for A

ITA 1644/BANG/2014[2012-13]Status: DisposedITAT Bangalore25 Mar 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

Section 201

194C to 194J so as to raise TDS demand again under section 201 and levy of interest under section 201(1A). Therefore, assessee's ground on this issue are to be allowed as the entire amount has been disallowed under the provisions of section 40(a)(i)/(ia) in the computation of income on the reason that

DELL INTERNATIONAL SERVICES INDIA PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result the appeals filed by assessee and revenue for A

ITA 1151/BANG/2015[2012-13]Status: DisposedITAT Bangalore25 Mar 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

Section 201

194C to 194J so as to raise TDS demand again under section 201 and levy of interest under section 201(1A). Therefore, assessee's ground on this issue are to be allowed as the entire amount has been disallowed under the provisions of section 40(a)(i)/(ia) in the computation of income on the reason that

INCOME TAX OFFICER, BANGALORE vs. M/S.DELL INDIA PVT.LTD.,, BANGALORE

In the result the appeals filed by assessee and revenue for A

ITA 2035/BANG/2016[2014-15]Status: DisposedITAT Bangalore25 Mar 2022AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

Section 201

194C to 194J so as to raise TDS demand again under section 201 and levy of interest under section 201(1A). Therefore, assessee's ground on this issue are to be allowed as the entire amount has been disallowed under the provisions of section 40(a)(i)/(ia) in the computation of income on the reason that

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1)(1), BENGALURU, BENGALURU vs. NUTRICRAFT INDIA PRIVATE LIMITED, BENGALURU

In the result appeal filed by the learned assessing officer is partly allowed for statistical purposes

ITA 298/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Muthu Shankar, CIT(DR)(ITAT), BengaluruFor Respondent: Smt. Suman Lunkar, CA
Section 143(3)Section 148ASection 153CSection 194C(6)Section 194C(7)Section 36(1)(ii)Section 40

section 194C(6) and 194C(7) are to be read together and thus after obtaining PAN from the transporters, the requisite particulars obtained from the transporters are furnished to the prescribed authority as provided u/s 194C(7), disallowance

M/S TIMES VPL LTD. vs. ADDL.C.I.T.,

In the result, the assessee's appeal for both assessment years 2008-09 and 2009-10 are partly allowed for statistical purposes

ITA 1193/BANG/2013[2008-09]Status: DisposedITAT Bangalore06 Feb 2015AY 2008-09

Bench: Shri Rajpal Yadav & Shri Jason P. Boaz

For Appellant: Shri Rajan Vora, C.AFor Respondent: Shri C.H. Sundar Rao, C.I.T (D.R)
Section 143(1)Section 143(3)Section 194CSection 40

6 (i) That the assessee is not liable to deduct tax at source under Section 194C of the Act in respect of its payments to BCCL. (ii) Section 40(a)(ia) of the Act cannot be invoked to disallow

JAYARAM REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

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

ITA 711/BANG/2025[2021-22]Status: DisposedITAT Bangalore09 Oct 2025AY 2021-22

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

section 194C of the Act. The grounds of appeal raised by the assessee on this issue are, therefore, dismissed. 51. The issue raised by the assessee though Ground Nos. 4 to 6 are interconnected challenging the disallowances

JAYARAMA REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), BENGALURU

In the result the appeal of the assessee is hereby partly allowed\nfor statistical purposes

ITA 706/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Oct 2025AY 2014-15
Section 132Section 132(4)Section 153A

section 194C of the Act. The grounds of appeal raised\nby the assessee on this issue are, therefore, dismissed.\n51. The issue raised by the assessee though Ground Nos.4 to 6 are\ninterconnected challenging the disallowances

A. KISORE RAO AND OTHERS vs. ITO,

In the result, the assessee's appeal for Assessment Year 2010-11 is allowed as indicated above

ITA 1737/BANG/2013[2010-11]Status: DisposedITAT Bangalore24 Jul 2015AY 2010-11
For Appellant: Shri K.K. Chythanya, AdvocateFor Respondent: Dr.P.K. Srihari, Addl. CIT (D.R.)
Section 139(1)Section 143(3)Section 201Section 40

6 of the judgment and/or order under challenge reads as follows : 7 “ In the present case before us the assessee has deducted tax under Section 194C(2) of the Act being payments made to sub-contractors and it is not a case of non-deduction of tax or no deduction of tax as is the import of section

JAYARAMA REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

In the result the appeal of the assessee is hereby partly allowed\nfor statistical purposes

ITA 709/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19
For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

section 194C of the Act. The grounds of appeal raised\nby the assessee on this issue are, therefore, dismissed.\n51.\nThe issue raised by the assessee though Ground Nos.4 to 6 are\ninterconnected challenging the disallowances

JAYARAMA REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRLCE-2(4), BENGALURU

ITA 705/BANG/2025[2013-14]Status: DisposedITAT Bangalore09 Oct 2025AY 2013-14
Section 132Section 132(4)Section 153A

section 194C of the Act. The grounds of appeal raised\nby the assessee on this issue are, therefore, dismissed.\n51.\nThe issue raised by the assessee though Ground Nos.4 to 6 are\ninterconnected challenging the disallowances