MICROFINISH VALVES PVT LTD,HUBLI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HUBLI

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

Bench: Shri N.V. Vasudevan & Shri Inturi Rama Raoassessment Year : 2012-13

section 2(22)(e) is to tax dividend in the hands of shareholder. The deeming provisions as it applies to the case of loans or advances by a company to a concern in which it’s shareholder has substantial interest, is based on the presumption that the loan or advances would ultimately be made available to the shareholders

BRIGADE ENTERPRISES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), , BANGALORE

In the result, the assessee’s appeals for assessment years 2008-09 to 2010-11 are partly allowed for statistical purposes

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

E R Per Jason P Boaz, Accountant Member These three appeals by the assessee are directed against the separate orders of CIT(A)-1, Bangalore, for Assessment Years 2008-09 to 2010-11. Since common issues are involved, these appeals were heard together and we ITA Nos.528 to 530/Bang/2018 Page 2 of 22 deem it appropriate to dispose them

BRIGADE ENTERPRISES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), BANGALORE

In the result, the assessee’s appeals for assessment years 2008-09 to 2010-11 are partly allowed for statistical purposes

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

E R Per Jason P Boaz, Accountant Member These three appeals by the assessee are directed against the separate orders of CIT(A)-1, Bangalore, for Assessment Years 2008-09 to 2010-11. Since common issues are involved, these appeals were heard together and we ITA Nos.528 to 530/Bang/2018 Page 2 of 22 deem it appropriate to dispose them

M/S BRIGADE ENTERPRISES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), BANGALORE

In the result, the assessee’s appeals for assessment years 2008-09 to 2010-11 are partly allowed for statistical purposes

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

E R Per Jason P Boaz, Accountant Member These three appeals by the assessee are directed against the separate orders of CIT(A)-1, Bangalore, for Assessment Years 2008-09 to 2010-11. Since common issues are involved, these appeals were heard together and we ITA Nos.528 to 530/Bang/2018 Page 2 of 22 deem it appropriate to dispose them

MICROFINISH VALVES PRIVATE LIMITED,HUBLI vs. ASST.C.I.T., HUBLI

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

Bench: Shri N. V. Vasudevan & Shri Jason P Boazit(It)A No.1449/Bang/2015 Assessment Year : 2011-12

disallowances: (i)Deemed Dividend under section 2(22)(e) - Rs.3,30,00,000/- (ii) Disallowance under section 40(a)(i) - Rs. 8,18,734/- (iii) Disallowance

MR. A. MOHIUDDIN,MANGALORE vs. ACIT, MANGALORE

In the result, the appeals of the assessees in ITA

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

section 2(22)(e) of the Act will not be applicable. Similar view was also expressed by the Hon’ble Punjab and Haryana High Court in the case of CIT Vs. Suraj Dev Dada. 16. Turning to the fact of the case, we find that undisputedly the assessee maintained the current account with the company and the ITA Nos.1223/B/10

ACIT, MANGALORE vs. MRS. SHAHANAZ MOHIUDDIN, MANGALORE

In the result, the appeals of the assessees in ITA

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

section 2(22)(e) of the Act will not be applicable. Similar view was also expressed by the Hon’ble Punjab and Haryana High Court in the case of CIT Vs. Suraj Dev Dada. 16. Turning to the fact of the case, we find that undisputedly the assessee maintained the current account with the company and the ITA Nos.1223/B/10

MR. A. MOHIUDDIN,,MANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX,, MANGALORE

In the result, the appeals of the assessees in ITA

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

section 2(22)(e) of the Act will not be applicable. Similar view was also expressed by the Hon’ble Punjab and Haryana High Court in the case of CIT Vs. Suraj Dev Dada. 16. Turning to the fact of the case, we find that undisputedly the assessee maintained the current account with the company and the ITA Nos.1223/B/10

MRS. SHAHANAZ MOHIUDDIN,MANGALORE vs. ACIT, MANGALORE

In the result, the appeals of the assessees in ITA

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

section 2(22)(e) of the Act will not be applicable. Similar view was also expressed by the Hon’ble Punjab and Haryana High Court in the case of CIT Vs. Suraj Dev Dada. 16. Turning to the fact of the case, we find that undisputedly the assessee maintained the current account with the company and the ITA Nos.1223/B/10

MR. A. MOHIUDDIN,MANGALORE vs. ACIT, MANGALORE

In the result, the appeals of the assessees in ITA

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

section 2(22)(e) of the Act will not be applicable. Similar view was also expressed by the Hon’ble Punjab and Haryana High Court in the case of CIT Vs. Suraj Dev Dada. 16. Turning to the fact of the case, we find that undisputedly the assessee maintained the current account with the company and the ITA Nos.1223/B/10

MR. A. MOHIUDDIN,MANGALORE vs. ACIT, MANGALORE

In the result, the appeals of the assessees in ITA

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

section 2(22)(e) of the Act will not be applicable. Similar view was also expressed by the Hon’ble Punjab and Haryana High Court in the case of CIT Vs. Suraj Dev Dada. 16. Turning to the fact of the case, we find that undisputedly the assessee maintained the current account with the company and the ITA Nos.1223/B/10

MR. A. MOHIUDDIN,MANGALORE vs. ACIT, MANGALORE

In the result, the appeals of the assessees in ITA

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

section 2(22)(e) of the Act will not be applicable. Similar view was also expressed by the Hon’ble Punjab and Haryana High Court in the case of CIT Vs. Suraj Dev Dada. 16. Turning to the fact of the case, we find that undisputedly the assessee maintained the current account with the company and the ITA Nos.1223/B/10

MR. A. MOHIUDDIN,MANGALORE vs. ACIT, MANGALORE

In the result, the appeals of the assessees in ITA

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

section 2(22)(e) of the Act will not be applicable. Similar view was also expressed by the Hon’ble Punjab and Haryana High Court in the case of CIT Vs. Suraj Dev Dada. 16. Turning to the fact of the case, we find that undisputedly the assessee maintained the current account with the company and the ITA Nos.1223/B/10

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)

E. Shridhar, CIT-DR\nDate of Hearing : 22-01-2025\nDate of Pronouncement : 21-04-2025\nORDER\nPER BENCH\nThese are the appeals filed by the assessee challenging the orders of\nthe Ld.CIT(A) -2, Panaji dated 30/01/2024 in respect of the A.Ys.2017-18,\n2018-19, 2019-20 and 2020-21. The grounds raised by the assessee for\neach

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

e)(i).\n15.15.\nWithout prejudice to the above, the Learned AO\nfailed to appreciate that circumstances envisaged under\nRule 6DD are only illustrative and not exhaustive and the\ncase of Appellant does not warrant invocation of section\n40A(3) as the impugned payments are genuine and are\nmade out of business exigency.\n15.16. Without prejudice to the Learned AO erred

SURESH ENTERPRISES PRIVATE LIMITED,HUBLI vs. ACIT, HUBLI

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

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Raom/S.Suresh Enterprises Pvt.Ltd. Akshay Chabbi Corner, Akshay Centre, Gokul Road, Hubli. … Appellant Pa No.Aaccs4691 N Vs. Asst. Commissioner Of Income-Tax, Circle 3(1), Hubli. … Respondent

section 2(22)(e) of IT. Act, 1961. The expression "Accumulated Profits' was defined in the 1961 Act so as to include current profit upto the date of distribution or payment. ii) Accumulated Profits-How to be Computed The phrase accumulated profits" does not mean aggregate of assessed profits but commercial profits. If certain disbursement have been disallowed

THE KARNATAKA STATE COOPERATIVE AGRICULTURE AND DEVELOPMENT BANK LIMITED ,BANGLAORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2022-23

e-stamping, commission on ITGI insurance premium etc. According to the ld. AR all such incomes are eligible for deduction under section 80P(2)(a)(i) of the Act. . Page 13 of 38 11. On the other hand, the learned Departmental Representative (Ld. DR) relied on the orders of the Assessing Officer and the Commissioner of Income Tax (Appeals

M/S KBD SUGARS & DISTILLERIES LTD. vs. ACIT,

In the result, the appeals of the assessee for the Assessment Years 2008-

e) Once a proximate cause for disallowance is established – which is the relationship of the expenditure with income which does not form part of the total income – a disallowance has to be effected. All expenditure under the provisions of the Act has to be disallowed under section 14A Income which does not form part of the total income is broadly