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117 results for “disallowance”+ Section 2(23)(x)clear

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Key Topics

Addition to Income74Disallowance49Section 153C42Section 143(3)40Section 14A40Deduction35Section 36(1)(va)33Section 25027Section 2(15)27

GLOBAL SECURITY SERVICES ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1) , BANGALORE

In the result, the appeal of the assessee is dismissed

ITA 150/BANG/2024[2018-19]Status: DisposedITAT Bangalore28 Jun 2024AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Shri Akshaya K.S., CAFor Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 143(1)(a)Section 36(1)(va)

disallowances made are beyond the scope and ambit of adjustment provided under section 143(1)(a) while processing the returns of income. At the time of filing of returns of income by the assessee for the respective assessment years, the law prevailing on the said date allowed the assessee to claim deduction of employees' contribution

THAMANNA ,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME, CIRCLE-2(1) , MYSORE

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

Showing 1–20 of 117 · Page 1 of 6

Section 153A27
Section 1125
Transfer Pricing21
ITA 1188/BANG/2024[2017-18]Status: DisposedITAT Bangalore22 Oct 2024AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Smt. Sheetal, AdvocateFor Respondent: Shri V. Parithivel, Jt. CIT(DR)(ITAT), Bengaluru
Section 139Section 139(1)Section 36(1)(va)Section 43

disallowances made are beyond the scope and ambit of adjustment provided under section 143(1)(a) while processing the returns of income. ♦ At the time of filing of returns of income by the assessee for the respective assessment years, the law prevailing on the said date allowed the assessee to claim deduction of employees' contribution

M/S. ADVAITH MOTORS PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU

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

ITA 525/BANG/2024[2020-21]Status: DisposedITAT Bangalore22 May 2024AY 2020-21

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2020-21

For Appellant: Shri H. Vinay Kumar, CAFor Respondent: Shri Srinath S., Jt.CIT(DR)(ITAT), Bengaluru
Section 143(1)Section 143(1)(a)Section 250Section 36(1)(va)Section 43B

disallowance should not be made u/s. 43B(b) towards employer’s contribution to PF/ESI. However the employees’ contribution to PF/ESI is governed by section 36(1)(va) and in this case the assessee deposited belatedly the employees’ contribution as per the respective Act. Further during the course of hearing, the ld. AR also raised the issue that the addition cannot

SHRI MAHAVEER CO-OPERATIVE CREDIT SOCIETY LTD,ALAGUR vs. INCOME TAX OFFICER, ALAGUR

In the result, the appeal by the assessee is allowed for statistical purposes\nPronounced in the open court on this 25th day of July, 2025

ITA 6/BANG/2025[2016-17]Status: DisposedITAT Bangalore25 Jul 2025AY 2016-17
Section 143(2)Section 143(3)Section 18Section 40Section 80PSection 80P(2)(a)Section 80P(2)(d)

X or Y.\n29. Thirdly, the gross total income must include income that is referred to in sub-\nsection (2).\n30. Fourthly, sub-clause (2)(a)(i) with which we are directly concerned, then\nspeaks of a co-operative society being \"engaged in\" carrying on the business of\nbanking or providing credit facilities to its members. What is important

GSSS CREDIT CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. INCOME-TAX OFFICER, WARD-2(2)(3), BANGALORE

In the result, the appeals of the assessee are allowed for\nstatistical purposes

ITA 248/BANG/2024[2017-18]Status: DisposedITAT Bangalore06 May 2024AY 2017-18
For Appellant: \nSmt. Suman Lunkar, C.A
Section 80P(2)(a)Section 80P(2)(d)

23,008 and AY\n2020-21 of Rs.45,04,703.\nAs regards deduction claimed under section 80P(2)(d)\nof ITA 1961, guidance has already been provided by the\nHon'ble Karnataka HC in the case of [2017] 83 taxmann.com\n140 (Karnataka) PCIT, Hubballi V. Totagars Co-operative Sale\nSociety dated 16/06/2017, distinguishing its own judgment in\nthe case

SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1 & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

ITA 2397/BANG/2024[2020-21]Status: DisposedITAT Bangalore09 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 143Section 36Section 5

x) of the act the above sum was also considered as income. Since the sum received by the assessee from his employees deemed to be income, no adjustment could be made in regard to the increasing the income as per clause (iv) of section 143 (1) (a) of the act before 1 April 2021. Therefore, the assessee submitted that according

SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1(1) & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

ITA 2396/BANG/2024[2019-20]Status: DisposedITAT Bangalore09 Dec 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 143Section 36Section 5

x) of the act the above sum was also considered as income. Since the sum received by the assessee from his employees deemed to be income, no adjustment could be made in regard to the increasing the income as per clause (iv) of section 143 (1) (a) of the act before 1 April 2021. Therefore, the assessee submitted that according

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

ITA 744/BANG/2023[2016-17]Status: DisposedITAT Bangalore03 Jan 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

For Appellant: Shri Ravishankar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 11Section 2(15)Section 234ASection 8

disallowance of the exemption claimed under section n of the Act, on the ground that the activities of the appellant are hit by the proviso to section 2(15) of the Act on the facts and circumstances of the case. ITA Nos.744 & 745/Bang/2023 Sanghamitra Rural Financial Services, Bangalore Page 2 of 54 4. The authorities below failed to appreciate that

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD.,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

ITA 720/BANG/2025[2015-16]Status: DisposedITAT Bangalore29 Jul 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

X’ amount of expenditure, the ld. AO is duty bound to examine the statement of the assessee about not incurring the expenditure or also about the quantum of expenditure, as the case may be. Such claim is required to be examined naturally having regard to the accounts of the assessee. This is so because the claim of expenditure is generally

MANIPAL HOSPITALS PVT. LTD (FORMERLY KNOWN AS COLUMBIA ASIA HOSPITALS PVT. LTD),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

ITA 722/BANG/2025[2018-19]Status: DisposedITAT Bangalore29 Jul 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

X’ amount of expenditure, the ld. AO is duty bound to examine the statement of the assessee about not incurring the expenditure or also about the quantum of expenditure, as the case may be. Such claim is required to be examined naturally having regard to the accounts of the assessee. This is so because the claim of expenditure is generally

MANIPAL GLOBAL EDUCATION SERVICES PVT LTD., ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(2), BANGALORE

In the result, the appeal of the assessee is allowed

ITA 976/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Jul 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

X’ amount of expenditure, the ld. AO is duty bound to examine the statement of the assessee about not incurring the expenditure or also about the quantum of expenditure, as the case may be. Such claim is required to be examined naturally having regard to the accounts of the assessee. This is so because the claim of expenditure is generally

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD. ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

ITA 719/BANG/2025[2014-15]Status: DisposedITAT Bangalore29 Jul 2025AY 2014-15

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

X’ amount of expenditure, the ld. AO is duty bound to examine the statement of the assessee about not incurring the expenditure or also about the quantum of expenditure, as the case may be. Such claim is required to be examined naturally having regard to the accounts of the assessee. This is so because the claim of expenditure is generally

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

ITA 721/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Jul 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

X’ amount of expenditure, the ld. AO is duty bound to examine the statement of the assessee about not incurring the expenditure or also about the quantum of expenditure, as the case may be. Such claim is required to be examined naturally having regard to the accounts of the assessee. This is so because the claim of expenditure is generally

WRITEMEN MEDIA PRIVATE LIMITED,BENGALURU vs. INCOME TAX OFFICER,WARD-7(1)(3), BENGALURU

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

ITA 1516/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Jul 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2014-15

For Appellant: Shri. Ravishankar, AdvocateFor Respondent: Shri. Ashwin D Gowda, Addl. CIT(DR)(ITAT), Bangalore
Section 115JSection 143(3)Section 153Section 56(2)(viib)

x. The learned authorities below placed reliance on the judgement of Hon’ble Court in the case of Agra Portfolio Pvt Ltd Vs ITO Ward 1(4), New Delhi in ITA No. 2189/De/2018 dated 16.05.2018, however, the learned authorities below failed to appreciate the fact that the Hon’ble High Court of Delhi has recently passed a judgement

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)

X out of which Rs. 53.47 cr. was found to be ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 6 of 46 prudentially written off. The majority of bad debts written off related to urban debts mounting to Rs. 218.09 Crores and the rural debts written off was only Rs. 0.77 Crores which has been separately reduced from the claim of provision

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)

X out of which Rs. 53.47 cr. was found to be ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 6 of 46 prudentially written off. The majority of bad debts written off related to urban debts mounting to Rs. 218.09 Crores and the rural debts written off was only Rs. 0.77 Crores which has been separately reduced from the claim of provision

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)

X of the Act. The order passed by the Ld. AO is without jurisdiction, inter cilia, d) insofar as it purports to give effect to an invalid order of the Ld. Panel. The directions issued by the Ld. Panel and the order passed by the Ld. e) AO is without jurisdiction, inter alia, in so far as it purports

PRIMARY AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED NIDLE,BELTHANGADY vs. INCOME-TAX OFFICER, WARD-1, PUTTUR

ITA 659/BANG/2023[2017-18]Status: DisposedITAT Bangalore30 Nov 2023AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Ms. Harsha J, C.A [Instructed by Sri SrihariFor Respondent: Shri Parithivel, JCIT (DR)
Section 234BSection 250Section 80P(2)(a)Section 80P(2)(d)

disallowance of provisions of Rs.21,34,129/-, it is merely provision but not an expenditures. The provisions are not allowed as per sec.37 of the Act, therefore, he requested that order of the CIT(A) should be upheld. 11. After hearing both sides and perusing the entire material on record and orders of the authorities below, we note that

SRI. MANIKANDAN VAZHUKKAPAR KUMARAN,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-1(1)(1), BANGALORE

In the result, all the appeals filed by the assessees stands dismissed

ITA 577/BANG/2023[2018-19]Status: DisposedITAT Bangalore29 Nov 2023AY 2018-19

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2018-19

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Nischal B., D.R
Section 139Section 143Section 143(1)Section 36(1)(va)

2(24)(x) has to computed accordingly. 3. Incorrect amount of disallowance 3.1 Without prejudice, the amount of disallowance under section 36(1)(va) to be restricted to the contributions to the relevant fund paid beyond the due date under the relevant law, as indicated in the independent auditors certificate dated 4.10.2023. 4. In view of the above and other

MOOG MOTION CONTROLS PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BANGALORE

In the result, the appeal is allowed

ITA 184/BANG/2024[2019-2020]Status: DisposedITAT Bangalore08 May 2024AY 2019-2020

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2019-20 M/S. Moog Motion Controls Pvt. Ltd., Acit, Site No.42-43, Doraisanipalya Circle – 4(1)(1), Village, Vs. Bengaluru. Opp. Oracle (Kalyani Magnum), Bilekahalli, Begur Hobli, Bengaluru – 560 076. Pan : Aadcm 3828 J Appellant Respondent Assessee By : Shri. Srinivas K. P, Ca Revenue By : Shri. V. Parithivel, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 20.03.2024 Date Of Pronouncement : 08.05.2024

For Appellant: Shri. Srinivas K. P, CAFor Respondent: Shri. V. Parithivel, JCIT(DR)(ITAT)
Section 139(1)Section 143(1)Section 36(1)(va)Section 90

2(24)(x) of the Act for the delayed remittance of the employees’ contribution of Rs.2,60,000/- and there was also delayed submission of Form No.67 due to this, the foreign tax credit claimed by the assessee of Rs.5,81,713/- was Page 3 of 19 disallowed which was claimed under section 90 of the Act in the revised