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198 results for “disallowance”+ Section 206clear

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Key Topics

Addition to Income64Disallowance57Section 143(3)40Section 10A39Deduction36Section 14A34Section 80P(2)(a)28Section 153C28Section 153A26

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

ITA 530/BANG/2018[2010-11]Status: DisposedITAT Bangalore08 Feb 2019AY 2010-11

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

For Appellant: Shri. B. R. Sudheendra, CAFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 143(3)Section 14A

disallowed as if there was no expenditure incurred by the respondent- assessee for conducting business. The CIT(A) has positively held that the business was set up and had commenced. The said finding is accepted. The respondent-assessee, therefore, had to incur expenditure for the business in the form of investment in shares of cement companies and to further expand

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

Showing 1–20 of 198 · Page 1 of 10

...
Section 4025
Section 143(1)22
Penalty12

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

ITA 528/BANG/2018[2008-09]Status: DisposedITAT Bangalore08 Feb 2019AY 2008-09

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

For Appellant: Shri. B. R. Sudheendra, CAFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 143(3)Section 14A

disallowed as if there was no expenditure incurred by the respondent- assessee for conducting business. The CIT(A) has positively held that the business was set up and had commenced. The said finding is accepted. The respondent-assessee, therefore, had to incur expenditure for the business in the form of investment in shares of cement companies and to further expand

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

ITA 529/BANG/2018[2009-10]Status: DisposedITAT Bangalore08 Feb 2019AY 2009-10

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

For Appellant: Shri. B. R. Sudheendra, CAFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 143(3)Section 14A

disallowed as if there was no expenditure incurred by the respondent- assessee for conducting business. The CIT(A) has positively held that the business was set up and had commenced. The said finding is accepted. The respondent-assessee, therefore, had to incur expenditure for the business in the form of investment in shares of cement companies and to further expand

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

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1519/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

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

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

disallow export commission expense amounting to INR 4,17,10,537 and commission paid for hiring of apartments ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 5 of 45 amounting INR 1,11,111 paid to non-resident parties under section 40(a)(i) of the Act without appreciating that such payments were not taxable in India

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1447/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

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

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

disallow export commission expense amounting to INR 4,17,10,537 and commission paid for hiring of apartments ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 5 of 45 amounting INR 1,11,111 paid to non-resident parties under section 40(a)(i) of the Act without appreciating that such payments were not taxable in India

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1448/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

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

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

disallow export commission expense amounting to INR 4,17,10,537 and commission paid for hiring of apartments ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 5 of 45 amounting INR 1,11,111 paid to non-resident parties under section 40(a)(i) of the Act without appreciating that such payments were not taxable in India

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1520/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

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

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

disallow export commission expense amounting to INR 4,17,10,537 and commission paid for hiring of apartments ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 5 of 45 amounting INR 1,11,111 paid to non-resident parties under section 40(a)(i) of the Act without appreciating that such payments were not taxable in India

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

disallowable under section 36' of ₹ 10,048,794/– was added to the total income. This sum is stated to be in respect of employees' contribution paid towards provident fund and employee state insurance scheme admittedly paid beyond the due date specified under the respective act. Similarly for assessment year 2020 – 21 the intimation under section ITA No. 2396 & 2397/ bang/2024

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

disallowable under section 36' of ₹ 10,048,794/– was added to the total income. This sum is stated to be in respect of employees' contribution paid towards provident fund and employee state insurance scheme admittedly paid beyond the due date specified under the respective act. Similarly for assessment year 2020 – 21 the intimation under section ITA No. 2396 & 2397/ bang/2024

SASKEN TECHNOLOGIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

ITA 404/BANG/2017[2012-13]Status: DisposedITAT Bangalore30 Nov 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 404/Bang/2017 Assessment Year : 2012-13 M/S. Sasken Technologies Ltd., (Formerly Known As The Deputy Sasken Communication Commissioner Of Technologies Ltd.), Income Tax, No. 139/25, Domlur Circle – 6(1)(1), Ring Road, Vs. Bangalore. Bangalore – 560 071. Pan: Aaecs6424R Appellant Respondent : Shri Padam Chand Khincha, Assessee By Ca : Shri K. Sankar Ganesh, Jcit Revenue By Dr Itat Date Of Hearing : 15-11-2022 Date Of Pronouncement : 30-11-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Assessment Order Dated 31.01.2017 Passed By Ld.Dcit, Circle – 6(1)(1), Bangalore For A.Y. 2012-13 On Following Concise Grounds Of Appeal: “1. General:- The Learned Ao & The Drp Erred In Passing The Order / Directions In The Manner Passed By Them. The Orders Passed Being Bad In Law Is Liable To Be Quashed.

For Respondent: Shri Padam Chand Khincha
Section 133(6)Section 2(24)Section 92BSection 92C

disallowance of deduction under section 10AA was dropped and the deduction as claimed by the assessee under section 10AA was granted. 2.7 Aggrieved by the final assessment order, the assessee filed present appeal before this Tribunal. 3. Ground Nos. 1 and 2 are general in nature and therefore do not require adjudication. 4. Ground Nos. 3.1 and 3.2: - Ld.AR submitted

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

ITA 1821/BANG/2025[2022-23]Status: DisposedITAT Bangalore09 Apr 2026AY 2022-23

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

For Appellant: Shri Bhardwaj Sheshadri, Advocate &For Respondent: Shri Subramanian, JCIT (DR)
Section 250Section 56Section 80PSection 80P(2)(a)

disallowances by following the ratio of the Hon’ble Supreme Court in case of Totgars Co-operative Sale Society Ltd. (supra). However, the Hon’ble High Court found that the assessee being cooperative society is only engaged in the business of providing credit facility to the members and other than that it does not engage in any other business

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

ITA 2469/BANG/2018[2008-09 ]Status: DisposedITAT Bangalore28 Nov 2019

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

206 AA of Income-tax Act. 8. For that, in the facts and circumstances of the case, the Ld. CIT (Appeals) erred in law as well as on facts in holding that, the tax payable by a UK tax resident on royalties / FTS earned from India cannot exceed 15% in view of Article 13(3) of India-UK Tax Treaty

VODAFONE SOUTH LIMITED,BANGALORE vs. DYDIT, BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

ITA 1160/BANG/2015[2013-14]Status: DisposedITAT Bangalore28 Nov 2019AY 2013-14

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

206 AA of Income-tax Act. 8. For that, in the facts and circumstances of the case, the Ld. CIT (Appeals) erred in law as well as on facts in holding that, the tax payable by a UK tax resident on royalties / FTS earned from India cannot exceed 15% in view of Article 13(3) of India-UK Tax Treaty

VODAFONE SOUTH LIMITED,BANGALORE vs. DYDIT, BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

ITA 1161/BANG/2015[2014-15]Status: DisposedITAT Bangalore28 Nov 2019AY 2014-15

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

206 AA of Income-tax Act. 8. For that, in the facts and circumstances of the case, the Ld. CIT (Appeals) erred in law as well as on facts in holding that, the tax payable by a UK tax resident on royalties / FTS earned from India cannot exceed 15% in view of Article 13(3) of India-UK Tax Treaty

DCIT, BANGALORE vs. M/S VODAFONE SOUTH LTD.,, NEW DELHI

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

ITA 1367/BANG/2015[2013-14]Status: DisposedITAT Bangalore28 Nov 2019AY 2013-14

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

206 AA of Income-tax Act. 8. For that, in the facts and circumstances of the case, the Ld. CIT (Appeals) erred in law as well as on facts in holding that, the tax payable by a UK tax resident on royalties / FTS earned from India cannot exceed 15% in view of Article 13(3) of India-UK Tax Treaty

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

ITA 2471/BANG/2018[2010-11]Status: DisposedITAT Bangalore28 Nov 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

206 AA of Income-tax Act. 8. For that, in the facts and circumstances of the case, the Ld. CIT (Appeals) erred in law as well as on facts in holding that, the tax payable by a UK tax resident on royalties / FTS earned from India cannot exceed 15% in view of Article 13(3) of India-UK Tax Treaty

JOINT COMMISSIONER OF INCOME TAX (OSD) CIRCLE-2(1)(IT), BANGALORE vs. M/S VODAFONE SOUTH LTD , BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

ITA 192/BANG/2018[2015-16]Status: DisposedITAT Bangalore28 Nov 2019AY 2015-16

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

206 AA of Income-tax Act. 8. For that, in the facts and circumstances of the case, the Ld. CIT (Appeals) erred in law as well as on facts in holding that, the tax payable by a UK tax resident on royalties / FTS earned from India cannot exceed 15% in view of Article 13(3) of India-UK Tax Treaty

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(2) INTERNATIONAL TAXATION , BANGALORE vs. M/S VODAFONE SOUTH LTD , BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

ITA 1176/BANG/2017[2013-14]Status: DisposedITAT Bangalore28 Nov 2019AY 2013-14

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

206 AA of Income-tax Act. 8. For that, in the facts and circumstances of the case, the Ld. CIT (Appeals) erred in law as well as on facts in holding that, the tax payable by a UK tax resident on royalties / FTS earned from India cannot exceed 15% in view of Article 13(3) of India-UK Tax Treaty

M.S VODAFONE MOBILES SERVICES LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

ITA 2472/BANG/2018[2011-12]Status: DisposedITAT Bangalore28 Nov 2019AY 2011-12

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

206 AA of Income-tax Act. 8. For that, in the facts and circumstances of the case, the Ld. CIT (Appeals) erred in law as well as on facts in holding that, the tax payable by a UK tax resident on royalties / FTS earned from India cannot exceed 15% in view of Article 13(3) of India-UK Tax Treaty