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184 results for “disallowance”+ Section 244clear

Sorted by relevance

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Key Topics

Section 143(3)70Disallowance70Addition to Income65Deduction44Section 153A39Section 40A(3)28Section 13227Section 10(1)27Section 80P(2)(a)23

M/S. SYNGENE INTERNATIONAL LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 6, BANGALORE

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

ITA 147/BANG/2020[2010-11]Status: DisposedITAT Bangalore13 Jun 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2010-11

For Appellant: Sri Padamchand Khincha, A.RFor Respondent: Sri Sumer Singh Meena, DR
Section 10ASection 10BSection 14ASection 250Section 32(1)(iia)Section 80

section 10A/10B is to be allowed in respect of disallowances made during assessment proceedings. Reliance is placed on the following decisions [PB — 205 read with CLC — 212 to 244

Showing 1–20 of 184 · Page 1 of 10

...
Section 234D23
Section 14A21
Business Income14

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

ITA 517/BANG/2015[2010-11]Status: DisposedITAT Bangalore01 Apr 2021AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri Muzaffar Hussain, CIT (DR)For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143Section 144CSection 144C(13)Section 194JSection 40Section 9(1)(iv)

disallowance u/s 40(a)(ia) of the Act was made on the findings of the AO for not deducting TDS on the purchase of software and also on legal and professional fees. 8. On the facts and in the circumstances of the case the Dispute Resolution Panel erred in not appreciating that the sub leased rental income is taxable without

M/S. BHARAT ELECTRONICS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

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

ITA 394/BANG/2023[2012-13]Status: DisposedITAT Bangalore29 Sept 2023AY 2012-13

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahuassessment Year : 2012-13 M/S. Bharat Electronics The Assistant Ltd., Commissioner Of Registered Office, Income Tax, Outer Ring Road Ltu, Nagawara, Circle – 1, Vs. Bangalore – 560 045. Bangalore. Pan: Aaacb5985C Appellant Respondent

For Appellant: Smt. Richa .B, CAFor Respondent: Shri Manoj Kumar, CIT-DR
Section 14ASection 43A

disallowed the entire foreign exchange loss of Rs. Rs. 48,23,924/- holding that the foreign exchange loss is attributable to the cost of capital assets acquired by the Appellant, and necessary adjustment towards depreciation shall be allowed on furnishing the requisite details. It is humbly submitted that the CIT(A) also, without appreciating the facts in hand, upheld

DCIT vs. M/S UNITED SPIRITS LTD.,,

In the result, the assessee’s appeals for assessment years 2007-08, 2008-09 and 2009-10 are treated as allowed for statistical purposes

ITA 652/BANG/2013[2008-09]Status: DisposedITAT Bangalore31 Mar 2015AY 2008-09

Bench: Smt. P. Madhavi Devi & Shri Abraham P George & Ita Nos.424 & 605(Bang)/2013 (Assessment Years: 2008-09 & 2009-10)

For Appellant: Shri K.R.Pradeep, CAFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 14A

section 14A cannot be invoked as has been held by the Hon'ble Karnataka High Court in the case of CCI Ltd. (250 ITR 291). The learned Authorised Representative submitted that in this regard, the assessee places reliance on the following decisions of the various Tribunals. ITA No.1277/B/2010, 424M605,652&653/Bang/2013 M/s. United Spirits Ltd. Page

M/S. UNITED SPIRITS LTD.,,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee’s appeals for assessment years 2007-08, 2008-09 and 2009-10 are treated as allowed for statistical purposes

ITA 1277/BANG/2010[2007-08]Status: DisposedITAT Bangalore31 Mar 2015AY 2007-08

Bench: Smt. P. Madhavi Devi & Shri Abraham P George & Ita Nos.424 & 605(Bang)/2013 (Assessment Years: 2008-09 & 2009-10)

For Appellant: Shri K.R.Pradeep, CAFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 14A

section 14A cannot be invoked as has been held by the Hon'ble Karnataka High Court in the case of CCI Ltd. (250 ITR 291). The learned Authorised Representative submitted that in this regard, the assessee places reliance on the following decisions of the various Tribunals. ITA No.1277/B/2010, 424M605,652&653/Bang/2013 M/s. United Spirits Ltd. Page

UNITED SPIRITS LTD. vs. ACIT,

In the result, the assessee’s appeals for assessment years 2007-08, 2008-09 and 2009-10 are treated as allowed for statistical purposes

ITA 605/BANG/2013[2009-10]Status: DisposedITAT Bangalore31 Mar 2015AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri Abraham P George & Ita Nos.424 & 605(Bang)/2013 (Assessment Years: 2008-09 & 2009-10)

For Appellant: Shri K.R.Pradeep, CAFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 14A

section 14A cannot be invoked as has been held by the Hon'ble Karnataka High Court in the case of CCI Ltd. (250 ITR 291). The learned Authorised Representative submitted that in this regard, the assessee places reliance on the following decisions of the various Tribunals. ITA No.1277/B/2010, 424M605,652&653/Bang/2013 M/s. United Spirits Ltd. Page

DCIT vs. M/S UNITED SPIRITS LTD.,,

In the result, the assessee’s appeals for assessment years 2007-08, 2008-09 and 2009-10 are treated as allowed for statistical purposes

ITA 653/BANG/2013[2009-10]Status: DisposedITAT Bangalore31 Mar 2015AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri Abraham P George & Ita Nos.424 & 605(Bang)/2013 (Assessment Years: 2008-09 & 2009-10)

For Appellant: Shri K.R.Pradeep, CAFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 14A

section 14A cannot be invoked as has been held by the Hon'ble Karnataka High Court in the case of CCI Ltd. (250 ITR 291). The learned Authorised Representative submitted that in this regard, the assessee places reliance on the following decisions of the various Tribunals. ITA No.1277/B/2010, 424M605,652&653/Bang/2013 M/s. United Spirits Ltd. Page

UNITED SPIRTIS LIMITED vs. ACIT,

In the result, the assessee’s appeals for assessment years 2007-08, 2008-09 and 2009-10 are treated as allowed for statistical purposes

ITA 424/BANG/2013[2008-09]Status: DisposedITAT Bangalore31 Mar 2015AY 2008-09

Bench: Smt. P. Madhavi Devi & Shri Abraham P George & Ita Nos.424 & 605(Bang)/2013 (Assessment Years: 2008-09 & 2009-10)

For Appellant: Shri K.R.Pradeep, CAFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 14A

section 14A cannot be invoked as has been held by the Hon'ble Karnataka High Court in the case of CCI Ltd. (250 ITR 291). The learned Authorised Representative submitted that in this regard, the assessee places reliance on the following decisions of the various Tribunals. ITA No.1277/B/2010, 424M605,652&653/Bang/2013 M/s. United Spirits Ltd. Page

M/S BOSCH LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE-1 , BANGALORE

In the result, appeal of the assessee is partly allowed

ITA 1629/BANG/2018[2013-14]Status: DisposedITAT Bangalore13 Sept 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2013-14 Bosch Limited, Vs. The Assistant Commissioner Hosur Road, Adugodi, Of Income Tax, Ltu, Bangalore – 560 030. Circle 1, Pan: Aaacm 9840P Bangalore. Appellant Respondent Appellant By : Shri Percy Pardiwala, Advocate Respondent By : Shri V S Chakrapani, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 01.09.2022 Date Of Pronouncement : 13.09.2022 O R D E R Per Padmavathy S.2. This Appeal Is Against The Order Of The Cit(Appeals), Bangalore-9, Bangalore Dated 31.3.2018 For The Assessment Year 2013- 14. 3. The Assessee Raised Grounds Pertaining To The Following Issues:- Deduction U/S. 35(2Ab) Computed On Net Expenditure As Opposed To Gross Expenditure Disallowance Of Provision For Bad & Doubtful Debts I) Disallowance Of Provision For Long Term Service Award Disallowance Of Expenditure U/S. 14A Of The Act Ii) Page 2 Of 67

For Appellant: Shri Percy Pardiwala, AdvocateFor Respondent: Shri V S Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 14ASection 35Section 37Section 43BSection 80J

244 by stating that when the assessee has not discharged the initial onus towards disallowance of expenses incurred towards earning exempt income, the revenue could not be faulted with for applying Rule 8D. 30. Before us, the ld. AR reiterated the submissions made before the lower authorities. The ld. AR drew our attention to the computation of suo motu disallowance

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)

section 80P(2)(a)(i) of the Act is partly allowed in favour of the assessee for statistical purposes. 20. The second issue raised by the assessee is related to the disallowance of provision for bad and doubtful debts to the tune of ₹ 1,15,39,244

M/S HONEYWELL TECHNOLOGY SOLUTIONS LAB PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the assessee's appeal is partly allowed

ITA 1210/BANG/2018[2010-11]Status: DisposedITAT Bangalore07 Jan 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojarim/S. Honeywell Technology Solutions Lab Pvt. Ltd., 151/1, Bannerghata Road, Doraisanpalya, Bangalore-560 076 ….Appellant Pan Aaach 4151J Vs. Dy. Commissioner Of Income Tax, Circle 3(1)(2), Bangalore. ……Respondent. Assessee By: Smt. Shreya Loyalka, C.A. Revenue By: Shri B.K. Panda, Cit (D.R)

For Appellant: Smt. Shreya Loyalka, C.AFor Respondent: Shri B.K. Panda, CIT (D.R)
Section 80J

244/-. Therefore, the Ld. DR submitted that the claim of the assessee to this extent is found to be excessive and the same needs to be disallowed. Considering above, the entire claim of the assessee in relation to regular workmen employed during the year needs to be disallowed as it does not satisfy the basic condition laid down

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal for Assessment Year 2005-06 is partly allowed

ITA 1305/BANG/2010[2002-03]Status: DisposedITAT Bangalore11 Mar 2022AY 2002-03

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1305 To 1308/Bang/2010 Assessment Years : 2002-03, 2003-04, 2004-05, 2005-06 Dcit, M/S. Transworld Ict Solutions Pvt. Ltd., Vs. No.15, Hoody, Whitefield Road, Central Circle – 2(1), Mahadevapura Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 03.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92C(2)

disallowing the claim of exemption under section 10A of the Act for the additions made by the TPO under the facts and circumstances of the case. 9. The authorities below are not justified in levying interest under Sec 234(A), (B), (C) on the facts and circumstances of the case. The levy is further bad in law as the computation

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal for Assessment Year 2005-06 is partly allowed

ITA 1307/BANG/2010[2004-05]Status: DisposedITAT Bangalore11 Mar 2022AY 2004-05

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1305 To 1308/Bang/2010 Assessment Years : 2002-03, 2003-04, 2004-05, 2005-06 Dcit, M/S. Transworld Ict Solutions Pvt. Ltd., Vs. No.15, Hoody, Whitefield Road, Central Circle – 2(1), Mahadevapura Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 03.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92C(2)

disallowing the claim of exemption under section 10A of the Act for the additions made by the TPO under the facts and circumstances of the case. 9. The authorities below are not justified in levying interest under Sec 234(A), (B), (C) on the facts and circumstances of the case. The levy is further bad in law as the computation

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal for Assessment Year 2005-06 is partly allowed

ITA 1306/BANG/2010[2003-04]Status: DisposedITAT Bangalore11 Mar 2022AY 2003-04

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1305 To 1308/Bang/2010 Assessment Years : 2002-03, 2003-04, 2004-05, 2005-06 Dcit, M/S. Transworld Ict Solutions Pvt. Ltd., Vs. No.15, Hoody, Whitefield Road, Central Circle – 2(1), Mahadevapura Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 03.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92C(2)

disallowing the claim of exemption under section 10A of the Act for the additions made by the TPO under the facts and circumstances of the case. 9. The authorities below are not justified in levying interest under Sec 234(A), (B), (C) on the facts and circumstances of the case. The levy is further bad in law as the computation

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal for Assessment Year 2005-06 is partly allowed

ITA 1308/BANG/2010[2005-06]Status: DisposedITAT Bangalore11 Mar 2022AY 2005-06

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1305 To 1308/Bang/2010 Assessment Years : 2002-03, 2003-04, 2004-05, 2005-06 Dcit, M/S. Transworld Ict Solutions Pvt. Ltd., Vs. No.15, Hoody, Whitefield Road, Central Circle – 2(1), Mahadevapura Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 03.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92C(2)

disallowing the claim of exemption under section 10A of the Act for the additions made by the TPO under the facts and circumstances of the case. 9. The authorities below are not justified in levying interest under Sec 234(A), (B), (C) on the facts and circumstances of the case. The levy is further bad in law as the computation

M/S TATA ELXSI LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX SPECIAL RANGE-7 , BANGALORE

In the result the appeal filed by assessee stands allowed for statistical purposes

ITA 907/BANG/2019[2013-14]Status: DisposedITAT Bangalore28 Feb 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14 M/S. Tata Elxsi Ltd., The Assistant Itpl Road, Commissioner Of Hoody, Income Tax, Whitefield Road, Ao As Special Range 7, Bangalore – 560 048. Vs. Bangalore. Pan: Aaact7872Q Appellant Respondent : Shri Padam Chand Assessee By Khincha, Ca : Shri Sanjay Kumar, Cit Revenue By (Dr) Date Of Hearing : 21-12-2021 Date Of Pronouncement : 28-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Order Dated 25.03.2019 By Ld.Cit(A)-7, Bangalore For Assessment Year 2013-14 On Following Grounds Of Appeal: “1. General Ground 1.1 The Learned Deputy Commissioner Of Income Tax- Circle 7(1)(1) (`A0'), Bangalore Has Erred In Passing The Assessment Order Under Section 143(3) Of The Income Tax Act, 1961 (`The Act') In The Manner Passed By Him & The Commissioner Of Income Tax-(Appeals)-7 (`Cit(A)') Has Erred In Partly Confirming The Said Assessment Order. The Said Order To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. 2. Grounds Relating To Disallowance Of Deduction Under Section 80Jjaa Of The Act 2.1. The Learned Ao Has Erred In Disallowing Deduction Under Section 80Jjaa Amounting To Rs. 13,14,23,244/-

For Respondent: Shri Padam Chand
Section 143(3)Section 234BSection 28Section 37Section 80J

disallowing deduction under section 80JJAA amounting to Rs. 13,14,23,244/- Page 2 of 14 and the learned CIT(A) has erred

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2, LTU, BENGALURU vs. M/S. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

ITA 446/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

244). In this judgment, the Hon’ble High Court observed that the requirement of 300 days of employment should be considered cumulatively across both the previous year and the succeeding year. As such, for availing the benefit under Section 80JJAA of the Act, it is not mandatory for the workmen to have worked for 300 days in a single previous

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE JOINT COMMISSIONER OF INCOME TAX, LARGE TAX PAYERS UNIT, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

ITA 593/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

244). In this judgment, the Hon’ble High Court observed that the requirement of 300 days of employment should be considered cumulatively across both the previous year and the succeeding year. As such, for availing the benefit under Section 80JJAA of the Act, it is not mandatory for the workmen to have worked for 300 days in a single previous

VIJAYA BANK ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX LARGE TAX PAYER UNIT , BANGALORE

In the result, Revenue’s appeal for Assessment Year 2012-13 is dismissed

ITA 915/BANG/2017[2012-13]Status: DisposedITAT Bangalore05 Jan 2018AY 2012-13

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri S. Ananthan, C.AFor Respondent: Shri Pramod Kumar Singh, JCIT (D.R)
Section 143(3)Section 14ASection 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

section 115JB of the Act are not applicable to the assessee which is a banking company. The decisions relied upon by the ld. counsel for the assessee, clearly support the plea of the assessee in this regard. Consequently, ground No.3 raised by the assessee is also allowed.” 54. Since the provisions of sec.115JB of the Act are not applicable

M/S. AMRUT DISTILLERIES PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals filed by the assessee are treated as allowed for statistical purposes

ITA 949/BANG/2023[2016-17]Status: DisposedITAT Bangalore28 Jan 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahuandshri. Soundararajan K

For Appellant: Shri. Prateek P, CAFor Respondent: Shri. Sridhar E, CIT(DR)(ITAT), Bangalore
Section 133ASection 40A(3)

disallowable under the said provision on account of contravention. The only instances, without prejudice to ITA No.948 to 950/Bang/2023 Page 16 of 23 the contention that there is no contravention of the provisions of Section 40A(3)in respect of such instances too, observed by the Learned Assessing Officer to contend that there is a payment in excess