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247 results for “disallowance”+ Section 260clear

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Mumbai1,173 Delhi798 Karnataka536 Bangalore247 Chennai212 Kolkata194 Ahmedabad138 Jaipur121 Pune99 Telangana95 Hyderabad59 Chandigarh58 Cochin44 Cuttack43 Surat42 Calcutta39 Indore38 Visakhapatnam36 Raipur34 Lucknow33 Rajkot30 Nagpur28 Amritsar20 SC16 Varanasi12 Punjab & Haryana9 Jodhpur8 Kerala7 Allahabad7 Patna6 Agra5 Dehradun5 Panaji3 Jabalpur3 Rajasthan3 Orissa3 Ranchi2 Guwahati2 Himachal Pradesh2 Bombay1 J&K1 RANJAN GOGOI PRAFULLA C. PANT1 Uttarakhand1 Andhra Pradesh1 H.L. DATTU S.A. BOBDE1

Key Topics

Section 153A84 Addition to Income71 Disallowance61 Section 13255 Section 14A51 Deduction35 Section 143(1)31 Section 1130 Section 153C24 Section 143(3)

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T, BANGALORE

In the result, Revenue’s appeal for A

ITA 102/BANG/2013[2005-06]Status: DisposedITAT Bangalore10 Nov 2017AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri H.N. Khincha, C.AFor Respondent: Shri R. N. Parbat, CIT-III (D.R)

Section 143(3)Section 195Section 40Section 92ASection 92C

260/- is liable for disallowance under section 40(a)(i) / 40(a)(ia). 7.2 The learned Commissioner of Income tax (Appeals

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

Showing 1–20 of 247 · Page 1 of 13

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24

Natural Justice23

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

disallowed since the situation contemplated by the first proviso viz. deduction and payment of tax in a subsequent year would never come about. Such unintended consequence has been sought to be taken care of by the second proviso inserted in section 40(a)(ia) by the Finance Act, 2012. There can be no 15 Sri.Singonahalli Chikkarevanna Gangadharaiah. doubt that

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

ITA 725/BANG/2018[2013-14]Status: DisposedITAT Bangalore31 Jul 2020AY 2013-14

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Percy Pardiwala, Sr. Advocate along with Ajay Roti, C.AFor Respondent: Shri K.V Arvind, Advocate

Section 10ASection 143Section 143(3)Section 144C(1)Section 92C

Section 92CC with the caption “Advance Pricing Agreement” provides through sub-section (1): `The Board, with the approval of the Central Government, may enter into an advance pricing agreement with any person, determining the arm's length price … in relation to an international transaction …’. Sub-section (2) gives the manner of determination of the ALP referred to in sub-section

ASSETZ INFRASTRUCTURE PRIVATE LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1), BANGALORE

In the result, the assessee's appeal for Assessment Year 2012-13 is allowed as indicated above

ITA 1533/BANG/2017[2012-13]Status: DisposedITAT Bangalore09 Feb 2018AY 2012-13

Bench: Shri Jason P Boaz & Shri Laliet Kumar

For Appellant: Shri B.R. Sudheendra, F.C.AFor Respondent: Shri Ramesh Kumar A, Addl. CIT (D.R)

Section 14Section 143(3)Section 14A

Section 143(3) of the Income Tax Act, 1961 (in short 'the Act') wherein the assessee's loss was determined at (-) Rs.1,69,30,260 in view of a disallowance

CANARA BANK,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, LTU,, BANGALORE

In the result, Revenue’s appeal for Assessment Year 2014-15 is partly allowed for statistical purposes

ITA 1899/BANG/2017[2014-15]Status: DisposedITAT Bangalore28 Sept 2018AY 2014-15

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri S. Ananthan, C.AFor Respondent: Smt. Neera Malhotra, CIT (D.R)

Section 115JSection 143(3)Section 14ASection 36(1)(vii)Section 36(1)(viia)Section 40

Section 143(3) of the Income Tax Act, 1961 (in short 'the Act') vide order dt.27.12.2016, wherein the assessee's income was determined at Rs.5897,92,23,130 in view of the following additions / disallowances :- i) Disallowance of bad debts written off Rs.1143,68,00,000 ii) Disallowance of claim of provision for bad Rs.415,26,46,585 and doubtful

YOKOGAWA INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX LARGE TAXPAYERS UNIT , BANGALORE

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

ITA 2088/BANG/2017[2013-14]Status: DisposedITAT Bangalore01 Feb 2024AY 2013-14

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 14A

disallowance made under Section 14A of the Income Tax Act, 1961 ("Act") [Ground Nos. 13 to 17]. We had also submitted that Ground Nos. 18 to 20 are consequential and further that additional Ground No. 21 relating to applicable rate of Dividend Distribution Tax ("DDT") will have to covered by decision of Special Bench of this Hon'ble Tribunal

M/S. SLK SOFTWARE PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, SPECIAL RANGE-6, BANGALORE

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

ITA 932/BANG/2023[2017-18]Status: DisposedITAT Bangalore31 Jan 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharath L, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)

disallowances made under section 40(a)(i). However, the Ld. CIT(A) without considering the argument forwarded by the assessee proceeded to dismiss the appeal of the assessee without assigning any reasoning. The relevant findings of the ld. CIT-A is reproduced as under: “5.3.3 The facts of the case, assessment order and submissions of the appellant have been considered

M/S. SLK SOFTWARE PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, SPECIAL RANGE-6N, BANGALORE

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

ITA 933/BANG/2023[2018-19]Status: DisposedITAT Bangalore31 Jan 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharath L, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)

disallowances made under section 40(a)(i). However, the Ld. CIT(A) without considering the argument forwarded by the assessee proceeded to dismiss the appeal of the assessee without assigning any reasoning. The relevant findings of the ld. CIT-A is reproduced as under: “5.3.3 The facts of the case, assessment order and submissions of the appellant have been considered

LEMNISK PRIVATE LIMITED (FORMERLY KNOWN AS 'VIZURY INTERACTIVE SOLUTIONS PRIVATE LIMITED'),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2) , BANGALORE

In the result appeal filed by assessee for assessment year

ITA 2129/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Apr 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri K.R. Vasudevan

disallowance of recruitment charges paid for non- deduction of tax at source Under section 40(a)(i). b. The learned CIT(A) failed to appreciate that the payments made in relation to recruitment services provided by various vendors fails under Article 12 / Article 14 of the respective tax treaties as given below: Service provider Amount Country Article reference Bank Accout

LEMNISK PRIVATE LIMITED (FORMERLY KNOWN AS 'VIZURY INTERACTIVE SOLUTIONS PVT LTD'),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result appeal filed by assessee for assessment year

ITA 1851/BANG/2017[2012-13]Status: DisposedITAT Bangalore29 Apr 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri K.R. Vasudevan

disallowance of recruitment charges paid for non- deduction of tax at source Under section 40(a)(i). b. The learned CIT(A) failed to appreciate that the payments made in relation to recruitment services provided by various vendors fails under Article 12 / Article 14 of the respective tax treaties as given below: Service provider Amount Country Article reference Bank Accout

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX OFFICER, CENTRAL CIRCLE-2(2), BENGALURU

ITA 23/BANG/2024[2015-16]Status: DisposedITAT Bangalore31 Oct 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

Section 153ASection 234ASection 250

260 ITR 80. 2. The notice issued under section 153A of the Act is bad in law in as much as it does not contain whether the learned Assessing Officer proposes to assess or reassess the income of the appellant and consequently the notice issued under section 153A of the Act is invalid and the entire assessment proceedings

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

ITA 25/BANG/2024[2017-18]Status: DisposedITAT Bangalore31 Oct 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Respondent: Shri. A. Shankar, Sr. Advocate

Section 132Section 153ASection 234ASection 250

260 ITR 80. 2. The notice issued under section 153A of the Act is bad in law in as much as it does not contain whether the learned Assessing Officer proposes to assess or reassess the income of the appellant and consequently the notice issued under section 153A of the Act is invalid and the entire assessment proceedings

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

ITA 21/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Oct 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore

Section 153ASection 234ASection 250

260 ITR 80. 2. The notice issued under section 153A of the Act is bad in law in as much as it does not contain whether the learned Assessing Officer proposes to assess or reassess the income of the appellant and consequently the notice issued under section 153A of the Act is invalid and the entire assessment proceedings

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

ITA 24/BANG/2024[2016-17]Status: DisposedITAT Bangalore31 Oct 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore

Section 153ASection 234ASection 250

260 ITR 80. 2. The notice issued under section 153A of the Act is bad in law in as much as it does not contain whether the learned Assessing Officer proposes to assess or reassess the income of the appellant and consequently the notice issued under section 153A of the Act is invalid and the entire assessment proceedings

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

ITA 22/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Oct 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore

Section 153ASection 234ASection 250

260 ITR 80. 2. The notice issued under section 153A of the Act is bad in law in as much as it does not contain whether the learned Assessing Officer proposes to assess or reassess the income of the appellant and consequently the notice issued under section 153A of the Act is invalid and the entire assessment proceedings

M/S SUNQUEST INFORMATION SYSTEMS (INDIA) PRVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 552/BANG/2015[2010-11]Status: DisposedITAT Bangalore21 Dec 2018AY 2010-11

Bench: Shri N.V Vasudevanshri Jason P Boazit(Tp)A No.552/Bang/2015

For Respondent: Shri C.H Sundar Rao, CIT

Section 143(3)Section 40Section 92

disallowance u/s.40(a)(ia) of the Act and all other grounds and additional grounds were not pressed for adjudication. 3. As far as ground Nos.9, 11 and 15 are concerned these grounds read as follows:- “9. The learned AO erred in adopting a threshold of 0% for applying the Related Party filter ('RPT") as per the directions

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

ITA 26/BANG/2024[2018-19]Status: DisposedITAT Bangalore31 Oct 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore

Section 153ASection 234ASection 250

260 ITR 80. iii. The learned assessing officer has not discharged the burden of proving that there is a valid search under section 132 (1) (a), (b) & (c) of the Act, and consequently the assumption of jurisdiction to make an assessment under section 153A of the Act is untenable in law. 2. The notice issued under section 153A

TECHNICOLOR INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee in ITA

ITA 300/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Jun 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Sharath Rao, A.RFor Respondent: Shri Vilas V Shinde, D.R

Section 260-A of the Act before this Court. 58. The appeals filed by the Revenue are therefore dismissed with no order as to costs." 9. Having heard the learned. counsels for the parties, we are therefore of the opinion that no substantial question of law arises in the present case also. The appeal filed by the Appellants- Revenue

TECHNICOLOR INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, the appeal of the assessee in ITA

ITA 217/BANG/2017[2011-12]Status: DisposedITAT Bangalore29 Jun 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Sharath Rao, A.RFor Respondent: Shri Vilas V Shinde, D.R

Section 260-A of the Act before this Court. 58. The appeals filed by the Revenue are therefore dismissed with no order as to costs." 9. Having heard the learned. counsels for the parties, we are therefore of the opinion that no substantial question of law arises in the present case also. The appeal filed by the Appellants- Revenue

M/S SALESFORCE.COM INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

Accordingly these ground raised by assessee stands allowed for statistical purposes

ITA 3286/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Mar 2021AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.3286/Bang/2018 Assessment Year : 2014-15

For Appellant: Shri Sumeet Khurana, C.AFor Respondent: Shri Pradeep Kumar, CIT (DR)

Section 133(6)Section 143(3)Section 92D

disallowing the same under section 40(a)(ia) of the Act. 4.2. That on the facts and circumstances of the case, the Learned Panel failed to appreciate that the Appellant had duly deducted tax at source on INR 24,586,946, where ever applicable, under section 194C/ 194J of the Act depending on the nature of the expense and deposited