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28 results for “disallowance”+ Section 32Aclear

Sorted by relevance

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Key Topics

Section 10A36Deduction22Disallowance19Addition to Income19Section 36(1)(viia)18Section 143(3)16Section 14A15Section 80I15Depreciation11

IBM GLOBAL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), BANGALORE

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

ITA 3464/BANG/2004[2000-2001]Status: DisposedITAT Bangalore31 Jul 2024AY 2000-2001

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2000-2001

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri D.K. Mishra, CIT-DR
Section 10ASection 10A(2)Section 10A(2)(ia)Section 142(1)Section 143(2)Section 143(3)

disallowance made in the assessment order was denying exemption claimed u/s. 10A of the act on the ground that, the export turnover brought into India does not amount to 75 percent of the total turnover of the STP unit. It was submitted by the assessee that, it treated export credits of the bank account maintained

Showing 1–20 of 28 · Page 1 of 2

Section 36(1)(vii)9
Section 54G8
Section 10B8

OPTO CIRCUITS INDIA PVT LTD ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-5(1)(2), BANGALORE

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

ITA 1316/BANG/2017[2013-14]Status: DisposedITAT Bangalore30 Sept 2022AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Shiva Prasad Reddy, ITPFor Respondent: Sri.Sumer Singh Meena, CIT-DR
Section 10ASection 10BSection 139(1)Section 143(3)Section 35(1)(i)Section 37

disallowance referring to sub-sections (5) & (6) of section 10A / 10B of the I.T.Act, which are applicable to the deduction u/s 10AA of the I.T.Act also. The provisions of sub-sections (5) & (6) of section 10A of the I.T.Act shall apply to the exemption u/s 10AA of the I.T.Act also by virtue of sub- section (8) of section 10AA

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

disallowances made by the AO by observing as under: “As seen from the above, a plain reading of the provisions shows that new machinery or plant should be acquired and installed by an assessee who is engaged in the business of manufacture or production of any article or thing. The assessee is not engaged in manufacture/production of article or thing

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

disallowances made by the AO by observing as under: “As seen from the above, a plain reading of the provisions shows that new machinery or plant should be acquired and installed by an assessee who is engaged in the business of manufacture or production of any article or thing. The assessee is not engaged in manufacture/production of article or thing

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)

32A of the Act at p. 896 held that section prescribes no point of time by which the reserve should be created and in this regard accepted that a reserve created after the closure of the accounts of the year qualifies by observing as under : "The second question which is raised only

M/S RAMSOFT TECHNOLOGIES PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

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

ITA 1460/BANG/2015[2008-09]Status: DisposedITAT Bangalore30 Jun 2016AY 2008-09

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Raom/S.Ramsoft Technologies Pvt. Ltd. No.104A, 4Th Cross, Electronic City, Hosur Road, Bangalore-561229. … Appellant Pa No.Aaacr 6948 R Vs. Deputy Commisioner Of Income-Tax, Circle 12(4), Bangalore. … Respondent

For Appellant: Shri Ramasubramanian, CAFor Respondent: Shri Sunil Kumar Agarwala, JCIT(A)
Section 10ASection 143(1)Section 143(3)Section 147Section 148Section 14A

32A. Clause (ii) of sub-section (2) of section 33 and sub-section (4) of section 35 of the Act or the second proviso to clause (ix) of sub-section (1) of section 36 shall not be applicable in relation to any such allowance or deduction. Similarly, no loss as referred to in sub-section (1) or in section

INDIANOIL SKYTANKING PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), BENGALURU

In the result, the appeals are partly allowed

ITA 407/BANG/2020[2017-18]Status: DisposedITAT Bangalore20 May 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 115Section 143(3)Section 36(1)(iii)Section 37(1)Section 80Section 80I

disallowance in this regard was made in the earlier assessment years towards interest expenditure. 77. On the other hand, the ld.DR supported the decision of the lower authorities. 78. We heard the rival submissions and perused the material on record. An interest rate swap contract is typically a contract between the two parties which decide to pay interest on fixed

M/S. INDIANOIL SKYTAKING PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), BANGALORE

In the result, the appeals are partly allowed

ITA 299/BANG/2020[2016-17]Status: DisposedITAT Bangalore20 May 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 115Section 143(3)Section 36(1)(iii)Section 37(1)Section 80Section 80I

disallowance in this regard was made in the earlier assessment years towards interest expenditure. 77. On the other hand, the ld.DR supported the decision of the lower authorities. 78. We heard the rival submissions and perused the material on record. An interest rate swap contract is typically a contract between the two parties which decide to pay interest on fixed

M/S INDIANOIL SKYTANKING PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeals are partly allowed

ITA 583/BANG/2019[2015-16]Status: DisposedITAT Bangalore09 May 2022AY 2015-16

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 115Section 143(3)Section 36(1)(iii)Section 37(1)Section 80Section 80I

disallowance in this regard was made in the earlier assessment years towards interest expenditure. 77. On the other hand, the ld.DR supported the decision of the lower authorities. 78. We heard the rival submissions and perused the material on record. An interest rate swap contract is typically a contract between the two parties which decide to pay interest on fixed

M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

ITA 321/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 Apr 2023AY 2015-16

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

For Appellant: Shri Ananthan, CA&For Respondent: Shri G. Manoj Kumar, CIT-DR
Section 115JSection 14ASection 194JSection 36Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

32A of the Act at p. 896 held that section prescribes no point of time by which the reserve should be created and in this regard accepted that a reserve created after the closure of the accounts of the year qualifies by observing as under: "The second question which is raised only

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

ITA 528/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 Apr 2023AY 2015-16

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

For Appellant: Shri Ananthan, CA&For Respondent: Shri G. Manoj Kumar, CIT-DR
Section 115JSection 14ASection 194JSection 36Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

32A of the Act at p. 896 held that section prescribes no point of time by which the reserve should be created and in this regard accepted that a reserve created after the closure of the accounts of the year qualifies by observing as under: "The second question which is raised only

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE vs. M/S COFFEEDAY GLOBAL LIMITED , BANGALORE

In the result, the appeals of the Revenue are partly allowed

ITA 3041/BANG/2018[2014-15]Status: DisposedITAT Bangalore24 Feb 2020AY 2014-15

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

Section 14ASection 32(1)(iia)Section 43A

disallowing the same. 6. On appeal, the CIT(A) after considering the submissions of the assessee held that the company was eligible for additional depreciation as claimed and directed that the same be allowed. According to the CIT(A), under the circumstances, converting raw coffee beans which are not fit for human consumption as such to 'liquid coffee' which

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE vs. M/S COFFEEDAY GLOBAL LIMITED , BANGALORE

In the result, the appeals of the Revenue are partly allowed

ITA 3040/BANG/2018[2013-14]Status: DisposedITAT Bangalore24 Feb 2020AY 2013-14

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

Section 14ASection 32(1)(iia)Section 43A

disallowing the same. 6. On appeal, the CIT(A) after considering the submissions of the assessee held that the company was eligible for additional depreciation as claimed and directed that the same be allowed. According to the CIT(A), under the circumstances, converting raw coffee beans which are not fit for human consumption as such to 'liquid coffee' which

SRI Y C KALLINATHA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the assessee is allowed

ITA 728/BANG/2016[2009-10]Status: DisposedITAT Bangalore15 Feb 2017AY 2009-10

Bench: Shri Vijay Pal Rao & Shri S. Jayaramanassessment Year : 2009-10

For Appellant: Shri. S. V. Ravishankar, AdvocateFor Respondent: Shri. M. K. Biju, JCIT
Section 10ASection 32(1)(iia)Section 36(1)

32A, 33, 35 and clause (ix) of Section 36(1) and also Sections 72(1) and 74(1) and (3) operative from the assessment year 2001-2002 alone would be significant. 8. The cardinal principles of interpretation of taxing statutes centers around the opinion of Rowlatt, J. in Cape Brandy Syndicate v. Inland Revenue Commissioner [1921] 1 KB 64 which

ACIT, MANGALORE vs. M/S CORPORATION BANK, MANGALORE

In the result, appeal of the revenue stands dismissed

ITA 1264/BANG/2013[2011-12]Status: DisposedITAT Bangalore11 Mar 2015AY 2011-12

Bench: Shri Rajpal Yadav & Shri Abraham P George

For Appellant: Shri S. Ananthan, CAFor Respondent: Dr. P.K.Srihari, Addl.CIT
Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viiia)

32A of the Act at p. 896 held that section prescribes no point of time by which the reserve should be created and in this regard accepted that a reserve created after the closure of the accounts of the year qualifies by observing as under : "The second question which is raised only

DEPUTY COMMISSIONER OF INCOME TAX,, UDUPI vs. SRI ASHOK M SHETTY, UDUPI

In the result, the revenue’s appeals for the Assessment Years 2010-

ITA 1436/BANG/2014[2010-11]Status: DisposedITAT Bangalore14 Aug 2015AY 2010-11

Bench: Shri George George, K & Shri Jason P Boaz

For Appellant: Shri V. Srinivasan, CAFor Respondent: Dr. P.K.Srihari, Addl.CIT
Section 10Section 10BSection 133ASection 143(3)Section 2

disallowance of deduction u/s 10B is that the appellant has not satisfied the third condition that it is not formed by transfer to a new business or machinery or plant previously used for any purpose. From the copies of the ledger accounts, balance sheets and fixed account schedules of Ashok Exports and Ashok Impex, it is clear that no machinery

JOINT COMMISSIONER OF INCOME TAX, LTU,, , BENGALURU vs. M/S. VIJAYA BANK, BENGALURU

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

ITA 1834/BANG/2018[2014-15]Status: DisposedITAT Bangalore11 Mar 2022AY 2014-15

Bench: Shri George George K & Ms. Padmavathy Sassessment Year : 2014-15

For Appellant: Shri Ananthan, C.A &For Respondent: Shri Pradeep Kumar, CIT(DR)
Section 115JSection 143(3)Section 234DSection 36(1)(vii)Section 36(1)(viia)Section 36(2)(v)Section 37(1)(vii)

32A of the Act at p. 896 held that section prescribes no point of time by which the reserve should be created and in this regard accepted that a reserve created after the closure of the accounts of the year qualifies by observing as under: "The second question which is raised only

TEXAS INSTRUMENTS (INDIA) PRIVATE LIMITED,BANGALORE vs. CIT, BANGALORE

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

ITA 731/BANG/2016[2009-10]Status: DisposedITAT Bangalore07 Jan 2021AY 2009-10

Bench: Shri N.V. Vasudevan & Shri B R Baskaranit(Tp)A No.731/Bang/2016 Assessment Year: 2009-10 M/S. Texas Instruments (India) Private Limited, Vs. The Additional Commissioner Of Bagmane Tech Park, Income Tax, Ltu, No.66/3, Adjacent To Lrde, Bangalore. Byrasandra, C V Raman Nagar, Bangalore – 560 093. Pan: Aaact 5445M Appellant Respondent Assessee By : Shri. Sharath Rao, Ca Revenue By : Shri. Pradeep Kumar, Cit (Dr) (Itat), Bengaluru. Date Of Hearing : 6.1.2020 Date Of Pronouncement : 7.1.2020

For Appellant: Shri. Sharath Rao, CAFor Respondent: Shri. Pradeep Kumar, CIT (DR) (ITAT), Bengaluru
Section 143(3)Section 263

32A of the Act, held that if appliances are capable of being installed and used in any place where people work or gather, and desire to communicate, such items cannot be construed as office appliances - the only requirement for claiming deduction under section 32(1)(iia) of the Act is that the assessee should be engaged in the business

M/S.FABSUN ENGINEERING PVT. LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BAILUR

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

ITA 1616/BANG/2016[2012-13]Status: DisposedITAT Bangalore31 Jan 2020AY 2012-13

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri.Balram R. Rao, AdvocateFor Respondent: Smt.Swapna Das, JCIT-DR
Section 54FSection 54GSection 54G(1)

disallowing the deduction claimed by the appellant uls 54G of the Act is accordingly, confirmed. The grounds of appeal raised in this regard are dismissed. 5. Against this, the assessee is in appeal before us. The learned AR reiterated the submissions made before the lower authorities. On the other hand, the learned Departmental Representative submitted that the assessee failed

M/S. HEALTHCARE GLOBAL ENTERPRISES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX,, BANGALORE

In the result, the appeal filed by the assessee for Assessment Year 2010-11 is dismissed

ITA 1901/BANG/2016[2010-11]Status: DisposedITAT Bangalore15 Dec 2017AY 2010-11

Bench: Shri Arun Kumar Garodia & Shri Lalit Kumar

For Appellant: Shri K.P. Srinivas, CAFor Respondent: Shri B.R. Ramesh, JCIT (DR)
Section 72ASection 79

disallowed by invoking the provisions of section 79 of the IT Act. Therefore, on this issue, we decide the issue in favour of the assessee. This ground of the assessee is allowed. 8. In the result the appeal of the assessee for Assessment Year 2009-10 is partly allowed. 9. Now we take up the appeal of the assessee