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1,091 results for “disallowance”+ Section 73clear

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Mumbai4,014 Delhi3,353 Bangalore1,091 Kolkata1,071 Chennai1,023 Ahmedabad881 Pune635 Hyderabad541 Jaipur499 Indore386 Chandigarh308 Surat265 Cochin204 Visakhapatnam146 Cuttack138 Raipur138 Lucknow103 Rajkot89 Nagpur81 Amritsar71 Jodhpur50 Guwahati49 Ranchi49 Karnataka47 Allahabad47 Calcutta44 Patna30 Agra24 Dehradun24 Telangana19 Panaji17 SC17 Jabalpur16 Varanasi10 Punjab & Haryana3 Rajasthan2 Kerala2 Gauhati1 Orissa1

Key Topics

Addition to Income80 Section 143(3)64 Disallowance50 Section 143(1)44 Section 14A35 Section 14833 Section 153C33 Deduction32 Section 10A30 Section 40

M/S UNITED BREWERIES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

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

ITA 481/BANG/2018[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR

Section 115JSection 143(2)Section 143(3)Section 14ASection 40Section 43B

73,88,587 Disallowance under section 14A 1,31,50,663 Disallowance under section 40(a)(ia) 8,24,77,951 Disallowance

Showing 1–20 of 1,091 · Page 1 of 55

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Section 139(1)25

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

disallowance as relatable to SEZ units. 47. Assuming without admitting that the payments made to Infosys Technologies (China) Co Ltd amounting to Rs.262,02,26,125 are liable for TDS u/s 195, as the demand raised under section 201(1)/(1A) in respect of the aforesaid payment has been fully paid in FY 2013-14, the said expenditure should

M/S INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 735/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R

Section 11Section 14ASection 194JSection 234BSection 40Section 80J

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

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

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 809/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R

Section 11Section 14ASection 194JSection 234BSection 40Section 80J

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU, BENGALURU vs. INFOSYS LIMITED, BENGALURU

In the result, appeal filed by the assessee is partly allowed and the appeal filed by the revenue is dismissed

ITA 245/BANG/2024[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt. Srinandini Das – CIT - DR

Section 1Section 10ASection 155Section 250

disallowance of deduction under section 10AA: 3.1. The learned NAC and the CIT(A) has erred in reducing the following incomes from profits of the business of SEZ units in computing deduction under section 10AA for the reason that the said incomes are not derived from the activity of software development and export. i) Interest on non-convertible debentures (NCDs

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

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

disallowing a sum of Rs. 6,18,73,785/- by invoking the provisions of section 40 (a)(ia) of the Act for non deduction

M/S. BRIGADE ENTERPRISES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

In the result appeal filed by assessee stands partly allowed

ITA 2364/BANG/2019[2013-14]Status: DisposedITAT Bangalore11 Oct 2021AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14 M/S. Brigade Enterprises Ltd., 26/1, 30Th Floor Wtc, The Dy. Commissioner Of Dr. Rajkumar Road, Income-Tax, Malleshwaram, Circle-2(3), Rajajinagar, Bengaluru. Vs. Bengaluru-560 100. Pan – Aaacb 7459 F Appellant Respondent Assessee By : Shri P.C Kincha, C.A Revenue By : Ms. Neera Malhotra, Cit(Dr) Date Of Hearing : 20-07-2021 Date Of Pronouncement : 11-10-2021 Order Per Beena Pillaipresent Appeal Has Been Filed By Assessee Against Order Dated 30/08/2019 Passed By The Ld.Cit(A)-11, Bangalore For Assessment Year 2013-14 On Following Grounds Of Appeal: “1. General Ground 1.1. The Order Passed By The Learned Commissioner Of Income Tax (Appeals) ["Cit(A) For Short Hereinafter"] To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. 2. Disallowance Under Section 14A R.W. Rule 8D 2.1. The Learned Deputy Commissioner Of Income Tax Central Circle - 2(3), Bangalore ["Ao" For Short Hereinafter] Has Erred In Making A Disallowance Of Rs. 2,02,22,837/- Under Se Tion 14A Comprising Of Disallowa,,Ø-1S. 1,73,98,969/- Under Rule 8D(2)(Ii) & Rs. 28,23,868/- Under Rule 8D(2)(Iii) & The Learned Cit(A) Has Erred In Confirming The Said Disallowance.

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

Section 14ASection 35DSection 36Section 36(1)(iii)Section 80

section 14A r.w. Rule 8D 2.1. The learned Deputy Commissioner of Income Tax Central Circle - 2(3), Bangalore ["AO" for short hereinafter] has erred in making a disallowance of Rs. 2,02,22,837/- under se tion 14A comprising of disallowa,,Ø-1s. 1,73

M/S. UNITED SPIRITS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BENGALURU

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

ITA 2701/BANG/2017[2013-14]Status: DisposedITAT Bangalore04 Apr 2022AY 2013-14

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2701/Bang/2017 : Asst.Year 2013-2014 M/S.United Spirits Limited The Deputy Commissioner Of Ub Towers, Income-Tax, Circle 7(1)(1) V. No.24 Vittal Mallya Road Bangalore. Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Senior Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 05.04.2022 Date Of Hearing : 24.03.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 12.10.2017 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In The Manufacture & Sale Of Alcoholic Beverage. The Assessee Filed Its Return Of Income For The Assessment Year 2013-2014 On 28.11.2013 Which Was Selected For Scrutiny Assessment. During The Course Of Assessment, The Assessee’S Case Was Also Referred To The Transfer Pricing Officer (Tpo). The Tpo Vide Order Dated 26.10.2016, Recommended Transfer Pricing Adjustments. The A.O., Thereafter, Passed A Draft Assessment Order Dated 30.12.2016. 2 It(Tp)A No.2701/Bang/2017 M/S.United Spirits Limited.

For Appellant: Sri.Percy Pardiwala, Senior AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR

Section 143(3)Section 14ASection 234BSection 234CSection 36(1)(iii)

disallowed, the closing stock also ought to be reduced from the taxable income resulting in no tax impact. 30 IT(TP)A No.2701/Bang/2017 M/s.United Spirits Limited. (iv) Notwithstanding and without prejudice to the above, we wish to submit that the TPO has not applied any of the six methods as prescribed under section 92C of the Act to determine

TEXO THE BUILDERS ,UDUPI vs. ACIT, CENTRAL CIRCLE-2, MANGALORE

In the result, we dismiss grounds raised by the assessee

ITA 1200/BANG/2025[2014-15]Status: DisposedITAT Bangalore13 Nov 2025AY 2014-15

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

For Appellant: Shri. Sandeep Chalapathy, CAFor Respondent: Shri. Subramanian S,JCIT(DR)(ITAT), Bangalore

Section 133ASection 147Section 148Section 154Section 40A(3)Section 68

section 40A(3) is warranted. Thus, in view of the facts of case and various decisions discussed above, we do not find any error in the findings of Commissioner (Appeals) in deleting disallowances of Rs. 60,73

CHANDRASHEKAR HEMANTH ,BENGALURU vs. INCOME TAX OFFICER WARD 7(2)(4) BANGALORE, BENGALURU

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

ITA 1677/BANG/2024[2017-18]Status: DisposedITAT Bangalore06 Jan 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Siddesh Nagaraj Gaddi, CAFor Respondent: Shri Sridhar E, CIT-DR

Section 139(1)Section 143(2)Section 250Section 69ASection 80

sections 72(1), 73(2), 73A(2), 74(1) or (3) and 74A(3) and 80 of the Act were relied on by the Ld.AR and contended that the losses in respect of the previous years could be set off against the current Page 4 of 14 years profits when the assessee had filed their return of income

DELL INDIA P LTD,BANGALORE vs. INCOME TAX OFFICER(TDS), LTU, BANGALORE

In the result the appeals filed by assessee and revenue for A

ITA 1644/BANG/2014[2012-13]Status: DisposedITAT Bangalore25 Mar 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

Section 40(a)(ia) and taxes paid on the same, there is no loss to revenue to the Government as the revenue is more than adequately compensated in the form of higher taxes by the deductor due to disallowance u/s 40(a)(ia). In this regard, the Company had made a detailed submission before the learned AO vide submission dated

INCOME TAX OFFICER, BANGALORE vs. M/S.DELL INDIA PVT.LTD.,, BANGALORE

In the result the appeals filed by assessee and revenue for A

ITA 2035/BANG/2016[2014-15]Status: DisposedITAT Bangalore25 Mar 2022AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

Section 40(a)(ia) and taxes paid on the same, there is no loss to revenue to the Government as the revenue is more than adequately compensated in the form of higher taxes by the deductor due to disallowance u/s 40(a)(ia). In this regard, the Company had made a detailed submission before the learned AO vide submission dated

DELL INTERNATIONAL SERVICES INDIA PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result the appeals filed by assessee and revenue for A

ITA 1151/BANG/2015[2012-13]Status: DisposedITAT Bangalore25 Mar 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

Section 40(a)(ia) and taxes paid on the same, there is no loss to revenue to the Government as the revenue is more than adequately compensated in the form of higher taxes by the deductor due to disallowance u/s 40(a)(ia). In this regard, the Company had made a detailed submission before the learned AO vide submission dated

M/S ALTISOURCE BUSINESS SOLUTIONS PVT. LTD.,,BANGALORE vs. ACIT, BANGALORE

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

ITA 208/BANG/2016[2011-12]Status: DisposedITAT Bangalore02 Jul 2021AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.208/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Shri Shishir Srivastava, CIT

Section 143Section 144C(13)Section 144C(5)Section 92C

section 40(a) when TDS liability on such expenses has arisen due to retrospective amendment. 18. Disallowance of brought forward business loss and unabsorbed depreciation —INR21,112,859 The learned AO has erred in disallowing brought forward business loss and unabsorbed depreciation amounting to INR Rs.1,64,07.586 and INR 47,05,273 respectively which is consequential in nature

M/S LIFESTYLE INTERNATIONAL PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the results appeal filed by assessee for assessment year

ITA 2826/BANG/2017[2012-13]Status: DisposedITAT Bangalore11 Oct 2021AY 2012-13

Bench: Shri Chandra Poojari & Smt Beena Pillai

disallowed the same under section 43(5) of the Act read with 73 of the Act, by stating that it is a speculation

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE vs. M/S LIFESTYLE INTERNATIONAL PVT LTD , BANGALORE

In the results appeal filed by assessee for assessment year

ITA 2473/BANG/2017[2012-13]Status: DisposedITAT Bangalore11 Oct 2021AY 2012-13

Bench: Shri Chandra Poojari & Smt Beena Pillai

disallowed the same under section 43(5) of the Act read with 73 of the Act, by stating that it is a speculation

M/S.LIFESTYLE INTERNATIONAL PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE

In the results appeal filed by assessee for assessment year

ITA 2334/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Oct 2021AY 2011-12

Bench: Shri Chandra Poojari & Smt Beena Pillai

disallowed the same under section 43(5) of the Act read with 73 of the Act, by stating that it is a speculation

M/S.LIFESTYLE INTERNATIONAL PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE

In the results appeal filed by assessee for assessment year

ITA 2333/BANG/2016[2009-10]Status: DisposedITAT Bangalore11 Oct 2021AY 2009-10

Bench: Shri Chandra Poojari & Smt Beena Pillai

disallowed the same under section 43(5) of the Act read with 73 of the Act, by stating that it is a speculation

ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. LIFESTYLE INTERNATIONAL (P) LTD.,, BANGALORE

In the results appeal filed by assessee for assessment year

ITA 2260/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Oct 2021AY 2011-12

Bench: Shri Chandra Poojari & Smt Beena Pillai

disallowed the same under section 43(5) of the Act read with 73 of the Act, by stating that it is a speculation

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

ITA 298/BANG/2021[2016-17]Status: DisposedITAT Bangalore24 Apr 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri Madhur Agarwal, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 144C(10)Section 92CSection 92C(3)

disallowance under section 80G amounting to INR 2,81,50,000 5. Non-allowability of additional claim filed by the Appellant pertaining to deduction of education cess amounting to INR 3.10.24.528 5.1 The Honorable DRP and learned AO have erred in law and on facts in not allowing the additional claim filed by the Appellant pertaining to deduction of education