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979 results for “disallowance”+ Section 9(1)(vii)clear

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Section 143(3)75Addition to Income63Disallowance53Section 153A52Section 4044Deduction44Section 36(1)(vii)32Section 10A30Section 14A23Section 148

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

ITA 161/PAN/2019[2015-16]Status: DisposedITAT Bangalore30 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

For Appellant: Shri Ananthan S. & Smt. Lalitha Rameswaran, CAsFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 14ASection 234BSection 36(1)(vii)Section 36(1)(viia)Section 40Section 41(4)

disallowed the claim made u/s 36(1)(vii) on identical reasons. However, the Tribunal has reversed the decision rendered by Ld CIT(A) by following the decision rendered by Hyderabad bench of Tribunal in the case of State Bank of ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 9 of 46 Hyderabad vs. DCIT (ITA No.450/Hyd/2015, ITA No.498 and 499/Hyd/2015 dated August

Showing 1–20 of 979 · Page 1 of 49

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Section 25021
Depreciation17

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

ITA 1107/BANG/2019[2015-16]Status: DisposedITAT Bangalore30 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

For Appellant: Shri Ananthan S. & Smt. Lalitha Rameswaran, CAsFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 14ASection 234BSection 36(1)(vii)Section 36(1)(viia)Section 40Section 41(4)

disallowed the claim made u/s 36(1)(vii) on identical reasons. However, the Tribunal has reversed the decision rendered by Ld CIT(A) by following the decision rendered by Hyderabad bench of Tribunal in the case of State Bank of ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 9 of 46 Hyderabad vs. DCIT (ITA No.450/Hyd/2015, ITA No.498 and 499/Hyd/2015 dated August

M/S SYNDICATE BANK,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, UDUPI

In the result, appeal of the revenue in ITA No

ITA 1219/BANG/2019[2015-16]Status: DisposedITAT Bangalore08 Aug 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Shri S. Ananthan, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115JSection 36(1)(vii)Section 36(1)(viia)

9 of 32 Thus, considered in light of principle laid down as referred to above, when the proviso to section 36(1)(vii) applies to bad debts written off relating to rural advances, the same cannot be applied for disallowing

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)

9. Ground No. 2 relates to disallowance of bad debts written off under Section 36(1)(vii) of the Act. The facts

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)

9. Ground No. 2 relates to disallowance of bad debts written off under Section 36(1)(vii) of the Act. The facts

THE KARNATAKA BANK LTD,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), MANGALURU

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

ITA 1907/BANG/2018[2014-15]Status: DisposedITAT Bangalore26 May 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranthe Karnataka Bank Ltd. Dcit, Circle - 2(1) Head Office, Mahaveera Circle Mangalore Vs. Kankanady Mangalore 575002 Pan – Aabct5589K Appellant Respondent Dcit, Circle – 2(1) The Karnataka Bank Ltd. Mangalore Head Office, Mahaveera Circle Vs. Kankanady Mangalore 575002 Pan – Aabct5589K Appellant Respondent Assessee By: Shri S. Ananthan, Ca & Smt. Lalitha Rameswaran, Ca Revenue By: Shri Mudavathu Harish Chandra Naik, Ca Date Of Hearing: 22.03.2022 Date Of Pronouncement: 26.05.2022 O R D E R Per: B.R. Baskaran, A.M. These Cross Appeals Are Directed Against The Order Dated 27-03-2018 Passed By Ld Cit(A), Mangaluru & They Relate To The Assessment Year 2014-15. 2. The Assessee Is A Banking Company Carrying On Banking Business. The Karnataka Bank Ltd.

For Appellant: Shri S. Ananthan, CA &For Respondent: Shri Mudavathu Harish
Section 14A

disallowance of Rs.192.02 crores.” 7.5 The Ld A.R submitted that the Ld CIT(A) has rendered his decision by following his decision rendered in AY 2013-14 and earlier years. He submitted that Finance Act, 2013 has inserted “Explanation 2” in sec. 36(1)(vii) of the Act and the same reads as under:- “Explanation 2 – For the removal

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 1177/BANG/2017[2014-15]Status: DisposedITAT Bangalore28 Nov 2019AY 2014-15

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

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

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

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

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

DEPUTY COMMISSIONER OF INCOME-TAX,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 1312/BANG/2016[2013-14]Status: DisposedITAT Bangalore28 Nov 2019AY 2013-14

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

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

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

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

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

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

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

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 2470/BANG/2018[2009-10]Status: DisposedITAT Bangalore28 Nov 2019AY 2009-10

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

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

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER 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 2818/BANG/2017[2015-16]Status: DisposedITAT Bangalore28 Nov 2019AY 2015-16

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

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

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

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

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

DEPUTY COMMISSIONER OF INCOME TAX,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 1313/BANG/2016[2014-15]Status: DisposedITAT Bangalore28 Nov 2019AY 2014-15

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

M/S VODAFONE SOUTH 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 2473/BANG/2018[2012-13]Status: DisposedITAT Bangalore28 Nov 2019AY 2012-13

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

Section 201

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts