DCIT, C-V, LUDHIANA vs. M/S HERO CYCLES LTD., LUDHIANA

In the result, appeal of the Department is dismissed and the appeal of the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 588/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 The DCIT C-V, Ludhiana बनाम M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 473/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana बनाम The ACIT C-V, Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P

disallowance of interest expenditure on amount advanced to subsidiary company and held that - "Commercial expediency in advancing loan does not arise only on account of there being transactions directly between holding company and subsidiary company. The two companies may even be in a different line of business. It would make no difference. It would still be commercially expedient

M/S HARYANA STATE INDUSTRIAL & INFRASTRUCTURE DEVELOPMENT CORPN.,,PANCHKULA vs. ACIT,, PANCHKULA

In the result, all the above appeals of the assessee are

Bench: The Itat. That In The First Round The Itat Had Held The Provisions Of Section 14A Of The Act, For The Purposes Of Disallowing Expenses Relating To Exempt Income, Applicable In The Facts Of The Present Cases On Noting That The Assessee Had Earned Exempt Income In The Form

section 14A of the Act and as per law. That subsequently the AO, after giving due opportunity of hearing to the assessee, had worked out the disallowance by applying the mathematical formula provided in Rule 8D of the Income Tax Rule, 1962 for the said purpose, making disallowance of expenses for the impugned assessment years as under: Asstt. Year Disallowance

RAMJEE CONCRETES PVT.LTD.,MOHALI vs. ITO-WARD-6(3), CHANDIGARH

The appeals are disposed of in the aforesaid terms

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 205/Chd/2021 "नधा"रण वष" / Assessment Year : 2019-20 Ramjee Concretes Private Limited, The Ito, बनाम #1238.Sector 91, Ward 6(3), Mohali, Punjab Chandigarh "थायी लेखा सं./Pan No: Aafcr9457E अपीलाथ"/Appellant ""यथ"/Respondent

207]. ITA No. 205-Chd-2021 Ramjee Concretes Private Limited, Chandigarh 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall not be deducted in computing the income chargeable under the head “profits and gains of business

ACIT, LUDHIANA vs. M/S AVON CYCLES LTD., LUDHIANA

In the result, the appeal filed by the Revenue is

Bench: Ms.Diva Singh & Ms. Annapurna Guptathe A.C.I.T., Vs. M/S Avon Cycles Ltd., Circle-5, G.T. Road, Ludhiana. Ludhiana. Pan: Aabca4140R & C.O.No.6/Chd/2016 In M/S Avon Cycles Ltd., Vs. The A.C.I.T., G.T. Road, Circle-5, Ludhiana. Ludhiana. Pan: Aabca4140R (Appellant) (Respondent)

disallowance of interest under section 36(1)(iii) of the Act on account of the same was warranted having been decided in the preceding years itself in favour of the assessee. As for the investment made in the impugned year amounting to Rs.1.21 crores, the Ld. counsel for the assessee stated that it had enough own funds for making

M/S CHADHA SUPER CARS (P) LTD vs. ADDL. CIT, LUDHIANA

In the result appeal of the Assessee is allowed

disallowance of Rs. 1266628/- made under section 36(1)(iii) of the Income Tax Act,1961 by the Ld. CIT(A)-II, Ludhiana may be quashed. 3. The facts of the case in brief are that the assessee has made investments in the shares of the Company namely R.S. Castings Pvt. Ltd. and R.S. Strips

ACIT,, LUDHIANA vs. M/S VARDHMAN TEXTILES LTD.,, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

disallowance of Rs. 1,00,000/- made by the Ld. CIT(A). In the instant year the Ld. CIT(A) has confirmed an amount of Rs. 2,00,000/- being the expenses incurred for earning of the dividend income. Following the same rationale we hereby uphold the order of the Ld. CIT(A). 7.4 As a result, the appeal

ACIT, LUDHIANA vs. M/S VARDHMAN TEXTILES LTD., LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

disallowance of Rs. 1,00,000/- made by the Ld. CIT(A). In the instant year the Ld. CIT(A) has confirmed an amount of Rs. 2,00,000/- being the expenses incurred for earning of the dividend income. Following the same rationale we hereby uphold the order of the Ld. CIT(A). 7.4 As a result, the appeal

M/S VARDHMAN TEXTILES LTD.,,LUDHIANA vs. ADDL. CIT,, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

disallowance of Rs. 1,00,000/- made by the Ld. CIT(A). In the instant year the Ld. CIT(A) has confirmed an amount of Rs. 2,00,000/- being the expenses incurred for earning of the dividend income. Following the same rationale we hereby uphold the order of the Ld. CIT(A). 7.4 As a result, the appeal

VARDHMAN TEXTILE LTD.,LUDHIANA vs. ACIT, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

disallowance of Rs. 1,00,000/- made by the Ld. CIT(A). In the instant year the Ld. CIT(A) has confirmed an amount of Rs. 2,00,000/- being the expenses incurred for earning of the dividend income. Following the same rationale we hereby uphold the order of the Ld. CIT(A). 7.4 As a result, the appeal

ACIT, LUDHIANA vs. VARDHMAN TEXTILES LTD., LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

disallowance of Rs. 1,00,000/- made by the Ld. CIT(A). In the instant year the Ld. CIT(A) has confirmed an amount of Rs. 2,00,000/- being the expenses incurred for earning of the dividend income. Following the same rationale we hereby uphold the order of the Ld. CIT(A). 7.4 As a result, the appeal

ACIT,, LUDHIANA vs. M/S VARDHMAN TEXTILES LTD.,, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

disallowance of Rs. 1,00,000/- made by the Ld. CIT(A). In the instant year the Ld. CIT(A) has confirmed an amount of Rs. 2,00,000/- being the expenses incurred for earning of the dividend income. Following the same rationale we hereby uphold the order of the Ld. CIT(A). 7.4 As a result, the appeal

VARDHMAN TEXTILES LTD.,,LUDHIANA vs. JCIT,, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

disallowance of Rs. 1,00,000/- made by the Ld. CIT(A). In the instant year the Ld. CIT(A) has confirmed an amount of Rs. 2,00,000/- being the expenses incurred for earning of the dividend income. Following the same rationale we hereby uphold the order of the Ld. CIT(A). 7.4 As a result, the appeal

M/S VARDHMAN TEXTILES LTD.,LUDHIANA vs. ACIT, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

disallowance of Rs. 1,00,000/- made by the Ld. CIT(A). In the instant year the Ld. CIT(A) has confirmed an amount of Rs. 2,00,000/- being the expenses incurred for earning of the dividend income. Following the same rationale we hereby uphold the order of the Ld. CIT(A). 7.4 As a result, the appeal

DCIT, CHANDIGARH vs. M/S KHANDELIA OIL & GENERAL MILLS PVT. LTD., CHANDIGARH

In the result, Appeal of the Revenue and the Cross Appeal of the Assessee are partly allowed for statistical purposes

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

207/- Total Rs. 3.66,536/- 12.2 As per assessment order, the assessee had not furnished any details of the services rendered and confirmations from these persons which were specifically asked for in the assessment proceedings. The Assessing Officer has also noticed that all the payments of brokerage have been made in cash in Kolkatta unit. The Assessing Officer finally disallowed

KHANDELIA OIL & GENERAL MILLS LTD.,CHANDIGARH vs. ADDL. CIT, CHANDIGARH

In the result, Appeal of the Revenue and the Cross Appeal of the Assessee are partly allowed for statistical purposes

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

207/- Total Rs. 3.66,536/- 12.2 As per assessment order, the assessee had not furnished any details of the services rendered and confirmations from these persons which were specifically asked for in the assessment proceedings. The Assessing Officer has also noticed that all the payments of brokerage have been made in cash in Kolkatta unit. The Assessing Officer finally disallowed

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

disallowed the foreign travel expenses which clearly form part of the operating expenses and the cost base and on which the assessee has reported the revenues after considering the mark up of 16.60%. Such an action on part of the AO is clearly in breach of letter and spirit of the APA which has been entered into by CBDT

ACIT, C-4, LUDHIANA vs. M/S AARTI STEELS LIMITED, LUDHIANA

Appeal of the Assessee are dismissed

207/-. 3. During the year the Assessing Officer has disallowed Rs. 10.54 Lacs under section 14A r.w.r 8D(1) calculating

M/S AARTI STEELS LIMITED,LUDHIANA vs. ADDL. CIT, R-5 , LUDHIANA

Appeal of the Assessee are dismissed

207/-. 3. During the year the Assessing Officer has disallowed Rs. 10.54 Lacs under section 14A r.w.r 8D(1) calculating

SH. RANA,LUDHIANA vs. ITO, LUDHIANA

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

Section 40(a)(ia) whereby it is provided that 30% of any sum payable to a resident shall be disallowed if tax is not deducted at source under Ch. XVIIB as against the 100% disallowance presently made. The purpose of this amendment was explained in the memorandum as under:- "the disallowance of whole of the amount of expenditure results into