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31 results for “disallowance”+ Section 272(1)(d)clear

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Key Topics

Section 14A23Addition to Income17Section 25011Reassessment11Section 8010Section 14810Disallowance10Deduction9Reopening of Assessment9

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

ITA 588/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh08 Sept 2025AY 2012-13

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

For Appellant: Shri Ashwani Kumar, Shri Ashish Aggarwal &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(38)Section 143(1)Section 14ASection 36(1)(iii)

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

Showing 1–20 of 31 · Page 1 of 2

Section 143(3)8
Section 1478
Section 80P(2)(a)6

IND SWIFT LABORATORIES LTD.,CHANDIGARH vs. DCIT, CIRCLE 1(1), CHANDIGARH

In the result, the appeal is allowed, as indicated

ITA 350/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh04 Jun 2024AY 2017-18

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri T.N.Singla, C.AFor Respondent: Shri Rohit Sharma, CIT-DR
Section 250Section 35Section 35(1)Section 35(1)(i)Section 35(2)

272 Taxman 90 (SC)], the assessee funded its sister concern without charging interest and AO disallowed such interest expenditure. The Hon'ble Bombay High Court held that there was no finding by the AO that the funds were not utilized for business purposes and that ITA 350/CHD/2023 A.Y. 2017-18 71 advancing loans to the sister concern was for purpose

ACIT, C-6, LUDHIANA vs. MAJESTIC HOTELS LTD., LUDHIANA

The appeal of the Revenue is dismissed

ITA 171/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh26 Nov 2018AY 2012-13
For Appellant: Shri Jagdeep Goel, CIT DRFor Respondent: Shri R.S. Khera, CA
Section 14ASection 250

272 CTR 277 (All), the Hon'ble Delhi High Court in the case of Cheminvest Ltd. (2015) 378 ITR 33(Del) and the Hon'ble Madras High Court in the case of Redington (India) Ltd. (2017) 392 ITR 633. 6. Before us the Ld. DR relied upon the order of the A.O. and stated that the claim of the assessee

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

ITA 644/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh18 Sept 2024AY 2015-16

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Rohit Jain, Advocate and Ms. Somya Jain, C.AFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 250Section 253Section 3

D B (India) Securities Ltd: 318 ITR 26 (Del) - CIT v. Bonanza Portfolio Ltd: 320 ITR 178 (Del) - CIT v. Shreyas S. Morakhia: 342 ITR 285 (Bom.) - CIT v. Pudumjee Pulp & Paper Mills Ltd.: 235 Taxman 451 (Bom.) - Angel Capital and Debt Market Ltd. v. ACIT: 118 TTJ 351 (Mum ITAT) - Angel Commodities Broking (P.) Ltd. v. DCIT

ACIT, CIRCLE, PANCHKULA vs. M/S JANAK GLOBAL RESOURCES PVT. LTD., PANCHKULA

In the result, the appeal of the Revenue is dismissed

ITA 470/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh16 Oct 2018AY 2014-15
For Appellant: Shri Manoj KumarFor Respondent: Shri Parikshit Aggarwal, CA
Section 36Section 36(1)(iii)

272 CTR 265 (P&H) and jurisdictional ITAT Chandigarh decision in the case of Swami Automobiles (P) Ltd. ITA No.74/Chd/2015 dated 10.02.2016, it is held that no disallowance u/s 40A read with rule 8D of the Income tax Rules was warranted in this case . Therefore addition of Rs.25,43,299/- made by the AO on this account for A.Y.2014-15

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

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

ITA 275/CHANDI/2020[2006-07]Status: DisposedITAT Chandigarh04 Mar 2021AY 2006-07

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

For Appellant: Shri A.K. Jindal, CAFor Respondent: Smt.Meenakshi Vohra, Addl.CIT
Section 14ASection 250(6)

D of the Rules in a mechanical manner. And lastly he argued that the assessee had not made investments in the shares of the borrowed funds. The investments have been made out of the interest free funds of the assessee. 12.2.1 On careful perusal of facts of the case, I find merit in the arguments of the appellant ARs. First

WARYAM STEEL CASTINGS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

ITA 715/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh14 May 2025AY 2019-20

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, C.A and Ms. Muskan Garg, C.AFor Respondent: Shri Ved Parkash Kalia, Sr. DR
Section 115JSection 148Section 250

disallowed entire purchases of Rs.4.17 Crores under Section 69C. The CIT(A) applied GP rate of 3.67% on bogus purchases, whereas the Tribunal enhanced the disallowance to 12.5% of bogus purchases. 5.6.7. The AO has, in the impugned order discussed as to how the assessee has not maintained Stock register, along with other reasons, based upon this finding

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

ITA 757/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh14 May 2025AY 2019-20

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, C.A and Ms. Muskan Garg, C.AFor Respondent: Shri Ved Parkash Kalia, Sr. DR
Section 115JSection 148Section 250

disallowed entire purchases of Rs.4.17 Crores under Section 69C. The CIT(A) applied GP rate of 3.67% on bogus purchases, whereas the Tribunal enhanced the disallowance to 12.5% of bogus purchases. 5.6.7. The AO has, in the impugned order discussed as to how the assessee has not maintained Stock register, along with other reasons, based upon this finding

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

ITA 596/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh30 May 2025AY 2017-18

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

272 CTR 265 (P&H HC) c. Deepak Mittal (2014) 361 ITR 131 (P&H) d. Shivam Motors (P) Ltd. (2015) 230 Taxman 63 (All. HC) e. Vardhman Chemtech Private Ltd. dtd.22.04.2016 79. During hearing, the ld. DR argued that the assessee had made substantial investments and incurred significant interest expenditure of Rs. 156.71 crores during the year. Despite

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

ITA 594/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh30 May 2025AY 2016-17

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

272 CTR 265 (P&H HC) c. Deepak Mittal (2014) 361 ITR 131 (P&H) d. Shivam Motors (P) Ltd. (2015) 230 Taxman 63 (All. HC) e. Vardhman Chemtech Private Ltd. dtd.22.04.2016 79. During hearing, the ld. DR argued that the assessee had made substantial investments and incurred significant interest expenditure of Rs. 156.71 crores during the year. Despite

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA

Appeal is allowed

ITA 593/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh30 May 2025AY 2016-17

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

272 CTR 265 (P&H HC) c. Deepak Mittal (2014) 361 ITR 131 (P&H) d. Shivam Motors (P) Ltd. (2015) 230 Taxman 63 (All. HC) e. Vardhman Chemtech Private Ltd. dtd.22.04.2016 79. During hearing, the ld. DR argued that the assessee had made substantial investments and incurred significant interest expenditure of Rs. 156.71 crores during the year. Despite

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA

Appeal is allowed

ITA 592/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh30 May 2025AY 2016-17

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

272 CTR 265 (P&H HC) c. Deepak Mittal (2014) 361 ITR 131 (P&H) d. Shivam Motors (P) Ltd. (2015) 230 Taxman 63 (All. HC) e. Vardhman Chemtech Private Ltd. dtd.22.04.2016 79. During hearing, the ld. DR argued that the assessee had made substantial investments and incurred significant interest expenditure of Rs. 156.71 crores during the year. Despite

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DCIT,CIRCLE, PANCHKULA, PANCHKULA

Appeal is allowed

ITA 588/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh30 May 2025AY 2014-15

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

272 CTR 265 (P&H HC) c. Deepak Mittal (2014) 361 ITR 131 (P&H) d. Shivam Motors (P) Ltd. (2015) 230 Taxman 63 (All. HC) e. Vardhman Chemtech Private Ltd. dtd.22.04.2016 79. During hearing, the ld. DR argued that the assessee had made substantial investments and incurred significant interest expenditure of Rs. 156.71 crores during the year. Despite

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

ITA 591/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh30 May 2025AY 2015-16

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

272 CTR 265 (P&H HC) c. Deepak Mittal (2014) 361 ITR 131 (P&H) d. Shivam Motors (P) Ltd. (2015) 230 Taxman 63 (All. HC) e. Vardhman Chemtech Private Ltd. dtd.22.04.2016 79. During hearing, the ld. DR argued that the assessee had made substantial investments and incurred significant interest expenditure of Rs. 156.71 crores during the year. Despite

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE,, PANCHKULA

Appeal is allowed

ITA 590/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh30 May 2025AY 2015-16

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

272 CTR 265 (P&H HC) c. Deepak Mittal (2014) 361 ITR 131 (P&H) d. Shivam Motors (P) Ltd. (2015) 230 Taxman 63 (All. HC) e. Vardhman Chemtech Private Ltd. dtd.22.04.2016 79. During hearing, the ld. DR argued that the assessee had made substantial investments and incurred significant interest expenditure of Rs. 156.71 crores during the year. Despite

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DCIT, CIRCLE, PANCHKULA, PANCHKULA

Appeal is allowed

ITA 589/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh30 May 2025AY 2015-16

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

272 CTR 265 (P&H HC) c. Deepak Mittal (2014) 361 ITR 131 (P&H) d. Shivam Motors (P) Ltd. (2015) 230 Taxman 63 (All. HC) e. Vardhman Chemtech Private Ltd. dtd.22.04.2016 79. During hearing, the ld. DR argued that the assessee had made substantial investments and incurred significant interest expenditure of Rs. 156.71 crores during the year. Despite

M/S GREATER MOHALI AREA DEVELOPMENT AUTHORITY,MOHALI vs. DCIT, C-6(1), MOHALI

In the result, the appeal of the assessee is hereby dismissed

ITA 1560/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh22 May 2018AY 2009-10

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumarassessment Year : 2009-10

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Sh. Gulshan Raj, CIT DR
Section 139Section 142Section 143(3)Section 147Section 148

d) The expenditure for such other purposes as the state Government may direct or permit. 3) The Authority shall keep its fund in any Scheduled Bank or in any Apex Co-operative Bank or a Central Co-operative Bank. 4)The Authority may invest any portion of its fund in such securities or in such other manner

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

ITA 162/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh12 Feb 2025AY 2013-14

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं . / ITA No.160, 161 & 162/ Chd/2023 निर्धारण वर्ष / Assessment Year : 2017-18, 2012-13 & 2013-14 The Jyoti Co-operative Non Agricultural Thrift & Credit Society Ltd. Sirmour, Solan, HP-173025 स्थायी लेखा सं. / PAN NO: AAABT1453G अपीलार्थी/Appellant बनाम The ITO H.P Ward-Nahan, Sirmour प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, Advocate राजस्व की ओर से / Revenue by : Dr. Ranjeet K

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 142(1)Section 80Section 80P(2)Section 80P(2)(a)

272 is not applicable as in that case, the society was engaged in the business of providing credit to its members apart from its marketing activities and under its bye laws, the profit from marketing activities had to be invested / parked in the FDRs and in view of the facts of that case, the Hon’ble Supreme Court held

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

ITA 161/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh12 Feb 2025AY 2012-13

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 142(1)Section 80Section 80P(2)Section 80P(2)(a)

272 is not applicable as in that case, the society was engaged in the business of providing credit to its members apart from its marketing activities and under its bye laws, the profit from marketing activities had to be invested / parked in the FDRs and in view of the facts of that case, the Hon’ble Supreme Court held

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

ITA 160/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh12 Feb 2025AY 2017-18
For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 142(1)Section 80Section 80P(2)Section 80P(2)(a)

272 is not applicable as in that case, the society was engaged in the business of providing credit to its members apart from its marketing activities and under its bye laws, the profit from marketing activities had to be invested / parked in the FDRs and in view of the facts of that case, the Hon’ble Supreme Court held