DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

disallowed the payments under Section 40A(ia) of the Act. While doing so, the AO observed as follows : "2.6 The provisions of section 195 are applicable to all payees whether individual or of any other status who are covered under the definition of nonresident as per section 6 of the Income Tax Act. Under this section there is no threshold

M/S STYLAM INDUSTRIES LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

disallowed the payments under Section 40A(ia) of the Act. While doing so, the AO observed as follows : "2.6 The provisions of section 195 are applicable to all payees whether individual or of any other status who are covered under the definition of nonresident as per section 6 of the Income Tax Act. Under this section there is no threshold

M/S STYLAM INDUSTRIES LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

disallowed the payments under Section 40A(ia) of the Act. While doing so, the AO observed as follows : "2.6 The provisions of section 195 are applicable to all payees whether individual or of any other status who are covered under the definition of nonresident as per section 6 of the Income Tax Act. Under this section there is no threshold

M/S PAGRO FROZEN FOODS PVT. LTD.,CHANDIGARH vs. ITO, W-2(3), CHANDIGARH

The appeal of the Assessee is dismissed

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

5,25,000/- The profits of assessee after disallowing the depreciation are assessed as hereunder: Returned Income: Rs. 31,54,889/- Add back Depreciation (Disallowed) Rs. 42,75,000/- Assessed Income: Rs. 74,29,889/- Less BF Losses: A.Y. Amount of brought Amount of dep. Set Balance carried forward unabsorbed off against the forward to the next depreciation current year

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

5. Issue of Disallowance under section 36(1)(iii) on purchase of Land A.Y. 2010-11: Ground No. 1 of the Revenue’s appeal 5.1 The assessee has purchased land from HSIDC and paid amount out of the capital available to the assessee. The Assessing Officer has disallowed interest under section 36(1)(iii) of Rs. 13.37 Lacs

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

5. Issue of Disallowance under section 36(1)(iii) on purchase of Land A.Y. 2010-11: Ground No. 1 of the Revenue’s appeal 5.1 The assessee has purchased land from HSIDC and paid amount out of the capital available to the assessee. The Assessing Officer has disallowed interest under section 36(1)(iii) of Rs. 13.37 Lacs

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

5. Issue of Disallowance under section 36(1)(iii) on purchase of Land A.Y. 2010-11: Ground No. 1 of the Revenue’s appeal 5.1 The assessee has purchased land from HSIDC and paid amount out of the capital available to the assessee. The Assessing Officer has disallowed interest under section 36(1)(iii) of Rs. 13.37 Lacs

ACIT, LUDHIANA vs. M/S MRS. BECTORS FOOD SPECIALTIES PVT. LTD., LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

5. Issue of Disallowance under section 36(1)(iii) on purchase of Land A.Y. 2010-11: Ground No. 1 of the Revenue’s appeal 5.1 The assessee has purchased land from HSIDC and paid amount out of the capital available to the assessee. The Assessing Officer has disallowed interest under section 36(1)(iii) of Rs. 13.37 Lacs

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

5. Issue of Disallowance under section 36(1)(iii) on purchase of Land A.Y. 2010-11: Ground No. 1 of the Revenue’s appeal 5.1 The assessee has purchased land from HSIDC and paid amount out of the capital available to the assessee. The Assessing Officer has disallowed interest under section 36(1)(iii) of Rs. 13.37 Lacs

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

5. Issue of Disallowance under section 36(1)(iii) on purchase of Land A.Y. 2010-11: Ground No. 1 of the Revenue’s appeal 5.1 The assessee has purchased land from HSIDC and paid amount out of the capital available to the assessee. The Assessing Officer has disallowed interest under section 36(1)(iii) of Rs. 13.37 Lacs

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

section 14 of the Act read Rule 8D of the Income Tax Rules is deleted. The aforesaid order has been followed by the ITAT in the Assessment Year's i.e. 2009-10 and 2011-12, we, therefore do not see any valid ground to interfere with the findings of the Ld. CIT (A) who rightly deleted the disallowance made

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55,326/-. The 1st appeal on ground No. 2(a) was that the Ld. DCIT failed to record proper satisfaction and established the nexus of interest relating to investment whose income is not chargeable to tax. 22.9 The calculation of disallowance under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, , AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55,326/-. The 1st appeal on ground No. 2(a) was that the Ld. DCIT failed to record proper satisfaction and established the nexus of interest relating to investment whose income is not chargeable to tax. 22.9 The calculation of disallowance under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, - vs. ROCKMAN INDUSTRIES LTD, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55,326/-. The 1st appeal on ground No. 2(a) was that the Ld. DCIT failed to record proper satisfaction and established the nexus of interest relating to investment whose income is not chargeable to tax. 22.9 The calculation of disallowance under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55,326/-. The 1st appeal on ground No. 2(a) was that the Ld. DCIT failed to record proper satisfaction and established the nexus of interest relating to investment whose income is not chargeable to tax. 22.9 The calculation of disallowance under section

DY. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, FOCAL POINT

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55,326/-. The 1st appeal on ground No. 2(a) was that the Ld. DCIT failed to record proper satisfaction and established the nexus of interest relating to investment whose income is not chargeable to tax. 22.9 The calculation of disallowance under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55,326/-. The 1st appeal on ground No. 2(a) was that the Ld. DCIT failed to record proper satisfaction and established the nexus of interest relating to investment whose income is not chargeable to tax. 22.9 The calculation of disallowance under section

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55,326/-. The 1st appeal on ground No. 2(a) was that the Ld. DCIT failed to record proper satisfaction and established the nexus of interest relating to investment whose income is not chargeable to tax. 22.9 The calculation of disallowance under section

DCIT CIRCLE-4, LUDHIANA, LUDHIANA vs. ROCKMAN INDUSTRIES LTD, LUDHIANA

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55,326/-. The 1st appeal on ground No. 2(a) was that the Ld. DCIT failed to record proper satisfaction and established the nexus of interest relating to investment whose income is not chargeable to tax. 22.9 The calculation of disallowance under section