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9 results for “disallowance”+ Section 56(2)(viia)clear

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Key Topics

Section 14814Section 36(1)(viii)14Deduction9Section 271(1)(c)8Section 36(1)(viia)8Section 80P(2)(a)6Section 366Disallowance6Addition to Income

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)

viia) to sub-section (24) to section 2 would have application, Even otherwise, on the principle of mutuality, the Hon’ble Supreme Court in Bangalore Club v. CIT [2013] 350 ITR 509/29 taxmann.com 29 has held that the interest earned on FDRs with banks would not be covered by the principle of mutuality as the transactions were not between

5
Section 2504
Section 234D4
Business Income3

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)

viia) to sub-section (24) to section 2 would have application, Even otherwise, on the principle of mutuality, the Hon’ble Supreme Court in Bangalore Club v. CIT [2013] 350 ITR 509/29 taxmann.com 29 has held that the interest earned on FDRs with banks would not be covered by the principle of mutuality as the transactions were not between

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)

viia) to sub-section (24) to section 2 would have application, Even otherwise, on the principle of mutuality, the Hon’ble Supreme Court in Bangalore Club v. CIT [2013] 350 ITR 509/29 taxmann.com 29 has held that the interest earned on FDRs with banks would not be covered by the principle of mutuality as the transactions were not between

THE KANGRA CENTRAL COOPERATIVE BANK LIMITED,DHARAMSHALA vs. DEPUTY COMMISSIONER OF INCOME TAX, PALAMPUR

In the result, both the appeals of the assessee are allowed

ITA 804/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh28 Jan 2025AY 2012-13

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Ashwani Kumar, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(3)Section 250Section 271(1)(c)Section 274Section 36(1)(viia)

56,35,140/- which was selected for scrutiny and thereafter, the assessment was completed under section 143(3) dt. 05/03/2014 wherein the AO has, interalia, made a disallowance of provision made towards standard assets amounting to Rs. 2,21,28,000/- and separately, the penalty proceedings were initiated under section 271(1)(c) of the Act for concealment of income

THE KANGRA CENTRAL COOPERATIVE BANK LIMITED,DHARAMSHALA vs. DEPUTY COMMISSIONER OF INCOME TAX, PALAMPUR

In the result, both the appeals of the assessee are allowed

ITA 805/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh28 Jan 2025AY 2013-14
For Respondent: \nShri Ashwani Kumar, C.A
Section 143(3)Section 250Section 271(1)(c)Section 274Section 36(1)(viia)

56,000/- includes provision of Rs.2,21,28,000/- on the\nPerforming Assets (designated by the assessee Bank as Standard Assets) i.e. the\nassets which are good, not bad and from which regular instalments of the\nprincipal/interest, as the case may be, are being received by the assessee Bank.\nThis provision of Rs.2,21,28,000/- has been

THE STATE BANK OF INDIA,PATIALA vs. ASSTT.COMMISSIONER OF INCOME TAX, PATIALA

The appeal of the Revenue is dismissed

ITA 861/CHANDI/2017[2011-12]Status: DisposedITAT Chandigarh09 Feb 2018AY 2011-12

Bench: Shri Sanjay Garg & Ms. Annapurna Guptathe State Bank Of India, Vs. The A.C.I.T., (Successor Of State Bank Of Patiala) Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D & The A.C.I.T., Vs. The State Bank Of India, Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D The A.C.I.T., Vs. The State Bank Of India, Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D The State Bank Of India, Vs. The A.C.I.T., (Successor Of State Bank Of Patiala) Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D & The A.C.I.T., Vs. The State Bank Of India, Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D The State Bank Of India, Vs. The A.C.I.T., (Successor Of State Bank Of Patiala) Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D

For Appellant: Shri C. Naresh, CAFor Respondent: Shri Alok Kumar,CIT DR
Section 36(1)(viii)

disallowance, holding that the assessee was duty bound to create and maintain the special reserve out of the profits of the eligible business during the relevant financial year itself and having not done so he held that the Assessing Officer had rightly denied the said claim of the assessee. The Ld.CIT(Appeals) distinguished all the case laws relied upon

ACIT, PATIALA vs. M/S THE STATE BANK OF PATIALA, PATIALA

The appeal of the Revenue is dismissed

ITA 721/CHANDI/2017[2014-15]Status: DisposedITAT Chandigarh09 Feb 2018AY 2014-15

Bench: Shri Sanjay Garg & Ms. Annapurna Guptathe State Bank Of India, Vs. The A.C.I.T., (Successor Of State Bank Of Patiala) Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D & The A.C.I.T., Vs. The State Bank Of India, Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D The A.C.I.T., Vs. The State Bank Of India, Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D The State Bank Of India, Vs. The A.C.I.T., (Successor Of State Bank Of Patiala) Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D & The A.C.I.T., Vs. The State Bank Of India, Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D The State Bank Of India, Vs. The A.C.I.T., (Successor Of State Bank Of Patiala) Circle Patiala, The Mall, Patiala. Pan: Aaccs0143D

For Appellant: Shri C. Naresh, CAFor Respondent: Shri Alok Kumar,CIT DR
Section 36(1)(viii)

disallowance, holding that the assessee was duty bound to create and maintain the special reserve out of the profits of the eligible business during the relevant financial year itself and having not done so he held that the Assessing Officer had rightly denied the said claim of the assessee. The Ld.CIT(Appeals) distinguished all the case laws relied upon

M/S STATE BANK OF PATIALA,,PATIALA vs. ACIT,, PATIALA

ITA 384/CHANDI/2008[1999-2000]Status: DisposedITAT Chandigarh31 Jul 2018AY 1999-2000

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

For Appellant: Shri. C. NareshFor Respondent: Shri. Manu Malik
Section 143Section 147Section 148Section 234DSection 36Section 36(1)(viia)

2 for A.Y. 2000-01 pertaining to issue of notice under section 148 are not pressed by the assessee therefore no adjudication is required. 4. The effective ground taken by the assessee is ground no. 3 upholding the addition on account of disallowance of deduction under section 36(1)(viia) which is common to ground

M/S STATE BANK OF PATIALA,,PATIALA vs. ACIT,, PATIALA

ITA 385/CHANDI/2008[2000-01]Status: DisposedITAT Chandigarh31 Jul 2018AY 2000-01

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

For Appellant: Shri. C. NareshFor Respondent: Shri. Manu Malik
Section 143Section 147Section 148Section 234DSection 36Section 36(1)(viia)

2 for A.Y. 2000-01 pertaining to issue of notice under section 148 are not pressed by the assessee therefore no adjudication is required. 4. The effective ground taken by the assessee is ground no. 3 upholding the addition on account of disallowance of deduction under section 36(1)(viia) which is common to ground