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95 results for “disallowance”+ Section 2(24)(iia)clear

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Key Topics

Section 143(1)60Disallowance58Section 14A45Addition to Income45Section 10B42Section 3540Section 32(1)(iia)38Section 14832Depreciation32Deduction

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

ITA 407/CHNY/2017[2014-15]Status: DisposedITAT Chennai05 May 2017AY 2014-15

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. R. Sivaraman, AdvocateFor Respondent: Shri. Shaji P. Jacob, IRS, Addl. CIT
Section 144ASection 14ASection 160(1)Section 161(1)Section 2(31)Section 56Section 56(1)Section 56(2)

Showing 1–20 of 95 · Page 1 of 5

32
Section 1130
Section 13(1)(c)24
Section 56(2)(vii)

iia) of the Act since assessee was not a trust created for a religious or charitable purpose. 22. What we find is that ld. Commissioner of Income Tax (Appeals) had confirmed the addition u/s. 2(24)(xv) of the Act r.w.s. 56(2)(vii) of the Act. Both these Sections are reproduced hereunder:- Sec. 2(24) ‘’income includes

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

ITA 406/CHNY/2017[2013-14]Status: DisposedITAT Chennai05 May 2017AY 2013-14

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. R. Sivaraman, AdvocateFor Respondent: Shri. Shaji P. Jacob, IRS, Addl. CIT
Section 144ASection 14ASection 160(1)Section 161(1)Section 2(31)Section 56Section 56(1)Section 56(2)Section 56(2)(vii)

iia) of the Act since assessee was not a trust created for a religious or charitable purpose. 22. What we find is that ld. Commissioner of Income Tax (Appeals) had confirmed the addition u/s. 2(24)(xv) of the Act r.w.s. 56(2)(vii) of the Act. Both these Sections are reproduced hereunder:- Sec. 2(24) ‘’income includes

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

ITA 2618/CHNY/2019[2015-16]Status: DisposedITAT Chennai07 Jul 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. Vijayaraghavan, AdvFor Respondent: Mr.A. Sasikumar, CIT
Section 115JSection 143(3)Section 14A

iia) of the Act on the same. The Ld. CIT, DR appearing before us are was unable to controvert the same. We therefore do not see any reason to interfere with the order of Ld. CIT(A) in this regard and accordingly dismiss this ground of the Revenue.” 5.2 The Ld. CIT, DR was not able to distinguish the above

DCIT, CHENNAI vs. M/S. VELS INSTITUTE OF SCIENCE & ADVANCED STUDIES, CHENNAI

In the result, appeals filed by the revenue for assessment

ITA 3550/CHNY/2018[2015-16]Status: DisposedITAT Chennai22 Dec 2021AY 2015-16

Bench: Shri Mahavir Singh, Vice- & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.3547 To 3550/Chny/2018 ("नधा"रणवष" / Assessment Years: 2012-13 To 2015-16) Deputy Commissioner Of Income Tax Vs M/S. Vels Institute Of Science, (Exemptions), Chennai Circle Technology & Advanced Chennai-600 034. Studies, 521/2, Anna Salai, Nandanam, Chennai-600 035. Pan: Aaatv 9804F (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. R.Sivaraman, AdvocateFor Respondent: 08.12.2021
Section 11Section 11(1)(d)Section 11(5)Section 12ASection 13Section 13(1)(c)Section 143(3)

iia) was inserted with effect from 1.4.1973 simultaneously with the present section 12, both of which were introduced from the said date by Finance Act, 1972. Section 12 makes it clear by the words appearing in parenthesis that contributions made with a specific direction that they shall form part of the corpus of the trust or institution shall

DCIT, CHENNAI vs. M/S. VELS INSTITUTE OF SCIENCE & ADVANCED STUDIES, CHENNAI

In the result, appeals filed by the revenue for assessment

ITA 3548/CHNY/2018[2013-14]Status: DisposedITAT Chennai22 Dec 2021AY 2013-14

Bench: Shri Mahavir Singh, Vice- & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.3547 To 3550/Chny/2018 ("नधा"रणवष" / Assessment Years: 2012-13 To 2015-16) Deputy Commissioner Of Income Tax Vs M/S. Vels Institute Of Science, (Exemptions), Chennai Circle Technology & Advanced Chennai-600 034. Studies, 521/2, Anna Salai, Nandanam, Chennai-600 035. Pan: Aaatv 9804F (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. R.Sivaraman, AdvocateFor Respondent: 08.12.2021
Section 11Section 11(1)(d)Section 11(5)Section 12ASection 13Section 13(1)(c)Section 143(3)

iia) was inserted with effect from 1.4.1973 simultaneously with the present section 12, both of which were introduced from the said date by Finance Act, 1972. Section 12 makes it clear by the words appearing in parenthesis that contributions made with a specific direction that they shall form part of the corpus of the trust or institution shall

DCIT, CHENNAI vs. M/S. VELS INSTITUTE OF SCIENCE & ADVANCED STUDIES, CHENNAI

In the result, appeals filed by the revenue for assessment

ITA 3549/CHNY/2018[2014-15]Status: DisposedITAT Chennai22 Dec 2021AY 2014-15

Bench: Shri Mahavir Singh, Vice- & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.3547 To 3550/Chny/2018 ("नधा"रणवष" / Assessment Years: 2012-13 To 2015-16) Deputy Commissioner Of Income Tax Vs M/S. Vels Institute Of Science, (Exemptions), Chennai Circle Technology & Advanced Chennai-600 034. Studies, 521/2, Anna Salai, Nandanam, Chennai-600 035. Pan: Aaatv 9804F (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. R.Sivaraman, AdvocateFor Respondent: 08.12.2021
Section 11Section 11(1)(d)Section 11(5)Section 12ASection 13Section 13(1)(c)Section 143(3)

iia) was inserted with effect from 1.4.1973 simultaneously with the present section 12, both of which were introduced from the said date by Finance Act, 1972. Section 12 makes it clear by the words appearing in parenthesis that contributions made with a specific direction that they shall form part of the corpus of the trust or institution shall

DCIT, CHENNAI vs. M/S. VELS INSTITUTE OF SCIENCE & ADVANCED STUDIES, CHENNAI

In the result, appeals filed by the revenue for assessment

ITA 3547/CHNY/2018[2012-13]Status: DisposedITAT Chennai22 Dec 2021AY 2012-13

Bench: Shri Mahavir Singh, Vice- & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.3547 To 3550/Chny/2018 ("नधा"रणवष" / Assessment Years: 2012-13 To 2015-16) Deputy Commissioner Of Income Tax Vs M/S. Vels Institute Of Science, (Exemptions), Chennai Circle Technology & Advanced Chennai-600 034. Studies, 521/2, Anna Salai, Nandanam, Chennai-600 035. Pan: Aaatv 9804F (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. R.Sivaraman, AdvocateFor Respondent: 08.12.2021
Section 11Section 11(1)(d)Section 11(5)Section 12ASection 13Section 13(1)(c)Section 143(3)

iia) was inserted with effect from 1.4.1973 simultaneously with the present section 12, both of which were introduced from the said date by Finance Act, 1972. Section 12 makes it clear by the words appearing in parenthesis that contributions made with a specific direction that they shall form part of the corpus of the trust or institution shall

DCIT, CHENNAI vs. M/S. VELS INSTITUTE OF SCIENCE & ADVANCED STUDIES, CHENNAI

In the result, ITA No.2858/Mds

ITA 2858/CHNY/2016[2013-14]Status: DisposedITAT Chennai17 Aug 2017AY 2013-14

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

For Appellant: Shri N. Madhavan, JCITFor Respondent: Shri R. Sivaraman, Advocate
Section 11Section 11(5)Section 13(1)Section 13(1)(c)Section 13(1)(d)Section 13(3)

disallowed the claim of the assessee on the ground that the money was advanced to the Managing Trustee. Since this Tribunal found that there was no violation of Section 13(1)(c) of the Act in respect of the agreement entered between the assessee-Trust and the Managing Trustee for purchase of property and it is not in dispute that

DCIT, CHENNAI vs. M/S. VELS INSTITUTE OF SCIENCE & ADVANCED STUDIES, CHENNAI

In the result, ITA No.2858/Mds

ITA 2857/CHNY/2016[2012-13]Status: DisposedITAT Chennai17 Aug 2017AY 2012-13

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

For Appellant: Shri N. Madhavan, JCITFor Respondent: Shri R. Sivaraman, Advocate
Section 11Section 11(5)Section 13(1)Section 13(1)(c)Section 13(1)(d)Section 13(3)

disallowed the claim of the assessee on the ground that the money was advanced to the Managing Trustee. Since this Tribunal found that there was no violation of Section 13(1)(c) of the Act in respect of the agreement entered between the assessee-Trust and the Managing Trustee for purchase of property and it is not in dispute that

M/S. ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, NCC-8(1), LTU-II, CHENNAI

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

ITA 2379/CHNY/2024[2012-13]Status: DisposedITAT Chennai12 Feb 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. VijayaraghavanFor Respondent: Mr.Nathala Ravi Babu, CIT
Section 14A

24,028/-. On appeal, the Ld. CIT(A) is noted to h . On appeal, the Ld. CIT(A) is noted to h . On appeal, the Ld. CIT(A) is noted to have confirmed the action of the AO. Now the assessee is in appeal before us. the action of the AO. Now the assessee is in appeal before

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

ITA 3251/CHNY/2024[2012-13]Status: DisposedITAT Chennai21 Apr 2025AY 2012-13

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(1)Section 143(2)Section 250Section 92BSection 92C

24. The assessee carried the matter in appeal before the CIT(A) against the disallowance of depreciation of ₹.1,04,34,735/- and addition of unexplained money of ₹.55,00,000/-. After considering the submissions of the assessee, the CIT(A) confirmed the disallowance of claim of depreciation and the disallowance made under section

M/S. EID PARRY INDIA LTD.,CHENNAI vs. DCIT, LTU-1,, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

ITA 3113/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Apr 2025AY 2014-15

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(1)Section 143(2)Section 250Section 92BSection 92C

24. The assessee carried the matter in appeal before the CIT(A) against the disallowance of depreciation of ₹.1,04,34,735/- and addition of unexplained money of ₹.55,00,000/-. After considering the submissions of the assessee, the CIT(A) confirmed the disallowance of claim of depreciation and the disallowance made under section

DCIT CORPORATE CIRCLE 6(2), CHENNAI vs. SUNDARAM CLAYTON LTD., CHENNAI

In the result, appeals filed by Revenue and the assessee

ITA 1376/CHNY/2018[2013-14]Status: DisposedITAT Chennai14 Jun 2021AY 2013-14

Bench: Shri V.Durga Rao & Shri G.Manjunatha

For Respondent: Mr. Vikram Vijayaraghavan
Section 14ASection 251(1)(a)Section 260ASection 32(1)(iia)Section 35

2)(iii) by considering only those investments which yield exempt income for the relevant assessment years. 12. The next issue that came up for our consideration for assessment year 2013-14 is disallowance of R&D expenditure u/s.35(2AB) and section 35(1)(iv) of the Act. During the year under consideration, the assessee has incurred capital expenditure other than

SUNDARAM CLAYTON LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

In the result, appeals filed by Revenue and the assessee

ITA 1356/CHNY/2018[2014-15]Status: DisposedITAT Chennai14 Jun 2021AY 2014-15

Bench: Shri V.Durga Rao & Shri G.Manjunatha

For Respondent: Mr. Vikram Vijayaraghavan
Section 14ASection 251(1)(a)Section 260ASection 32(1)(iia)Section 35

2)(iii) by considering only those investments which yield exempt income for the relevant assessment years. 12. The next issue that came up for our consideration for assessment year 2013-14 is disallowance of R&D expenditure u/s.35(2AB) and section 35(1)(iv) of the Act. During the year under consideration, the assessee has incurred capital expenditure other than

DCIT CORPORATE CIRCLE 6(2), CHENNAI vs. SUNDARAM CLAYTON LTD., CHENNAI

In the result, appeals filed by Revenue and the assessee

ITA 1254/CHNY/2018[2014-15]Status: DisposedITAT Chennai14 Jun 2021AY 2014-15

Bench: Shri V.Durga Rao & Shri G.Manjunatha

For Respondent: Mr. Vikram Vijayaraghavan
Section 14ASection 251(1)(a)Section 260ASection 32(1)(iia)Section 35

2)(iii) by considering only those investments which yield exempt income for the relevant assessment years. 12. The next issue that came up for our consideration for assessment year 2013-14 is disallowance of R&D expenditure u/s.35(2AB) and section 35(1)(iv) of the Act. During the year under consideration, the assessee has incurred capital expenditure other than

SUNDARAM CLAYTON LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

In the result, appeals filed by Revenue and the assessee

ITA 1355/CHNY/2018[2013-14]Status: DisposedITAT Chennai14 Jun 2021AY 2013-14

Bench: Shri V.Durga Rao & Shri G.Manjunatha

For Respondent: Mr. Vikram Vijayaraghavan
Section 14ASection 251(1)(a)Section 260ASection 32(1)(iia)Section 35

2)(iii) by considering only those investments which yield exempt income for the relevant assessment years. 12. The next issue that came up for our consideration for assessment year 2013-14 is disallowance of R&D expenditure u/s.35(2AB) and section 35(1)(iv) of the Act. During the year under consideration, the assessee has incurred capital expenditure other than

ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the Revenue in ITA

ITA 2834/CHNY/2014[1995-96]Status: DisposedITAT Chennai23 Sept 2016AY 1995-96

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Arun C. Bharath, IRS, CIT
Section 35D(2)Section 35D(2)(c)

2,57,13,271/- to the total income of the assessee. While doing so, the tolerable limit of 5% variation was taken with regard to each transaction. Aggrieved by the order, the assessee filed an appeal before Commissioner of Income Tax (Appeals). The ld. Authorised Representative contented that the AO has disallowed the difference in the price, charged

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

ITA 2825/CHNY/2014[2005-06]Status: DisposedITAT Chennai23 Sept 2016AY 2005-06

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Arun C. Bharath, IRS, CIT
Section 35D(2)Section 35D(2)(c)

2,57,13,271/- to the total income of the assessee. While doing so, the tolerable limit of 5% variation was taken with regard to each transaction. Aggrieved by the order, the assessee filed an appeal before Commissioner of Income Tax (Appeals). The ld. Authorised Representative contented that the AO has disallowed the difference in the price, charged

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

ITA 2827/CHNY/2014[2007-08]Status: DisposedITAT Chennai23 Sept 2016AY 2007-08

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Arun C. Bharath, IRS, CIT
Section 35D(2)Section 35D(2)(c)

2,57,13,271/- to the total income of the assessee. While doing so, the tolerable limit of 5% variation was taken with regard to each transaction. Aggrieved by the order, the assessee filed an appeal before Commissioner of Income Tax (Appeals). The ld. Authorised Representative contented that the AO has disallowed the difference in the price, charged

INDIA PISTONS LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 2(2), CHENNAI

In the result the appeal of the assessee in ITA

ITA 2339/CHNY/2017[2010-11]Status: DisposedITAT Chennai26 Sept 2019AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Rao] आयकर अपील सं./I.T.A. Nos.2339 & 2340/Chny/2017 "नधा"रण वष" /Assessment Years :2010-11 & 2011-12. M/S. India Pistons Limited, The Deputy Commissioner Of Vs. Huzur Gardens, Income Tax, Sembium, Corporate Circle 2(2) Chennai 600 011. Chennai.

For Respondent: Ms. R. Anitha, IRS, JCIT
Section 143(3)Section 14ASection 32(1)

Section 32 (1) (iia). The said clause (iia), admittedly, was inserted by virtue of the Finance (No.2) Act, 2002, with effect from 01.04.2003. 8.2.In so far as the second Circular is concerned, i.e, Circular no.8 of 2002 dated 27.08.2002, in our view, in no way, helps the case of the Revenue. The Circular does not dwell on the point which