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48 results for “disallowance”+ Section 194C(3)clear

Sorted by relevance

Mumbai547Kolkata413Delhi402Chennai200Bangalore181Ahmedabad135Hyderabad69Jaipur58Cuttack52Cochin48Rajkot42Visakhapatnam40Raipur38Pune38Indore36Nagpur25Chandigarh25Amritsar21Surat19Panaji17Karnataka15Lucknow14Allahabad13Ranchi12Guwahati11Patna7Kerala7Calcutta5Jodhpur5Dehradun5Agra4SC3Jabalpur3Gauhati1Telangana1Uttarakhand1Rajasthan1Varanasi1

Key Topics

Section 4063Section 194C44Addition to Income41Deduction19Disallowance17TDS15Section 143(3)14Section 80P12Section 19410Section 10

CEE PEE GRANITES P.LTD,MALAPPURAM vs. ACIT, TIRUR

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 400/COCH/2011[2006-07]Status: DisposedITAT Cochin17 Mar 2017AY 2006-07

Bench: Shri Abraham P. George & Shri George George. K.] आयकर अपील सं./I.T.A. No.400/ Coch/2011 िनधा"रण वष" /Assessment Years : 2006-2007

For Respondent: Shri. Shanthom Bose, CIT, DR
Section 194Section 194CSection 194C(3)Section 3Section 40

Section 194C(3) of the Act, has not been verified by any of the lower authorities. We are of the opinion that considering the facts and circumstances, these are aspects are to be verified by the ld. Assessing Officer. We therefore, remit the issue of disallowance

Showing 1–20 of 48 · Page 1 of 3

9
Section 698
Section 153C7

CEE PEE MARBLE & GRANITES,MALAPPURAM vs. ITO, TIRUR

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 401/COCH/2011[2006-07]Status: DisposedITAT Cochin17 Mar 2017AY 2006-07

Bench: Shri Abraham P. George & Shri George George. K.] आयकर अपील सं./I.T.A. No.400/ Coch/2011 िनधा"रण वष" /Assessment Years : 2006-2007

For Respondent: Shri. Shanthom Bose, CIT, DR
Section 194Section 194CSection 194C(3)Section 3Section 40

Section 194C(3) of the Act, has not been verified by any of the lower authorities. We are of the opinion that considering the facts and circumstances, these are aspects are to be verified by the ld. Assessing Officer. We therefore, remit the issue of disallowance

M/S AC CARGO MANAGEMENT P.LTD,,COCHIN vs. THE ITO, COCHIN

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

ITA 320/COCH/2013[2007-08]Status: DisposedITAT Cochin23 Mar 2017AY 2007-08

Bench: Shri Abraham P. George & Shri George George. K.] आयकर अपील सं./I.T.A. No. 320/Coch/2013. िनधा"रण वष" /Assessment Year : 2007-2008. Vs. M/S. Ac Cargo Management The Income Tax Officer, Pvt. Ltd, Ward 1(1) 1St Floor, Chacko Chambers, Kochi Civil Lines Road, Palarivattom, Kochi 682 025. [Pan Aaeca 2206K] (अपीलाथ" अपीलाथ" अपीलाथ"/Appellant) अपीलाथ" (ू"यथ" ू"यथ" ू"यथ"/Respondent) ू"यथ"

For Appellant: Shri. R. Krishnan, C.A
Section 194Section 194CSection 194ISection 40

194C of the Act was not applicable to it, by virtue of the judgment of Hon’ble Madras 282 ITR 3. Thereupon ld. Assessing Officer put the assessee on notice that such payment fell within the definition of rent given in the Explanation to Section 194 I of the Act. As per ld. Assessing Officer containarized trucks leased

SRI T.T.KURUVILLA,ALAPPUZHA vs. DCIT, ALAPPUZHA

In the result, the appeal filed by the Revenue is allowed for statistical

ITA 325/COCH/2010[2006-07]Status: DisposedITAT Cochin07 Jun 2017AY 2006-07

Bench: S/Shri Abraham P. George, Am & George George K., Jm

Section 194Section 194C(3)Section 40

disallowance made by the Assessing Officer. 4. On further appeal, the ITAT allowed the appeal of the assessee. The Tribunal relying on the order of the Special Bench of the Tribunal in the case of Merilyn Shipping & Transport vs. Addl. CIT (2012) 70 DTR 81 held that section 40(a)(ia) of the Act does not have application since

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 475/COCH/2016[2012-13]Status: DisposedITAT Cochin11 May 2018AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

disallowed all these payments by invoking provisions of section 40(a)(ia) of the Act. The CBDT vide circular No.715 dated 8.8.1995 has also clarified that sections 194C and 194J refer to any sum paid. Thus as TDS is to be deducted on `any sum paid’; hence it does not make any difference as to whether the sum is paid

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 134/COCH/2016[2011-12]Status: DisposedITAT Cochin11 May 2018AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

disallowed all these payments by invoking provisions of section 40(a)(ia) of the Act. The CBDT vide circular No.715 dated 8.8.1995 has also clarified that sections 194C and 194J refer to any sum paid. Thus as TDS is to be deducted on `any sum paid’; hence it does not make any difference as to whether the sum is paid

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

3 was allowed in favour of the assessee, ground No. 3.1 does not require any adjudication. Accordingly, ground No. 3.1 stands dismissed. 10. The ground of appeal Nos. 4 to 4.2 challenge the disallowance of excessive claim u/s. 35(2AB) of the Act. The in-house R&D Units of the Company located at Limda (Vadodra) and Perambra (Kochi

M/S.RAJA &CO,PALAKKAD vs. THE DCIT, THRISSUR

In the result, the appeals of the assessee are dismissed

ITA 159/COCH/2019[2009-10]Status: DisposedITAT Cochin26 Jun 2019AY 2009-10

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 194CSection 40

section 194C are not applicable to the appellant. 3. The appellant has made the payment to the transporter on behalf of the seller and provisions of sec. 194C are not attracted. I.T.A. Nos.158&159//Coch/2019 4. Without prejudice to the above contention, the amendments to sec. 40(a)(ia) by Finance Act (No.2), 2014 is retrospective and the disallowance

M/S.RAJA &CO,PALAKKAD vs. THE DCIT, THRISSUR

In the result, the appeals of the assessee are dismissed

ITA 158/COCH/2019[2008-09]Status: DisposedITAT Cochin26 Jun 2019AY 2008-09

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 194CSection 40

section 194C are not applicable to the appellant. 3. The appellant has made the payment to the transporter on behalf of the seller and provisions of sec. 194C are not attracted. I.T.A. Nos.158&159//Coch/2019 4. Without prejudice to the above contention, the amendments to sec. 40(a)(ia) by Finance Act (No.2), 2014 is retrospective and the disallowance

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

ITA 465/COCH/2025[2013-2014]Status: DisposedITAT Cochin22 Aug 2025AY 2013-2014

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri R. Krishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 148Section 194CSection 40

disallowance of charges paid to MPCMS towards professional charges made by the appellant for non deduction of tax at source on such payments invoking provisions of section 40(a)(ia) of the Act. 11. Brief facts of the case are that the appellant had engaged services of an organization called MPCMS for rendering professional services in terms of agreement entered

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

ITA 464/COCH/2025[2006-2007]Status: DisposedITAT Cochin22 Aug 2025AY 2006-2007

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri R. Krishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 148Section 194CSection 40

disallowance of charges paid to MPCMS towards professional charges made by the appellant for non deduction of tax at source on such payments invoking provisions of section 40(a)(ia) of the Act. 11. Brief facts of the case are that the appellant had engaged services of an organization called MPCMS for rendering professional services in terms of agreement entered

MUTHOOT FINCORP LIMITED,TRIVANDRUM vs. ITO,CIRCLE CENTRAL, TRIVANDRUM

In the result, the appeals filed by the assessee stand dismissed

ITA 496/COCH/2025[2010-2011]Status: DisposedITAT Cochin22 Aug 2025AY 2010-2011

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri R. Krishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 148Section 194CSection 40

disallowance of charges paid to MPCMS towards professional charges made by the appellant for non deduction of tax at source on such payments invoking provisions of section 40(a)(ia) of the Act. 11. Brief facts of the case are that the appellant had engaged services of an organization called MPCMS for rendering professional services in terms of agreement entered

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 310/COCH/2019[2010-11]Status: DisposedITAT Cochin30 Sept 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

disallowed by the Assessing Officer, holding that it was income from other sources. The assessee appealed to the Commissioner, who came to the conclusion that the assessee was liable to pay tax on capital gains on the amount of Rs.35 lacs after deducting an amount of Rs.7 lacs as cost of acquisition. The Department and assessee challenged the decision before

THE ACIT, CEN-CIRCLE, KOTTAYAM vs. SRI.JOSE THOMAS, ADOOR

In the result, the appeals of the assesses in ITA no

ITA 238/COCH/2019[2011-12]Status: DisposedITAT Cochin30 Sept 2019AY 2011-12

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

disallowed by the Assessing Officer, holding that it was income from other sources. The assessee appealed to the Commissioner, who came to the conclusion that the assessee was liable to pay tax on capital gains on the amount of Rs.35 lacs after deducting an amount of Rs.7 lacs as cost of acquisition. The Department and assessee challenged the decision before

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 309/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

disallowed by the Assessing Officer, holding that it was income from other sources. The assessee appealed to the Commissioner, who came to the conclusion that the assessee was liable to pay tax on capital gains on the amount of Rs.35 lacs after deducting an amount of Rs.7 lacs as cost of acquisition. The Department and assessee challenged the decision before

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 306/COCH/2019[2006-07]Status: DisposedITAT Cochin30 Sept 2019AY 2006-07

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

disallowed by the Assessing Officer, holding that it was income from other sources. The assessee appealed to the Commissioner, who came to the conclusion that the assessee was liable to pay tax on capital gains on the amount of Rs.35 lacs after deducting an amount of Rs.7 lacs as cost of acquisition. The Department and assessee challenged the decision before

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 29/COCH/2019[2006-07]Status: DisposedITAT Cochin30 Sept 2019AY 2006-07

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

disallowed by the Assessing Officer, holding that it was income from other sources. The assessee appealed to the Commissioner, who came to the conclusion that the assessee was liable to pay tax on capital gains on the amount of Rs.35 lacs after deducting an amount of Rs.7 lacs as cost of acquisition. The Department and assessee challenged the decision before

MRS.GRACY BABU,ADOOR P.O., PATHANAMTHITTA vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 210/COCH/2019[2011-12]Status: DisposedITAT Cochin30 Sept 2019AY 2011-12

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

disallowed by the Assessing Officer, holding that it was income from other sources. The assessee appealed to the Commissioner, who came to the conclusion that the assessee was liable to pay tax on capital gains on the amount of Rs.35 lacs after deducting an amount of Rs.7 lacs as cost of acquisition. The Department and assessee challenged the decision before

THE DCIT CEN-CIRCLE, KOTTAYAM vs. SMT.GRACY BABU, ADOOR P.O.

In the result, the appeals of the assesses in ITA no

ITA 54/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

disallowed by the Assessing Officer, holding that it was income from other sources. The assessee appealed to the Commissioner, who came to the conclusion that the assessee was liable to pay tax on capital gains on the amount of Rs.35 lacs after deducting an amount of Rs.7 lacs as cost of acquisition. The Department and assessee challenged the decision before

SMT.GRACY BABU,ADOOR P.O. vs. THE DCIT CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 33/COCH/2019[2005-06]Status: DisposedITAT Cochin30 Sept 2019AY 2005-06

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

disallowed by the Assessing Officer, holding that it was income from other sources. The assessee appealed to the Commissioner, who came to the conclusion that the assessee was liable to pay tax on capital gains on the amount of Rs.35 lacs after deducting an amount of Rs.7 lacs as cost of acquisition. The Department and assessee challenged the decision before