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36 results for “TDS”+ Exemptionclear

Sorted by relevance

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Key Topics

Section 44B130Section 194A23Deduction20Section 143(3)15Exemption14Section 1012TDS12Section 12A11Addition to Income10Section 154

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

In the result, the appeal of the assessee is dismissed

ITA 725/DEL/2017[2013-14]Status: DisposedITAT Dehradun19 Mar 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] M/S Uttrakhand Purv Ito,Ward-2(5), Sainik Kalyan Nigam Ltd. Aayakar Bhawan,13-A, Subhash (Upnl) Vs Road, Dehradun Uttrakhand- Station Sub Area, Garhi 248003 Cantt, Dehradun-248003 Pan-Aaacu7129D Assessee Revenue Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri Amar Pal Singh, Sr. Dr Date Of Hearing 31.01.2025 Date Of Pronouncement 19.03.2025

Section 10Section 142(1)Section 143(3)Section 148Section 234A

exempted this Corporation from the provisions of TDS for a period of five years from 2009-10, issued u/s 119(1) of IT Act, 1961. This

Showing 1–20 of 36 · Page 1 of 2

8
Section 9(1)(vii)8
Section 271C8

SERCEL SA ,DEHRADUN vs. DCIT, CIRCLE-2, DDN, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 59/DDN/2023[2020-21]Status: DisposedITAT Dehradun13 Mar 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 142(1)Section 143(3)Section 195Section 44BSection 9(1)(i)

TDS was deducted by Oil and Natural Gas Corporation Limited (ONGS) u/s 195 of the Act, in it’s ITR. The assessee has reported an amount of Rs. 108,27,23,947/- as exempt

YES BANK LTD.,MUMBAI vs. ADDL. CIT (TDS), DEHRADUN

In the result, the appeals of the assessee are allowed

ITA 7498/DEL/2017[2013-14]Status: DisposedITAT Dehradun15 Dec 2022AY 2013-14

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 7498/Del/2017 : Asstt. Year : 2013-14 Ita No. 7499/Del/2017 : Asstt. Year : 2014-15

For Appellant: NoneFor Respondent: Smt. Mayank Prabha Tomar, Addl. CIT
Section 194ASection 194A(3)(iii)Section 201Section 201(1)Section 271Section 271CSection 274Section 4

exempt from tax on its income. 10. Vide letter dated 28 July 2016, the Bank has filed detailed submission as to why penalty should not be levied under section 271 of the Act. However the TDS

YES BANK LTD.,MUMBAI vs. ADDL. CIT (TDS), DEHRADUN

In the result, the appeals of the assessee are allowed

ITA 7499/DEL/2017[2014-15]Status: DisposedITAT Dehradun15 Dec 2022AY 2014-15

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 7498/Del/2017 : Asstt. Year : 2013-14 Ita No. 7499/Del/2017 : Asstt. Year : 2014-15

For Appellant: NoneFor Respondent: Smt. Mayank Prabha Tomar, Addl. CIT
Section 194ASection 194A(3)(iii)Section 201Section 201(1)Section 271Section 271CSection 274Section 4

exempt from tax on its income. 10. Vide letter dated 28 July 2016, the Bank has filed detailed submission as to why penalty should not be levied under section 271 of the Act. However the TDS

ACIT, CIRCLE- 2, DEHRADUN vs. RAJESH BALLABH, DEHRADUN

In the result appeal of the Revenue is dismissed

ITA 44/DEL/2018[2014-15]Status: DisposedITAT Dehradun19 Jan 2022AY 2014-15

Bench: Shri R.K.Panda & Shri K.Narasimha Chary

Section 194CSection 201Section 40Section 44A

TDS under section 194C, whereas w.e.f. 1/6/2015 the transport suppliers shall also furnish a declaration that he owns less than 10 carriages at any time during the Page 4 of 8 financial year relevant to the assessment year. Further the provision as applicable up to 31/5/2015 does not bar the exemption

INSTITUTE OF CLINICAL RESEARCH INDIA SOCIETY,DEHRADUN vs. CIT(A), DEHRADUN

Appeal is allowed

ITA 45/DDN/2024[2012-13]Status: DisposedITAT Dehradun13 Jun 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2012-13 Institute Of Clinical Research Vs. Commissioner Of Income India Society, Tax (Appeals), 1St Floor, Building No.1, Dehradun Treenetra Vihar, Near Kargt Chowk, Dehradun Pan :Aabai3710P (Appellant) (Respondent) Assessee By None Department By Sh. Amar Pal Singh, Sr. Dr

Section 11Section 12ASection 194Section 194JSection 2(15)Section 40

TDS thereupon to the tune of Rs.12,10,250/-, in the course of assessment framed on 19.11.2019 and upheld in the lower appellate discussion. 4. That being the case, the Revenue could hardly dispute the clinching fact that the assessee/appellate; who happens to be the registered trust, is already entitled for section 11 exemption

STATE BANK OF INDIA,DEHRADUN vs. ITO (TDS), DEHRADUN

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5018/DEL/2018[2012-13]Status: DisposedITAT Dehradun31 Aug 2022AY 2012-13

Bench: Shri N.K.Billaiya & Shri Kul Bharat[Through Video Conferencing At New Delhi] [Assessment Year : 2012-13] State Bank Of India, Vs Ito (Tds), 1-New Cantt. Road, Dehradun. Dehradun, Uttarakhand. Pan-Aaacs8577K Appellant Respondent Appellant By None Respondent By Smt. Mayank Prabha Tomar, Sr.Dr Date Of Hearing 23.08.2022 Date Of Pronouncement 31.08.2022 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Assessee For The Assessment Year 2012- 13 Is Directed Against The Order Of Ld. Cit(A), Dehradun Dated 10.05.2018. 2. The Assessee Has Raised Following Grounds Of Appeal:- 1. “That On The Facts & Circumstances Of The Case & Provisions Of The Law, The Ld Cit(A) Has Passed The Order Contrary To The Direction Of Hon’Ble Itat Delhi Vide Its Order Dated 07/11/2017. Therefore, The Said Order Of Ld Cit (A) Being Without His Jurisdiction & Authority Is Liable To Be Quashed & The Matter Needs To Be Set Aside To The Ld Ao As Per Said Order Of Hon’Ble Itat Delhi. 2. That Without Prejudice To Ground No 1 Above & On The Facts & Circumstances Of The Case & Provisions Of The Law, The Ld Cit (A) Erred In Confirming The Denial Of Exemption U/S 10(5) In Respect Of Reimbursement Of Leave Travel Concession Involving Foreign Leg Through Circuitous Route As Long As The Employees Designated Place Is In India For His Leave Travel Concession & He Actually Visits The Place As Designated.

Section 10(5)

TDS), 1-New Cantt. Road, Dehradun. Dehradun, Uttarakhand. PAN-AAACS8577K APPELLANT RESPONDENT Appellant by None Respondent by Smt. Mayank Prabha Tomar, Sr.DR Date of Hearing 23.08.2022 Date of Pronouncement 31.08.2022 ORDER PER KUL BHARAT, JM : The present appeal filed by the assessee for the assessment year 2012- 13 is directed against the order of Ld. CIT(A), Dehradun dated

PANJAB NATIONAL BANK,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS), DEHRADUN

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

ITA 10/DDN/2020[2011-2012]Status: DisposedITAT Dehradun06 Aug 2021AY 2011-2012

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 10/Ddn/2020 : Asstt. Year: 2011-12 Ita No. 11/Ddn/2020 : Asstt. Year: 2012-13 Ita No. 12/Ddn/2020 : Asstt. Year: 2013-14 Ita No. 13/Ddn/2020 : Asstt. Year: 2014-15 Ita No. 14/Ddn/2020 : Asstt. Year: 2015-16 Punjab National Bank, Vs Acit(Tds), Subhash Road Branch, Dehradun Dehradun (Appellantt (Respondent) Pan No. Mrtp02168F Assessee By : Sh. Vimal Kishore, Ca Revenue By : Sh. N. C. Upadhyaya, Sr. Dr Date Of Hearing: 12.07.2021 Date Of Pronouncement: 06.08.2021

For Appellant: Sh. Vimal Kishore, CAFor Respondent: Sh. N. C. Upadhyaya, Sr. DR
Section 10Section 10(25)Section 139Section 154Section 194Section 194ASection 194A(3)(f)Section 201(1)

TDS), Subhash Road Branch, Dehradun Dehradun (APPELLANTT (RESPONDENT) PAN No. MRTP02168F Assessee by : Sh. Vimal Kishore, CA Revenue by : Sh. N. C. Upadhyaya, Sr. DR Date of Hearing: 12.07.2021 Date of Pronouncement: 06.08.2021 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeals have been filed by the assessee against the orders of ld. CIT (A), Dehradun dated

PANJAB NATIONAL BANK,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS), DEHRADUN

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

ITA 14/DDN/2020[2015-2016]Status: DisposedITAT Dehradun06 Aug 2021AY 2015-2016

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 10/Ddn/2020 : Asstt. Year: 2011-12 Ita No. 11/Ddn/2020 : Asstt. Year: 2012-13 Ita No. 12/Ddn/2020 : Asstt. Year: 2013-14 Ita No. 13/Ddn/2020 : Asstt. Year: 2014-15 Ita No. 14/Ddn/2020 : Asstt. Year: 2015-16 Punjab National Bank, Vs Acit(Tds), Subhash Road Branch, Dehradun Dehradun (Appellantt (Respondent) Pan No. Mrtp02168F Assessee By : Sh. Vimal Kishore, Ca Revenue By : Sh. N. C. Upadhyaya, Sr. Dr Date Of Hearing: 12.07.2021 Date Of Pronouncement: 06.08.2021

For Appellant: Sh. Vimal Kishore, CAFor Respondent: Sh. N. C. Upadhyaya, Sr. DR
Section 10Section 10(25)Section 139Section 154Section 194Section 194ASection 194A(3)(f)Section 201(1)

TDS), Subhash Road Branch, Dehradun Dehradun (APPELLANTT (RESPONDENT) PAN No. MRTP02168F Assessee by : Sh. Vimal Kishore, CA Revenue by : Sh. N. C. Upadhyaya, Sr. DR Date of Hearing: 12.07.2021 Date of Pronouncement: 06.08.2021 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeals have been filed by the assessee against the orders of ld. CIT (A), Dehradun dated

PANJAB NATIONAL BANK,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS), DEHRADUN

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

ITA 12/DDN/2020[2013-14]Status: DisposedITAT Dehradun06 Aug 2021AY 2013-14

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 10/Ddn/2020 : Asstt. Year: 2011-12 Ita No. 11/Ddn/2020 : Asstt. Year: 2012-13 Ita No. 12/Ddn/2020 : Asstt. Year: 2013-14 Ita No. 13/Ddn/2020 : Asstt. Year: 2014-15 Ita No. 14/Ddn/2020 : Asstt. Year: 2015-16 Punjab National Bank, Vs Acit(Tds), Subhash Road Branch, Dehradun Dehradun (Appellantt (Respondent) Pan No. Mrtp02168F Assessee By : Sh. Vimal Kishore, Ca Revenue By : Sh. N. C. Upadhyaya, Sr. Dr Date Of Hearing: 12.07.2021 Date Of Pronouncement: 06.08.2021

For Appellant: Sh. Vimal Kishore, CAFor Respondent: Sh. N. C. Upadhyaya, Sr. DR
Section 10Section 10(25)Section 139Section 154Section 194Section 194ASection 194A(3)(f)Section 201(1)

TDS), Subhash Road Branch, Dehradun Dehradun (APPELLANTT (RESPONDENT) PAN No. MRTP02168F Assessee by : Sh. Vimal Kishore, CA Revenue by : Sh. N. C. Upadhyaya, Sr. DR Date of Hearing: 12.07.2021 Date of Pronouncement: 06.08.2021 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeals have been filed by the assessee against the orders of ld. CIT (A), Dehradun dated

PANJAB NATIONAL BANK,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS), DEHRADUN

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

ITA 11/DDN/2020[2012-2013]Status: DisposedITAT Dehradun06 Aug 2021AY 2012-2013

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 10/Ddn/2020 : Asstt. Year: 2011-12 Ita No. 11/Ddn/2020 : Asstt. Year: 2012-13 Ita No. 12/Ddn/2020 : Asstt. Year: 2013-14 Ita No. 13/Ddn/2020 : Asstt. Year: 2014-15 Ita No. 14/Ddn/2020 : Asstt. Year: 2015-16 Punjab National Bank, Vs Acit(Tds), Subhash Road Branch, Dehradun Dehradun (Appellantt (Respondent) Pan No. Mrtp02168F Assessee By : Sh. Vimal Kishore, Ca Revenue By : Sh. N. C. Upadhyaya, Sr. Dr Date Of Hearing: 12.07.2021 Date Of Pronouncement: 06.08.2021

For Appellant: Sh. Vimal Kishore, CAFor Respondent: Sh. N. C. Upadhyaya, Sr. DR
Section 10Section 10(25)Section 139Section 154Section 194Section 194ASection 194A(3)(f)Section 201(1)

TDS), Subhash Road Branch, Dehradun Dehradun (APPELLANTT (RESPONDENT) PAN No. MRTP02168F Assessee by : Sh. Vimal Kishore, CA Revenue by : Sh. N. C. Upadhyaya, Sr. DR Date of Hearing: 12.07.2021 Date of Pronouncement: 06.08.2021 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeals have been filed by the assessee against the orders of ld. CIT (A), Dehradun dated

PANJAB NATIONAL BANK,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS) , DEHRADUN

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

ITA 13/DDN/2020[2014-2015]Status: DisposedITAT Dehradun06 Aug 2021AY 2014-2015

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 10/Ddn/2020 : Asstt. Year: 2011-12 Ita No. 11/Ddn/2020 : Asstt. Year: 2012-13 Ita No. 12/Ddn/2020 : Asstt. Year: 2013-14 Ita No. 13/Ddn/2020 : Asstt. Year: 2014-15 Ita No. 14/Ddn/2020 : Asstt. Year: 2015-16 Punjab National Bank, Vs Acit(Tds), Subhash Road Branch, Dehradun Dehradun (Appellantt (Respondent) Pan No. Mrtp02168F Assessee By : Sh. Vimal Kishore, Ca Revenue By : Sh. N. C. Upadhyaya, Sr. Dr Date Of Hearing: 12.07.2021 Date Of Pronouncement: 06.08.2021

For Appellant: Sh. Vimal Kishore, CAFor Respondent: Sh. N. C. Upadhyaya, Sr. DR
Section 10Section 10(25)Section 139Section 154Section 194Section 194ASection 194A(3)(f)Section 201(1)

TDS), Subhash Road Branch, Dehradun Dehradun (APPELLANTT (RESPONDENT) PAN No. MRTP02168F Assessee by : Sh. Vimal Kishore, CA Revenue by : Sh. N. C. Upadhyaya, Sr. DR Date of Hearing: 12.07.2021 Date of Pronouncement: 06.08.2021 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeals have been filed by the assessee against the orders of ld. CIT (A), Dehradun dated

PURAN SINGH NEGI,HALDWANI vs. THE ASSIST COMMISSIONER OF INCOME TAX , NANITAL

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 33/DDN/2020[2016-17]Status: DisposedITAT Dehradun04 Jan 2023AY 2016-17

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.I.T.A. No. 33/Ddn/2020 (A.Y 2016-17)

Section 2Section 28Section 56

exemptions the assessee is due for and discharge the Demand raised by the Ld.AO The appellant craves for leave to add, alter, amend and / or modify any of the grounds of appeal before or at the time of hearing the Appeal.” 3. There is a delay of two months in filing the present appeal. The Ld. AR has filed

DR. VIRENDRA SWAROOP EDUCATIONAL FOUNDATION,KANPUR vs. ACIT, CENTRAL CIRCLE, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 211/DDN/2025[2023-24]Status: DisposedITAT Dehradun16 Jan 2026AY 2023-24

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2023-24] Dr. Virendra Swaroop Vs Acit Educational Foundation Central Circle 15/96, Civil Lines, Kanpur Dehradun Uttar Pradesh-208001 Pan-Aaajd0224D Appellant Respondent Assessee By Shri Salil Kapoor, Adv. Shri Rajiv Sahni, Ca Shri Sumit Lal Chandanim, Adv. Shri Shivam Yadav, Adv. & Ms. Ananya Kapoor, Adv. Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 16.09.2025 By Ld. Pr. Commissioner Of Income Tax (Central), Kanpur [“Pcit”] Passed U/S 12(Ab)(4)(Ii) Of The Income Tax Act, 1961[“The Act”] Cancelling The Registration Granted U/S 12A Of The Act From Assessment Year 2023-24 & Onwards.

Section 11Section 12Section 127Section 12ASection 12A(1)(ac)Section 132Section 143(3)

Exemption) and as such no valid jurisdiction was assumed by PCIT(Central). Hence, impugned order is illegal, bad in law, without jurisdiction and liable to be quashed. 7. That the PCIT has erred in holding that the activities of the appellant are not being carried out in accordance with the objects of the trust, despite extensive documentary evidence filed during

SUNIL SRIVASTAVA,HALDWANI vs. THE INCOME TAX OFFICER, WARD-2(1)(3), HALDWANI

In the result, the appeal of the assessee is allowed

ITA 10/DDN/2021[2016-17]Status: DisposedITAT Dehradun15 Sept 2023AY 2016-17

Bench: Him From Time To Time

Section 10(38)Section 143(3)Section 206CSection 44A

exempt u/s 10(38) of the Act. The assessee also furnished the ledger account of the assessee as appearing in the books of M/s Sushil Financial Services P Ltd, Mumbai for trading of shares and commodities, which was accepted by the ld. AO. 4. Further as per Form 26AS, the assessee had tax collected at source u/s 206CA

SOLAR TURBINES INTERNATIONAL COMPANY,BANGALORE vs. DCIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN

Appeal is dismissed

ITA 6710/DEL/2017[2014-15]Status: DisposedITAT Dehradun30 Mar 2026AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing) Assessment Year: 2014-15 M/S. Solar Turbines Vs. Dcit, International Company International Taxation, (Singapore Branch Of Solar Cirrcle-2, Turbines International Dehradun Company, Usa), M/S. Deloitte Haskins & Sells Deloitte Centre, Anchorage Ii, #100/2, Richmond Road, Bangalore -560025 Pan: Aajcs3585J (Appellant) (Respondent) Assessee By None Department By Sh. A.S. Rana, Sr. Dr Date Of Hearing 16.01.2026 Date Of Pronouncement 30.03.2026 Order

Section 143(3)Section 154Section 90(2)

TDS [ITA 4052/Del./2015] The Appellant craves leave to add, alter, amend or delete any or all the grounds of appeal on or before the date of hearing.” 3. We next notice with the able assistance coming from the Revenue side that the assessee/appellant is aggrieved against the learned CIT(A)’s order dated 30th August, 2017 rejecting its section

ACIT, CIRCLE- 3, NAINITAL vs. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

ITA 1200/DEL/2018[2013-14]Status: DisposedITAT Dehradun09 May 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 142Section 143(3)Section 14ASection 36(1)(va)

TDS). The Ld. Counsel has submitted that the contact receipts received from the Government is shown as liability unless the project is commenced. However, the AO is of the view that the same has to be taxed as income on accrual basis as the assessee is maintaining its books of accounts on mercantile system. After commencement of the project

ACIT, NAINITAL vs. M/S. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

ITA 908/DEL/2017[2012-13]Status: DisposedITAT Dehradun09 May 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 142Section 143(3)Section 14ASection 36(1)(va)

TDS). The Ld. Counsel has submitted that the contact receipts received from the Government is shown as liability unless the project is commenced. However, the AO is of the view that the same has to be taxed as income on accrual basis as the assessee is maintaining its books of accounts on mercantile system. After commencement of the project

INSTITUTE OF CLINICAL RESEARCH (INDIA) SOCIETY,DEHRADUN vs. ACIT, DEHRADUN

In the result, the appeal filed by the assessee in ITA No

ITA 4207/DEL/2010[2006-07]Status: DisposedITAT Dehradun15 Jan 2025AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri A.S. Rana, Sr. DR
Section 11Section 13Section 36(1)(iii)Section 40A(2)Section 40A(2)(b)Section 68

exemption u/s 11 of the Act. In view of the concession from the ld AR, the ground no 1 is allowed. 7. Ground No. 2 pertains to the deletion of disallowance u/s 40A(2) of the Act. 8. Briefs facts relating to this issue are that during the course of assessment proceedings, the Assessing Officer noticed that the assessee

DCIT, DEHRADUN vs. M/S INSTITUTE OF CLINICAL RESEARCH (INDIA) SOCIETY,, DEHRADUN

In the result, the appeal filed by the assessee in ITA No

ITA 3927/DEL/2012[2008-09]Status: DisposedITAT Dehradun15 Jan 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri A.S. Rana, Sr. DR
Section 11Section 13Section 36(1)(iii)Section 40A(2)Section 40A(2)(b)Section 68

exemption u/s 11 of the Act. In view of the concession from the ld AR, the ground no 1 is allowed. 7. Ground No. 2 pertains to the deletion of disallowance u/s 40A(2) of the Act. 8. Briefs facts relating to this issue are that during the course of assessment proceedings, the Assessing Officer noticed that the assessee