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

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

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

36(1)(va) r.w.s.2(24)(x) of the Act. (ii) Disallowance of interest of Rs.50,50,442/- on Government loans/ advances (iii) Disallowance of interest of Rs.65,56,936/- on earmarked fund (iv) Disallowance of interest under 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

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

36(1)(va) r.w.s.2(24)(x) of the Act. (ii) Disallowance of interest of Rs.50,50,442/- on Government loans/ advances (iii) Disallowance of interest of Rs.65,56,936/- on earmarked fund (iv) Disallowance of interest under section

RAJESH AGGARWAL ,DEHRADUN vs. THE DEPUTY COMMISSIONER OF INCOME TAX OFFICER, CENTRAL CIRCLE, DEHRADUN

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

36. Search under section 132 enables an Assessing Officer to issue notice to file returns under section 153A. Section 153A is a substantive provision to do the assessment for six assessment years. Section 153A, by way of adaptation, conveys the responsibility for filing of the return under section 139 Therefore, a return filed in pursuance of a notice issued under

REENA VERMA,HARIDWAR vs. ITO, WARD-1(3)(5), ROORKEE

In the result, the appeal of the assessee stands partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

disallowed these payments under section 40A(3) of the Act as there was no exceptional clause to make such payments in cash under Rule 6DD of the Income Tax Rules. Keeping in view the above facts, the AO rejected the books of accounts of the assessee under section 145(3) of the Act and applied net profit

PSB PAPERS PRIVATE LIMITED,U.S. NAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX , BAREILLY

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

disallow the bad debts, instead, he had merely directed to examine 4 the claim of deduction of bad debts after giving sufficient opportunity to the assessee. 7. It is not in dispute that the Assessing Officer having raised queries on various issues during the course of assessment proceedings has not raised any query regarding the allowability of bad debts

RITU SINGHAL,DEHRADUN vs. DCIT/ACIT , CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

disallowance was made. Given the\nnature of the transactions as salary payments, they are fully allowable as business\nexpenditures under Section 37 of the Income Tax Act, 1961.\nRelevant Law - Section 37 of the Income Tax Act, 1961:\nAny expenditure (not being expenditure of the nature described in sections 30 to 36

HIMANSHU SHUKLA,RUDRAPUR vs. THE ASSISTANT DIRECTOR OF INCOME TAX , BANGALORE

In the result, appeal of the assessee is dismissed

disallowance made on account of employee’s contribution to Provident Fund and Employee State Insurance in the facts and circumstances of the instant case. 4. We have heard rival submissions and perused the materials available on record. This issue is no longer res integra in view of the decision of the Hon’ble Supreme court in the case of Checkmate

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

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

disallowed a proportionate interest @ 12% per annum on amount of Rs. 1 crore holding that the interest bearing funds have been diverted for non-business purpose invoking the provisions of section 36

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

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

disallowed a proportionate interest @ 12% per annum on amount of Rs. 1 crore holding that the interest bearing funds have been diverted for non-business purpose invoking the provisions of section 36

BHUPENDRA BORA,GHAZIABAD vs. DCIT, DEHRADUN

In the result, the appeal is allowed

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) Bhupendra Bora, Vs. Dcit, Flat No. S4, Plot No. 618A, Circle-1(1)(1), Sector-1, Vaishali, Dehradun Ghaziabad (Appellant) (Respondent) Pan: Ajkpb5486A Assessee By : None Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 17/03/2025 Date Of Pronouncement 02/04/2025

36,790/- and claimed relief under Section 90/ 90A of the Act on account of foreign tax credit of Rs. 5,72,956/-. The said revised return was also processed by the Learned CPC under Section 143(1) of the Act on 21-04-2021 accepting the returned income. However, the Learned CPC did not give the relief for foreign

DCIT, CIRCLE-1(1)(1), SUBHASH ROAD vs. UJVN LIMITED, GMS ROAD

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

sections": [ "250", "143(1)", "36(1)(va)", "115BAA" ], "issues": "1. Disallowance of depreciation on demerged assets. 2. Timeliness of deposit

DCIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. SAMSUNG HEAVY INDUSTRIES CO. LTD., GURGAON

In the result, appeal of the assessee in ITA No

section 40(a)(ia) of the Act. It was also noticed that the AO had disallowed the said amount and the AO has calculated the income of the assessee from Inside India activity at a loss of Rs. 23,33,939/- in the following manner. Thus, the contention is that the AO in A.Y. 2007-08 had in principle accepted

SAMSUNG HEAVY INDUSTRIES CO. LTD.,GURGAON vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, appeal of the assessee in ITA No

section 40(a)(ia) of the Act. It was also noticed that the AO had disallowed the said amount and the AO has calculated the income of the assessee from Inside India activity at a loss of Rs. 23,33,939/- in the following manner. Thus, the contention is that the AO in A.Y. 2007-08 had in principle accepted

PUSHPA DEVI,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result the Appeal of the Assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Pushpa Devi Vs. Income Tax Officer, 31-Awas Vikas Colony, Ward 1(4) (1), Verbhadara Road, Rishikesh, Rishikesh, 249201, Uttarakhand Rishikesh, Uttarakhand Pan: Aldpd9616P Appellant Respondent Assessee By Sh. K. K. Juneja, Adv Revenue By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 10/07/2025 Date Of Pronouncement 08/08/2025 Order

Section 144B of the Income Tax Act, 1961 ('Act' for short) by making an addition of Rs. 36,05,530/- on account of suppression of sale receipts u/s 28 of the Act and also made addition of Rs. 13,74,000/- u/s 68 of the Act on account of unsecured loan. Aggrieved by the assessment order dated 05/03/2024, the Assessee

M/S UJVN LIMITED ,UTTARAKHAND vs. DEPUTY COMMISSIONER OF INCOME TAX, UTTARAKHAND

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

sections": [ "250", "143(1)", "36(1)(va)", "115BAA" ], "issues": "Whether depreciation on demerged assets is allowable? Whether delayed employee contributions to PF/ESI paid after salary disbursement but within statutory limits should be disallowed

ASSISTANT COMMISSIONER OF INCOME TAX, DEHRADUN vs. WESTERN GECO INTERNATIONAL LIMITED, HARYANA

The Appeal of the Revenue is dismissed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 141/Del/2024 (A.Y 2021-22)

disallowance made by the A.O. by following the ratio laid down by the Special Bench of the Tribunal in Assessee’s own case for Assessment Year 2011-12 in ITA No. 6436/Del/2014 and 6536/Del/2014 and the Judgments of High Courts. 6. As against the order of the Ld. CIT(A) dated 20/06/2024, the Department preferred the present Appeal

MB PETROLEUM SERVICES LLC,MUMBAI vs. DDIT, DEHRADUN

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

Bench: Shri Saktijit Dey & Shri M. Balaganeshmb Petroleum Services Llc, Vs. Ddit, Kirtane & Pandit, H-16, Circle-1, Saraswati Colony, Sitaldevi International Taxation, Temple Road, Mahim, Dehradun Mumbai (Appellant) (Respondent) Pan: Aaecm2604H

disallowance of Rs 20,22,921/- being payment to Global Marine Technologies. 12. That the AO and DRP have grossly erred on facts and in law in not allowing the assessee the proper and due credit of TDS. 13. That the explanations, submissions and evidences filed by the assessee have not been considered judiciously and examined and interpreted legally

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

disallowing deduction u/s 80IC/Chapter VI-A of the Act. 4. On the facts and circumstances of the case and in law, the Ld. AO/DRP have failed to appreciate that to invoke the provisions of Section 92BA, existence of any 'arrangement' to ‘more than ordinary profits’ between the Appellant and its Associate Enterprise (“AE”) need to be established under the provisions