CIT vs. KRIBHCO

80P(2)(d) of the Act and, therefore, has to be disallowed under Section 14A. 5. The assessee succeeded in the first appeal and before the tribunal. We may notice that in the first appeal, the assessee had raised several contentions on merits as to the quantum of disallowance of the expenditure under the head “interest” and had pointed

ZILA SAHKARI BANK LTD.,BULANDSHAHR vs. DCIT, CIRCLE- 3(1), BULANDSHAHR

In the result, the appeal of the Revenue is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2015-16 Zila Sahkari Bank Ltd., Bulandshahr Vs Dcit, C/O Kashyap & Co., Circle-3(1), 114, Citi Centre, Bulandshahr. Bb Road, Meerut, Uttar Pradesh – 250001. Pan: Aaaaz0005B (Appellant) (Respondent) Assessee By : Shri P.S. Kashyap, Ca Revenue By : Shri Bhupendra Anant, Sr. Dr Date Of Hearing : 08.05.2023 Date Of Pronouncement : 22.05.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.914/Del/2021 For Ay 2015-16 Arises Out Of The Order Of The Commissioner Of Income Tax (Appeals), Ghaziabad [Hereinafter Referred To As ‘Ld. Cit(A)’, In Short] In Appeal No.358717431080118 Dated 31.07.2019 Against The Order Of Assessment Passed U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 22.12.2017 By The Ld. Assessing Officer, Circle-3(1), Bulandshahr (Hereinafter Referred To As ‘Ld. Ao’).

Section 80P(2)(d) of the Act says- "in respect of any income by way of interest or dividends derived by the co operative investment with any other co-operative society, the whole of such income." The appellant has received dividend from IFFCO and U.P. Cooperative Bank Ltd, which are cooperative society. As far as IFFCO is concerned, the fact

SHIVALIK PRINTS LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE-8, NEW DELHI

In the result, assessees’ appeals in ITA nos

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishraassessment Year: 2011-12 & Assessment Year: 2012-13

d) CIT v. Punjab Financial Corpn. [2002] 254 ITR 61 (Punj.& Har.) (FB) / [2002] 121 Taxman 656 (Punjab & Haryana) (FB) e) [2012] 20 taxmann.com 97 (DEL), Mrs. Manju Kapoor Dalmia v. ITO f) [2014] 41 taxmann.com 184 (Guj.), CIT v. Xavier Kelavani Mandal (P) Ltd.” 7. In rejoinder, learned counsel for the assessee relied upon the note filed distinguishing

M/S. SHIVALIK PRINTS LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, assessees’ appeals in ITA nos

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishraassessment Year: 2011-12 & Assessment Year: 2012-13

d) CIT v. Punjab Financial Corpn. [2002] 254 ITR 61 (Punj.& Har.) (FB) / [2002] 121 Taxman 656 (Punjab & Haryana) (FB) e) [2012] 20 taxmann.com 97 (DEL), Mrs. Manju Kapoor Dalmia v. ITO f) [2014] 41 taxmann.com 184 (Guj.), CIT v. Xavier Kelavani Mandal (P) Ltd.” 7. In rejoinder, learned counsel for the assessee relied upon the note filed distinguishing

MUFG BANK LTD,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION) CIRCLE-2(2)(1), NEW DELHI

In the result appeal of the assessee is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)

80P(2)(a)(i) of the Income-tax Act, 1961. This has been so held in Bihar State Co-operative Bank Ltd. v. CIT [1960] 39 ITR 114 (SC), CIT v. Karnataka State Co-operative Apex Bank [2001] 251 ITR 194 (SC) and CIT v. Ramanathapuram District Co-operative Central Bank Ltd. [2002] 255 ITR 423 (SC). 3. The principle

NATIONAL AGRICULTURAL COOPERATIVE MARKETING FEDERATION OF INDIA,NEW DELHI vs. ACIT CIRCLE-32(1), NEW DELHI

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

depreciation to 5%. I.T.A. No. 3555/DEL/2019 (A.Y. 2014-15) (Revenue) a. “On the facts and circumstances of the case, whether the CIT (A) has erred in not examining the issue of disallowance u/s 40(a)(i) of the Income Tax Act, 1961 made by the Assessing Officer, as the assessee had failed to furnish any cogent explanation in support

ACIT CIRCLE-54(1), NEW DELHI vs. NATIONAL AGRICULTURAL COOPERATIVE MARKETING FEDERATION OF INDIA, NEW DELHI

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

depreciation to 5%. I.T.A. No. 3555/DEL/2019 (A.Y. 2014-15) (Revenue) a. “On the facts and circumstances of the case, whether the CIT (A) has erred in not examining the issue of disallowance u/s 40(a)(i) of the Income Tax Act, 1961 made by the Assessing Officer, as the assessee had failed to furnish any cogent explanation in support

ACIT CIRCLE-54(1), NEW DELHI vs. NATIONAL AGRICULTURAL COOPERATIVE MARKETING FEDERATION OF INDIA, NEW DELHI

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

depreciation to 5%. I.T.A. No. 3555/DEL/2019 (A.Y. 2014-15) (Revenue) a. “On the facts and circumstances of the case, whether the CIT (A) has erred in not examining the issue of disallowance u/s 40(a)(i) of the Income Tax Act, 1961 made by the Assessing Officer, as the assessee had failed to furnish any cogent explanation in support

ACIT CIRCLE-54(1), NEW DELHI vs. NATIONAL AGRICULTURAL COOPERATIVE MARKETING FEDERATION OF INDIA, NEW DELHI

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

depreciation to 5%. I.T.A. No. 3555/DEL/2019 (A.Y. 2014-15) (Revenue) a. “On the facts and circumstances of the case, whether the CIT (A) has erred in not examining the issue of disallowance u/s 40(a)(i) of the Income Tax Act, 1961 made by the Assessing Officer, as the assessee had failed to furnish any cogent explanation in support

DCIT, NEW DELHI vs. M/S. CENTRAL WAREHOUSING CORP., NEW DELHI

In the result, all the appeals filed by the Revenue, i

Bench: Shri O.P. Kant, Accountantmember & Shri K.N. Chary[Through Video Conferencing]

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between ‘stock-in-trade' and ‘investment' and provides that if the motive behind purchase and sale of shares

DCIT, NEW DELHI vs. M/S. CENTRAL WAREHOUSING CORP., NEW DELHI

In the result, all the appeals filed by the Revenue, i

Bench: Shri O.P. Kant, Accountantmember & Shri K.N. Chary[Through Video Conferencing]

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between ‘stock-in-trade' and ‘investment' and provides that if the motive behind purchase and sale of shares

DCIT, NEW DELHI vs. M/S. CENTRAL WAREHOUSING CORP., NEW DELHI

In the result, all the appeals filed by the Revenue, i

Bench: Shri O.P. Kant, Accountantmember & Shri K.N. Chary[Through Video Conferencing]

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between ‘stock-in-trade' and ‘investment' and provides that if the motive behind purchase and sale of shares

CENTRAL WAREHOUSING CORPORATION,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals filed by the Revenue, i

Bench: Shri O.P. Kant, Accountantmember & Shri K.N. Chary[Through Video Conferencing]

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between ‘stock-in-trade' and ‘investment' and provides that if the motive behind purchase and sale of shares

DCIT, NEW DELHI vs. M/S. CENTRAL WAREHOUSING CORPORATION, NEW DELHI

In the result, all the appeals filed by the Revenue, i

Bench: Shri O.P. Kant, Accountantmember & Shri K.N. Chary[Through Video Conferencing]

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between ‘stock-in-trade' and ‘investment' and provides that if the motive behind purchase and sale of shares

M/S. CENTRAL WAREHOUSING CORPORATION,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the appeals filed by the Revenue, i

Bench: Shri O.P. Kant, Accountantmember & Shri K.N. Chary[Through Video Conferencing]

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between ‘stock-in-trade' and ‘investment' and provides that if the motive behind purchase and sale of shares

M/S. RELIGARE SECURITIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal of the assessee stands allowed in terms of our directions contained in the preceding

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastavaasstt. Year: 2008-09

depreciation. It was further submitted that the assessee had sought to file additional evidences before the Ld. CIT (A) which was rejected and the addition on this account was upheld. The Ld. AR submitted that as on date, 77% of the invoices were available and the same were open to verification. It was also submitted that the financial statements

BSC C&C JV,NEW DELHI vs. ACIT CIRCLE-62(1), NEW DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri C. N. Prasad & Shri M. Balaganeshm/S. Bsc C&C Joint Venture, Vs. Acit, 74, Hemkunt Colony, Circle-62(1), New Delhi-110048 New Delhi (Appellant) (Respondent) Pan: Aadfb8115G Assessee By : Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Revenue By: Shri Jitender Singh, Cit Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 20/08/2025

2. The only issue to be decided in this appeal is as to whether the Learned CITA was justified in not allowing the additional ground of appeal with regard to claim of deduction under section 80IA of the Act in the facts and circumstances of the instant case. M/s. BSC C&C Joint Venture 3. We have heard the rival

M/S THE ORIENTAL INSSURANCE CO.LTD.,,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Anil Chaturvedi & Shri Anubhav Sharmam/S. The Oriental Insurance Co. Ltd, Vs. The Dcit, A 25/27, Asaf Ali Road, Ltu, New Delhi New Delhi-110002 (Appellant) (Respondent) Pan: Aaact0627R

d) Disallowance u/s 14A - Rs. 49,84,91,810/- (e) Guest House Expenses - Rs. 47,43,236/- (f) Provision for Standard Assets - Rs. 2,94,82,474/- 3. The Id. Assessing Officer has made an addition of a sum of Rs. 10,27,94,88,259/- on account of gains from transfer of long term capital asset being equity shares