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85 results for “disallowance”+ Section 35Aclear

Sorted by relevance

Delhi85 Mumbai60 Bangalore27 Chennai13 Hyderabad10 Ahmedabad7 Pune7 Kolkata6 SC4 Dehradun2 Guwahati2 Cochin2 Panaji2 Chandigarh2 Cuttack2 Jaipur1 Karnataka1 Surat1 Allahabad1 MADAN B. LOKUR S.A. BOBDE1 Telangana1

Key Topics

Section 143(3)43 Section 14A42 Addition to Income38 Disallowance34 Deduction33 Section 144C32 Section 8031 Section 92C27 Transfer Pricing22 Section 144C(13)

THE COMMISSIONER OF INCOME TAX vs. M/S VRV BREWERIES & BOTTELING

ITA/594/2005HC Delhi19 Aug 2011

Bench: HON'BLE MR. JUSTICE SANJAY KISHAN KAUL,HON'BLE MR. JUSTICE RAJIV SHAKDHER

For Appellant: Ms Rashmi Chopra, AdvocateFor Respondent: Mr Ajay Vohra, Ms Kavita Jha & Mr Somnath Shukla

disallowance by invoking both the provisions, that is, sections 40A(2)(a) and Section 35A. The result was that the disallowances

THE COMMISSIONER OF INCOME TAX vs. M/S V.R.V. BREWERIES & BOTTELI

ITA/559/2006HC Delhi19 Aug 2011

Bench: HON'BLE MR. JUSTICE SANJAY KISHAN KAUL,HON'BLE MR. JUSTICE RAJIV SHAKDHER

For Appellant: Ms Rashmi Chopra, AdvocateFor Respondent: Mr Ajay Vohra, Ms Kavita Jha & Mr Somnath Shukla

Showing 1–20 of 85 · Page 1 of 5

18

Comparables/TP15

disallowance by invoking both the provisions, that is, sections 40A(2)(a) and Section 35A. The result was that the disallowances

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

ITA 1545/DEL/2015[2010-11]Status: DisposedITAT Delhi24 Oct 2016AY 2010-11

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. NC Sawain, CIT DR

Section 143Section 143(3)Section 144CSection 92C

disallowed on the ground of the same being contingent in nature. He further submitted that similar provision for increase in prices as at the end of the year was accepted and allowed in Hero MotoCorp Limited Vs. JCIT & DCIT Vs. Hero MotoCorp Ltd. ITA Nos. 1545/Del/2015 and 2424/Del/2015 (AY 2010-11) ITA No. 1609/Del/2016 and 914/Del/2016 (AY 2011-12) Page

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, CIRCLE- 11(1), NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

ITA 1351/DEL/2018[2009-10]Status: DisposedITAT Delhi23 Apr 2019AY 2009-10

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

For Appellant: Amount of Proposed international

Section 115JSection 143(3)Section 144C

disallowing this claim. Therefore, Ground No. 18 to 18.2 are allowed in favour of the assessee.” From the records it can be seen that the provision for the material is worked out in respect of price amendments which were already issued on 31.03.2009 which was made on the basis of actual supplied made upto the end of the year

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

ITA 7895/DEL/2019[2015-16]Status: DisposedITAT Delhi16 Oct 2020AY 2015-16

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)

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shr Surender Pal, CIT DR

Section 143(3)Section 14ASection 244ASection 37(1)Section 44C

35A) of the act. The assessee company has not disallowed the proportionate expenditure incurred on the above income as per the provisions of Section

HERO MOTOCROP LTD.,NEW DELHI vs. ACIT, CIRCLE- 11(1), NEW DELHI

The appeal of the assessee is partly allowed

ITA 9187/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Apr 2021AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2015-16

Section 115JSection 143(3)Section 144CSection 145ASection 80ISection 92C

disallowance made in that year was deleted on the ground that since in the first place, the Hero Motocorp Ltd. vs. ACIT parties were not related to the assessee company in terms of section 40A (2), disallowance on ground of excessive purchase price could not have been made under that section. Further, the Tribunal held that the transactions were entered

ACIT, NEW DELHI vs. M/S. GEO CONNECT LTD., NEW DELHI

In the result, appeals filed by the assessee in ITA Nos

ITA 5851/DEL/2011[2002-03]Status: DisposedITAT Delhi17 Jan 2017AY 2002-03

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

section 35A to 35E of the Act and apart from that there is no provision under the Act under which deferred revenue expenditure could be allowed to the assessee . 6.1 In view of above observations, the Assessing Officer disallowed

M/S GEO CONNECT LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeals filed by the assessee in ITA Nos

ITA 127/DEL/2011[2003-04]Status: DisposedITAT Delhi17 Jan 2017AY 2003-04

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

section 35A to 35E of the Act and apart from that there is no provision under the Act under which deferred revenue expenditure could be allowed to the assessee . 6.1 In view of above observations, the Assessing Officer disallowed

GEO CONVEST LTD vs. DCIT CIRCLE-12 (1),

In the result, appeals filed by the assessee in ITA Nos

ITA 1927/DEL/2008[2002-2003]Status: DisposedITAT Delhi17 Jan 2017AY 2002-2003

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

section 35A to 35E of the Act and apart from that there is no provision under the Act under which deferred revenue expenditure could be allowed to the assessee . 6.1 In view of above observations, the Assessing Officer disallowed

DCIT CIRCLE-12 (1) vs. GEO CONNECT LTD,

In the result, appeals filed by the assessee in ITA Nos

ITA 2088/DEL/2008[2002-2003]Status: DisposedITAT Delhi17 Jan 2017AY 2002-2003

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

section 35A to 35E of the Act and apart from that there is no provision under the Act under which deferred revenue expenditure could be allowed to the assessee . 6.1 In view of above observations, the Assessing Officer disallowed

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal No. 2424/Del/ 2015 filed by the revenue in assessment year 2010-11 is partly allowed

ITA 1616/DEL/2017[2012-13]Status: DisposedITAT Delhi13 Jun 2018AY 2012-13

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 143(3)Section 144CSection 92C

disallowance made u/s 40(a)(ia) is to be deleted. 14.96. It would be pertinent to point that section 194C was amended by the Finance (2) Act, 2009 w.e.f. 1.10.2009, whereby the definition of “work” was enlarged to include contract for manufacturing or supplying a product according to the requirement or specification of a customer by using material purchased from

HERO MOTOCORP LTD.,,NEW DELHI vs. ADDL.CIT, RANGE-11, NEW DELHI

In the result ground No

ITA 6990/DEL/2017[2013-14]Status: DisposedITAT Delhi20 Jun 2018AY 2013-14

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 6990/Del/2017 (A.Y 2013-14)

Section 143(3)Section 144C

disallowed as being capital in nature. Thus, the Ld. AR submitted that for the aforesaid cumulative reasons, no portion of the royalty expenditure or Technical Guidance fees incurred by the assessee calls for being disallowed. 49. The Ld. DR relied upon the Assessment Order and Order of the TPO but could not distinguish the order of the Tribunal for A.Ys

STERIA INDIA LTD.,NOIDA vs. ADDL.CIT, SPECIAQL RANGE-8, NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

ITA 3992/DEL/2017[2013-14]Status: DisposedITAT Delhi28 Sept 2020AY 2013-14

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Sh. Anupam Kant Garg, CIT DR

Section 143Section 143(3)Section 144CSection 92C

disallowance of deduction u/s 10 AA of the act. The assessee claimed deduction of ₹ 188,349,607 whereas the learned that assessing officer allowed only 18,80,82,642. The main reason is the exclusion of the expenditure of ₹ 72,296,526/– from the total turnover of the assessee for the purpose of computing deduction

STERIA (INDIA) LTD.,NOIDA vs. ADDL. CIT, SPL. RANGE- 8 , NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

ITA 5745/DEL/2018[2014-15]Status: DisposedITAT Delhi28 Sept 2020AY 2014-15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Sh. Anupam Kant Garg, CIT DR

Section 143Section 143(3)Section 144CSection 92C

disallowance of deduction u/s 10 AA of the act. The assessee claimed deduction of ₹ 188,349,607 whereas the learned that assessing officer allowed only 18,80,82,642. The main reason is the exclusion of the expenditure of ₹ 72,296,526/– from the total turnover of the assessee for the purpose of computing deduction

M/S STERIA NDIA LTD.,,NOIDA vs. ADDL CIT, NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

ITA 741/DEL/2017[2012-13]Status: DisposedITAT Delhi28 Sept 2020AY 2012-13

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Sh. Anupam Kant Garg, CIT DR

Section 143Section 143(3)Section 144CSection 92C

disallowance of deduction u/s 10 AA of the act. The assessee claimed deduction of ₹ 188,349,607 whereas the learned that assessing officer allowed only 18,80,82,642. The main reason is the exclusion of the expenditure of ₹ 72,296,526/– from the total turnover of the assessee for the purpose of computing deduction

M/S. KRISHAK BHARTI COOPERATIVE LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2342/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Dec 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

disallowance u/s 14A. 3.2.6 Further, Ld. AR has relied upon the judicial pronouncement of the jurisdictional Delhi High Court in the appellant's own case pertaining to A.Y. 2006-07 in ITA No.444/2011 decided on 18/07/2012 relating dividend income of RS.15,011 /- from NAFED, which is included in the total income and only deduction u/s 80P(2)(d) has been

ACIT,, NEW DELHI vs. M/S KRISHAK BHARATI COOPERATIVE LTD.,, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2973/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Dec 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

disallowance u/s 14A. 3.2.6 Further, Ld. AR has relied upon the judicial pronouncement of the jurisdictional Delhi High Court in the appellant's own case pertaining to A.Y. 2006-07 in ITA No.444/2011 decided on 18/07/2012 relating dividend income of RS.15,011 /- from NAFED, which is included in the total income and only deduction u/s 80P(2)(d) has been

M/S. KRISHAK BHARTI COOPERATIVE LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2341/DEL/2017[2010-11]Status: DisposedITAT Delhi29 Dec 2021AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

disallowance u/s 14A. 3.2.6 Further, Ld. AR has relied upon the judicial pronouncement of the jurisdictional Delhi High Court in the appellant's own case pertaining to A.Y. 2006-07 in ITA No.444/2011 decided on 18/07/2012 relating dividend income of RS.15,011 /- from NAFED, which is included in the total income and only deduction u/s 80P(2)(d) has been

ACIT,, NEW DELHI vs. M/S KRISHAK BHARATI COOPERATIVE LTD.,, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2972/DEL/2017[2010-11]Status: DisposedITAT Delhi29 Dec 2021AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

disallowance u/s 14A. 3.2.6 Further, Ld. AR has relied upon the judicial pronouncement of the jurisdictional Delhi High Court in the appellant's own case pertaining to A.Y. 2006-07 in ITA No.444/2011 decided on 18/07/2012 relating dividend income of RS.15,011 /- from NAFED, which is included in the total income and only deduction u/s 80P(2)(d) has been

STANDARD CHARTERED GRINDLAYS PTY LTD.,NEW DELHI vs. DDIT, NEW DELHI

Appeal is partly allowed

ITA 3578/DEL/2013[1995-96]Status: DisposedITAT Delhi10 Mar 2017AY 1995-96

Bench: Shri I. C. Sudhir & Shri O. P. Kant

For Appellant: Ms. Shashi M. Kapila, Adv.; &For Respondent: Shri Anuj Arora, CIT [DR]

Section 153Section 156Section 220(2)Section 244ASection 250Section 254

disallowance of interest, but could not succeed. The assessee also could not succeed on other issues i.e. time limitation for giving appeal effect, interest charged under section 244A and 220(2) of the Act, hence present appeal has been preferred by the assessee. 5. Ground Nos. 1, 2 and 3 : In these grounds the claim of the assessee is that