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1,152 results for “disallowance”+ Section 96clear

Sorted by relevance

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Key Topics

Addition to Income79Section 143(3)50Disallowance45Section 14738Deduction28Section 43B26Section 14820Section 153A17Reassessment17Section 68

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

Appeal of the Revenue is dismissed

ITA 1982/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Feb 2023AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

Section 14ASection 2(22)(e)Section 40Section 40a

96,78,288 IRFC-7.18% 1.83,21,712 HUDCO-7.34% 1,83,50,000 HUDCO-8.51% 45,46,438 NHPC-8.18% 54,13,927 PFC-8.18% 98,71,812 Total 15,11,45,290 Detailed working of disallowance under section

M/S. PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 2162/DEL/2017[2013-14]Status: Disposed

Showing 1–20 of 1,152 · Page 1 of 58

...
15
Transfer Pricing14
Reopening of Assessment14
ITAT Delhi
29 Nov 2023
AY 2013-14

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

section 36(1)(viii). This addition may kindly be deleted. 6. That the disallowances made/upheld and the observations made are unjust, unlawful and based on mere surmises and conjectures. additions/disallowances made cannot be justified by any material on record and in any case they are excessive. 7. That the explanation given and the evidence produced, material placed and available

ACIT, NEW DELHI vs. M/S. PTC INDIA FINANCIAL SERVICES LTD., NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 2175/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2023AY 2013-14

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

section 36(1)(viii). This addition may kindly be deleted. 6. That the disallowances made/upheld and the observations made are unjust, unlawful and based on mere surmises and conjectures. additions/disallowances made cannot be justified by any material on record and in any case they are excessive. 7. That the explanation given and the evidence produced, material placed and available

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. PTC INDIA FINANCIAL SERVICES LTD, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 7433/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Nov 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

section 36(1)(viii). This addition may kindly be deleted. 6. That the disallowances made/upheld and the observations made are unjust, unlawful and based on mere surmises and conjectures. additions/disallowances made cannot be justified by any material on record and in any case they are excessive. 7. That the explanation given and the evidence produced, material placed and available

PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, CIRCLE- 19(2), NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 7273/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Nov 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

section 36(1)(viii). This addition may kindly be deleted. 6. That the disallowances made/upheld and the observations made are unjust, unlawful and based on mere surmises and conjectures. additions/disallowances made cannot be justified by any material on record and in any case they are excessive. 7. That the explanation given and the evidence produced, material placed and available

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

ITA 4796/DEL/2017[2012-13]Status: PendingITAT Delhi13 Jul 2023AY 2012-13

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

Section 14A

96,32,660/- which was subsequently revised on 26/03/2014 at Rs.218,31,32,540/-. The case was selected for scrutiny. Order u/s 143(3) of the Act was passed on 31/03/2015 assessing the income at Rs. 307,17,44,697/- after disallowance of Rs.16,72,58,935/- u/s 14A read with Rule 8D of the Income Tax Rules, 1962 (‘Rules

RELIGARE FINVEST LTD.,NEW DELHI vs. ACIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

ITA 7856/DEL/2017[2014-15]Status: DisposedITAT Delhi13 Jul 2023AY 2014-15

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

Section 14A

96,32,660/- which was subsequently revised on 26/03/2014 at Rs.218,31,32,540/-. The case was selected for scrutiny. Order u/s 143(3) of the Act was passed on 31/03/2015 assessing the income at Rs. 307,17,44,697/- after disallowance of Rs.16,72,58,935/- u/s 14A read with Rule 8D of the Income Tax Rules, 1962 (‘Rules

ACIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD.,, NEW DELHI

In the result, -Appeal in ITA No

ITA 5202/DEL/2017[2012-13]Status: DisposedITAT Delhi13 Jul 2023AY 2012-13

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

Section 14A

96,32,660/- which was subsequently revised on 26/03/2014 at Rs.218,31,32,540/-. The case was selected for scrutiny. Order u/s 143(3) of the Act was passed on 31/03/2015 assessing the income at Rs. 307,17,44,697/- after disallowance of Rs.16,72,58,935/- u/s 14A read with Rule 8D of the Income Tax Rules, 1962 (‘Rules

ACIT (OSD), CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, -Appeal in ITA No

ITA 133/DEL/2018[2014-15]Status: DisposedITAT Delhi13 Jul 2023AY 2014-15

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

Section 14A

96,32,660/- which was subsequently revised on 26/03/2014 at Rs.218,31,32,540/-. The case was selected for scrutiny. Order u/s 143(3) of the Act was passed on 31/03/2015 assessing the income at Rs. 307,17,44,697/- after disallowance of Rs.16,72,58,935/- u/s 14A read with Rule 8D of the Income Tax Rules, 1962 (‘Rules

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

ITA 6116/DEL/2018[2015-16]Status: DisposedITAT Delhi13 Jul 2023AY 2015-16

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

Section 14A

96,32,660/- which was subsequently revised on 26/03/2014 at Rs.218,31,32,540/-. The case was selected for scrutiny. Order u/s 143(3) of the Act was passed on 31/03/2015 assessing the income at Rs. 307,17,44,697/- after disallowance of Rs.16,72,58,935/- u/s 14A read with Rule 8D of the Income Tax Rules, 1962 (‘Rules

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

ITA 547/DEL/2018[2013-14]Status: DisposedITAT Delhi13 Jul 2023AY 2013-14

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

Section 14A

96,32,660/- which was subsequently revised on 26/03/2014 at Rs.218,31,32,540/-. The case was selected for scrutiny. Order u/s 143(3) of the Act was passed on 31/03/2015 assessing the income at Rs. 307,17,44,697/- after disallowance of Rs.16,72,58,935/- u/s 14A read with Rule 8D of the Income Tax Rules, 1962 (‘Rules

DCIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, -Appeal in ITA No

ITA 7553/DEL/2018[2015-16]Status: DisposedITAT Delhi13 Jul 2023AY 2015-16

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

Section 14A

96,32,660/- which was subsequently revised on 26/03/2014 at Rs.218,31,32,540/-. The case was selected for scrutiny. Order u/s 143(3) of the Act was passed on 31/03/2015 assessing the income at Rs. 307,17,44,697/- after disallowance of Rs.16,72,58,935/- u/s 14A read with Rule 8D of the Income Tax Rules, 1962 (‘Rules

DEV BHUMI DOLD CHAIN PVT. LTD,DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

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

ITA 3163/DEL/2019[2014-15]Status: DisposedITAT Delhi09 May 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 115JSection 143(3)Section 37Section 37(1)Section 40Section 40ASection 40A(3)

Disallowance of Rs.2,96,150/- under section 37 of the Act, ii. Disallowance of Rs.15,77,164/- under section 40(a)(ia) of the Act, iii. Disallowance

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

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

ITA 1507/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Feb 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

disallowance made by the assessee u/s 43B of the Act was denied by the AO. The AO computed the disallowance out of R&D cess amounting to Rs.33.89 crores. Ld. Counsel for the assessee submitted that at the outset, it may be noted that as per the provision of Land Research and Development, cess is imposed on import of technology

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

ITA 961/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Feb 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

disallowance made by the assessee u/s 43B of the Act was denied by the AO. The AO computed the disallowance out of R&D cess amounting to Rs.33.89 crores. Ld. Counsel for the assessee submitted that at the outset, it may be noted that as per the provision of Land Research and Development, cess is imposed on import of technology

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

SECTION 45, READ WITH SECTION 28(i), OF THE INCOME-TAX ACT, 1961 - CAPITAL GAINS, CHARGEABLE AS - ISSUE OF TAXABILITY OF SURPLUS ON SALE OF SHARES AND SECURITIES - CAPITAL GAINS OR BUSINESS INCOME - INSTRUCTIONS IN ORDER TO REDUCE LITIGATION CIRCULAR NO.6/2016 [F.NO.225/12/2016-ITA-II], DATED 29-2-2016 1. Sub-section (14) of section 2 of the Income

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

SECTION 45, READ WITH SECTION 28(i), OF THE INCOME-TAX ACT, 1961 - CAPITAL GAINS, CHARGEABLE AS - ISSUE OF TAXABILITY OF SURPLUS ON SALE OF SHARES AND SECURITIES - CAPITAL GAINS OR BUSINESS INCOME - INSTRUCTIONS IN ORDER TO REDUCE LITIGATION CIRCULAR NO.6/2016 [F.NO.225/12/2016-ITA-II], DATED 29-2-2016 1. Sub-section (14) of section 2 of the Income

BIO MED PRIVATE LIMITED,GHAZIABAD vs. ADDL. CIT, SPECIAL RANGE, GHAZIABAD, GHAZIABAD

In the result, this appeal is partly allowed as above

ITA 3544/DEL/2023[2013-14]Status: DisposedITAT Delhi09 Apr 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraassessment Year: 2013-14

Section 14ASection 35

disallowed the claim under section 35(2AB)of the Act. 4 Bio Med Private Limited 6. We have heard both parties at length and have perused the material available on the record. We find merit in the argument/contention/ submission of the Ld. Counsel. In the case of Marksans Pharma Ltd. (supra), the Tribunal is of the view that prior

ACIT, CIRCLE-10(1), NEW DELHI vs. IRCON INTERNATIONAL LTD, NEW DELHI

In the result, both appeals of the Revenue are dismissed as above

ITA 1104/DEL/2023[2018-19]Status: DisposedITAT Delhi18 Jul 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 115JSection 14ASection 80I

section 80IA(13) does not prevent developers in claiming deduction u/s 80IA(4). Similarly showing the receipts as work receipts in the books of accounts of the appellant alone cannot determine the character of the appellant which in our opinion was that of development. The argument of revenue that infrastructure facility should be owned by the appellant is also misplaced

ACIT CIRCLE 10(1), NEW DELHI vs. IRCON INTERNATIONAL LTD, NEW DELHI

In the result, both appeals of the Revenue are dismissed as above

ITA 1108/DEL/2023[2017-18]Status: DisposedITAT Delhi18 Jul 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 115JSection 14ASection 80I

section 80IA(13) does not prevent developers in claiming deduction u/s 80IA(4). Similarly showing the receipts as work receipts in the books of accounts of the appellant alone cannot determine the character of the appellant which in our opinion was that of development. The argument of revenue that infrastructure facility should be owned by the appellant is also misplaced