BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

8 results for “disallowance”+ Section 92A(2)(i)clear

Sorted by relevance

Mumbai73Delhi49Bangalore33Kolkata30Chennai17Pune16Hyderabad8Ahmedabad4Cochin2Jaipur2Karnataka2Telangana1Indore1Jabalpur1

Key Topics

Section 80I28Section 143(3)17Addition to Income8Section 92C5Deduction5Section 153A4Transfer Pricing4Section 143(2)3Section 353Section 115J

NEOVANTAGE BIO-TECHNOLOGY PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE 5(1), HYDERABAD

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

ITA 924/HYD/2024[2020-21]Status: DisposedITAT Hyderabad10 Sept 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Respondent: Dr. Narendra Kumar Naik
Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 92C

section 92A(2)(c) of the Act was not satisfied since the loan advanced did not constitute ITA Nos.923 & 924/Hyd/2024 21 51% of the book value of total assets on the date of agreement. Accordingly, the lender and the assessee cannot be treated as Associated Enterprises (“AEs”), and no benchmarking is permissible. In their second contention, the Ld. AR submitted

3
Disallowance3
Section 144C(5)2

NEOVANTAGE INNOVATION PARK PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD 16(3), HYDERABAD

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

ITA 923/HYD/2024[2020-21]Status: DisposedITAT Hyderabad10 Sept 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Respondent: Dr. Narendra Kumar Naik
Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 92C

section 92A(2)(c) of the Act was not satisfied since the loan advanced did not constitute ITA Nos.923 & 924/Hyd/2024 21 51% of the book value of total assets on the date of agreement. Accordingly, the lender and the assessee cannot be treated as Associated Enterprises (“AEs”), and no benchmarking is permissible. In their second contention, the Ld. AR submitted

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 606/HYD/2016[2012-13]Status: DisposedITAT Hyderabad31 Jul 2023AY 2012-13

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A
Section 143(3)Section 153ASection 80I

disallowed the claim of the assessee u/s. 80IA stating that the deduction was not claimed in the original return of income and the assessee is not the owner of infrastructure facility, so as to be eligible for claim u/s. 80IA of the Act. The relevant observation of the Assessing Officer in the body of the assessment order reads as under

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 604/HYD/2016[2010-11]Status: DisposedITAT Hyderabad31 Jul 2023AY 2010-11

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A
Section 143(3)Section 153ASection 80I

disallowed the claim of the assessee u/s. 80IA stating that the deduction was not claimed in the original return of income and the assessee is not the owner of infrastructure facility, so as to be eligible for claim u/s. 80IA of the Act. The relevant observation of the Assessing Officer in the body of the assessment order reads as under

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 605/HYD/2016[2011-12]Status: DisposedITAT Hyderabad31 Jul 2023AY 2011-12

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A
Section 143(3)Section 153ASection 80I

disallowed the claim of the assessee u/s. 80IA stating that the deduction was not claimed in the original return of income and the assessee is not the owner of infrastructure facility, so as to be eligible for claim u/s. 80IA of the Act. The relevant observation of the Assessing Officer in the body of the assessment order reads as under

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 603/HYD/2016[2009-10]Status: DisposedITAT Hyderabad31 Jul 2023AY 2009-10

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A
Section 143(3)Section 153ASection 80I

disallowed the claim of the assessee u/s. 80IA stating that the deduction was not claimed in the original return of income and the assessee is not the owner of infrastructure facility, so as to be eligible for claim u/s. 80IA of the Act. The relevant observation of the Assessing Officer in the body of the assessment order reads as under

ASTRIX LABORATORIES LIMITED (AMALGAMATED WITH MYLAN LABORATORIES LIMITED) HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-16(2), HYDERABAD, HYDERABAD

In the result, the appeal of the assessee is dismissed

ITA 952/HYD/2017[2007-08]Status: DisposedITAT Hyderabad22 Jun 2022AY 2007-08

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2007-08 M/S. Astrix Laboratories Vs. The Deputy Commissioner Limited, (Amalgamated Of Income Tax, With M/S. Mylan Circle 16(2), Laboratories Limited), Hyderabad. Hyderabad. Pan : Aafca4120R. (Appellant) (Respondent) Assessee By: Sri K.A. Sai Prasad. Revenue By: Sri Rajendra Kumar, Cit Date Of Hearing: 20.06.2022 Date Of Pronouncement: 22.06.2022 O R D E R Per Laliet Kumar, J.M. This Appeal Is Filed By The Assessee Feeling Aggrieved By The Order Of Dy.Commissioner Of Income Tax, Circle 16(2), Hyderabad Dt.31.03.2017 For The Assessment Year 2007-08 On The Following Grounds : “1. The Order Passed By The Assessing Officer U/S 143(3) R.W.S. 144C & 92Ca Of The Income Tax Act, Passed On 31.03.2017 Is Contrary T The Facts & Law. 2. The Tpo Erred In Not Following The Hon’Ble Tribunal’S Directions & Thereby Making An Adjustment Of Rs.4,61,00,000/- U/S 92Ca Of The Act In Respect Of Sales Made To Associated Enterprises.” 2. The Brief Facts Of The Case Are As Under :

For Appellant: Sri K.A. Sai PrasadFor Respondent: Sri Rajendra Kumar, CIT
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 144CSection 253Section 92ASection 92C

Section 92A of the Act, the case was referred to Transfer Pricing Officer (Additional Commissioner of Income Tax), who issued Transfer Pricing Order u/s 92CA of the Act dated 29.10.2010. The Assessing Officer framed Draft Assessment Order u/s 143(3) dated 31.12.2010 taking into account the above Transfer Pricing Order. The Assessing Officer vide his draft order has determined

MYLAN LABORATORIES LIMITED (FORMERLY KNOWN AS MATRIX LABORATORIES LIMITED), HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-16(2), HYDERABAD, HYDERABAD

In the result, the appeal filed by the assessee is dismissed

ITA 953/HYD/2017[2007-08]Status: DisposedITAT Hyderabad27 Jun 2022AY 2007-08

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2007-08 Mylan Laboratories Vs. Dcit,Circle-16(2) Limited(Formerly Matrix It Towers, Masab Tank Laboratories Limited) Hyderabad-500 004 Plot No.564/A/22, Road No.92, Jubilee Hills Hyderabad-500 033

For Appellant: Shri K.A.Sai Prasad, CAFor Respondent: Shri Rajendra Kumar,CIT-DR
Section 115JSection 143(1)Section 143(3)Section 144CSection 35Section 92ASection 92C

disallowing the weighted deduction at 150% of Rs.2,26,00,589/- u/s 35(2AB) of the Act in respect of clinical drug trials carried out by it on the ground that it is incurred outside the "in-house R&D". 3. The TPO erred in not following the Hon'ble Tribunal's directions and thereby retaining the adjustment