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21 results for “TDS”+ Section 14A(3)clear

Sorted by relevance

Mumbai1,086Delhi594Chennai495Bangalore245Kolkata239Ahmedabad108Hyderabad50Raipur38Pune36Visakhapatnam34Ranchi30Karnataka29Chandigarh23Jaipur21Indore17Lucknow15Cuttack10Surat10Rajkot9Amritsar8Guwahati7Calcutta5Varanasi4Cochin4Panaji3Nagpur3Telangana3Dehradun2Punjab & Haryana1Jodhpur1

Key Topics

Section 14A41Section 26335Section 143(3)24Disallowance15Addition to Income13Section 271(1)(c)10Section 14710Section 270A10Section 36(1)(iii)10Section 80I

ASSOCIATED SOAPSTONE DISTRIBUTING CO PRIVATE LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -2, JAIPUR, JAIPUR

ITA 243/JPR/2023[2018-19]Status: DisposedITAT Jaipur04 Mar 2024AY 2018-19
For Appellant: Shri Rohan Sogani, CAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 139(1)Section 143(2)Section 143(3)Section 14ASection 263Section 36(1)(ii)Section 37

14A, read with Rule 8D, of Rs.\n23,31,312 [\"Issue No. 1”].\n•\nInterest of Rs. 55,810 on delayed payment of TDS not eligible for\ndeduction under Section 36(1)(ii) or Section 37 [“Issue No. 2"].\n•\nExcess MAT Credit, pertaining to AY 2016-17, Rs. 96,13,814 erroneously\nallowed. [\"Issue No. 3

Showing 1–20 of 21 · Page 1 of 2

8
Deduction8
TDS6

CAREER POINT LIMITED,KOTA, RAJASTHAN vs. PRINCIPAL COMMISSIONER OF INCOME TAX, UDAIPUR, RAJASTHAN

In the result, the appeal of the assessee is allowed

ITA 242/JPR/2023[2018-19]Status: DisposedITAT Jaipur22 Aug 2023AY 2018-19

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri Ajey Malik (CIT)
Section 143(2)Section 143(3)Section 14ASection 263

TDS u/s 194C was deducted towards rendering, managing and 36 Career Point Limited, Kota. maintaining services by the assessee firm. Consequently, the AO accepted the explanation of the assessee firm and assessed the income under the head ‘’Income from Business and Profession’’. However, ld. PCIT while invoking the provisions of Section 263 of the Act erred in placing a restrictive

RASHLEELA ENTERPRISES PRIVATE LIMITED,JAIPUR vs. THE PCIT (CENTRAL), JAIPUR

In the result, the appeal of the assessee is allowed

ITA 461/JPR/2024[2019-20]Status: DisposedITAT Jaipur05 Sept 2024AY 2019-20
For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Arvind Kumar, CIT-DR
Section 143(3)Section 14ASection 153DSection 263

3) nor prejudicial to the interest of revenue as\nthe amount of disallowance as the amount of disallowance according to\nthe provisions of Rule 8D as applicable for the year under\nconsideration would be merely Rs. 2,118/- on account of indirect\nexpenses and nil on account of direct expenses as there were no\ndirectly attributable expenses.\nIn view

M/S ETERNAL HEART CARE CENTRE & RESEARCH INSTITUTE PVT. LTD. ,3A, JAGATPURA ROAD, NEAR JAWAHAR CIRCLE, JAIPUR vs. PCIT, JAIPUR-2, JAIPUR

In the result, appeal filed by the assessee is allowed

ITA 263/JPR/2023[2018-19]Status: DisposedITAT Jaipur06 Sept 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Yogesh Parwal, CA &For Respondent: Shri James Kurian, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 263Section 271A

3. In compliance of notice under section 142(1) of the Income Tax Act, 1961, the assessee filed the requisitioned details documents electronically. 4. On the basis of material available on record and the explanation of the assessee on the issue, the total income of the assessee is hereby computed at Nil which also includes total income of the assessee

SH. NAWAL KISHORE DANGAYACH,A-34-A, RAM NAGAR, SHASTRI NAGAR, JAIPUR vs. ACIT, CIRCLE-4, , JAIPUR

In the result, appeal of the assessee is partly allowed

ITA 304/JPR/2023[2016-17]Status: DisposedITAT Jaipur10 Oct 2023AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Smt. Monisha Choudhary ( Addl. CIT) a
Section 14ASection 37

3 SHRI NAWAL KISHORE DANGAYACH VS ACIT, CIRCLE-4, JAIPUR the Act. The relevant narration as made by the AO in para 2.4 of the assessment order is as under:- ‘’2.4 Thus, total disallowance u/s 14A is worked out to Rs.78,311/- and the same is treated as expenditure incurred in relation to tax free investment. Hence, the amount

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

ITA 598/JPR/2024[2018-2019]Status: DisposedITAT Jaipur26 Dec 2024AY 2018-2019
For Appellant: Sh. Siddharth Ranka, AdvFor Respondent: \nSh. Saurav Harsh, Adv.&
Section 142(1)Section 143(2)Section 144oSection 14ASection 263Section 69

14A - As decided in Era\nInfrastructure (India) Ltd. [2022 (7) TMI 1093 - DELHI HIGH COURT]Amendment to\nsection 14A of the Act which is for removal of doubts cannot be presumed to be\nretrospective.\n• Hon'ble Delhi High Court in the case of PCIT v. Era Infrastructure (India) Ltd.\n(2022) 7 TMI 1093:Whether ITAT erred in relying

M/S RAJASTHAN STATE INDUSTRIAL DEVELOPMENT AND INVESTMENT CORPORATION LTD.,JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

In the result, both the appeals of the assessee are allowed as indicated hereinabove

ITA 310/JPR/2025[2014-15]Status: DisposedITAT Jaipur06 Aug 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274Section 80

3,72,56,000 Nil Set aside on account of reduction in nature of land under litigation Short credit of TDS 1,44,565 Nil Nil Thus after the order of ITAT dt.10.04.2018 (PB 18-83), following disallowance made by the AO stood confirmed:- RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORATION LTD VS DCIT, CIRCLE-6, JAIPUR Disallowance of CSR Expenses

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

In the result, all appeals of the revenue are stands dismissed

ITA 901/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

3), Kolkata that they are Directors in the various companies which is controlled & managed by Mr. Anjani Banka. Statement of Mr. Anjani Banka was also recorded by the DDIT(Inv.), Unit-2(3), Kolkata on 29.03.2014 wherein he accepted that he is engaged in providing accommodation entries in form of share capital, unsecured loan, LTCG etc and to facilitate

M/S RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORATION LTD.,JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

In the result, both the appeals of the assessee are allowed as indicated\nhereinabove

ITA 309/JPR/2025[2013-14]Status: DisposedITAT Jaipur06 Aug 2025AY 2013-14
For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 14ASection 271(1)(c)Section 274Section 80

3,72,56,000 | Nil | Set aside\n| on account of reduction in\n| nature of land\nunder\n| litigation\n| Short credit of TDS | 1,44,565 | Nil | Nil\n\nThus after the order of ITAT dt.10.04.2018 (PB 18-83), following disallowance\nmade by the AO stood confirmed:-\n\n5\nITA NO.309 & 310/JPR/2025\nRAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORATION

AU SMALL FINANCE BANK LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAIPUR-1

In the result both the appeals filed by the assessee in ITA

ITA 203/JPR/2022[2017-18]Status: DisposedITAT Jaipur28 Jul 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Sanjay Jhanwar, Sr. AdvocateFor Respondent: Shri James Kurian, CIT
Section 115JSection 263Section 35ASection 36(1)(viia)

Section 115JB of the Act. 6. Under the facts and the circumstances of the case and in law the Ld.PCIT, Jaipur-1 has grossly erred in directing the AO for fresh assessment even after appreciating the certificate u/s 35AC(2) of the Act, as submitted during the proceedings u/s 263 of the Act. 7. Under the facts and the circumstances

APM INDUSTRIES LTD,BHIWADI, ALWAR vs. DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE - 1, ALWAR

In the result, appeal of the assessee is allowed

ITA 203/JPR/2023[2018-19]Status: DisposedITAT Jaipur12 Sept 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 203/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2018-19 APM Industries Ltd. SP-147, Industrial Area Bhiwadi, Alwar cuke Vs. Deputy Commissioner of Income Tax Central Circle-01, Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AACCA 5114 G vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. S. L. Poddar jktLo dh vksj ls@ Revenue by : Smt. Monisha Choudhary (JCIT) a l

For Appellant: Sh. S. L. PoddarFor Respondent: Smt. Monisha Choudhary (JCIT) a
Section 142(1)Section 143(2)Section 143(3)Section 194ASection 263Section 40Section 40A(7)

3,89,47,418/- was liable to TDS u/s. 194A of the Act. Therefore, as per provision of section 40(a)(ia) of the Act, 30 % of this amount which comes to Rs. 1,05,52,530/- was liable to be disallowed. The ld. PCIT further observed that the assessee received duty drawback of Rs. 2,37,355/-. However, there

DEREWALA INDUSTRIES LIMITED,JAIPUR vs. ACIT/DCIT CIR-6, JAIPUR

Appeal is partly allowed; while

ITA 170/JPR/2025[2017-18]Status: DisposedITAT Jaipur08 Apr 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Vinod Kumar Gupta, CAFor Respondent: Shri Anup Singh, Addl. CIT-DR
Section 14ASection 195(1)Section 250Section 37(1)Section 40Section 40A

3,63,287/- worked out u/s. 40(a)(i) of the Act due to non-deduction of the TDS; after disallowance a sum of Rs. 5,73,999/- worked out u/s. 14A of the Act; and after disallowance of a sum of Rs.75,000/-as per provisions of section

JAIPUR TELECOM PRIVATE LIMITED,JAIPUR vs. DCIT CIRCLE 1, JPR, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 788/JPR/2023[2017-18]Status: DisposedITAT Jaipur22 Apr 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Tarun Mittal (C.A.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 143(3)Section 270ASection 43(1)

14A -Held, yes -Whether this by no stretch of imagination could be held to be 'misreporting' - Held, yes - Whether further, in absence of details as to which limb of section 270A was attracted and how ingredient of sub-section (9) of section 270A was satisfied, mere reference to word 'misreporting' by revenue in penalty order to deny immunity from imposition

JAIPUR TELECOM PVT. LTD,JAIPUR vs. DCIT CIRCLE 1, JPR, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 789/JPR/2023[2018-19]Status: DisposedITAT Jaipur22 Apr 2024AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Tarun Mittal (C.A.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 143(3)Section 270ASection 43(1)

14A -Held, yes -Whether this by no stretch of imagination could be held to be 'misreporting' - Held, yes - Whether further, in absence of details as to which limb of section 270A was attracted and how ingredient of sub-section (9) of section 270A was satisfied, mere reference to word 'misreporting' by revenue in penalty order to deny immunity from imposition

M/S GVK JAIPUR EXPRESSWAY PRIVATE LIMITED,TELANGANA vs. PCIT 2, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 248/JPR/2023[2018-19]Status: DisposedITAT Jaipur19 Aug 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115Section 115JSection 143(3)Section 14ASection 263Section 36(1)(iii)Section 80

14A of the Act, while directing that the said\ndisallowance be made u/s 36(1)(iii) of the Act and further holding that the said\ndisallowance cannot be added back to the assessee's income computed under\nthe provisions of section 115JB of the Act.\"\n30. Similar is the position in the Hon'ble High Court in relation to\nother

GEETANJALI HOTELS & PROMOTERS PVT LTD,JAIPUR vs. ACIT, JAIPUR

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

ITA 298/JPR/2017[2012-13]Status: DisposedITAT Jaipur26 Sept 2022AY 2012-13
For Appellant: Shri Mahendra Gargieya ( Adv.) &For Respondent: Ms. Runi Pal (Addl.CIT)a
Section 143(3)Section 14ASection 251(2)Section 36(1)(iii)

14A.(AO Pg 5-6 ) 3 Investment in AOPs (PB 3,82,10,700/- The investment in the AOP is 41) made to obtain the liquor contract in Rajasthan. The AOP was obtaining liquor [Initial investment contract in earlier years and in as such, was commercial F.Y 2012-13 investment only. (A.Y 2013-14)] Total

GEETANJALI HOTELS & PROMOTERS PVT LTD,JAIPUR vs. ACIT, JAIPUR

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

ITA 299/JPR/2017[2013-14]Status: DisposedITAT Jaipur26 Sept 2022AY 2013-14
For Appellant: Shri Mahendra Gargieya ( Adv.) &For Respondent: Ms. Runi Pal (Addl.CIT)a
Section 143(3)Section 14ASection 251(2)Section 36(1)(iii)

14A.(AO Pg 5-6 ) 3 Investment in AOPs (PB 3,82,10,700/- The investment in the AOP is 41) made to obtain the liquor contract in Rajasthan. The AOP was obtaining liquor [Initial investment contract in earlier years and in as such, was commercial F.Y 2012-13 investment only. (A.Y 2013-14)] Total

ALLEN CAREER INSTITUTE,JAIPUR vs. JCIT, KOTA

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

ITA 620/JPR/2016[2011-12]Status: DisposedITAT Jaipur04 Aug 2022AY 2011-12
For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri A.S. Nehra, Addl. CIT
Section 143(3)Section 36Section 36(1)(iii)Section 37(1)

section 36 (i)(iii). The assessee firm did not borrow any fresh money during the year and even have no opening borrowed money. Bank overdraft account is not borrowed money, because overdraft account is against the assessee own bank FDRs. It means bank overdraft is assesee own money taken out of FDR account temporarily. As and when the assessee needed

DCIT, CIRCLE-3, JAIPUR, JAIPUR vs. M/S. JOY SYNDICATE & ENCLAVE PVT. LTD. , JAIPUR

In the result, the appeal filed by the Revenue is allowed for statistical purposes

ITA 102/JPR/2020[2013-14]Status: DisposedITAT Jaipur26 Sept 2022AY 2013-14
For Appellant: Shri Rajeev Sogani ( C.A.)For Respondent: Ms Runi Pal (Addl. CIT)a fu/kZkfjrh dh vksj ls@
Section 14ASection 801Section 80I

section 80113(10) are applicable or not on the sale booked after the insertion of both these clauses. 5. The AO arrived the findings that the assessee company made investment in unquoted shares and Mutual Fund of Rs. 5,29,99,200/- but no expenditure has been debited to P/L account. Under the circumstances, the disallowance u/s 14A is calculated

VIKAS OIL MILL,KHAIRTHAL vs. ITO WARD 1(5), ALWAR, ALWAR

In the result, the appeal of the assessee is allowed

ITA 721/JPR/2025[2011-12]Status: DisposedITAT Jaipur01 Sept 2025AY 2011-12

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपील सं. / ITA No. 721/JP/2025 निर्धारण वर्ष / Assessment Year : 2011-12 M/s Vikas Oil Mill बनाम ITO, Ward 1(5), Alwar G-26/27, Ind. Area, Khairthal, Vs.301404, Alwar स्थायी लेखा सं./जीआईआर सं./PAN/GIR No.: AABFV2322F अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Sh. Gautam Singh Choudhary, JCIT सुनवाई की तारीख / Date of Hear

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 143(3)Section 263

section (set-aside/263) 143(3) of the Income Tax Act, 1961 [ for short “Act”] by Income-tax Officer- 1(5), Alwar [ for short AO]. 2 Vikas Oil Mill vs. ITO 2. The assessee challenges that order on the following grounds: - “1. The Ld. Assessing officer has erred in law as well as on the facts and circumstances