AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED,KOTA vs. DCIT/ACIT CIR-2, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

disallowance of ₹1,95,27,206/- under section 43B\nHowever, the disallowance has been made only because the assessee failed

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

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

section 275(1)(a). Hence the penalty order should have been passed before 31.10.2018 and therefore the penalty order dt.29.03.2019 passed by AO is clearly barred by limitation. 6. On merits it is submitted that the penalty has been imposed by the AO for concealment of income on two issues namely disallowance of CSR expenses and disallowance

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

section 275(1)(a). Hence the penalty order should have\nbeen passed before 31.10.2018 and therefore the penalty order dt.29.03.2019 passed by AO\nis clearly barred by limitation.\n\n6. On merits it is submitted that the penalty has been imposed by the AO for concealment of\nincome on two issues namely disallowance of CSR expenses and disallowance

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, both set of cross appeals for the respective assessment years are disposed off with above directions

206 Taxmann 563 (Kar): • DCIT Vs. Gulshan Investment Company Ltd. (2013) 86 DTR 262 (Kol-Trib) In view of above, the disallowance of Rs.71,75,575/- made by AO under Rule 8D(2)(iii) is incorrect and against the provisions of the Act. 5.4 It was further submitted that this issue has been considered by the Hon’ble ITAT

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

section 14A cannot be invoked for disallowance merely because the assessee has incidental dividend income. He has further contended that even otherwise when the assessee has not incurred any expenditure for earning the dividend income then, no disallowance is called for. The ld. AR has referred to the assessee’s own interest free funds which is more than 14 times

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. DCIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

section 14A cannot be invoked for disallowance merely because the assessee has incidental dividend income. He has further contended that even otherwise when the assessee has not incurred any expenditure for earning the dividend income then, no disallowance is called for. The ld. AR has referred to the assessee’s own interest free funds which is more than 14 times

ACIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

section 14A cannot be invoked for disallowance merely because the assessee has incidental dividend income. He has further contended that even otherwise when the assessee has not incurred any expenditure for earning the dividend income then, no disallowance is called for. The ld. AR has referred to the assessee’s own interest free funds which is more than 14 times

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

section 14A cannot be invoked for disallowance merely because the assessee has incidental dividend income. He has further contended that even otherwise when the assessee has not incurred any expenditure for earning the dividend income then, no disallowance is called for. The ld. AR has referred to the assessee’s own interest free funds which is more than 14 times

DCIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORTATION LTD., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

section 14A cannot be invoked for disallowance merely because the assessee has incidental dividend income. He has further contended that even otherwise when the assessee has not incurred any expenditure for earning the dividend income then, no disallowance is called for. The ld. AR has referred to the assessee’s own interest free funds which is more than 14 times

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

section 14A cannot be invoked for disallowance merely because the assessee has incidental dividend income. He has further contended that even otherwise when the assessee has not incurred any expenditure for earning the dividend income then, no disallowance is called for. The ld. AR has referred to the assessee’s own interest free funds which is more than 14 times

ACIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

section 14A cannot be invoked for disallowance merely because the assessee has incidental dividend income. He has further contended that even otherwise when the assessee has not incurred any expenditure for earning the dividend income then, no disallowance is called for. The ld. AR has referred to the assessee’s own interest free funds which is more than 14 times

ACIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORATION LTD., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

section 14A cannot be invoked for disallowance merely because the assessee has incidental dividend income. He has further contended that even otherwise when the assessee has not incurred any expenditure for earning the dividend income then, no disallowance is called for. The ld. AR has referred to the assessee’s own interest free funds which is more than 14 times

DCIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORTATION LTD., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

section 14A cannot be invoked for disallowance merely because the assessee has incidental dividend income. He has further contended that even otherwise when the assessee has not incurred any expenditure for earning the dividend income then, no disallowance is called for. The ld. AR has referred to the assessee’s own interest free funds which is more than 14 times

DCIT, JAIPUR vs. JADAU JEWELLERS & MFG (P) LTD., JAIPUR

In the result, the appeals filed by the assessee are partly allowed and that of the Revenue are dismissed

Section 40(a)(ia) provides for certain disallowances in certain cases notwithstanding that those amounts are generally allowed under the general section. The computation u/s.29 has to be made u/s.145 on the basis of books of account regularly maintained by the assessee which the Assessing Officer did by estimating the profit at 5% of the sales. The learned Counsel

DURGA PRASAD SHARMA,JAIPUR vs. I.T.O. WARD 1(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

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

disallowed under section 69C despite banking transactions. The appellant also relied on certain decisions including CIT v. Sunrise ToolingSystems (2014) 361 ITR 206

OM PRAKASH RASORIA,ALWAR vs. ITO, ALWAR

section 54B-Incom-tax Act, 1961. 5.8 Accordingly, I hold that the purchase of land amounting to Rs. 15,23,360/-in the name of wife Smt. Anita Rajni is not eligible for the purpose of computing deduction u/s 54B of the I.T. Act and the disallowance made by the AO on this amount is confirmed. As regards the computation

SHYAM APPARELS P.LTD.,JAIPUR vs. ITO, JAIPUR

206-209). The Ld. CIT(A) disregarded this plea of the assessee, on the ground that, no certificate as prescribed under proviso to section 201(1) r.w. rule 31ACB, certifying that the taxes in respect of interest income were duly paid by the NBFCs was filed by the assessee. In support of claim, assessee is now furnishing certificates from

ITO, JAIPUR vs. SHYAM APPARELS PVT. LTD., JAIPUR

206-209). The Ld. CIT(A) disregarded this plea of the assessee, on the ground that, no certificate as prescribed under proviso to section 201(1) r.w. rule 31ACB, certifying that the taxes in respect of interest income were duly paid by the NBFCs was filed by the assessee. In support of claim, assessee is now furnishing certificates from