AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED, KOTA,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

section 234A/B/C are\nof consequential in nature, hence not adjudicated. Accordingly, the grounds of appeal\nraised hereby are disallowed with unwavering resolve.\n7. In the result, the appeals are dismissed.”\n8\nITA Nos.197 to 199/JP/2025\nAhluwalia Erectors & Fabricators Pvt. Ltd.\nHence this appeal.\nGOA 1: Is a general ground of appeal and make be considered while deciding\nthe other grounds

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

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

section 234A/B/C are\nof consequential in nature, hence not adjudicated. Accordingly, the grounds of appeal\nraised hereby are disallowed with unwavering resolve.\n7. In the result, the appeals are dismissed.”\n8\nITA Nos.197 to 199/JP/2025\nAhluwalia Erectors & Fabricators Pvt. Ltd.\nHence this appeal.\nGOA 1: Is a general ground of appeal and make be considered while deciding\nthe other grounds

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

section 234A/B/C are\nof consequential in nature, hence not adjudicated. Accordingly, the grounds of appeal\nraised hereby are disallowed with unwavering resolve.\n7. In the result, the appeals are dismissed.”\n8\nITA Nos.197 to 199/JP/2025\nAhluwalia Erectors & Fabricators Pvt. Ltd.\nHence this appeal.\nGOA 1: Is a general ground of appeal and make be considered while deciding\nthe other grounds

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

disallowed said claim on ground that interest paid under section\n201(1A) would be penal in nature - Whether since tax was deducted by\nassessee on behalf of third party, interest charged on failure to remit\nsame within due date to government would be compensatory in nature\nand interest paid on delayed payment of TDS under section 201(1A)\nwas

ACIT, CIRCLE, BHARATPUR vs. M/S. JAGDAMBE STONE COMPANY, BHARATPUR

In the result, this appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am

disallowed the Freight Expenses of Rs. 1,44,13,853/- [30% of 4,80,46,176/-] by wrongly invoking the Section

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)

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 Rs.1,41,42,000/- Disallowance u/s 14A Rs. 71,75,575/- After the order of Hon’ble ITAT, AO again issued notice

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

In the result, the appeal of the assessee is allowed

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

disallowance under section 14A read with rule 8D can be made as the assessee has non- interest bearing funds in the shape of share capital and reserves are much more than the investment which may result exempt income. Further, the assessee has not incurred any indirect expenses to earn the exempt income and ld PCIT has not bring any material

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

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 LTD VS DCIT, CIRCLE-6, JAIPUR\n\nDisallowance of CSR Expenses\nDisallowance u/s 14A\nRs.1,41,42,000/-\nRs.71,75,575/-\n\nAfter the order

AGRASEN ENGINEERING INDUSTRIES PRIVATE LIMITED,JAIPUR vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Him.

section 14A r.w.r.8D and thereby Rs. 23,20,009/- was disallowed u/s 14A of the IT Act and added back to the taxable income of the assessee. 10. When the assessee carried that matter before the ld. CIT(A) based on the various case laws cited there in ld. CIT(A) restricted the addition u/s. 14A to the extent

NIMBUS PIPES LIMITED,JAIPUR vs. ACIT CIRCLE-4, JAIPUR

In the result, the appeal of the assessee is dismissed

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

disallowed under Section 43-B which, as stated above, was inserted with effect from 1-4- 1984 *** 22. It is important to note once again that, by the Finance Act, 2003, not only is the second proviso deleted but even the first proviso is sought to be amended by bringing about a uniformity in tax, duty, cess

PARIS ELYSEES INDIA PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-7, JAIPUR

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

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

section 36(1)(va). Thus, only factual reporting, which was mandated, was done and no opinion was expressed regarding the disallowance. Otherwise also no disallowance can be made on the basis of mere reporting in Audit Report. The disallowance can be made only on the basis of relevant law and taking into account judicial view in that regard. 2.2.iv

SMT. KAMLESH KANWAR RATHORE,3, RAMCHAND COLONY, NEAR UTSAV VATIKA, MASUDA ROAD, BEAWAR vs. CPC, BENGALURU, BENGALURU

In the result, the appeal of the assessee is allowed

44,812/- towards employee’s contribution towards ESI and PF. On appeal, the ld. CIT(A), NFAC has confirmed the disallowance made U/s 143(1) on account of assessee’s failure to pay the employee’s contribution of PF/ESI within the prescribed due dates as per Section

SHIV LAL,ALWAR vs. CPC, BENGALURU, BENGALURU

In the result, the appeal of the assessee is allowed

44,709/- towards employee’s contribution towards ESI and PF. On appeal, the ld. CIT(A), NFAC has confirmed the disallowance made U/s 143(1) on account of Sh. Shiv lal vs. CPC assessee’s failure to pay the employee’s contribution of PF/ESI within the prescribed due dates as per Section

OCEAN EXIM INDIA PRIVATE LTD,JAIPUR vs. ITO WARD 1(2), JAIPUR

In the result, the appeal of the assessee is dismissed

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

disallowed under Section 43-B which, as stated above, was inserted with effect from 1-4- 1984 *** 22. It is important to note once again that, by the Finance Act, 2003, not only is the second proviso deleted but even the first proviso is sought to be amended by bringing about a uniformity in tax, duty, cess

BIMAL ROY SONI,J L N MARG vs. DCIT, CIRCLE - 1, JAIPUR, STATUE CIRCLE

In the result, appeals of the assessee is partly allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 239 & 240/JP/2022 fu/kZkj.k o"kZ@Assessment Years : 2013-14 & 2014-15 Bimal Roy Soni 11, Chetak Marg, JLN Marg Jaipur cuke Vs. DCIT, Circle-01, Jaipur NCR, Building LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AFPPS 1588 H vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Akhilesh Kumar Jain (C.A.) jktLo dh vksj ls@ Revenue by : Smt Runi Pal (Addl. CIT) a lquokb

section 14A would not be applicable in the case of the assessee as the investment has been made solely for the purpose of having the controlling interest. There is no change into the facts in this year as well. The revenue has not brought to our notice any contrary binding precedent. Moreover, the assessee has dividend income to the tune

BIMAL ROY SONI,J L N MARG vs. DCIT, CIRCLE-1, JAIPUR, N.C.R. BUILDING

In the result, appeals of the assessee is partly allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 239 & 240/JP/2022 fu/kZkj.k o"kZ@Assessment Years : 2013-14 & 2014-15 Bimal Roy Soni 11, Chetak Marg, JLN Marg Jaipur cuke Vs. DCIT, Circle-01, Jaipur NCR, Building LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AFPPS 1588 H vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Akhilesh Kumar Jain (C.A.) jktLo dh vksj ls@ Revenue by : Smt Runi Pal (Addl. CIT) a lquokb

section 14A would not be applicable in the case of the assessee as the investment has been made solely for the purpose of having the controlling interest. There is no change into the facts in this year as well. The revenue has not brought to our notice any contrary binding precedent. Moreover, the assessee has dividend income to the tune

TELECRATS INDIA PRIVATE LIMITED,JAIPUR vs. ITO WARD 1(1), JAIPUR, JAIPUR

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

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

44. There is no doubt that in Alom Extrusions, this court did consider the impact of deletion of second proviso to Section 43B,which mandated that unless the amount of employers’contribution was deposited with the authorities, the deduction otherwise permissible in law, would not be available. This court was of the opinion that the omission was curative, and that

TELECRATS INDIA PRIVATE LIMITED,JAIPUR vs. ITO WARD 1(1), JAIPUR , JAIPUR

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

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

44. There is no doubt that in Alom Extrusions, this court did consider the impact of deletion of second proviso to Section 43B,which mandated that unless the amount of employers’contribution was deposited with the authorities, the deduction otherwise permissible in law, would not be available. This court was of the opinion that the omission was curative, and that

KATRATHAL GRAM SEWA SAHKARI SAMITI LIMITED ,KATRATHAL vs. ITO WARD 1 SIKAR, SIKAR

disallowance of the assessee's\r\nclaim for deduction u/s.80P of Rs.16,40,116/- made by the A.O.\r\nIt is also noteworthy to mention that the CBDT vide its Circular No. 13/2023\r\ndt.26.07.2023 has directed the Department to allow the condonation of delay\r\nwhere the return has been filed after due date as to claim made