M/S. CHAMBAL FERTILIZERS AND CHEMICALS LIMITED,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA

In the result, appeal of the revenue is dismissed

disallowance, by invoking section 14A r.w.r 8D, of Rs. 24,90,000/-. It is submitted that the provisions of section 36(1)(iii) of the Act allow a deduction for interest on 24 ITA NO. 201(6

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. DCIT, KOTA

In the result, appeal of the revenue is dismissed

disallowance, by invoking section 14A r.w.r 8D, of Rs. 24,90,000/-. It is submitted that the provisions of section 36(1)(iii) of the Act allow a deduction for interest on 24 ITA NO. 201(6

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. ACIT, KOTA

In the result, appeal of the revenue is dismissed

disallowance, by invoking section 14A r.w.r 8D, of Rs. 24,90,000/-. It is submitted that the provisions of section 36(1)(iii) of the Act allow a deduction for interest on 24 ITA NO. 201(6

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 43B could not have been applied to the case of the\nassessee."\n1.4.4 CIT v. ATS Real Estate Builders (P.) Ltd. [2025] 172 taxmann.com 611\n(Delhi - Trib.) (DC 14-16) held that,\n“6. The ground no. 2 to 4 of appeal are in respect of single issue i.e. disallowance

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 43B could not have been applied to the case of the\nassessee."\n1.4.4 CIT v. ATS Real Estate Builders (P.) Ltd. [2025] 172 taxmann.com 611\n(Delhi - Trib.) (DC 14-16) held that,\n“6. The ground no. 2 to 4 of appeal are in respect of single issue i.e. disallowance

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 43B could not have been applied to the case of the\nassessee.\"\n1.4.4 CIT v. ATS Real Estate Builders (P.) Ltd. [2025] 172 taxmann.com 611\n(Delhi - Trib.) (DC 14-16) held that,\n“6. The ground no. 2 to 4 of appeal are in respect of single issue i.e. disallowance

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

disallowance under Section 14A in the case of the assessee\ncompany.\n19\nITA243/JP/2023\nASSOCIATED SOAPSTONE DISTRIBUTING CO. PVT LTD. VS Pr.CIT-2, JAIPUR\n1.3.v In the below mentioned cases, Explanation inserted to Section 14A,\nvideFinance Act, 2022, is held to have a prospective effect.\n•\nERA Infrastructure (India) Ltd. [2022] 448 ITR 674 (Delhi) [CLC -\nPages

DEVIKA BUILDESTATE PRIVATE LIMITED,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

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

Disallowance of expense solely on the ground of non-compliance of notice u/s 133(6) is not legally sustainable. 6. The contention of the Ld. CIT(A) in confirming the addition made by the Ld. AO, on the ground that “notices under Section

NIRMAL KUMAR BARDIYA,JAIPUR vs. ACIT, CIRCLE-1, JAIPUR, JAIPUR

In the result, both the appeals of the assessee are allowed

disallowed under section 43B read with section 36(1)(va) of the Act in view of the binding decisions of the Hon’ble Rajasthan High Court.” 6

RMC GEMS INDIA LTD,JAIPUR vs. ADIT, CPC, BANGLORE

In the result, the appeal of the assessee is allowed

section 139 (1), then the same cannot be disallowed in view of the binding precedent of Hon'ble jurisdictional High Court including the decision in case of CIT vs. SBBJ, 99 DTR 131 (Raj.). The Ld. CIT (Appeals) has confirmed the disallowance by purportedly following the decision of Hon'ble jurisdictional High Court dated 13th 6

GIRNAR SOFTWARE PRIVATE LIMITED,6TH FLOOR, JAIPUR TEXTILE MARKET, B-2, NEAR MODEL TOWN, MALVIYA NAGAR, JAIPUR vs. PCIT – 2, JAIPUR, NEW CENTRAL REVENUE BUILDING

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 made by Assessing Officer under Rule 8D read with Section 14A. Further, amendment made by Finance Act 2022 is prospective in nature. • PCIT vs. MMTC Ltd. (2022) 6

GOSIL EXPORTS PVT LTD,JAIPUR vs. DCIT, CIRCLE -I, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: Due Date Of Filing Return.’’

disallowed under section 438 or under section 36(1)(va) of the LT.Act, In the case of [2014] CIT v.Jaipur Vidyut Vitran Nigam Ltd (49 taxmann.com 540 (Raj), the Hon'ble Rajasthan High Court has held that: "6

ASSISSTANT COMMISSIONER OF INCOME TAX, AJMER vs. SHREE CEMENT LTD, BEAWAR

Accordingly, the same is dismissed

6. That on the facts and in the circumstances of the case, the Ld. CIT (Appeals), was not justified and erred in law in confirming the disallowances made by the A.O. on account of payment made to the transporter to the tune of Rs. 1,00,00,000/-. 7. That on the facts and in the circumstances of the case

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT ASSESSMENT CENTRE, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, AJMER, AJMER

section 80IA vide clause (iii) to the Explanation below Sec. 80A(6) & Sec. 80IA(8)) were not urged. Hence considering these\nadditional submissions and following arms’ length principles, it is humbly prayed that Reliability Charge, at-least @ Rs. 1.50 per unit or mark up of 15% for each of the two distinct benefits be kindly allowed

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CENTRAL CIRCLE-4, JAIPUR , JAIPUR

In the result, the appeal of the assessee is allowed

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

disallowable under section 37 (total of 7a to 7j)". 37 (total of 7a to 7j)". 9 VAIBHAV GLOBAL LTD VS DCIT, CIRCLE-4, JAIPUR 6

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)

6. No Immunity Under Section 273B The assessee has not shown any reasonable cause for the incorrect claims made. Hence, the immunity under Section 273B is not available, and the penalty levied is fully sustainable. 7. Final Judicial Support A. Cases Supporting Disallowance

AMIT SINGH,BHIWADI (ALWAR) vs. DCIT, CPC- BENGALURU, CPC- BENGALURU

In the result, the appeal of the assessees is allowed

Section 36(1)(va) r.w.s.2(24)(x) , there is no distinction between employees' and employer contribution to PF & ESIC, and if the total contribution is deposited on or before the due date of furnishing return of income u/s 139(1) of the Act, then no disallowance can be made towards employees' contribution to provident fund & ES/C." 6

DOLCAS BOTANOSYS PVT. LTD. BIKANER,BIKANER vs. ADIT, CPC, BANGLORE/ACIT, C-1 JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

disallowed under section 43B read with section 36(1)(va) of the Act in view of the binding decisions of the Hon’ble Rajasthan High Court.” 6