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\nunder section 43B to only the amount remaining unpaid till the filing of return by\nthe appellant.”\nThereafter, the jurisdictional AO i.e, DCIT, Circle-Kota passed an order on\n20.09.2022 giving effect of the Appeal Order stating as under-\n6. The assessee has filed ITR for the AY 2019-20 declaring total income of Rs.\n81,73

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

73 TTJ 624 (Ahd), judgment of Allahabad High Court in the case of CIT V. Prem Heavy Engineering Works P. Ltd., 285 ITR 554 (All.), and the judgment of Hon'ble Supreme Court in the case of Munjal Sales Corporation V. CIT, 298 ITR 298 (SC).” a. As regards the disallowance made under section

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

In the result, appeal of the revenue is dismissed

73 TTJ 624 (Ahd), judgment of Allahabad High Court in the case of CIT V. Prem Heavy Engineering Works P. Ltd., 285 ITR 554 (All.), and the judgment of Hon'ble Supreme Court in the case of Munjal Sales Corporation V. CIT, 298 ITR 298 (SC).” a. As regards the disallowance made under section

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

In the result, appeal of the revenue is dismissed

73 TTJ 624 (Ahd), judgment of Allahabad High Court in the case of CIT V. Prem Heavy Engineering Works P. Ltd., 285 ITR 554 (All.), and the judgment of Hon'ble Supreme Court in the case of Munjal Sales Corporation V. CIT, 298 ITR 298 (SC).” a. As regards the disallowance made under 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)

73,140 Nil Nil CSR expenses 6,41,42,000 6,41,42,000 1,41,42,000 Deduction u/s 80IA 15,33,95,189 Nil Nil Disallowance u/s 14A 71,75,575 71,75,575 71,75,575 Service Tax Receivable 1,93,00,000 1,93,00,000 Set aside Excess provision

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

73,140 | Nil | Nil\n| CSR expenses | 6,41,42,000 | 6,41,42,000 | 1,41,42,000\n| Deduction u/s 80IA | 15,33,95,189 | Nil | Nil\n| Disallowance u/s 14A | 71,75,575 | 71,75,575 | 71,75,575\n| Service Tax Receivable | 1,93,00,000 | 1,93,00,000 | Set aside\n| Excess provision

M/S. RATAN CONDUCTORS,JAIPUR vs. ACIT, CIRCLE-4, JAIPUR

In the result, this appeal of the assessee is allowed for statistical purposes only

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1259/Jp/2019 Assessment Year: 2012-13 M/S Ratan Conductors, Cuke A.C.I.T., Vs. H-377(B), Road No. 17, Vki Area, Circle-4, Jaipur. Jaipur. Pan No.: Aabfr 8166 P Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Ashok Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Smt. Monisha Choudhary (Jcit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 05/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/09/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Jaipur Dated 21/08/2019 For The A.Y. 2012-13 Wherein Following Grounds Have Been Taken By The Assessee: “1. Disallowance Of Interest Of Rs. 17,73,769/- On Account Of Non Tds:- That On The Facts & In The Circumstances Of The Case Ld. Cit(A) Has Grossly Erred In Law & Facts In Confirming Disallowance Of Interest Of Rs.17,73,769/- Paid To M/S Barelays Investment & Loan (India) Ltd. (Rs. 298826/-) & M/S Future Capital (Rs. 1474943/-) On Account Of Non Deduction Of Tds Thereon By Invoking Provisions Of Section 40(A)(Ia) Of The It Act 1961. (A) The Assessee Firm Paid, Interest Of Rs. 2,98,826/- To Nbfc. M/S Barelays Investment & Loan (India) Ltd. & Rs.14,74,943/- To M/S Future Capital Another Nbfc. The Assessee Firm Raised Loan

Section 40 (a) (ia) no disallowance could be made in the hands of assessee u/s 40 (a) (ia) so the disallowance of Rs. 17,73

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

In the result, the appeal of the assessee is allowed

section 14A r.wrule 8D in respect of total finance cost\nincurred at Rs. 86,73,560/- by ignoring the submission filed by the\nassessee that entire finance cost is incurred on specified and\nidentifiable items and no part of the finance cost is directly related to\ninvestment made in shares and therefore in absence of any\nexpenditure no disallowance

M/S AMRAPALI EXPORTS,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, JAIPUR

In the result, the ground No

disallowances so made by the Assessing officer. 11. The Co-ordinate Bench in case of ITO vs. Anthelio Business Technologies Pvt. Ltd. 78 taxmann.com 203 (Mumbai) in context of deduction under section 10B relying on the aforesaid CBDT Circular has taken a similar view and it would be relevant to refer to the findings of the Co-ordinate Bench which

M/S VIJAYETA BUILDCON PVT. LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result, the ground of the assessee’s appeal is allowed

disallowed u/s 40A(3) of the Act. The Hon’ble High Court held that rule 6DD(j) is not exhaustive of the circumstances in which the proviso to section 40A(3) is applicable and it only illustrative. The Hon’ble High Court refers to the decision of the Hon’ble Rajasthan High Court in case of Smt. Harshila Chordia

RADHEY SHYAM AGARWAL (DECEASED) THROUGH LEGAL HEIR,JAIPUR vs. ITO, WARD 7(1), , JAIPUR

In the result, the appeal of the assessee is allowed

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

disallowed the setting off of the loss of AY 2013-14 with that of the profit of the current year since the return of income for AY 2013-14 was as belated return. 5.3 During the course of the appellate proceedings, the appellant claimed that the phrase "or sub-section (2) of section 73A" was inserted in section

RADHEY SHYAM AGARWAL,JAIPUR vs. ITO, WARD 7(1), JAIPUR, JAIPUR

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

disallowed. The appellant filed rectification application u/s. 154 on 24-01-2019 and the application was rejected vide order u/s. 154 dated 17.04.2019, due to the reason that the return of income for AY 2013-14 was filed beyond the time prescribed u/s 139(1). 5.2. Having considered the submissions of the appellant, it is seen that the due date

RUKMANI DEVI AGARWAL,JAIPUR vs. ITO, WARD 7(1), JAIPUR, JAIPUR

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

disallowed. The appellant filed rectification application u/s. 154 on 24-01-2019 and the application was rejected vide order u/s. 154 dated 17.04.2019, due to the reason that the return of income for AY 2013-14 was filed beyond the time prescribed u/s 139(1). 5.2. Having considered the submissions of the appellant, it is seen that the due date

M/S TRADITIONAL GALLERY PVT. LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, JAIPUR

In the result, appeals of the assessee are allowed

section 36(1)(iii) and disallowance of Rs. 33,83,847/- on account of disallowance u/s 14A of the IT Act. Aggrieved by the order of the AO, the assessee preferred appeal before the ld. CIT (A). The ld. CIT (A) confirming the order of the AO, sustained the addition of Rs. 91,15,011/-. Now the assessee

M/S TRADITIONAL GALLERY PVT. LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, JAIPUR

In the result, appeals of the assessee are allowed

section 36(1)(iii) and disallowance of Rs. 33,83,847/- on account of disallowance u/s 14A of the IT Act. Aggrieved by the order of the AO, the assessee preferred appeal before the ld. CIT (A). The ld. CIT (A) confirming the order of the AO, sustained the addition of Rs. 91,15,011/-. Now the assessee

SHREE SIDDHI VINAYAK INDUCTION PVT. LTD.,JAIPUR vs. DCIT, JAIPUR

In the result ITA NO. 01/JPR/2021 for A

73,019/- made by Ld. AO u/s 36(1)(va) of the Income Tax Act,1961. Appellant prays that disallowance so confirmed deserves to be deleted. 4. That the appellant craves the leave to amend / alter all or any of the grounds of this appeal on or before the hearing of the matter.” 5. All three appeals are argued

M/S SHRI SIDDHI VINAYAK INDUCTION P. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

In the result ITA NO. 01/JPR/2021 for A

73,019/- made by Ld. AO u/s 36(1)(va) of the Income Tax Act,1961. Appellant prays that disallowance so confirmed deserves to be deleted. 4. That the appellant craves the leave to amend / alter all or any of the grounds of this appeal on or before the hearing of the matter.” 5. All three appeals are argued

SHREE SIDDHI VINAYAK INDUCTIONS PVT. LTD.,JAIPUR vs. DCIT, CENTRAL CIRCLE-3, JAIPUR

In the result ITA NO. 01/JPR/2021 for A

73,019/- made by Ld. AO u/s 36(1)(va) of the Income Tax Act,1961. Appellant prays that disallowance so confirmed deserves to be deleted. 4. That the appellant craves the leave to amend / alter all or any of the grounds of this appeal on or before the hearing of the matter.” 5. All three appeals are argued