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37 results for “disallowance”+ Section 108clear

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Key Topics

Section 260A266Section 26031Section 10B16Disallowance10Section 65(1)9Section 639Section 807Deduction7Section 80I6Section 54F

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S. TE CONNECTIVITY INDIA PVT. LTD.,

Accordingly dispose of the appeal as allowed

ITA/53/2024HC Karnataka05 Jun 2025

Bench: ACTING CHIEF JUSTICE,S RACHAIAH

Section 143(2)Section 143(3)Section 144C(13)Section 260ASection 263Section 40

disallowance u/s 40(a)(ia) on the transactions discussed above. He shall give the assessee an opportunity to furnish necessary evidence to establish his claim and explain why the proposed additions be not made to income. The AO shall consider the facts, and the results of any enquiries made, as well as the explanation furnished by the assessee, and make

THE PR COMMISSIONER OF INCOME TAX vs. M/S MPHASIS LTD

Showing 1–20 of 37 · Page 1 of 2

6
Addition to Income5
Revision u/s 2634

The appeal is dismissed accordingly

ITA/62/2018HC Karnataka24 Feb 2021

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 10BSection 143(3)Section 144Section 260

disallowance of foreign exchange loss on forward contracts of Rs.26,31,35,000/- by following the decision of Bombay High Court in the case of CIT vs. D.Chethan and Co., in ITA No.278 of 2014 dated 01.10.2016, by allowing the foreign exchange loss as business loss even when the assessee camouflaged the forward contract loss i.e., marked to market loss

SMT. PUNEETHA @ PUNEETHA B. A. vs. SRI. D. RAVI

The appeal is dismissed accordingly

RPFC/62/2018HC Karnataka28 Feb 2020

Bench: R DEVDAS

Section 10BSection 143(3)Section 144Section 260

disallowance of foreign exchange loss on forward contracts of Rs.26,31,35,000/- by following the decision of Bombay High Court in the case of CIT vs. D.Chethan and Co., in ITA No.278 of 2014 dated 01.10.2016, by allowing the foreign exchange loss as business loss even when the assessee camouflaged the forward contract loss i.e., marked to market loss

M/S BANGALORE ELECTRICITY SUPPLY COMPANY LTD vs. THE DEPUTY COMMISSIONER OF INCOME-TAX

In the result, the order passed by the tribunal

ITA/204/2013HC Karnataka27 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 115JSection 143(2)Section 143(3)Section 260Section 260ASection 80I

disallowed the deduction claimed under Section 80IA(4)(iv)(c) of the Act and held that computation as per normal provisions of the Act is adopted as tax liability. 3. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals), who by an order dated 10.02.2009 dismissed the appeal preferred by the assessee. The assessee thereupon approached

SATISH KUMAR PANDEY vs. ASSISTANT COMMISSIONER OF INCOME TAX

Appeals are allowed

ITA/696/2019HC Karnataka16 Dec 2022

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

Section 143(3)Section 260Section 48

disallowed the expenses and made an addition of Rs. 1,18,29,300. The 2KPMG India Private Limited. 3 Assessing Officer. 4Income Tax Act, 1961. I.T.A No.695/2019 C/W I.T.A No.696/2019 5 CIT(A)5 and ITAT6 have confirmed the addition. Hence, these appeals. 5. Shri. Sudheendra, learned Advocate for the Assessees submitted that: • admittedly, the assessees entered into an agreement

PR COMMISSIONER OF vs. M/S SYNGENE

In the result, we do not find any merit in this appeal, the

ITA/184/2016HC Karnataka02 Dec 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 10BSection 260Section 260A

disallowed the deduction claimed by the assessee under Section 10B of the Act to the tune of Rs.21,31,59,892/- and added it to the income of the assessee. 5 4. The assessee thereupon approached the Commissioner of Income Tax (Appeals) who by an order dated 22.06.2012 inter alia held that Assessing Officer as unable to counter the claim

THE COMMISSIONER OF INCOME TAX vs. SHRI RAVINDRA UPADRASHTA

Appeal is dismissed;

ITA/108/2020HC Karnataka06 Feb 2023

Bench: P.S.DINESH KUMAR,RAMACHANDRA D. HUDDAR

Section 260Section 54F

disallowance made under section 54F of the Act by holding that the investment made by assessee outside India satisfies the condition for seeking deduction under section 54F even 1 Income tax Appellate Tribunal, Bengaluru Bench - 3 - ITA No. 108

MR.SIDDHARTH JAIN vs. THE OFFICIAL LIQUIDATOR OF

Appeal is dismissed;

CA/108/2020HC Karnataka24 Jan 2020

Bench: S SUNIL DUTT YADAV

Section 260Section 54F

disallowance made under section 54F of the Act by holding that the investment made by assessee outside India satisfies the condition for seeking deduction under section 54F even 1 Income tax Appellate Tribunal, Bengaluru Bench - 3 - ITA No. 108

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S TT STEEL SERVICE INDIA PVT LTD

ITA/665/2023HC Karnataka14 Oct 2024

Bench: V KAMESWAR RAO,S RACHAIAH

Section 260Section 92Section 92BSection 92C

Section 92CA could be invalid and bad in law. 7. It is for this precise reason, tribunal has rightly held that order passed by the TPO and DRP is unsustainable in the eyes of law. The said finding is based on the authoritative principles enunciated by the Hon’ble Supreme Court in Kolhapur Canesugar Works Ltd referred to herein supra

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/882/2017HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/550/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/563/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/507/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/562/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

THE PR COMMISSIONER OF INCOME TAX vs. M/S GOOGLE INDIA PRIVATE LTD

The appeals stand disposed of

ITA/125/2020HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/898/2017HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/504/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/564/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/549/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section

M/S GOOGLE IRELAND LIMITED vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/506/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section