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

Accordingly dispose of the appeal as allowed

Bench: ACTING CHIEF JUSTICE,S RACHAIAH

8. According to him, the order passed by the PCIT under Section 263 does not dispute the fact that the amount of Rs.36,34,10,000/- represents discounts. In that view of the matter, the only plausible view is that Section 194H does not stand attracted and therefore the conclusion that there ought to be a disallowance under Section

MANGALORE REFINERY AND PETROCHEMICALS LTD vs. PRINCIPAL COMMISSIONER OF INCOME TAX

In the result, I pass the following:-

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

13,09,37,839 Disallowance under section 14A of the IT Act 9,03,79,391 7 8. Being aggrieved

MANGALORE REFINERY AND PETROCHEMICALS LTD vs. PRINCIPAL COMMISSIONER OF INCOME TAX

In the result, I pass the following:-

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

13,09,37,839 Disallowance under section 14A of the IT Act 9,03,79,391 7 8. Being aggrieved

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

13) of the Income Tax Act on 31.12.2013, determining total income at Rs.10,86,34,35,052/- by making various additions, which reads as under: Additional / Issues Rs. Transfer pricing adjustments 112,20,92,081/- Claim of bogus transportation expenses of iron ore 40% attributable towards illegal mining. 86,43,47,335/- Disallowance of expenses claimed under section

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S.J.J.GLASTRONICS PVT LTD

The appeal stands dismissed

Bench: S.SUJATHA,J.M.KHAZI

8. Section 115JB of the Act is a complete code in itself. The controversy relating to disallowance under Section 14A of the Act for determining book profit under Section 115JB was dealt with, in extenso by the Delhi ITAT Bench in the case of Vireet Investment Private Ltd., supra and the relevant portion of the said decision has been quoted

HINDUSTAN AERONAUTICS LIMITED vs. ASSISTANT COMMISSIONER

In the result, the order of the

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

8. With regard to claim of the assessee under Section 14A of the Act, it is pointed out that assessee had earned dividend income from two companies, in which it had made strategic investments, which was exempt under Section 10(34) of the Act and since, no expenses were incurred to earn the exempt income, the assessee did not make

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

In the result, the order of the

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

8. With regard to claim of the assessee under Section 14A of the Act, it is pointed out that assessee had earned dividend income from two companies, in which it had made strategic investments, which was exempt under Section 10(34) of the Act and since, no expenses were incurred to earn the exempt income, the assessee did not make

KARNATAKA STATE BEVERAGES CORPORTION LIMITED vs. THE COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr. Justice Anand Byrareddy Writ Petition No.12872 Of 2013 (T-It) Connected With Writ Petition No.14687 Of 2014 (T-It), Writ Petition No.15910 Of 2015 (T-It) & Writ Petition No.17514 Of 2015 (T-It) In W.P.No.12872 Of 2013 Between: Karnataka State Beverages Corporation Limited, Represented By It’S Executive Director (Finance), Sri. Shrikant B Vanahalli, Aged About 57 Years, No.78, Seethalakshmi Towers, Mission Road, Bangalore 560 027. …Petitioner

13 3. The learned counsel for the petitioner would contend that the several reasons assigned by the Assessing Officer in the Assessment orders pertaining to the above years would raise the following issues: i) Section 40(a)(iib) of the Income-tax Act disallows the privilege fee from the Assessment Year 2014-15 and subsequent years only and the amendment

THE COMMISSIONER OF INCOME-TAX vs. TEXAS INSTRUMENTS INDIA PVT LTD

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

8. The Assessee has filed an appeal as regards disallowance in respect of Section 80JJ(AA); the Revenue filed an appeal insofar as finding relating to the aspect of tax deducted at source referred to above. The Tribunal taking into account the decision rendered by it in another matter where it had held that the employees/workmen in the software industry

M/S TEJAS NETWORKS LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, I proceed to pass the following:

Bench: The Hon’Ble Mr.Justice Aravind Kumar

disallow such claim made by the assessee though duly certified by the prescribed authority by taking recourse to the later portion of sub-clause (ii) of sub-section (4) of Section 43 of the Act. He would summarise his 9 submissions by contending the definition of ‘scientific research’ found in Section 43(4) has been imported to Section

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

8. We have considered the submissions made by learned counsel for the parties and have perused the record. Twin issues arise for consideration in the appeal preferred by the assessee viz., disallowance of interest on borrowed capital insofar as it pertains to investment made in the foreign subsidiary of the assessee and disallowance of interest under Section 36 and disallowance

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

8. We have considered the submissions made by learned counsel for the parties and have perused the record. Twin issues arise for consideration in the appeal preferred by the assessee viz., disallowance of interest on borrowed capital insofar as it pertains to investment made in the foreign subsidiary of the assessee and disallowance of interest under Section 36 and disallowance

PR. COMMISSIONER OF INCOME TAX vs. M/S AMALGAMATED BEAN COFFEE TRADING CO LTD

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

8. We have considered the submissions made by learned counsel for the parties and have perused the record. Twin issues arise for consideration in the appeal preferred by the assessee viz., disallowance of interest on borrowed capital insofar as it pertains to investment made in the foreign subsidiary of the assessee and disallowance of interest under Section 36 and disallowance

M/S DELHI INTERNATIONAL AIRPORT LTD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

M/S DELHI INTERNATIONAL vs. THE PRINCIPAL COMMISSIONER

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

THE PR. COMMISSIONER OF INCOME TAX, vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD.,

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

THE PR. COMMISSIONER OF INCOME TAX, vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD.

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

M/S DELHI INTERNATIONAL AIRPORT LTD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before