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

14-15. The AO has erroneously not made the disallowance in the asstt. order. Not making this disallowance is contrary to law. 5. This is not a case where the Assessing Officer has taken one of the legally plausible views. Not making the above disallowance is legally untenable. Moreover, the Hon'ble Supreme Court (Constitution Bench) have recently

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

Disallowance under section 40(a)(i): Particulars Disputed Income Disputed tax [i.e., tax @ 33.99% on disputed income] Payable under DTVST Act @s 50% of tax As per Petitioner 42,92,10,516 14

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

Disallowance under section 40(a)(i): Particulars Disputed Income Disputed tax [i.e., tax @ 33.99% on disputed income] Payable under DTVST Act @s 50% of tax As per Petitioner 42,92,10,516 14

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

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

14 if 1947). As amended by Finance Act, 2020 Taxation Laws (Amendment) Act, 2019 Deduction in respect of employment of new employees. 80JJAA. (1) Where the gross total income of an assessee to whom section 44AB applies, includes any profits and gains derived from business, there shall, subject to the conditions specified in sub-section (2), be allowed a deduction

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

14 and machinery by a specified percentage out of book value of plant and machinery, whereas, under Section 35D(1)(ii) and proviso to Section 36(1)(iii) prior to its amendment used the word 'extension'. 6. It is also submitted that for the subsequent Assessment Years 2011-12, 2012-13, 2013-14, the Commissioner of Income Tax (Appeals

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

14 and machinery by a specified percentage out of book value of plant and machinery, whereas, under Section 35D(1)(ii) and proviso to Section 36(1)(iii) prior to its amendment used the word 'extension'. 6. It is also submitted that for the subsequent Assessment Years 2011-12, 2012-13, 2013-14, the Commissioner of Income Tax (Appeals

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

14 and machinery by a specified percentage out of book value of plant and machinery, whereas, under Section 35D(1)(ii) and proviso to Section 36(1)(iii) prior to its amendment used the word 'extension'. 6. It is also submitted that for the subsequent Assessment Years 2011-12, 2012-13, 2013-14, the Commissioner of Income Tax (Appeals

THE COMMISSIONER OF INCOME TAX vs. M/S. STATE BANK OF MYSORE

In the result, the order passed by the tribunal

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

14 regard. The tribunal in paragraph 9 of its order that it was the duty of the Assessing Officer to identify the expenditure which is relatable to earning of the exempt income and only such part of expenditure has to be disallowed under Section

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

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

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

disallowance was founded on the proviso to Section 92C(4) of the Act. - 12 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 17. It is material to note that the TP adjustments are made pursuant to the APA entered into by the Assessee with CBDT. Section 92CC

PR COMMISSIONER OF INCOME TAX-5 vs. M/S NOVELL SOFTWARE DEVELOPMENT (INDIA) PVT.LTD.

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

Bench: ALOK ARADHE,R. NATARAJ

disallowance under Section 14(a)(i)(a) of the Act be made. The Tribunal, by an order dated 30.09.2016, dismissed

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

The appeal stands dismissed

Bench: S.SUJATHA,J.M.KHAZI

disallowed under section 14A cannot be added to the book profits computed under Section 115JB. 10. Similarly, in the case of Commissioner of Income Tax vs. Gokaldas Images (P) Ltd., reported in - 14

ESSILOR INDIA PVT LTD vs. THE DEPUTY

The appeal is disposed of

Bench: ALOK ARADHE,SHIVASHANKAR AMARANNAVAR

disallowance of Rs.1,61,035/- under Section 14A of the Act read with Rule 8D of the Rules. From the perusal of the order passed by the assessing officer and in particular paragraph 7 to 14