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36 results for “disallowance”+ Section 144(3)clear

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Key Topics

Section 26084Section 143(3)20Addition to Income15Disallowance14Section 260A13Section 14412Section 10B10Deduction10Depreciation10Section 80P

PR. COMMISSIONER OF INCOME TAX vs. SHRI. GALI JANARDHANA REDDY

ITA/704/2018HC Karnataka31 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 132Section 143(3)Section 144Section 148Section 153CSection 153DSection 260A

3), Bangalore dated 31.03.2013 an appeal was preferred before the Commissioner of Income Tax (Appeals) – VI wherein the appellate order and ground of decision was passed. The assessments under Section 153C read with Section 144 of the IT Act for assessment years 2005-06 to 2010-11 and under Section 154D read with Section 144 for the assessment year

PR. COMMISSIONER OF INCOME TAX vs. SMT. G. LAKSHMI ARUNA

Showing 1–20 of 36 · Page 1 of 2

9
Section 153C9
Exemption9
ITA/705/2018HC Karnataka31 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 132Section 143(3)Section 144Section 153CSection 153DSection 260A

3), Bangalore dated 31.03.2013, further an appeal was preferred before the Commissioner of Income Tax (Appeals) – VI wherein the appellate order and ground of decision was passed. The assessments under Section 153C read with Section 144 of the IT Act for assessment years 2005-06 to 2010-11 and under Section 153D read with Section 144 for the assessment year

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

ITA/100012/2017HC Karnataka17 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 143(3)Section 144CSection 144C(13)Section 260ASection 37(1)Section 92ASection 92C

3) of the I.T. Act. He is competent to transfer all international transactions without referring the matter to the Transfer Pricing Officer. Therefore, the Commissioner exercised jurisdiction under Section 265 of the I.T. Act and directed the assessing officer to transfer the file to the transfer pricing officer in accordance with law. This order of the commissioner was challenged

THE PR. COMMISSIONER OF INCOME TAX vs. M/S CISCO SYSTEMS

The appeals are allowed; the impugned

ITA/27/2019HC Karnataka18 Jun 2021

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

Section 143(3)Section 144Section 260ASection 263Section 32

3) read with Section 144(C) of the Act of 1961 on 12.10.2012, wherein the assessing officer has disallowed the excess

M/S. MFAR HOLDINGS PVT LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals are allowed in part setting aside

ITA/81/2025HC Karnataka29 Oct 2025

Bench: B M SHYAM PRASAD,T.M.NADAF

Section 143(3)Section 144(3)Section 153CSection 260

Section 144(3) of the Income Tax Act, 1961 [for short, 'the IT Act'] resulting in certain disallowances vide the assessment

THE COMMISSIONER OF INCOME TAX (EXEMPTION) vs. CMR JNANADHARA TRUST

The appeals stand dismissed

ITA/142/2025HC Karnataka21 Feb 2026

Bench: S.G.PANDIT,K. V. ARAVIND

Section 260Section 260A

disallows application of income to concerns referred to in sub-section (3) only where such application results in a direct or indirect benefit to the - 12 - HC-KAR NC: 2026:KHC:10978-DB ITA No. 142 of 2025 C/W ITA No. 143 of 2025 ITA No. 144

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

The appeal is dismissed accordingly

ITA/62/2018HC Karnataka24 Feb 2021

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 10BSection 143(3)Section 144Section 260

disallowed the deduction under 3 Section 10B of the Income tax Act, 1961 (‘the Act’ for short) in respect of two units claimed by the assessee for income from onsite-subcontract work given to its associated enterprises in its order passed under Section 143(3) r/w Section 144

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

disallowed the deduction under 3 Section 10B of the Income tax Act, 1961 (‘the Act’ for short) in respect of two units claimed by the assessee for income from onsite-subcontract work given to its associated enterprises in its order passed under Section 143(3) r/w Section 144

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S. PUMA SPORTS INDIA P., LTD.,

The appeal stands dismissed

ITA/223/2018HC Karnataka12 Mar 2021

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 143(3)Section 144Section 260Section 40Section 5(2)(b)Section 9(1)(i)Section 92C

144(C)(13) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’) by making transfer pricing adjustment for Rs.4,16,65,106/- on the basis of the order passed under Section 92CA of the Act dated 24.10.2016. The assessing authority also made other additions. The assessee’s objections were not considered by the Dispute Resumption Panel and therefore

MPHASIS LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

WP/13313/2017HC Karnataka01 Aug 2018

Bench: The Hon’Ble Mr.Justice B. Veerappa Writ Petition No.13313 Of 2017 (T-It)

Section 10ASection 143(2)Section 143(3)Section 144C(13)Section 154Section 28Section 40Section 80J

disallowance under Section 40(a)(ia) of the Act is to be made of the expenses incurred and claimed by the assessee but before the payment of which, the assessee has failed to deduct tax at source. The genuineness of the expenditure is not in dispute. The dispute is whether Tax Deducted at Source was to be made before making

THE COMMISSIONER OF INCOME-TAX LTU vs. M/S. CANARA BANK

The appeal stands disposed of as

ITA/270/2018HC Karnataka30 Jun 2021

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

Section 14ASection 260

144) AND GODHRA 6 ELECTRICITY CO.LTD CASE (REPORTED IN 225 ITR PAGE 746)? 7. Whether on the facts and in the circumstances of the case, the Tribunal is right in law in holding that addition to book profits under Section 115 JB towards expenditure on exempt income is purely academic in nature as the Tribunal has held that no disallowance

MADHU SOUHARDA PATHINA SAHAKARI NIYAMITHA vs. THE INCOME TAX OFFICER

The appeal stands dismissed

ITA/207/2024HC Karnataka13 Jan 2026

Bench: S.G.PANDIT,K. V. ARAVIND

Section 142(1)Section 144Section 260Section 80ASection 80A(5)Section 80P

3. Sri Hemant Pai, learned counsel appearing for Sri Lochana S. Babu, learned counsel for the appellant–assessee, submits that, it is undisputed that the assessee has not filed a - 4 - HC-KAR NC: 2026:KHC:1855-DB ITA No. 207 of 2024 return of income for the year 2017-18. It is contended that the assessee is nevertheless entitled

THE COMMISSIONER OF INCOME TAX AND ANR vs. M/S ANIL KUMAR AND CO

ITA/200001/2014HC Karnataka25 Feb 2016

Bench: ARAVIND KUMAR,RAM MOHAN REDDY

Section 143(3)Section 260ASection 44ASection 6

disallowed the addition of `3,60,00,000/- made by the Assessing Officer and deleted the said addition. On the issue of Gross Profit adopted by the Assessing Officer at 4% it came to be held that assessee had maintained regular books of accounts and also stock register which are duly audited under section 44AB of the Income

PR COMMISSIONER OF INCOME TAX vs. M/S FORTUNA PROJECTS

ITA/191/2018HC Karnataka11 Oct 2022

Bench: P.S.DINESH KUMAR,C.M. POONACHA

Section 260Section 40A(3)

disallowance under Section 40A(3) and 40(a)(ia) of the Income - Tax does not arise as there was no claim for deduction of expenses? 2. Heard Sri E.I. Sanmathi, learned Advocate for the Revenue. 3. Despite service, there is no representation on behalf of the Assessee. Hence, on the last date of hearing, we had requested Sri A.Shankar, learned

PR. COMMISSIONER OF INCOME TAX vs. M/S CHAMUNDI WINERY AND DISTILLERY

ITA/467/2015HC Karnataka25 Sept 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

144 (SC) 01-03 2 Godhra Electricity Co. Ltd Vs. CIT 225 ITR 746 (SC) 04-11 13 CIT Vs. Chemosyn Ltd 371 ITR 427 (Bom) 75-79 14 Poorna Electric Supply Co. Ltd Vs. CIT [1965] 56 ITR 521 (SC) 80-85 17 CIT Vs. Chamanlal Mangaldas & Co. 39 ITR 8 (SC) 101-104 18 CIT Vs. Chamanlal Mangaldas

THE PR. COMMISSIONER OF INCOME TAX (4) vs. M/S CHAMUNDI WINERY AND DISTILLERY

ITA/172/2017HC Karnataka25 Sept 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

144 (SC) 01-03 2 Godhra Electricity Co. Ltd Vs. CIT 225 ITR 746 (SC) 04-11 13 CIT Vs. Chemosyn Ltd 371 ITR 427 (Bom) 75-79 14 Poorna Electric Supply Co. Ltd Vs. CIT [1965] 56 ITR 521 (SC) 80-85 17 CIT Vs. Chamanlal Mangaldas & Co. 39 ITR 8 (SC) 101-104 18 CIT Vs. Chamanlal Mangaldas

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S KIDS KEMP

In the result, the appeal fails and is hereby dismissed

ITA/8/2019HC Karnataka26 Aug 2021

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 143(1)Section 143(3)Section 154Section 260Section 32(2)

3. Thereafter, a notice under Section 154 of the Act was served on the assessee by which it was proposed to disallow the unabsorbed depreciation. The assessee submitted its response to the aforesaid notices and the 4 Assessing Officer, by an order dated 25.02.2014 passed under Section 154 of the Act, rectified the assessment and disallowed the unabsorbed assessment

SMT M. R. PRABHAVATHY vs. THE ASSISTANT COMMISSIONER

In the result, the appeal fails and is hereby dismissed

WTA/8/2019HC Karnataka16 Jan 2020

Bench: ARAVIND KUMAR,E.S.INDIRESH

Section 143(1)Section 143(3)Section 154Section 260Section 32(2)

3. Thereafter, a notice under Section 154 of the Act was served on the assessee by which it was proposed to disallow the unabsorbed depreciation. The assessee submitted its response to the aforesaid notices and the 4 Assessing Officer, by an order dated 25.02.2014 passed under Section 154 of the Act, rectified the assessment and disallowed the unabsorbed assessment

SHRI NARAYAN RAO HEBRI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

The appeal stands dismissed

ITA/166/2025HC Karnataka20 Feb 2026

Bench: S.G.PANDIT,K. V. ARAVIND

Section 115BSection 133ASection 143(2)Section 260Section 260A

144. - 11 - ITA No. 166 of 2025 3. As regards additional income of Rs.1,14,20,100/-. 3.1 The Lower Authorities are not justified in assessing the additional income of Rs.1,14,20,100/- declared by the Appellant in his return of income merely on the basis of statement recorded without any evidence collected in the course of the said

THE COMMISSIONER OF INCOME TAX vs. M/S BPL SANYO FINANCE LTD

In the result, the appeal filed by the revenue is

ITA/652/2006HC Karnataka11 Sept 2013

Bench: The Tribunal Was Arising From The Order Dated 4Th June 2004 Passed By The Commissioner Of Income Tax (Appeals) Bangalore (For Short “The

Section 115JSection 133Section 139Section 139(5)Section 143(1)Section 143(3)Section 260ASection 271Section 271(1)Section 271(1)(c)

3-10-2000 of Sri S.Madhava, Managing Director of Bellary Steel and after considering the contents thereof, observed thus: “Even reading the aforesaid statement by Shri S Madhava, it cannot be conclusively proved that BSAL never obtained any SGCI rollers. There is no mention, as to which transaction is not genuine or which manufacturer is non-existing. The rollers