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17 results for “disallowance”+ Section 144Cclear

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Key Topics

Section 26034Section 143(3)11Section 144C6Section 2636Disallowance6Addition to Income6Section 260A5Section 144C(13)5Section 92C5Section 147

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

Section 144C(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

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

5
Transfer Pricing4
Deduction3

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

144C(13) of the Act was passed on 18.12.2018. Aggrieved by the DAO, the respondent-assessee filed objections to the same. The objections were disposed of, pursuant to which, the Assessing Officer passed the final assessment order dated 25.10.2019. Subsequently, the appellant-PCIT initiated proceedings under Section 263 of the Act on 19.03.2022 seeking to revise the final assessment order

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

In the result, I proceed to pass the following:

WP/7004/2014HC Karnataka24 Apr 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

Section 143(3)Section 144C(1)Section 144C(13)Section 35Section 35(1)(i)

Section 144C(5) of the Act and in compliance of the directions issued by the DRP, first respondent – assessing Officer concluded the final assessment. The assessing Officer under the assessment order dated 31.01.2013 disallowed

M/S AMD FAR EAST LTD., vs. THE JOINT DIRECTOR OF INCOME-TAX

ITA/419/2016HC Karnataka08 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 115JSection 143Section 144CSection 260Section 260ASection 37Section 92C

Section 144C of the Act, making certain disallowances of expenditure. Objection was filed by the assessee against the draft assessment

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

144C(13) of the Act determining the total income of the petitioner at `524,81,23,820/-and total tax payable as per the assessment order at `191,88,91,064/-. Aggrieved by the said assessment order the petitioner has filed an appeal before the Tribunal and the same is pending. The petitioner also filed an application under Section

PR.COMMISSIONER OF INCOME TAX-7 vs. M/S TEXPORT OVERSEAS PVT LTD

ITA/392/2018HC Karnataka12 Dec 2019

Bench: ARAVIND KUMAR,SURAJ GOVINDARAJ

Section 143(3)Section 144C(13)Section 14ASection 260ASection 8(2)(iii)Section 92BSection 92CSection 98B

144C(13) of Income Tax Act, 1961 (for short ‘Act’) came to be passed on 30.06.2017 whereby the assessing officer had made transfer pricing adjustment and other additions. Assessing authority (for short ‘AO’) has made a reference to transfer pricing order under Section 92CA of the Act to determine arms length price as the assessee had entered into specified domestic

HERBALIFE INTERNATIONAL INDIA PVT LTD vs. THE COMMISSIONER OF INCOME TAX

In the result, the assessee's appeal for

ITA/433/2018HC Karnataka20 May 2025

Bench: V KAMESWAR RAO,S RACHAIAH

Section 143(3)Section 144CSection 260Section 263

144C of the IT Act. The Assessing Officer in the assessment order determined the total income of the appellant as Rs.4,42,53,130/- after making adjustments to the returned loss by the appellant in the revised return dated 31.03.2010. The Assessing Officer thereafter issued a notice dated 19.08.2013 under Section 154 of the IT Act proposing to rectify

NOVO NORDISK INDIA PRIVATE LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, I proceed to pass the following:

WP/9487/2015HC Karnataka20 Mar 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

Section 143(2)Section 143(3)Section 144CSection 226Section 254

Section 144C of the Act passed an assessment order on 30.1.2014 making certain disallowances and tax liability was determined at Rs.109

DELL INDIA PVT LTD vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/8901/2015HC Karnataka23 Mar 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

Section 143(3)Section 144CSection 147Section 148

144C of the Act came to be passed on 31.01.2014, Annexure-H. Being aggrieved by the same petitioner is said to have filed an appeal and same is filed before first appellate authority and same is pending. 3. First respondent has issued a notice under section 148 of the Income Tax Act to the petitioner-assessee on 27.03.2014 Annexure

XIAOMI TECHNOLOGY INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

In the result, I pass the following:

WP/16692/2022HC Karnataka16 Dec 2022

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

Section 281BSection 281ESection 92C

disallowed. On 10.08.2022, petitioner submitted a detailed response along with documents and contested the said Notice and proceedings. - 6 - 2.3 On 11.08.2022, upon obtaining approval from the 3rd respondent, the 1st respondent passed the impugned order under Section 281B of the I.T.Act provisionally attaching the subject fixed deposits of the petitioner in a sum of INR 3,700 crores

PR COMMISSIONER OF INCOME TAX-6 vs. M/S SAPA EXTRUSION INDIA PVT LTD

In the result, the appeal fails and is hereby

ITA/680/2019HC Karnataka10 Mar 2020

Bench: ALOK ARADHE,M.NAGAPRASANNA

Section 143(1)Section 143(3)Section 260

Section 143(3) read with 144C of the Act by which the assessee’s loss was determined at `31,49,38,785/- by disallowing

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/515/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

M/S. HIMALAYA DRUG COMPANY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

ITA/441/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/512/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/509/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/513/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/514/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding