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 DTVSV Act @ 50% of tax As per Petitioner 37,28,12,027 12,67,18

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant

M/S DELHI INTERNATIONAL vs. THE PRINCIPAL COMMISSIONER

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant

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

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

section 40(a)(ia) is not attracted and the authorities were justified in disallowing the said deduction and treating I.T.A. NO.141 OF 2020 c/w I.T.A. NO.151 OF 2020 18

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

disallowance of interest under Section 36(1)(iii) of the Act. Similarly twin issues arise for consideration in this appeal viz., whether loan processing and other charges can be allowed as revenue expenditure or has to be treated as capital in nature and whether the tribunal has acted in contravention of the provision of Section

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

disallowance of interest under Section 36(1)(iii) of the Act. Similarly twin issues arise for consideration in this appeal viz., whether loan processing and other charges can be allowed as revenue expenditure or has to be treated as capital in nature and whether the tribunal has acted in contravention of the provision of Section

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

disallowance of interest under Section 36(1)(iii) of the Act. Similarly twin issues arise for consideration in this appeal viz., whether loan processing and other charges can be allowed as revenue expenditure or has to be treated as capital in nature and whether the tribunal has acted in contravention of the provision of Section

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

disallowed privilege fee collected from such wholesale distributors by invoking Section 40(a)(ii). It is also a matter of record that the Central Government Undertakings like BSNL, MTNL pay 18

HINDUSTAN AERONAUTICS LIMITED vs. ASSISTANT COMMISSIONER

In the result, the order of the

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

18 revenue, whereas substantial question of law involved in ITA No.468/2016 is answered against the revenue and in favour of the assessee. In the result, the order of the Tribunal dated 22.04.2016 in so far as it pertains to disallowance of the claims of the assessee under Section

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

18 revenue, whereas substantial question of law involved in ITA No.468/2016 is answered against the revenue and in favour of the assessee. In the result, the order of the Tribunal dated 22.04.2016 in so far as it pertains to disallowance of the claims of the assessee under Section

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

PR. COMMISSIONER OF INCOME TAX - 4 vs. M/S STERLING DEVELOPERS

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

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

18,36,660/- as against the revised income which was mentioned by the assessee to the extent of Rs.4,79,57,900/- by making certain additions and disallowances. The Assessing Officer also made a disallowance under Section

PR. COMMISSIONER OF vs. M/S STERLING DEVELOPERS

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

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

18,36,660/- as against the revised income which was mentioned by the assessee to the extent of Rs.4,79,57,900/- by making certain additions and disallowances. The Assessing Officer also made a disallowance under Section

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