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

19. We also note that, the Senior Counsel for the respondent has made submissions on the merit of the issue to say that the conclusion drawn by the PCIT in the order under Section 263 of the Act that a disallowance

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

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 the said amount as the income of the Assessee and claiming tax on that amount. 9. Insofar as the second substantial question of law is concerned, the facts

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

disallowance under Section 14A read with Rule 8D(ii)of the Rules and therefore, the same conclusion ought to have been applied to Section 36(1)(iii) as well. Therefore, in the fact situation of the case, the remand by the tribunal to the Assessing Officer to examine whether the investments were made out of the funds of the assessee

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

disallowance under Section 14A read with Rule 8D(ii)of the Rules and therefore, the same conclusion ought to have been applied to Section 36(1)(iii) as well. Therefore, in the fact situation of the case, the remand by the tribunal to the Assessing Officer to examine whether the investments were made out of the funds of the assessee

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 under Section 14A read with Rule 8D(ii)of the Rules and therefore, the same conclusion ought to have been applied to Section 36(1)(iii) as well. Therefore, in the fact situation of the case, the remand by the tribunal to the Assessing Officer to examine whether the investments were made out of the funds of the assessee

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 invoking provisions of Section 40(a)(ii). One other aspect which the Assessing Officer has sought to hold against the petitioner is as to the State Government being a shareholder of the company and therefore, was receiving privilege fee far in excess of what the shareholder would be entitled to, is also an observation which is irrelevant

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 that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

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 that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

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 that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

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 that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

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 that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

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 that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

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

The appeal stands disposed of as

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

disallowed the same under provisions of Section 14A of the Act?" 19. So far as the substantial question of law No.1

THE COMMISSIONER OF INCOME-TAX, vs. M/S CORPORATION BANK

In the result, the third substantial question of law is also answered

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowance under Section 36(1)(vii) of the Act. 3. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals) who by an order dated 18.07.2013 partly allowed the appeal preferred by the assessee. The revenue thereupon filed an appeal before the Income Tax Appellate Tribunal (hereinafter referred to as 'the tribunal' for short). The tribunal

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

19 assessing officer would be out of bounds to examine the correctness of the said certificate. On the other hand, Revenue is contending that without going into the issue of the correctness of such certificate or its contents thereof, the power of the assessing officer to disallow the claim made by an assessee under Section

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

19. It is further contended that on the issue of Disallowance under Section 37(1), the Tribunal has grossly erred

THE COMMISSIONER OF INCOME TAX vs. M/S QUEST GLOBAL ENGINEERING SERVICES PVT. LTD.,

In the result, we don to find any

Bench: ALOK ARADHE,R. NATARAJ

19 disclosure standards notified under sub-section (2) of section 145. (2) For the purposes of sub-section (1), gain or loss arising on account of the effects of change in foreign exchange rates shall be in respect of all foreign currency transactions, including those relating to - (i) monetary items and non-monetary items. (ii) translation of financial statements