THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

2) Disallowance of Expenses under Explanation to section 37 (1) and in respect of third issue i.e. Addition made on account of sale 57 of Land, we set aside the order of CIT (A) on that issue and restore the matter to A.O. for a fresh decision with the same directions as were given by the tribunal

M/S FIDELITY BUSINESS SERVICES INDIA PVT LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX

Bench: S.SUJATHA,VINEET KOTHARI

17,400/- and the said shares were sold through another broker for `2,94,300/- on 29/03/1962 and thus the Assessee incurred a loss of `23,100/- for the said year, the learned Tribunal held that though the said loss in sale and purchase of the shares could not be termed as ‘speculative transactions’ and the lower Authorities were

COMMISSIONER OF INCOME TAX-III vs. M./S WIPRO LIMITED

The appeal is disposed of

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowance in respect of reimbursement of medical expenses granted by the assessee to its employees by ignoring the fact that the same is excluded as per proviso to viii of Section 17(2

M/S J K CEMENT WORKS vs. THE STATE OF KARNATAKA

Bench: H.B.PRABHAKARA SASTRY,VINEET KOTHARI

17 / 39 (2) Deduction of input tax under this Section shall be allowed only after commencement of commercial production, or sale of taxable goods or sale of any goods in the course of export out of the territory of the India by the registered dealer [xxx].” -- “ Act No.32 of 2004 [From 1.4.2005] FIFTH SCHEDULE INPUT TAX RESTRICTED GOODS [Section

THE COMMISSIONER OF INCOME TAX vs. PRAVEEN V DODDANAVAR

Bench: SREENIVAS HARISH KUMAR,VINEET KOTHARI

17 / 39 (2) Deduction of input tax under this Section shall be allowed only after commencement of commercial production, or sale of taxable goods or sale of any goods in the course of export out of the territory of the India by the registered dealer [xxx].” -- “ Act No.32 of 2004 [From 1.4.2005] FIFTH SCHEDULE INPUT TAX RESTRICTED GOODS [Section

THE BAILHONGAL URBAN COOPERATIVE BANK LTD vs. THE COMMISSIONER OF INCOME TAX

Bench: S.ABDUL NAZEER,P.S.DINESH KUMAR

17 / 39 (2) Deduction of input tax under this Section shall be allowed only after commencement of commercial production, or sale of taxable goods or sale of any goods in the course of export out of the territory of the India by the registered dealer [xxx].” -- “ Act No.32 of 2004 [From 1.4.2005] FIFTH SCHEDULE INPUT TAX RESTRICTED GOODS [Section

SRI N GOVINDARAJU vs. THE INCOME TAX OFFICER

Appeal stands disposed of

Bench: S.SUJATHA,VINEET SARAN

disallowance of expenditure, were upheld by the Tribunal. Being aggrieved by the said order of the Tribunal, this appeal has been filed, which has been admitted on the following four substantial questions of law: 6 (1) Whether the Tribunal was correct in upholding re- assessment proceedings, when the reason recorded for re-opening of assessment under S.147 of Act itself

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 254(2) 17

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 254(2) 17

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 254(2) 17

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

17 of 2013), shall not be deemed to be a speculative transaction. Section 43AA: Subject to the provisions of section 43A, any gain or loss arising on account of any change in foreign exchange rates shall be treated as income or loss, as the case may be, and such gain or loss shall be computed in accordance with the income

M/S NANDI STEELS LIMITED vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

In the result, the findings

Bench: ALOK ARADHE,R. NATARAJ

disallowed the claim of set off of brought forward loss. It is also pointed out that proviso to Section 72(i) was omitted by Finance act, 1999 with effect from 01.04.2000 and for the impugned assessment year 2003-04, the assessee was not required to carry on the business for the purpose of set off of brought forward business loss

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

17) dealing with computation of deduction under Section 80HHC in respect of profits from export of tea held that Section 10 groups in one place various incomes which are exempt from tax. In respect of incomes on which deductions under Chapter VI-A are allowed, such incomes are wholly or partly tax free incomes. Section 10-A provides deduction

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

17) dealing with computation of deduction under Section 80HHC in respect of profits from export of tea held that Section 10 groups in one place various incomes which are exempt from tax. In respect of incomes on which deductions under Chapter VI-A are allowed, such incomes are wholly or partly tax free incomes. Section 10-A provides deduction

THE COMMISSIONER OF INCOME-TAX vs. M/S BOSCH LTD

The appeal is dismissed

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

17 of the Act contrary to Section 115WB (3) of the Act. ii. Whether, in the facts and in the circumstances of the case, the Tribunal was correct in setting aside the order passed under section 263 of the Act on the ground that the order of assessment was not erroneous and prejudicial to the interest of the revenue when

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

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), the disputed tax which 15 is subject matter of departmental appeal before the High Court is as under:- AYs Tax Arrears Disputed tax [i.e., tax @ 33.99% on disputed income] Payable under VsVs

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), the disputed tax which 15 is subject matter of departmental appeal before the High Court is as under:- AYs Tax Arrears Disputed tax [i.e., tax @ 33.99% on disputed income] Payable under VsVs