PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

24. It is apparent that in a case where the assessee voluntarily computes the ALP pursuant to an APA entered into with CBDT, none of the conditions as set out in sub-section (3) of Section 92C are attracted. It follows that sub-section (4) of Section 92C is not attracted. 25. More importantly, the proviso to sub-section

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

VI-A are allowed, such incomes are wholly or partly tax free incomes. Section 10-A provides deduction out of the total income and it is not the income which is exempt from tax. Hence, the deduction which is allowed under Section 10-A is an item of income on which tax is not paid. After referring to the Judgment

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

VI-A are allowed, such incomes are wholly or partly tax free incomes. Section 10-A provides deduction out of the total income and it is not the income which is exempt from tax. Hence, the deduction which is allowed under Section 10-A is an item of income on which tax is not paid. After referring to the Judgment

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

VI-A of the Act. The return was processed under Section 143(1) of the Act and was subsequently taken up for scrutiny. The Assessing Officer by an order dated 22.2.2013, inter alia, made the addition on account of disallowance of provision of loss of derivative contracts to the extent of Rs.16,35,54,352/- out of total provision made

THE COMMISSIONER OF INCOME TAX vs. M/S. STATE BANK OF MYSORE

In the result, the order passed by the tribunal

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

2(24)(x) read with Section 36(va) of the Act? (iii) Whether the Appellate Authorities were correct in holding that the Assessing Officer has not discharged his burden of proving that the entire income under investment is from the investments made by utilizing borrowed funds, when 80% of the funds employed in the business are borrowed funds and recorded

M/S J K INDUSTRIES LTD vs. THE JOINT COMMISSIONER OF INCOME TAX

In the result, all questions are answered against the

Bench: D.V.SHYLENDRA KUMAR,B.SREENIVASE GOWDA

VI, and has submitted that in the wake of the deduction permitted under Chapter VIA, deduction permitted under Section 80C to 80U are to be allowed from the gross total income of an assessee and that the deduction so permitted cannot exceed the gross total income of the assessee. 11. It is also brought to our notice the distinction

THE COMMISSIONER OF INCOME-TAX vs. M/S. IBC KNOWLEDGE PARK PVT. LTD.,

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

24. Learned counsel for the Revenue, however, contended that the Appellate Authorities were not right in holding that a sum of Rs.1.91 crore cannot be disallowed as a deduction. He submitted that the said amount was not reflected in the balance sheet and no particulars had been furnished by the assessee in that regard. Learned counsel contended that the Appellate

THE COMMISIONER OF INCOME-TAX vs. M/S IBC KNOWLEDGE PARK PVT LTD

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

24. Learned counsel for the Revenue, however, contended that the Appellate Authorities were not right in holding that a sum of Rs.1.91 crore cannot be disallowed as a deduction. He submitted that the said amount was not reflected in the balance sheet and no particulars had been furnished by the assessee in that regard. Learned counsel contended that the Appellate

THE COMMISSIONER OF INCOME-TAX vs. M/S. IBC KNOWLEDGE PARK PVT. LTD.,

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

24. Learned counsel for the Revenue, however, contended that the Appellate Authorities were not right in holding that a sum of Rs.1.91 crore cannot be disallowed as a deduction. He submitted that the said amount was not reflected in the balance sheet and no particulars had been furnished by the assessee in that regard. Learned counsel contended that the Appellate

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

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

vi. ACIT -Vs.- Marico Ltd. [(2020) 117 taxmann.com 244 (SC)]; vii. JCIT -Vs.- Cognizant Technology Solutions India (P.) Ltd. [(2023) 146 taxmann.com 197 (SC)]. 7. That apart it is his submission that, there is no error in the order of the Assessing Officer as is evident from the submissions made. The conclusion drawn by the PCIT in the order under

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

The appeals are allowed; the impugned

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

disallowed the excess depreciation claimed on networking equipments. 3. The Principal Commissioner of Income Tax, Bengaluru, thereafter issued a notice under Section 263 of the Act of 1961 on 5.3.2015 and called upon the assessee to explain as to why the assessment order passed by the assessing officer under Section 143(3) of the Act of 1961 should

THE COMMISSIONER OF INCOME TAX vs. M/S AMCO POWER SYSTEMS LTD.,

Bench: B.MANOHAR,VINEET SARAN

vi. 17/01/2003 Rs. 5,00,000 vii. 03/04/2004 Rs. 30,000 viii. 13/04/2004 Rs. 1,60,000 ix. 13/07/2004 Rs. 1,00,000 x. 27/07/2004 Rs. 2,00,000 xi. 06/09/2004 Rs. 3,00,000 xii. 10/12/2004 Rs. 5,00,000 xiii. 09/03/2005 Rs. 10,000 xiv. 31/01/2006 Rs. 3,72,00,000 Total

THE COMMISSIONER OF INCOME TAX vs. M/S AMCO POWER SYSTEMS LTD.,

Bench: B.MANOHAR,VINEET SARAN

vi. 17/01/2003 Rs. 5,00,000 vii. 03/04/2004 Rs. 30,000 viii. 13/04/2004 Rs. 1,60,000 ix. 13/07/2004 Rs. 1,00,000 x. 27/07/2004 Rs. 2,00,000 xi. 06/09/2004 Rs. 3,00,000 xii. 10/12/2004 Rs. 5,00,000 xiii. 09/03/2005 Rs. 10,000 xiv. 31/01/2006 Rs. 3,72,00,000 Total

THE COMMISSIONER OF INCOME TAX vs. M/S AMCO POWER SYSTEMS LTD.,

Bench: B.MANOHAR,VINEET SARAN

vi. 17/01/2003 Rs. 5,00,000 vii. 03/04/2004 Rs. 30,000 viii. 13/04/2004 Rs. 1,60,000 ix. 13/07/2004 Rs. 1,00,000 x. 27/07/2004 Rs. 2,00,000 xi. 06/09/2004 Rs. 3,00,000 xii. 10/12/2004 Rs. 5,00,000 xiii. 09/03/2005 Rs. 10,000 xiv. 31/01/2006 Rs. 3,72,00,000 Total

THE COMMISSIONER OF INCOME TAX vs. M/S AMCO POWER SYSTEMS LTD

Bench: B.MANOHAR,VINEET SARAN

vi. 17/01/2003 Rs. 5,00,000 vii. 03/04/2004 Rs. 30,000 viii. 13/04/2004 Rs. 1,60,000 ix. 13/07/2004 Rs. 1,00,000 x. 27/07/2004 Rs. 2,00,000 xi. 06/09/2004 Rs. 3,00,000 xii. 10/12/2004 Rs. 5,00,000 xiii. 09/03/2005 Rs. 10,000 xiv. 31/01/2006 Rs. 3,72,00,000 Total

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

24,729 Less: TDS 28,20,543 Balance Tax 14,76,04,186 Less: Advance Tax 7,50,00,000 Balance Tax 7,26,04,186 Add: Interest u/s234A – 1,30,68,753 235B – 1,59,97,806 2,90,66,559 13 Total Tax 10,16,70,745 Less: 140A paid 2,00,00,000 Net Amount Payable