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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 154. Notice u/s 142(1) was issued on 21.12.2001 with a questionnaire. Further notices u/s 142 (1) were issued on various dates beginning from 7.10.2003 to 8.3.2004. The assessee- company filed written replies along with enclosures from time to time. The return furnished on 30.10.2001 was processed u/s 143(3) of the I.T.Act on 24.03.2004 and order was passed

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

Disallowance of expenses claimed under section 37(1) towards illegal mining. 387,76,69,992/- 4. Aggrieved by the above additions, the assessee preferred an appeal before the Tribunal against the additions made hereinabove, which came to be allowed. 5. It is stated in the appeal that during the assessment proceedings, it was observed that, M/s GLA Trading International

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

1(3), Bangalore dated 31.03.2013, further an appeal was preferred before the Commissioner of Income Tax (Appeals) – VI wherein the appellate order and ground of decision was passed. The assessments under Section 153C read with Section 144 of the IT Act for assessment years 2005-06 to 2010-11 and under Section 153D read with Section 144 for the assessment

PR. COMMISSIONER OF INCOME TAX vs. SHRI. GALI JANARDHANA REDDY

Bench: K.SOMASHEKAR,UMESH M ADIGA

1(3), Bangalore dated 31.03.2013 an appeal was preferred before the Commissioner of Income Tax (Appeals) – VI wherein the appellate order and ground of decision was passed. The assessments under Section 153C read with Section 144 of the IT Act for assessment years 2005-06 to 2010-11 and under Section 154D read with Section 144 for the assessment year

COMMISSIONER OF INCOME TAX-III vs. M/S SYNDICATE BANK

The appeals are disposed of

Bench: ALOK ARADHE,RAVI V HOSMANI

disallowing an amount of Rs.192,53,21,426/- on reversal of interest pertaining to earlier years as deduction out of current years income and added back to interest on zero coupon bonds to the tune of RS.1,03,53,095/- along with other additions/disallowance in computation of regular income/book profit. It was held that as per section 36(1)(viia

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 on the ground that in terms of proviso to Section 36(1)(iii) which was incorporated in the At with effect form 01.04.2004 the interest cost ought to have been capitalized. 21 12. It is pertinent to mention here that prior to amendment of Section 36(1)(iii) vide Finance Act, 2003, it is a well settled proposition

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

disallowance on the ground that in terms of proviso to Section 36(1)(iii) which was incorporated in the At with effect form 01.04.2004 the interest cost ought to have been capitalized. 21 12. It is pertinent to mention here that prior to amendment of Section 36(1)(iii) vide Finance Act, 2003, it is a well settled proposition

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

disallowance on the ground that in terms of proviso to Section 36(1)(iii) which was incorporated in the At with effect form 01.04.2004 the interest cost ought to have been capitalized. 21 12. It is pertinent to mention here that prior to amendment of Section 36(1)(iii) vide Finance Act, 2003, it is a well settled proposition

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

23,61,083 metric tons at a cost of Rs.168,,69,93,902/- is disallowed. The jurisdictional error committed is the assessing officer’s jurisdiction is Deputy Commissioner of Income Tax, 35 Central Circle-1(3), Bengaluru, whereas the jurisdictional assessing officer of the transporters is located in Andhra Pradesh. 31.Admittedly, as stated above the evidence of transporters recorded

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

23,231/- came to be disallowed. 24. Thus, an amount of ` 48,41,82,071/- out of deduction of ` 89,35,48,193/- claimed under Section 38 35(2AB) was disallowed and added to the income of the assessee. It has been held by the second respondent that the mandate of the prescribed authority is limited to certifying to what

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

In the result, the appeals are partly allowed

Bench: B.MANOHAR,DILIP B.BHOSALE

23. That takes us to consider the next question of law A2. This question and the question of law A6 in ITA No.68/2007 are similar and hence can be considered and decided together. The Assessing Officer disallowed the deduction, under Sections 80HH and 80I of the IT Act, claimed by the respondent-assessee in respect of industrial vanaspathi unit

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

23. Third substantial question of law is with regard to the disallowance of interest of Rs.1,91,14,354/-. The Assessing Officer had held that the balance sheet did not - 28 - reflect any accrued interest and hence, the same could not be allowed as a deduction. The Appellate Commissioner had directed the Assessing Officer to allow deduction on payment

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

23. Third substantial question of law is with regard to the disallowance of interest of Rs.1,91,14,354/-. The Assessing Officer had held that the balance sheet did not - 28 - reflect any accrued interest and hence, the same could not be allowed as a deduction. The Appellate Commissioner had directed the Assessing Officer to allow deduction on payment

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

23. Third substantial question of law is with regard to the disallowance of interest of Rs.1,91,14,354/-. The Assessing Officer had held that the balance sheet did not - 28 - reflect any accrued interest and hence, the same could not be allowed as a deduction. The Appellate Commissioner had directed the Assessing Officer to allow deduction on payment

THE COMMISSIONER OF INCOME TAX vs. M/S BPL SANYO FINANCE LTD

In the result, the appeal filed by the revenue is

Bench: The Tribunal Was Arising From The Order Dated 4Th June 2004 Passed By The Commissioner Of Income Tax (Appeals) Bangalore (For Short “The

23. We have perused Section 271 (1) (c) (iii) and Explanation-I (B) of the Act. Under this provision, if AO in the course of any proceedings under the Act is satisfied that any person has “concealed” the particulars of his income or furnish “inaccurate particulars” of such income, he may direct such person to pay by way of penalty

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 (EXEMPTION) vs. CMR JNANADHARA TRUST

The appeals stand dismissed

Bench: S.G.PANDIT,K. V. ARAVIND

disallowance has been sought to be made by invoking Section 13(1)(c) primarily on the ground that the concerns have earned higher profits, as reflected in their statements of profit and loss. 9. It is also contended that the concerns have paid higher remuneration to their Directors. However, there is no comparative material placed on record to demonstrate that

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

23,45,836 Sri Shankar submits that this is being referred to at page 27 of the paper book filed in this appeal, which is part of the assessment year, the same has not been taken for examination. 12 15. On this aspect, Sri Shankar has placed reliance on the decisions in 1) TOPMAN EXPORTS vs COMMISSIONER OF INCOME