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

disallowance and this is clearly contrary to law. 6. In view of the above discussion, the assessee's reply cannot be accepted. 7. In Cochin International Airport Ltd. (92 taxmann.com 277), the Hon'ble ITAT Cochin have explained the provisions of section 263 and observed as follows: 7.1 In order to ascertain whether an order sought to be revised under

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

27 of the Act recognises the right of the Government to grant a lease of its right to 'manufacture, supply or sell intoxicants. Section 34 of the Act read with Section 59(d) empowers the Financial Commissioner to direct that a licence, permit or pass be granted under the Act on payment of such fees and subject to such restrictions

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

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

disallowed by the AO. The claim of the Assessee is this that if the worker is employed on permanent basis then only because in the present year, working days are less than 300 days because he was employed after 66 days from the start of the previous year then no deduction will be available under this section in respect

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

M/S DELHI INTERNATIONAL vs. THE PRINCIPAL COMMISSIONER

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowing the claim under section 40(a)(ia) of the Act. 6. Learned counsel appearing for the Revenue, justifying the impugned order of the Tribunal submitted that, the Airlines Operators while paying Passenger Service Fees [PSF (SC & FC) were retaining the amount - 12 - of 2.5% of the invoice value on account of prompt payment by them to the assessee before

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

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

disallowed the deduction claimed by the assessee under Section 35(2AB) of the Act incurred by assessee in a sum of ` 48,41,82,071/- as against the total deduction of ` 89,35,48,193/- claimed by the assessee under Section 35(2AB) of the Act. 41 26. A perusal of the report submitted by the prescribed authority

THE PR.COMMISSIONER OF INCOME TAX CIT(A) vs. M/S. ADVAITH MOTORS PVT LTD.,

Bench: S.SUJATHA,VINEET KOTHARI

Section 14A of the Act r/w 8D of the Rules could exceed the expenditure computed under Rule-8D of the Rules by the assessee to the extent of Rs.56,55,867/-. 3. The Assessing Authority disallowed the expenditure to the extent of Rs.1,27

ANTONY PARAKAL KURIAN vs. ASSISTANT COMMISSIONER OF INCOME TAX

Appeal is allowed in part

Bench: S.SUJATHA,S RACHAIAH

disallowed. As regards the claim made under Section 54F of the Act, the same came to be rejected. M.P.No.163/Bang/2020 was preferred by the assessee, the same came to be allowed in part directing Commissioner of Income Tax [Appeals] to decide 9 regarding eligibility of Rs.90 lakhs also under Section 54 of the Act, rejecting the other contentions raised

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

Section 14A in M/S NOVEL SOFTWARE INDIA (P) LTD. are factually incorrect and we hasten to clarify the same. However, from relevant extract of Paragraph 40, it is evident that only expenses proportionate to earning of exempt income could be disallowed under 27

THE PR COMMISSIONER OF vs. M/S MAHAVEER CALYX

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

27,310/- under Rule 8D(2)(II) while making the disallowance under Section 14A of the Act 6 without appreciating

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

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

THE PR. COMMISSIONER OF INCOME TAX, CIT (A) vs. M/S. MANIPAL HEALTH SYSTEMS PVT. LTD.,

Appeal is dismissed

Bench: P.S.DINESH KUMAR,C.M. POONACHA

disallowance made under Section 40A(2) of the Act is based on surmises and hence, unsustainable. 12. The ITAT has rightly held that the AO has not doubted the payment nor held the payment as excessive even though in terms of Section 40A (2) only ‘legitimate needs of the business’ is allowable as expenditure. Thus there is no material

SHRI. SHANKARLAL GILADA vs. THE INCOME TAX OFFICER,

Bench: G.NARENDAR,M.NAGAPRASANNA

disallowed and cannot be treated as business expenditure. Keeping this objective behind Section 14-A of the Act in mind, the said provision has to be interpreted, particularly, the word “in relation to the income” that does not form part of total income. Considered in this hue, the principle of apportionment of expenses comes into play as that