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): Particulars Disputed Income Disputed tax [i.e., tax @ 33.99% on disputed income] Payable under DTVSV Act @ 50% of tax As per Petitioner 37,28

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 is untenable in law and - 28 - ITA No.53 of 2024 failure to do so has resulted in short computation of income of Rs. 10,90,23,000/- (@30% of Rs.36,34,10,000/-) with a consequent tax effect of Rs.5,74,38,22/-. This has resulted in Loss to revenue. Considering these facts, the assessment order is erroneous

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

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

disallow deductions claimed merely by making a Book entry based on Merchantile System of Accounting. At the same time, Section 43-B [main section] made it mandatory for the Department to grant deduction in computing the income under Section 28

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

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

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

28. It is in this background, sub-section (4) of Section 43 will have to be considered, which defines as to what activities would constitute “scientific research” as indicated under the said Section namely, Section 43(4). As to whether any expenditure incurred in the acquisition of rights in or arising out of scientific research as indicated in clause

THE COMMISSIONER OF INCOME TAX vs. M/S GARNIWAL EXPORTS (P) LTD

Appeal is allowed

Bench: D.V.SHYLENDRA KUMAR,B.S.INDRAKALA

disallowed the deduction claimed in respect of the price of Rs.17,78,155/- received by the assessee by way of transfer of quota opining that the amount represented business income of the assessee; that it cannot be attributed to any export activity as the amount is not by export but received 4 within the country; that Section 80HHC benefit being

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

disallowance under Section 14-A of the Act in a sum of Rs.41,28,225/- and provision for ex- gratia

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance?” Additional substantial question of law in ITA No.702/2018; - 26 - “Whether on the facts and in the circumstances of the case and in law, the Tribunal is right in law in deleting addition of income of Rs.69,04,00,000/- by directing the assessing authority to allow it on cash basis which was made by assessing authority on accrual basis

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance?” Additional substantial question of law in ITA No.702/2018; - 26 - “Whether on the facts and in the circumstances of the case and in law, the Tribunal is right in law in deleting addition of income of Rs.69,04,00,000/- by directing the assessing authority to allow it on cash basis which was made by assessing authority on accrual basis

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance?” Additional substantial question of law in ITA No.702/2018; - 26 - “Whether on the facts and in the circumstances of the case and in law, the Tribunal is right in law in deleting addition of income of Rs.69,04,00,000/- by directing the assessing authority to allow it on cash basis which was made by assessing authority on accrual basis

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance?” Additional substantial question of law in ITA No.702/2018; - 26 - “Whether on the facts and in the circumstances of the case and in law, the Tribunal is right in law in deleting addition of income of Rs.69,04,00,000/- by directing the assessing authority to allow it on cash basis which was made by assessing authority on accrual basis

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

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance?” Additional substantial question of law in ITA No.702/2018; - 26 - “Whether on the facts and in the circumstances of the case and in law, the Tribunal is right in law in deleting addition of income of Rs.69,04,00,000/- by directing the assessing authority to allow it on cash basis which was made by assessing authority on accrual basis

M/S DELHI INTERNATIONAL vs. THE PRINCIPAL COMMISSIONER

Bench: S.SUJATHA,S VISHWAJITH SHETTY

disallowance?” Additional substantial question of law in ITA No.702/2018; - 26 - “Whether on the facts and in the circumstances of the case and in law, the Tribunal is right in law in deleting addition of income of Rs.69,04,00,000/- by directing the assessing authority to allow it on cash basis which was made by assessing authority on accrual basis

THE COMMISSIONER OF INCOME TAX vs. M/S RAJMAHAL SILKS

The appeal is disposed of

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowance made under Section 40A(3) can be only on the basis of profit and loss account and only on those expenditures claimed in terms of Section 28

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. M/S QUEST GLOBAL ENGINEERING SERVICES PVT. LTD.,

In the result, we don to find any

Bench: ALOK ARADHE,R. NATARAJ

disallowance under Section 14A has to be made even taxpayer has not earned any exempt income, this court has misread the ratio of the decision of the Supreme Court in MAXOPP INVESTMENT 28