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 u/s 40(a)(ia) on the transactions discussed above. He shall give the assessee an opportunity to furnish necessary evidence to establish his claim and explain why the proposed additions be not made to income. The AO shall consider the facts, and the results of any enquiries made, as well as the explanation furnished by the assessee, and make

M/S. EVERGREEN HARDWARE STORES vs. THE ASSISTANT COMMISSIONER OF

Appeal is allowed

Bench: P.S.DINESH KUMAR,UMESH M ADIGA

Section 14A of the Act on the facts and circumstances of the case. 5. Whether the Tribunal was justified in confirming the disallowance of Rs.3,33

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

Bench: S.SUJATHA,VINEET KOTHARI

Section 33(4) of the 1922 Act means ‘on the subject matter of appeal’ before the Tribunal and reading the relevant Rules 22 and 27 of the Income Tax Rules governing the procedure before the Tribunal, the subject matter of appeal before the Tribunal, the grounds of appeal raised by the appellant in his Memorandum of appeal and the grounds

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

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

disallowed under Section 43-B of the Act while computing the business I.T.A. NO.141 OF 2020 c/w I.T.A. NO.151 OF 2020 33

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

section and the question was, of allowing or disallowing the deduction claimed as privilege fee in the present case on hand and this has extensively been dealt with by the Assessing Officer in the course of the assessment order with reference to true nature of the valid parameters and incidents for a fee, as distinct from other imposition such

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

33 92CA is applicable in the cases where arm length price has to be computed under section 92C of the Act, in the cases relating to an international transaction. The term international transaction has been defined in section 92B of the Act. Subsection (1) section 92B eads as under" for the purpose of this Act and section

THE COMMISSIONER OF INCOME-TAX, vs. M/S CORPORATION BANK

In the result, the third substantial question of law is also answered

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 143(1) of the Act o 15.06.2012 and a refund of 4 Rs.133,39,33,970/- was granted. Subsequently, the assessee filed a second revised return on 11.01.2013 in which income of Rs.1367,59,11,162/- was admitted. The Assessing Officer vide order dated 19.02.2013 made an addition on account of depreciation on investment portfolio, disallowance

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

33 does not accept the claim of the assessee made under Section 35(2AB), he has to refer the matter to the Board, which inturn, will refer the question to the prescribed authority. The decision of the prescribed authority would be final as could be seen from clause (b) of sub- section (3) of Section 35. Thus, it would emerge

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

SHRI. SHANKARLAL GILADA vs. THE INCOME TAX OFFICER,

Bench: G.NARENDAR,M.NAGAPRASANNA

33,030/- for the respective years. The Assessing Officer has completely misconstrued and misdirected himself on facts, as the disallowance of any amount under Section

M/S WIPRO LIMITED vs. THE ADDITIONAL COMMISSIONER OF INCOME-TAX,

In the result, the appeal is disposed of in terms of

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

33,78,265/- was rightly disallowed under Section 14A of the Act and was upheld by the Dispute Resolution Panel

PR COMMISSIONER OF INCOME TAX- 4 vs. M/S JUPITER

Appeal is allowed in part accordingly

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

disallowance made under Section 14A read with Rule 8D(ii) of the Act by relying upon the decision of Hon'ble Delhi High Court in the case of Cheminvest Limited (reported in 378 ITR page 33

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

In the result, the appeals are partly allowed

Bench: B.MANOHAR,DILIP B.BHOSALE

33. The AO while dealing with the question A4 in this appeal treated the donation made by the assessee to the Khandesh Education Society as a contribution contemplated by Section 40A(9) of the Act. In other words, the AO disallowed

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

disallowed as it was not meant for management of construction, but on other expenses, such as advertisement, sales promotion etc. Therefore, the income had to be assessed under the head income from other sources. The Tribunal held that the income had to be assessed as business income and the assessee could not have received a sum of Rs.78.25 lakh without

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

disallowed as it was not meant for management of construction, but on other expenses, such as advertisement, sales promotion etc. Therefore, the income had to be assessed under the head income from other sources. The Tribunal held that the income had to be assessed as business income and the assessee could not have received a sum of Rs.78.25 lakh without

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

disallowed as it was not meant for management of construction, but on other expenses, such as advertisement, sales promotion etc. Therefore, the income had to be assessed under the head income from other sources. The Tribunal held that the income had to be assessed as business income and the assessee could not have received a sum of Rs.78.25 lakh without

COMMISSIONER OF INCOME TAX-III vs. M/S MPHASIS SOFTWARE AND SERVICES

The appeals stand dismissed

Bench: ARAVIND KUMAR,VINEET SARAN

Section 10A of the Act in respect of its Mumbai unit. The Assessing Officer, in its assessment order, disallowed a portion of the deduction claimed by the assessee. 3 Out of the total earned revenue of Rs.81,33

M/S. HINDUSTAN COCA COLA vs. STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

33 under Sub-Section (4) of Section 10, if it is not accounted for.” It is contended that in the case of M/s. Infinite Builders and Developers, Bangalore Vs. The Additional Commissioner of Commercial Taxes, (STA 59 of 2009 and 75-83 of 2013), this court has categorically held that: “the benefit of input tax cannot be extended by overlooking