HINDUSTAN AERONAUTICS LIMITED vs. ASSISTANT COMMISSIONER

In the result, the order of the

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowance was made for the Assessment Year 2009-10. 8. With regard to claim of the assessee under Section 14A of the Act, it is pointed out that assessee had earned dividend income from two companies, in which it had made strategic investments, which was exempt under Section 10(34

THE PR COMMISSIONER OF INCOME TAX vs. M/S HINDUSTAN AERONAUTICS LTD

In the result, the order of the

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowance was made for the Assessment Year 2009-10. 8. With regard to claim of the assessee under Section 14A of the Act, it is pointed out that assessee had earned dividend income from two companies, in which it had made strategic investments, which was exempt under Section 10(34

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 which, as stated above, was inserted with effect from 1st April, 1984. It is also relevant to note that the first proviso which came into force with effect from 1st April, 1988 was not on the statute book when the assessments were made in the case of Allied Motors (P) Limited (supra). However, the Assessee

ESSILOR INDIA PVT LTD vs. THE DEPUTY

The appeal is disposed of

Bench: ALOK ARADHE,SHIVASHANKAR AMARANNAVAR

Section 10(34) of the Act. The Assessing Officer passed an order of assessment dated 28.10.2010 and disallowed a sum of Rs.34

ESSILOR INDIA PVT LTD vs. THE DEPUTY

In the result, the order passed by the Tribunal dated 07

Bench: ALOK ARADHE,SHIVASHANKAR AMARANNAVAR

Section 10(34) of the Act. The Assessing officer passed an order of assessment dated 28.10.2010 and disallowed a sum of Rs.26

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

disallowance under Section 36(1)(vii) of the Act. 3. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals) who by an order dated 18.07.2013 partly allowed the appeal preferred by the assessee. The revenue thereupon filed an appeal before the Income Tax Appellate Tribunal (hereinafter referred to as 'the tribunal' for short). The tribunal

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

disallow the claim made by an assessee under Section 35(2AB) which does not include any expenditure incurred in the acquisition of rights, in, or arising out of scientific research would be within the domain of the jurisdictional assessing Officer. In other words, the issue of jurisdiction of assessing officer to examine such claim, is an issue which requires

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

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

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 144C(13) of the Income Tax Act on 31.12.2013, determining total income at Rs.10,86,34,35,052/- by making various additions, which reads as under: Additional / Issues Rs. Transfer pricing adjustments 112,20,92,081/- Claim of bogus transportation expenses of iron ore 40% attributable towards illegal mining. 86,43,47,335/- Disallowance

M/S KRISHNAGIRI ESTATE vs. THE KARNATAKA APPELLATE TRIBUNAL

Bench: The Hon'Ble Mr. Justice Aravind Kumar

disallowed by the assessing officer came to be affirmed. 4 3. Petitioner filed an application under Section 34(7) of the Act vide

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 of the Act and added a sum of Rs.7,34,975/- by applying Rule 8D(iii). 3. The assessee

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

Appeal is allowed

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

Section 45(4) of the IT Act as long term Capital gains, is not sustainable. 13. It was argued by Shri. Shankar that by applying the same logic, the Assessing Officer has 4 (1984)17 Taxmann. 330 KAR (para 4) I.T.A No.201/2017 12 added short-term Capital gains at 30% on the building which was constructed on the plot owned

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S FIBRES AND FABRICS INTERNATIONAL PVT. LTD.,

In the result, we do not find any merit in this

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

34(1)(b) would have no application. 8. A Full Bench of this Court in 'DELL INDIA PVT. LTD. Vs. JOINT COMMISSIONER OF INCOME-TAX, BANGALORE' (2021) 123 TAXMANN.COM 468 (KAR) dealt with the question whether 'reason to believe' in the context of Section 147 of the Income Tax Act can be based on mere change of opinion

THE PR. COMMISSIONER OF INCOME TAX, vs. THE TOTAGARS CO-OPERATIVE SALE SOCIETY,

The appeal is dismissed

Bench: SREENIVAS HARISH KUMAR,RAGHVENDRA S. CHAUHAN

Section 10(34) of the Act, the assessee filed its returns. While assessing the income tax returns, the Assessing Officer disallowed

THE COMMISSIONER vs. M/S VIJAYA BANK

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowed the aforesaid amount in terms of Section 14A of the Act. A sum of Rs.3,43,28,658/- being 5% thereof was estimated as expenditure incurred for earning such income. 3. The assessee, thereupon, filed an appeal. The Commissioner of Income Tax (Appeals) by an order dated 31.05.2011 partly allowed the appeal. Being aggrieved, the revenue as well

THE COMMISSIONER vs. M/S CANARA BANK

In the result, we do not find merit in these

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowed the same under provisions of Section 14A of the Act?’ 6 3. Learned counsel for the assessee submitted that the substantial questions of law No.1 and 4 are answered against the revenue by judgment dated 17.01.2020 passed by a Bench of this Court in ITA No.97/2010 and connected matter. It is further submitted that the substantial question

THE COMMISSIONER vs. M/S CANARA BANK

In the result, we do not find merit in these

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowed the same under provisions of Section 14A of the Act?’ 6 3. Learned counsel for the assessee submitted that the substantial questions of law No.1 and 4 are answered against the revenue by judgment dated 17.01.2020 passed by a Bench of this Court in ITA No.97/2010 and connected matter. It is further submitted that the substantial question