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

Section 35(2AB) in respect of Research and Development expenditure in a sum of ` 89,35,48,193/-, a sum of ` 48,41,82,071/- was disallowed

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

48,54,153/- by reducing the interest rate to 8.5% as against 12% as held by the Assessing Officer. (iii) the disallowance of interest on borrowed capital allegedly utilized for capital work-in-progress was upheld but the quantum of disallowance was reduced from Rs.7,97,79,326/- to Rs.5,05,06,362/- by reducing the interest rate from

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

48,54,153/- by reducing the interest rate to 8.5% as against 12% as held by the Assessing Officer. (iii) the disallowance of interest on borrowed capital allegedly utilized for capital work-in-progress was upheld but the quantum of disallowance was reduced from Rs.7,97,79,326/- to Rs.5,05,06,362/- by reducing the interest rate from

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

48,54,153/- by reducing the interest rate to 8.5% as against 12% as held by the Assessing Officer. (iii) the disallowance of interest on borrowed capital allegedly utilized for capital work-in-progress was upheld but the quantum of disallowance was reduced from Rs.7,97,79,326/- to Rs.5,05,06,362/- by reducing the interest rate from

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

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

Section 2(s) of the I.D. Act and disallowed the claim, on an appeal filed by the Assessee, the Commissioner, Income-tax (Appeals) CIT(A) accepted the Assessee’s I.T.A. NO.141 OF 2020 c/w I.T.A. NO.151 OF 2020 48

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

Bench: S.SUJATHA,VINEET KOTHARI

Disallowance under Section 14A of Rs.2,48,85,000/- as expenses to earn exempted Dividend income of Rs.1,80,30,965/- is per se absurd

THE COMMISSIONER OF INCOME TAX vs. M/S. CHAITANYA PROPERTIES PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

Disallowance under Section 14A of Rs.2,48,85,000/- as expenses to earn exempted Dividend income of Rs.1,80,30,965/- is per se absurd

PR. COMMISSIONER OF INCOME-TAX-4 vs. KARNATAKA STATE FINANCIAL CORPORATION LTD

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 14A of the I.T.Act for Rs.2,48,72,710/- and the same was disallowed by adding back

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

disallowance of 10% of dividend income under Section 14A of the Act. 5. The Assessee is engaged in the business of providing back office support and data processing services to its customers. The Assessee had filed its return of income [ROI] for the AY 2015-16 and AY 2016-17 on 30.11.2015 and 14.10.2016 respectively. The Assessee had declared

ESSILOR INDIA PVT LTD vs. THE DEPUTY

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

Bench: ALOK ARADHE,SHIVASHANKAR AMARANNAVAR

48. Applying the principles of statutory interpretation for interpreting retrospectively of a fiscal statute and looking into the nature and purpose of sub-Section (2) and sub-Section (3) of Section 14A as well as purpose and intent of Rule 8D coupled with the explanatory notes in the Finance Bill, 2006 and the departmental understanding as reflected by Circular dated

SATISH KUMAR PANDEY vs. ASSISTANT COMMISSIONER OF INCOME TAX

Appeals are allowed

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

48 of the Income Tax Act, 1961? 2. Heard Shri. B R Sudheendra, learned Advocate for the Assessees and Shri. Dilip, learned Standing Counsel for the Revenue. 1Income Tax Appellate Tribunal. I.T.A No.695/2019 C/W I.T.A No.696/2019 4 3. Briefly stated the facts of the case are, Appellant/Assessees filed their returns for the Assessment year 2016-2017. They are the shareholders

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

48. The grounds relating to Corporate Tax issue as per Grounds No. 6, 9 and 10, the learned AR of the assessee submitted that three issues are involved in this ground i.e. 1) Disallowance of Transportation charges, 2) Disallowance of Expenses under Explanation to section

PR COMMISSIONER OF vs. M/S WIPRO LIMITED

In the result, the appeal is disposed of in terms

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowance under Section 40(a)(ia) of the Act has rightly been made. It is also pointed out that Section 40 of the Act begins with a non obstante clause and has an overriding effect on Section 30 to Section 48

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

Appeal is allowed

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

48,398/- by making various additions and disallowances. The CIT(A)2 partly allowed assessee's appeal. Feeling aggrieved, both assessee and Revenue filed their appeals before ITAT and the ITAT has dismissed both appeals. In this appeal, assessee is aggrieved by: (i) disallowance of Rs.53,367/- under Section

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

PRINCIPAL COMMISSIONER OF INCOME TAX-5 vs. M/S. NADATHUR ESTATES PVT. LTD.,

Appeal stands dismissed

Bench: SATISH CHANDRA SHARMA,RAVI V HOSMANI

disallowance under section 14A r.w.r.8D (2)(iii) by taking into account only the investments which yielded exempt income during the said year, by relying on the decision of the Special Bench in the case of ACIT vs. Vireet Investment (P) Ltd., (82 taxman.com 415 (Del) when the assessing authority has rightly invoked section 14A r/w Rule

THE PR. COMMISSIONER OF INCOME TAX vs. MRS. VANAJA MATTHEN

The appeal is dismissed

Bench: This Court, Questioning The Order Dated 25.01.2017 In

disallowed deduction under Section 54F of the Income-Tax Act, 1961 (‘the Act’ for short) on the ground that the assessee purchased the property vide sale deeds dated 10.09.2008 and 20.11.2008, however, the construction of the flats have not been completed when the purchase was made under the said sale deeds. Further, it observed that the construction was completed

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

48,96,860/- and deduction of Rs.75,000/- was claimed under Chapter VI-A of the Act. The return was processed under Section 143(1) of the Act and was subsequently taken up for scrutiny. The Assessing Officer by an order dated 22.2.2013, inter alia, made the addition on account of disallowance