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599 results for “disallowance”+ Section 8(2)clear

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Key Topics

Section 26093Section 260A57Addition to Income38Deduction35Disallowance34Section 143(3)33Section 14833Section 14731Section 10A26Section 263

M/S T T K PRESTIGE LTD vs. THE UNION OF INDIA REPTD BY ITS FINANCE SECRETARY

WP/26037/2005HC Karnataka06 Dec 2019

Bench: The Hon’Ble Mr.Justice P.B. Bajanthri W.P. No.26037/2005 C/W W.P.No.4464/2007 & W.P.No.27087/2005(It)

Section 115

disallowed under section 37 of the Act is outside the purview of fringe benefit tax as explained by CBDT Circular dated 29/8/2005 in response to Question No.35. Hence the contention of the assessee that levy of fringe benefit tax is double taxation is incorrect. 6. It is submitted that the petitioner has contended that the benefits/expenses can be taxed

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

The appeals are dismissed

ITA/141/2020HC Karnataka21 Apr 2021

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

Section 143(2)

Showing 1–20 of 599 · Page 1 of 30

...
16
Section 80I15
Charitable Trust7
Section 194
Section 2
Section 206A
Section 40
Section 80J

8. The Assessee has filed an appeal as regards disallowance in respect of Section 80JJ(AA); the Revenue filed an appeal insofar as finding relating to the aspect of tax deducted at source referred to above. The Tribunal taking into account the decision rendered by it in another matter where it had held that the employees/workmen in the software industry

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

ITA/100012/2017HC Karnataka17 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 143(3)Section 144CSection 144C(13)Section 260ASection 37(1)Section 92ASection 92C

2) 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

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

ITA/512/2017HC Karnataka23 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 2(22)(e)Section 254Section 260

8. Since the said Assessment Order was passed in pursuance of the directions of the Dispute Resolution Panel (DRP) under Section 144 C (5) of the Income Tax Act, 1961, the Assessee Company preferred an appeal before the learned Income Tax Appellate Tribunal (ITAT), who disposed of the said appeal by the impugned Order dated 22/02/2017. Date of Judgment

M/S J K CEMENT WORKS vs. THE STATE OF KARNATAKA

STRP/100001/2014HC Karnataka23 Mar 2017

Bench: H.B.PRABHAKARA SASTRY,VINEET KOTHARI

Section 63Section 65Section 65(1)

8. Having given our earnest consideration to the rival submissions, we are of the considered opinion that the present Revision Petitions filed by the assessee deserve to succeed and the question of law framed above deserves to be answered in favour of the petitioner assessee and against the Revenue. The reasons are as follows: 9. Chapter II dealing with

THE COMMISSIONER OF INCOME TAX vs. PRAVEEN V DODDANAVAR

ITA/100003/2014HC Karnataka20 Feb 2017

Bench: SREENIVAS HARISH KUMAR,VINEET KOTHARI

Section 63Section 65Section 65(1)

8. Having given our earnest consideration to the rival submissions, we are of the considered opinion that the present Revision Petitions filed by the assessee deserve to succeed and the question of law framed above deserves to be answered in favour of the petitioner assessee and against the Revenue. The reasons are as follows: 9. Chapter II dealing with

THE BAILHONGAL URBAN COOPERATIVE BANK LTD vs. THE COMMISSIONER OF INCOME TAX

ITA/100001/2014HC Karnataka16 Dec 2015

Bench: S.ABDUL NAZEER,P.S.DINESH KUMAR

Section 63Section 65Section 65(1)

8. Having given our earnest consideration to the rival submissions, we are of the considered opinion that the present Revision Petitions filed by the assessee deserve to succeed and the question of law framed above deserves to be answered in favour of the petitioner assessee and against the Revenue. The reasons are as follows: 9. Chapter II dealing with

PR COMMISSIONER OF INCOME TAX-5 vs. M/S PAGE INDUSTRIES LTD

In the result, the appeal fails and is hereby dismissed

ITA/285/2017HC Karnataka08 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(2)Section 14ASection 260Section 80JSection 92C

disallowance of Rs.74,08,964/- under the provisions of Section 80JJAA of the Act were proposed. The 5 assessee thereupon filed objections before the Dispute Resolution Panel contesting all the additions. The Dispute Resolution Panel, however rejected the objections preferred by the assessee. The assessee thereupon filed an appeal before the Income Tax Appellate Tribunal (hereinafter referred

SRI N GOVINDARAJU vs. THE INCOME TAX OFFICER

Appeal stands disposed of

ITA/504/2013HC Karnataka01 Jul 2015

Bench: S.SUJATHA,VINEET SARAN

Section 143(1)Section 147Section 148Section 45(2)

8(2), Bangalore 82 2 Commissioner of Income Tax Appeals II, Bangalore 82 Respondents (By Sri E Sanmathi Indrakumar, Adv.) Appeal is filed under S.260 A of the Income Tax Act, 1961 praying to set aside the order passed by the ITAT, Bangalore in ITA 970/Bang/2009 on 26.04.2010, etc. ® 2 Appeal having been reserved on 20th April, 2015, coming

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

Appeal is dismissed

ITA/817/2018HC Karnataka12 Oct 2023

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

Section 260Section 40A(2)

8. Section 40A(2) reads as follows: 40A(1) xxxxx (2) (a) Where the assessee incurs any expenditure in respect of which payment has been or is to be made to any person referred to in clause (b) of this sub-section, and the 2 [Assessing Officer] is of opinion that such expenditure is excessive or unreasonable having regard

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S.J.J.GLASTRONICS PVT LTD

The appeal stands dismissed

ITA/167/2021HC Karnataka13 Apr 2022

Bench: S.SUJATHA,J.M.KHAZI

Section 10Section 11Section 115JSection 12Section 143(3)Section 14ASection 254Section 260Section 260A

8. Section 115JB of the Act is a complete code in itself. The controversy relating to disallowance under Section 14A of the Act for determining book profit under Section 115JB was dealt with, in extenso by the Delhi ITAT Bench in the case of Vireet Investment Private Ltd., supra and the relevant portion of the said decision has been quoted

PR. COMMISSIONER OF INCOME TAX vs. M/S AMALGAMATED BEAN COFFEE TRADING CO LTD

In the result, the orders dated 21

ITA/388/2018HC Karnataka12 Mar 2021

Bench: ALOK ARADHE,ASHOK S.KINAGI

Section 260Section 260A

8. We have considered the submissions made by learned counsel for the parties and have perused the record. Twin issues arise for consideration in the appeal preferred by the assessee viz., disallowance of interest on borrowed capital insofar as it pertains to investment made in the foreign subsidiary of the assessee and disallowance of interest under Section 36 and disallowance

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

ITA/315/2018HC Karnataka12 Mar 2021

Bench: ALOK ARADHE,ASHOK S.KINAGI

Section 260Section 260A

8. We have considered the submissions made by learned counsel for the parties and have perused the record. Twin issues arise for consideration in the appeal preferred by the assessee viz., disallowance of interest on borrowed capital insofar as it pertains to investment made in the foreign subsidiary of the assessee and disallowance of interest under Section 36 and disallowance

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

ITA/313/2018HC Karnataka12 Mar 2021

Bench: ALOK ARADHE,ASHOK S.KINAGI

Section 260Section 260A

8. We have considered the submissions made by learned counsel for the parties and have perused the record. Twin issues arise for consideration in the appeal preferred by the assessee viz., disallowance of interest on borrowed capital insofar as it pertains to investment made in the foreign subsidiary of the assessee and disallowance of interest under Section 36 and disallowance

M/S NANDI STEELS LIMITED vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

In the result, the findings

ITA/103/2012HC Karnataka23 Feb 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(1)Section 143(3)Section 147Section 148Section 260Section 260ASection 6

disallowed the claim of set off of brought forward loss. It is also pointed out that proviso to Section 72(i) was omitted by Finance act, 1999 with effect from 01.04.2000 and for the impugned assessment year 2003-04, the assessee was not required to carry on the business for the purpose of set off of brought forward business loss

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

ITA/107/2025HC Karnataka12 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 10ASection 14ASection 260Section 260A

8. In addition to the above, the AO made a disallowance of ₹23,93,733/- for AY 2015-16 and ₹25,12,500/- in respect of the AY 2016-17, under Section 14A of the Act. The AO noted that the Assessee had earned income from dividends during the previous year relevant to the assessment years and is exempt from

THE COMMISSIONER OF INCOME TAX vs. M/S QUEST GLOBAL ENGINEERING SERVICES PVT. LTD.,

In the result, we don to find any

ITA/133/2015HC Karnataka15 Feb 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(1)Section 14ASection 260Section 73

disallowance under Section 14A of the Act, the Commissioner of Income Tax (Appeals) upheld the order of the Assessing Officer. In the result, the appeal preferred by the assessee was partly allowed. The assessee as well as the revenue filed appeals before the Income Tax Appellate Tribunal against the order of Commissioner of Income Tax (Appeals). The Tribunal

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

ITA/881/2008HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

8 - 2. The Deputy Commissioner of Income Tax Central Circle 1(3), C.R.Building, Queens Road, Bangalore. ...APPELLANTS (By Sri E.R.Indrakumar, Senior Counsel for Sri K.V.Aravind, Adv.) AND : M/s Wipro Ltd., Doddakannelli, Sarjapur Road Bangalore. …RESPONDENT (By Sri Venkataraman, Senior Counsel for Dr.R.B.Krishna, Adv.) This I.T.A. is filed under Section 260-A of I.T.Act, 1961 arising out of order dated

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

The appeals stand disposed of, accordingly

ITA/211/2009HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

8 - 2. The Deputy Commissioner of Income Tax Central Circle 1(3), C.R.Building, Queens Road, Bangalore. ...APPELLANTS (By Sri E.R.Indrakumar, Senior Counsel for Sri K.V.Aravind, Adv.) AND : M/s Wipro Ltd., Doddakannelli, Sarjapur Road Bangalore. …RESPONDENT (By Sri Venkataraman, Senior Counsel for Dr.R.B.Krishna, Adv.) This I.T.A. is filed under Section 260-A of I.T.Act, 1961 arising out of order dated

MANGALORE REFINERY AND PETROCHEMICALS LTD vs. PRINCIPAL COMMISSIONER OF INCOME TAX

In the result, I pass the following:-

WP/10523/2022HC Karnataka18 Nov 2022

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

Section 5(1)

2. Both the petitions are by the same petitioner – assessee seeking identical reliefs. While W.P.No.10551/2022 is in relation to the assessment year 2008-09, W.P.No.10523/2022 is in relation to the assessment year 2009-10. Since common issues arise for consideration in both the matters, they are taken up together and disposed of by this common order. 3. Heard