COMMISSIONER OF INCOME TAX-III vs. M/S SYNDICATE BANK

The appeals are disposed of

Bench: ALOK ARADHE,RAVI V HOSMANI

vii) of the I.T. Act is limited to the amount which exceeds the credit balance of the provisions made under section 36(1)(viia) of the I.T. Act?”. 2) “Whether on the facts and in the circumstances of the case the tribunal’s order can be considered as perverse in nature since tribunal has allowed the assessee’s appeal

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S. PUMA SPORTS INDIA P., LTD.,

The appeal stands dismissed

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

disallowance made under Section 40(a)(1) of the Act for the sum of 5 Rs.7,29,13,934/- by holding that the income of the non-residents by way of commission cannot be considered as accrued or arisen or deemed to accrue or arise in India as the services of such agents were rendered or utilized outside India

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

In the result, the appeals are partly allowed

Bench: B.MANOHAR,DILIP B.BHOSALE

vii) of sub-Section 1 of Section 36 as it stood in 1986-87, it appears that it was necessary for the assessee to establish before the Assessing Officer that any debt or part thereof had become a bad debt in the previous year. In view thereof, learned counsel appearing for the Revenue submitted that no such efforts were made

THE COMMISSIONER OF INCOME TAX vs. ING VYSYA BANK LTD

In the result, this appeal is allowed in part,

Bench: B.MANOHAR,D.V.SHYLENDRA KUMAR

vii-a) had not been complied with by the assessee. (4) Whether the Tribunal was correct in holding that the Assessing Officer had correctly disallowed the claim made by the assessee regarding entertainment expenditure of Rs.16,21,016/- on the basis that 50% should be treated a expenditure relating to staff and cannot be brought 4 under the rigor

M/S HAJEE A.P.BAVA & COMPANY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

In the result, the appeal is

Bench: ALOK ARADHE,M.NAGAPRASANNA

disallowed. 3. The appellant filed an appeal before the Commissioner of Income Tax (Appeals). The Commissioner of Income Tax (Appeals) by an order dated 20.09.2017 inter alia held that assessee has only created a provision for doubtful entry in the books of 6 accounts and since it is following a double entry system of accounting, corresponding entries have been made

THE COMMISSIONER OF INCOME-TAX vs. M/S LUWA INDIA PVT LTD

Bench: RAVI MALIMATH,N.KUMAR

vii) of sub-section (1) of section 9; (iii) “professional services” shall have the same meaning as in clause (a) of the Explanation to section 194J; (iv) “work” shall have the same meaning as in Explanation III to section 194C; (v) “rent” shall have the same meaning as in clause (i) to the Explanation to section 194-I; (vi) “royalty

THE COMMISSIONER vs. M/S VIJAYA BANK

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

vii-a) 5 of the Act. The Assessing Officer disallowed the depreciation claimed on securities classified as ‘Held to Maturity’ and further held that the assessee had earned aggregate sum of Rs.68,65,73,177/-, which is exempt under various sub-Sections of Section 10 of the Act and disallowed the aforesaid amount in terms of Section

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

VII.—The provisions of this section shall apply to a proceeding for the execution of a decree and references in this section to any suit, issue or former suit shall be construed as references, respectively, to a proceeding for the execution of the decree, question arising in such proceeding and a former proceeding for the execution of that decree. Explanation

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

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

9. In the appeal preferred before the Appellate Commissioner by the assessee by common order dated 21/3/2013, the Appellate Commissioner disposed of the appeals rejecting the challenge made by the assessee with regard to initiation of proceedings under Section 153C of the Act, while granting relief against disallowances made by the Assessing Officer by following the earlier order

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

9. In the appeal preferred before the Appellate Commissioner by the assessee by common order dated 21/3/2013, the Appellate Commissioner disposed of the appeals rejecting the challenge made by the assessee with regard to initiation of proceedings under Section 153C of the Act, while granting relief against disallowances made by the Assessing Officer by following the earlier order

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

9. In the appeal preferred before the Appellate Commissioner by the assessee by common order dated 21/3/2013, the Appellate Commissioner disposed of the appeals rejecting the challenge made by the assessee with regard to initiation of proceedings under Section 153C of the Act, while granting relief against disallowances made by the Assessing Officer by following the earlier order

THE COMMISSIONER OF INCOME-TAX vs. M/S DAVANGERE DISTRICT CENTRAL CO-OPERATIVE BANK

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

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

disallowed Rs.17,38,222 under section 40(a)(ia) by considering the available materials on record as well as provisions of the Act"?" 4. The learned counsel appearing for the appellants- revenue has fairly submitted before this court that so far as substantial question Nos.3 & 4 are concerned, he is not pressing for the same. 5. Learned counsel

MANIPAL HEALTH SYSTEMS

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

Bench: ARAVIND KUMAR

disallowed Rs.17,38,222 under section 40(a)(ia) by considering the available materials on record as well as provisions of the Act"?" 4. The learned counsel appearing for the appellants- revenue has fairly submitted before this court that so far as substantial question Nos.3 & 4 are concerned, he is not pressing for the same. 5. Learned counsel

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S. DAVANGERE DISTRICT CENTRAL CO-OP BANK LTD.,

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

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

disallowances were mainly in respect of Provisions for NPA's, RO & SAO's cost, accrued interest on NPA's, addition on account of Bank Reconciliation Provisions. Assessee preferred an appeal before the CIT(A). The CIT(A) partly allowed the appeal. As such Revenue and Assessee both preferred the appeal before the Tribunal. The Tribunal has partly allowed both

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

disallowance made under Section 40[a][ia] for non deduction of TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

disallowance made under Section 40[a][ia] for non deduction of TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating

THE PR. COMMISIONER INCOME TAX vs. M/S. GMR INFRASTRUCTURE LTD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

disallowance made under Section 40[a][ia] for non deduction of TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating