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48 results for “disallowance”+ Section 92clear

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Key Topics

Section 26089Section 260A31Disallowance21Addition to Income15Section 115J14Section 14A12Section 143(3)10Section 40A(3)9Section 5(1)8

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)

Disallowance under section 40(a)(i): Particulars Disputed Income Disputed tax [i.e., tax @ 33.99% on disputed income] Payable under DTVST Act @s 50% of tax As per Petitioner 42,92

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

In the result, I pass the following:-

WP/10551/2022HC Karnataka18 Nov 2022

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

Section 5(1)

Disallowance under section 40(a)(i): Particulars Disputed Income Disputed tax [i.e., tax @ 33.99% on disputed income] Payable under DTVST Act @s 50% of tax As per Petitioner 42,92

Showing 1–20 of 48 · Page 1 of 3

Section 2636
Transfer Pricing6
Deduction6

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S. TE CONNECTIVITY INDIA PVT. LTD.,

Accordingly dispose of the appeal as allowed

ITA/53/2024HC Karnataka05 Jun 2025

Bench: ACTING CHIEF JUSTICE,S RACHAIAH

Section 143(2)Section 143(3)Section 144C(13)Section 260ASection 263Section 40

disallowance and this is clearly contrary to law. 6. In view of the above discussion, the assessee's reply cannot be accepted. 7. In Cochin International Airport Ltd. (92 taxmann.com 277), the Hon'ble ITAT Cochin have explained the provisions of section

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

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

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

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

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

disallowance of Rs.7,97,70,326/- as interest on capital attributable to 20 capital work in progress relying on proviso Section 36(1)(iii) of the Act. The assessee is in the business of manufacture and trade in coffee and allied products. It has more than 1000 coffee shops with brand name 'Café Coffee Day'. The assessee had capital work

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

disallowance of Rs.7,97,70,326/- as interest on capital attributable to 20 capital work in progress relying on proviso Section 36(1)(iii) of the Act. The assessee is in the business of manufacture and trade in coffee and allied products. It has more than 1000 coffee shops with brand name 'Café Coffee Day'. The assessee had capital work

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

disallowance of Rs.7,97,70,326/- as interest on capital attributable to 20 capital work in progress relying on proviso Section 36(1)(iii) of the Act. The assessee is in the business of manufacture and trade in coffee and allied products. It has more than 1000 coffee shops with brand name 'Café Coffee Day'. The assessee had capital work

THE PR. COMMISSIONER OF INCOME TAX, vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD.,

ITA/702/2018HC Karnataka14 Dec 2021

Bench: S.SUJATHA,S VISHWAJITH SHETTY

Section 260

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

M/S DELHI INTERNATIONAL vs. THE PRINCIPAL COMMISSIONER

ITA/514/2018HC Karnataka14 Dec 2021

Bench: S.SUJATHA,S VISHWAJITH SHETTY

Section 260

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

THE PR. COMMISSIONER OF INCOME TAX, vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD.

ITA/701/2018HC Karnataka14 Dec 2021

Bench: S.SUJATHA,S VISHWAJITH SHETTY

Section 260

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

M/S DELHI INTERNATIONAL AIRPORT LTD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX

ITA/515/2018HC Karnataka14 Dec 2021

Bench: S.SUJATHA,S VISHWAJITH SHETTY

Section 260

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

THE PR. COMMISSIONER OF INCOME TAX, vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD.,

ITA/703/2018HC Karnataka14 Dec 2021

Bench: S.SUJATHA,S VISHWAJITH SHETTY

Section 260

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

M/S DELHI INTERNATIONAL AIRPORT LTD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX

ITA/513/2018HC Karnataka14 Dec 2021

Bench: S.SUJATHA,S VISHWAJITH SHETTY

Section 260

disallowance under Section 40(a)(ia) of the Act. - 18 - 15. The arguments advanced by the learned counsel for the appellant that this order of the Tribunal suffers from infirmity, for the reason, that the net proceeds of PSF-(SC) was held by it in fiduciary capacity and collected the same on behalf of Government of India which

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

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

ITA/50/2019HC Karnataka26 Mar 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 143(1)Section 14ASection 14WSection 260Section 260A

disallowance under Section 14A of the Act of Rs.4,92,78,160/- and under Rule 8D(2)(iii) of the Income

PR. COMMISSIONER OF vs. M/S STERLING DEVELOPERS

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

ITA/49/2019HC Karnataka10 Mar 2021

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

Section 143(1)Section 14ASection 14WSection 260Section 260A

disallowance under Section 14A of the Act of Rs.4,92,78,160/- and under Rule 8D(2)(iii) of the Income

THE COMMISSIONER OF INCOME-TAX vs. M/S. KINGFISHER FINVEST INDIA LTD

In the result, the appeals filed by the Revenue

ITA/100/2015HC Karnataka29 Sept 2020

Bench: ALOK ARADHE(ACJ),M.I.ARUN

Section 14ASection 260

disallowed the interest expenditure of Rs.57,92,44,082/- under Section 14A of the Act read with Rule 8D of the Income

M/S.M K AGROTECH PRIVATE LTD vs. THE ADDL COMMISSIONER OF INCOME TAX

The appeal is allowed

ITA/83/2010HC Karnataka29 Nov 2018

Bench: The Hon'Ble Mr. Justice Ravi Malimath

Section 143(2)Section 260ASection 40ASection 40A(3)Section 6

disallow the deduction claimed as expenditure in respect of which payment is not made by crossed cheque or crossed bank draft. The payment by crossed cheque or crossed bank draft is insisted on to enable the assessing authority to ascertain whether the payment was genuine or whether it was out of the income from undisclosed sources. The terms of Section

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

THE COMMISSIONER OF INCOME TAX vs. SYNDICATE BANK

ITA/97/2010HC Karnataka17 Jan 2020

Bench: ALOK ARADHE,RAVI V HOSMANI

Section 115JSection 143(1)Section 14ASection 260

92,53,033/- as book profit under Section 115JA of the Act. The return was processed under Section 143(1) of the Act resulting in refund of Rs.10,62,37,618/-. Thereafter a notice was issued under Section 143(2) of the Act. The Assessing Officer by an order dated 31.12.2002 inter alia held that since exempted dividend does