D.C.I.T CIR - 10(1), KOLKATA vs. M/S EUREKA FORBS LTD, KOLKATA

disallowing sub-section (2) and (3) thereof which only specify the\nmode of computation of expenditure relatable to income which is not\nincludible in total income. Further, once clause (f) of Explanation (1)\nsection 115JB of the Act specifies that the book profit as shown in the\nstatement of profit and loss is to be increased by the amount

RITA GUPTA,KOLKATA vs. DCIT, CEN. CIR.2(2), KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

disallowing the claim of set off was upheld by the successive appellate authorities on. On reference u/s 256(1) of the Act, the Hon’ble High Court held that Section 10(27) of the Act excluded term only the income derived from a business of livestock breeding or poultry or dairy farming. The said section did not exclude the business

D.C.I.T CIR - 10(1), KOLKATA vs. M/S EUREKA FORBS LTD, KOLKATA

In the result, the appeal filed by the Revenue in ITA No

disallowing sub-section (2) and (3) thereof which only specify the\nmode of computation of expenditure relatable to income which is not\nincludible in total income. Further, once clause (f) of Explanation (1)\nsection 115JB of the Act specifies that the book profit as shown in the\nstatement of profit and loss is to be increased by the amount

D.C.I.T CIR - 10(1), KOLKATA vs. M/S EUREKA FORBS LTD, KOLKATA

In the result, the appeal filed by the Revenue in ITA No

disallowing sub-section (2) and (3) thereof which only specify the\nmode of computation of expenditure relatable to income which is not\nincludible in total income. Further, once clause (f) of Explanation (1)\nsection 115JB of the Act specifies that the book profit as shown in the\nstatement of profit and loss is to be increased by the amount

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

10(34) of the Income Tax Act and\naccordingly is not satisfactory in accordance with the provision of 14A of the\nIncome Tax Act.\nThe Jurisdictional Calcutta High Court in the case of Dhanuka & Sons Vs\nCIT (339 1TR 319), disallowance under section 14A can indeed be made. In\nDhanuka's case (supra), Their Lordships have, inter alia, observed

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

10(34) of the Income Tax Act and accordingly is not satisfactory in accordance with the provision of 14A of the Income Tax Act. The Jurisdictional Calcutta High Court in the case of Dhanuka & Sons Vs CIT (339 ITR 319), disallowance under section 14A can indeed be made. In Dhanuka's case (supra), Their Lordships have, inter alia, observed

D.C.I.T CIR - 10(1), KOLKATA vs. M/S EUREKA FORBS LTD, KOLKATA

disallowing sub-section (2) and (3) thereof which only specify the\nmode of computation of expenditure relatable to income which is not\nincludible in total income. Further, once clause (f) of Explanation (1)\nsection 115JB of the Act specifies that the book profit as shown in the\nstatement of profit and loss is to be increased by the amount

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

In the result, the appeals filed by the assessee in ITA Nos

10(34) of the Income Tax Act and\naccordingly is not satisfactory in accordance with the provision of 14A of the\nIncome Tax Act.\nThe Jurisdictional Calcutta High Court in the case of Dhanuka & Sons Vs\nCIT (339 1TR 319), disallowance under section 14A can indeed be made. In\nDhanuka's case (supra), Their Lordships have, inter alia, observed

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

10(34) of the Income Tax Act and\naccordingly is not satisfactory in accordance with the provision of 14A of the\nIncome Tax Act.\nThe Jurisdictional Calcutta High Court in the case of Dhanuka & Sons Vs\nCIT (339 1TR 319), disallowance under section 14A can indeed be made. In\nDhanuka's case (supra), Their Lordships have, inter alia, observed

M/S TATA GLOBAL BEVERAGES LIMITED,KOLKATA vs. THE DCIT, CIRCLE-4(2), KOLKATA, KOLKATA

In the result, the appeals filed by the assessee for AY 2012-

Bench: Dr. Manish Borad & Sonjoy Sarma

13 December 2017] is enclosed at pages 29-30 of the CTCL. The Appellant has always disallowed the direct expenses incurred by it for the purposes of earning exempt income. Additionally, the Appellant also suo motu disallows a portion of the expenses pertaining to managerial/staff time spent on investments and/or portfolio related work. The computation of the disallowance made

M/S TATA GLOBAL BEVERAGES LIMITED,KOLKATA vs. THE DCIT, CIRCLE-4(2), KOLKATA, KOLKATA

In the result, the appeals filed by the assessee for AY 2012-

Bench: Dr. Manish Borad & Sonjoy Sarma

13 December 2017] is enclosed at pages 29-30 of the CTCL. The Appellant has always disallowed the direct expenses incurred by it for the purposes of earning exempt income. Additionally, the Appellant also suo motu disallows a portion of the expenses pertaining to managerial/staff time spent on investments and/or portfolio related work. The computation of the disallowance made

M/S. COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

section 115JB of the\nAct is a self-contained code and only the disallowances mentioned in\nthe explanation could have been made. Further, clause (f) of\nExplanation 1 to section 115JB of the Act refers to the amount or\namounts of expenditure relatable to any income to which section 10\napplies. The Ld. AO has not made any disallowance

COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

section 115JB of the\nAct is a self-contained code and only the disallowances mentioned in\nthe explanation could have been made. Further, clause (f) of\nExplanation 1 to section 115JB of the Act refers to the amount or\namounts of expenditure relatable to any income to which section 10\napplies. The Ld. AO has not made any disallowance

DCIT,CC-2(2), AAYAKAR BHAWAN POORVA vs. ARYAN MINING AND TRADING CORPORATION LIMITED, HIDE LANE

In the result, the appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Choubey, Jm & Shri Rakesh Mishra, Am Aryan Mining & Trading Dcit, Central Circle-2(2), Corporation Limited, 110, Shantipally, 4 Th Floor, P-1, Hide Lane, Johar Building, Vs. Pin-700073, West Bengal Pin-700073, West Bengal (Respondent) (Appellant) Pan No. Aadca7247B Assessee By : Shri A.K. Tulsian, Ar Revenue By : Shri Praveen Kishore, Dr Date Of Hearing: 11.06.2025 Date Of Pronouncement: 23.06.2025

13. I have perused the material placed before me. It is an admitted fact that the Hon’ble Apex Court has categorically held that book profit is to be considered under section 115JB as per the Companies (Schedule 3) Act and hence any disallowance is not permitted to be added in the calculation of book profit under section 115JB

SENBO ENGINEERING LIMITED,KOLKATA vs. DCIT, CIR-11, KOLKATA. , KOLKATA

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Years: 2007-08 Senbo Engineering Limited, Deputy Commissioner Of 87, Lenin Sarani, Vs Income Tax, Circle-11, Kolkata - 700013 Kolkata - 700013 (Pan: Aadcs6138B) (Appellant) (Respondent)

13. As per the direction of the Tribunal given by its order dated 21.07.2014, op- portunity was given by the Id. CIT(Appeals) to the Assessing Officer in the second round and availing the same, the Assessing Officer submitted a remand report putting forth the case of the Revenue on the issue relating to the assessee's claim for deduction

APEEJAY PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 8(1), KOLKATA, KOLKATA

In the result, appeals of the assessee for Assessment Year 2013-14

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 116/Kol/2023 Assessment Year: 2013-14

section 14A of the Act confirmed by the ld. CIT(A). We notice that the impugned disallowance consists of two amounts, one is the interest disallowance under Rule 8D(2)(ii) and other is expenditure disallowance under Rule 8D(2)(iii) r.w.s. 14A of the Act. So far as the interest disallowance is concerned, the ld. Counsel for the assessee

APEEJAY PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 8(1), KOLKATA, KOLKATA

In the result, appeals of the assessee for Assessment Year 2013-14

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 116/Kol/2023 Assessment Year: 2013-14

section 14A of the Act confirmed by the ld. CIT(A). We notice that the impugned disallowance consists of two amounts, one is the interest disallowance under Rule 8D(2)(ii) and other is expenditure disallowance under Rule 8D(2)(iii) r.w.s. 14A of the Act. So far as the interest disallowance is concerned, the ld. Counsel for the assessee

APEEJAY PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 8(1), KOLKATA, KOLKATA

In the result, appeals of the assessee for Assessment Year 2013-14

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 116/Kol/2023 Assessment Year: 2013-14

section 14A of the Act confirmed by the ld. CIT(A). We notice that the impugned disallowance consists of two amounts, one is the interest disallowance under Rule 8D(2)(ii) and other is expenditure disallowance under Rule 8D(2)(iii) r.w.s. 14A of the Act. So far as the interest disallowance is concerned, the ld. Counsel for the assessee