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

section 10 applies. The Ld. AO has not made any disallowance of expenditure debited in the profit and loss account as prepared under the Companies Act as neither any direct expenses nor any interest has been disallowed under Rule 8D of the IT Rules and the disallowance has been made only under clause (iii) of Rule

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

10 consecutive years from the year in\nwhich such business will be operational or ready for operation. Therefore,\nthe disallowance proposed here to the extent of Rs.77,70,880/- and added\nback to the returned income of the assessee.”\n6.2 The Ld. CIT(A) after considering the facts of the case and\nsubmissions of the assessee gave his findings

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

disallowed\nunder Rule 8D of the IT Rules and the disallowance has been made only\nunder clause (iii) of Rule 8D as per the formulae mentioned therein and\nthe same is not to be considered for the purpose of MAT and the\naddition, if any, made to the book profit on account of disallowance u/s\nPage 43\nITA

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

10 consecutive years from the year in\nwhich such business will be operational or ready for operation. Therefore,\nthe disallowance proposed here to the extent of Rs.77,70,880/- and added\nback to the returned income of the assessee.\"\n6.2 The Ld. CIT(A) after considering the facts of the case and\nsubmissions of the assessee gave his findings

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

section 10\napplies. The Ld. AO has not made any disallowance of expenditure\ndebited in the profit and loss account as prepared under the Companies\nAct as neither any direct expenses nor any interest has been disallowed\nunder Rule 8D of the IT Rules and the disallowance has been made only\nunder clause (iii) of Rule

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

section 10\napplies. The Ld. AO has not made any disallowance of expenditure\ndebited in the profit and loss account as prepared under the Companies\nAct as neither any direct expenses nor any interest has been disallowed\nunder Rule 8D of the IT Rules and the disallowance has been made only\nunder clause (iii) of Rule

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

46,72,000/- & Rs. 58,78,000/- u/s 14A of the Act towards expenditure related to exempt income. Ld. AO examined the quantification of the said disallowance but was not satisfied and observed that the company managed its investment portfolio by using the common establishment/infrastructure and therefore, it is not possible to justify the working adopted for computing the disallowance

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

46,72,000/- & Rs. 58,78,000/- u/s 14A of the Act towards expenditure related to exempt income. Ld. AO examined the quantification of the said disallowance but was not satisfied and observed that the company managed its investment portfolio by using the common establishment/infrastructure and therefore, it is not possible to justify the working adopted for computing the disallowance

DCIT EXEMPTIONS CIRCLE 1(1), KOLKATA vs. B P PODDAR FOUNDATION FOR EDUCATION, KOLKATA

In the result, appeal of the revenue stands dismissed

Bench: Shri George Mathan & Shri Sanjay Awasthiआयकर अपील सं /Ita No.637/Kol/2025 (निर्धारण वर्ा /Assessment Year. : 2022-2023) Dcit Exemptions Circle-1(1), Vs B P Poddar Foundation For Education, Kolkata 18, Poddar Court, Rabindra Sarani, Kolkata-700071 Pan No. :Aaatb 5418 M (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) रधजस्व की ओर से /Revenue By : Shri Raja Sengupta, Cit-Dr निर्धाररती की ओर से /Assessee By : Shri S.K.Tulsiayn, Advocate सुनवाई की तारीख / Date Of Hearing : 18/06/2025 घोषणा की तारीख/Date Of Pronouncement : 23/06/2025 आदेश / O R D E R Per George Mathan, Jm : This Is An Appeal Filed By The Revenue Against The Order Dated 23.12.2024, Passed By The Ld. Addl./Jcit(A)-9, Mumbai For A.Y.2022- 2023. 2. Shri Raja Sengupta, Cit-Dr Appeared On Behalf Of The Revenue & Shri S.K.Tulsiyan, Advocate Appeared On Behalf Of The Assessee. 3. The Appeal Filed By The Revenue Is Delayed By 26 Days For Which The Revenue Has Filed The Necessary Condonation Petition. The Reasons Given Are Plausible & Same Are Accepted. Accordingly, The Delay Is Condoned & The Appeal Is Admitted For Hearing. 4. At The Time Of Hearing, Ld.Ar Has Filed His Written Submission Which Read As Under :- Before The Income Tax Appellate Tribunal, Kolkata "A" Bench. Kolkata.

46,390/- was raised on the Appellant Trust. Copy of the Response of the Assesee Trust along with the Intimation u/s 143(1) dated 04/04/2023 is enclosed as under: "Annexure E: Response of Appellant Trust" - Pg 52 "Annexure F: Intimation u/s 143(1) dated 04/04/2023 for the A.Y.2022-23."-Pgs 53 -62 2.3. In appeal, the Ld. CIT(A) after considering

MAYURAKSHI GRAMIN BANK EMPLOYEES PROVIDENT FUND, PBGB REGIONAL, ,SURI, BIRBHUM vs. D.C.I.T., CIRCLE - 3, SURI, SURI, BIRBHUM

In the result, the appeal filed by the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1159/Kol/2024 Assessment Year: 2015-2016 Mayurakshi Gramin Bank Employees Provident Fund,………………………………………Appellant Pbgb Regional, Suri Birbhum-731101, West Bengal [Pan:Aabtm2580Q] -Vs.- Deputy Commissioner Of Income Tax,……...Respondent Circle-3, Suri, Aayakar Bhawan, Lalkuthipara, Suri, Birbhum-731101, W.B. Appearances By: Shri S.K. Tulsian, Advocate & Ms. Lata Goyal, Ca, Appeared On Behalf Of The Assessee Shri Subhro Das, Addl. Cit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 23, 2025 Date Of Pronouncing The Order: January 31, 2025 O R D E R

disallowed in assessment year 2013-14. The said issue came up before the ITAT for assessment year 2013-14, wherein the assesese raised alternative plea of its correct taxable income for the first time and, therefore, the matter was restored back to the file of ld. Assessing Officer. The ld. Assessing Officer did not accept the plea of the assessee

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

46,36,000/- and disallowance u/s 14A read with Rule 8D of the IT Rules amounting to ₹6,07,60,388/-. 04. Aggrieved by the said order assessee preferred the appeal before the ld. CIT (A), wherein the appeal of the assessee has been partly allowed. 05. Being aggrieved and dissatisfied, the Revenue preferred an appeal before

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

EIH LIMITED,KOLKATA vs. D.C.I.T., INCOME TAX DEPARTMENT, NFAC, DELHI, KOLKATA

In the result, both the appeals of the assessee are partly allowed

Bench: SHRI RAJPAL YADAV, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

10,32,739/- on this account. However, the Ld. AO applied Rule 8D of the I.T. Rules and disallowed the impugned amount. The Ld. AR pointed out that in the appellant’s own case for AY 2013-14 (ITA No. 2225/Kol/2017, para 5.3 of this order) it has been held that the disallowance u/s 14A of the Act, r.w. Rule

EIH LIMITED ,KOLKATA vs. DCIT, NFAC, DELHI

In the result, both the appeals of the assessee are partly allowed

Bench: SHRI RAJPAL YADAV, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

10,32,739/- on this account. However, the Ld. AO applied Rule 8D of the I.T. Rules and disallowed the impugned amount. The Ld. AR pointed out that in the appellant’s own case for AY 2013-14 (ITA No. 2225/Kol/2017, para 5.3 of this order) it has been held that the disallowance u/s 14A of the Act, r.w. Rule

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

section 10\napplies. The Ld. AO has not made any disallowance of expenditure\ndebited in the profit and loss account as prepared under the Companies\nAct as neither any direct expenses nor any interest has been disallowed\nunder Rule 8D of the IT Rules and the disallowance has been made only\nunder clause (iii) of Rule

DCIT(EXEMPTION), CIRCLE 1(1) KOLKATA, KOLKATA vs. HOOGHLY RIVER BRIDGE COMMISSIONER, KOLKATA

In the result, both the appeals of the revenue are partly allowed

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. Nos.1147 & 1148/Kol/2024 Assessment Years: 2012-11 & 2013-14

disallowed the expenditure incurred on infrastructure development work, treating the same as capital in nature. AYs 2012-13 & 2013-14 5. The Ld. counsel, at this stage, stated that initially, when the assessee received grant for the first time before the year 1992, the same was booked as loan in the books of account of the assessee and thereafter

DCIT(EXEMPTION), CIRCLE-1(1), KOLKATA, KOLKATA vs. HOOGHLY RIVER BRIDGE COMMISSIONER, KOLKATA

In the result, both the appeals of the revenue are partly allowed

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. Nos.1147 & 1148/Kol/2024 Assessment Years: 2012-11 & 2013-14

disallowed the expenditure incurred on infrastructure development work, treating the same as capital in nature. AYs 2012-13 & 2013-14 5. The Ld. counsel, at this stage, stated that initially, when the assessee received grant for the first time before the year 1992, the same was booked as loan in the books of account of the assessee and thereafter