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964 results for “bogus purchases”+ Section 36(1)clear

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Key Topics

Addition to Income73Section 143(3)50Section 153C47Section 153A45Disallowance44Section 14841Section 6840Section 14738Section 14A31

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

ITA 1548/MUM/2023[2018-2019]Status: DisposedITAT Mumbai30 Jan 2026AY 2018-2019
For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

section 36(1)(iii) of the Act observed as\nfollows: -\n\"16 We have heard rival submission of the parties on the issue in dispute and\nperused the relevant material on record. As far as argument of rule of\nconsistency is concerned, the Ld. CIT(A) has rejected the contention of the\nassessee following the decision

BANK OF INDIA,MUMBAI vs. ACIT-2(1)(2), MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Showing 1–20 of 964 · Page 1 of 49

...
Section 10(38)26
Bogus Purchases24
Long Term Capital Gains20
ITA 1451/MUM/2023[2016-17]Status: DisposedITAT Mumbai30 Jan 2026AY 2016-17

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

section 143(3) of the Act, disagreed with the submissions of the assessee and held that perpetual bonds are in the nature of debt instruments with no maturity date. Only the issuing company can buy back the bonds from the investors. Therefore, it was held these bonds are perpetual in nature. Since in the case of perpetual bonds, the investor

BANK OF INDIA,MUMBAI vs. THE NATIONAL FACELESS ASSESSMENT CENTRE, MUMBAI

ITA 1452/MUM/2023[2018-19]Status: DisposedITAT Mumbai30 Jan 2026AY 2018-19
For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

1 to 160\nof the paper book filed by the assessee. It is noticed that assessing officer has\nspecifically asked the assessee vide notice dated 24.11.2016 to provide the detail\nof income tax reversal on distribution of unsecured perpetual securities. In this\nregard assessee has given detailed submission vide letter dated 16.12.2016\nstating that it has issued 11.4% unsecured perpetual

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

ITA 1547/MUM/2023[2016-2017]Status: DisposedITAT Mumbai30 Jan 2026AY 2016-2017

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

section 143(3) of the Act, disagreed with the submissions of the assessee and held that perpetual bonds are in the nature of debt instruments with no maturity date. Only the issuing company can buy back the bonds from the investors. Therefore, it was held these bonds are perpetual in nature. Since in the case of perpetual bonds, the investor

DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

ITA 684/BANG/2015[2011-12]Status: DisposedITAT Mumbai03 Nov 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel
Section 2Section 250Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 41(1)

purchase during the year?" 3. Question No. i arises out of the judgment of the Income Tax Appellate Tribunal in remanding the issue before the Assessing Officer for proper verification of facts. The record would suggest that the assessee, in view of its success before the Tribunal on the issue of disallowance of interest credited to Interest Suspense Account

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

ITA 661/BANG/2015[2011-12]Status: DisposedITAT Mumbai03 Nov 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel
Section 2Section 250Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 41(1)

purchase during the year?" 3. Question No. i arises out of the judgment of the Income Tax Appellate Tribunal in remanding the issue before the Assessing Officer for proper verification of facts. The record would suggest that the assessee, in view of its success before the Tribunal on the issue of disallowance of interest credited to Interest Suspense Account

DCIT-3(4), MUMBAI vs. M/S UNION OF BANK OF INDIA, MUMBAI

ITA 1818/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Sept 2024AY 2017-18
Section 115JSection 14ASection 36(1)(viii)

section 36(1)(viii)\nhad come up before the Tribunal in ITA NO.1627/Mum/2014(supra). The Tribunal\nvide order dated 08/01/2016 has remitted the issue back to the file of Assessing\nOfficer to allow the deduction based on actual interest earned from eligible advances\nafter deducting cost and expenses on reasonable basis. The CIT(A) has restored the\nissue to Assessing

UNION BANK OF INDIA,MUMBAI vs. DCIT, CIR - (LTU)-2, MUMBAI

ITA 1440/MUM/2023[2016-17]Status: DisposedITAT Mumbai27 Sept 2024AY 2016-17
Section 115JSection 14ASection 36(1)(viii)

section 36(1)(viii)\nhad come up before the Tribunal in ITA NO.1627/Mum/2014(supra). The Tribunal\nvide order dated 08/01/2016 has remitted the issue back to the file of Assessing\nOfficer to allow the deduction based on actual interest earned from eligible advances\nafter deducting cost and expenses on reasonable basis. The CIT(A) has restored the\nissue to Assessing

INCOME TAX OFFICER, KALYAN vs. J D ELECTRIC WORKS, KALYAN

In the result, the appeal of the Revenue is dismissed

ITA 4521/MUM/2023[2009-10]Status: DisposedITAT Mumbai06 May 2024AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2009-10

For Appellant: Mr. Shashank MehtaFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 1Section 148

section 143(3) r.w.s. 147 of the ) r.w.s. 147 of the Act. On further appeal On further appeal, the ld CIT(A) deleted the addition. Aggrieved, , the ld CIT(A) deleted the addition. Aggrieved, the Revenue is in appeal raising grounds reproduced above. the Revenue is in appeal raising grounds reproduced above. the Revenue is in appeal raising grounds reproduced

DCIT-3(4), MUMBAI vs. M/S UNION OF BANK OF INDIA, MUMBAI

ITA 1819/MUM/2023[2016-17]Status: DisposedITAT Mumbai27 Sept 2024AY 2016-17
Section 115JSection 14ASection 36(1)(viii)

section 36(1)(viii)\nhad come up before the Tribunal in ITA NO.1627/Mum/2014(supra). The Tribunal\nvide order dated 08/01/2016 has remitted the issue back to the file of Assessing\nOfficer to allow the deduction based on actual interest earned from eligible advances\nafter deducting cost and expenses on reasonable basis. The CIT(A) has restored the\nissue to Assessing

UNION BANK OF INDIA,MUMBAI vs. DCIT, CIR - (LTU)-2, MUMBAI

ITA 1441/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Sept 2024AY 2017-18
Section 115JSection 14ASection 36(1)(viii)

section 36(1)(viii)\nhad come up before the Tribunal in ITA NO.1627/Mum/2014(supra). The Tribunal\nvide order dated 08/01/2016 has remitted the issue back to the file of Assessing\nOfficer to allow the deduction based on actual interest earned from eligible advances\nafter deducting cost and expenses on reasonable basis. The CIT(A) has restored the\nissue to Assessing

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

ITA 7066/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Jan 2026AY 2016-17

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

36. Thus, the penalty proceedings were initiated for ‘concealing the particulars of income and for furnishing inaccurate particulars of taxable income’. Though, Section 270A of the Act was mentioned there was no reference to under-reporting or misreporting of income. In the subsequent notice dated 18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

ITA 7067/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

36. Thus, the penalty proceedings were initiated for ‘concealing the particulars of income and for furnishing inaccurate particulars of taxable income’. Though, Section 270A of the Act was mentioned there was no reference to under-reporting or misreporting of income. In the subsequent notice dated 18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing

DCIT 3(1)(1),MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD, MUMBAI

ITA 7065/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Jan 2026AY 2015-16

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

36. Thus, the penalty proceedings were initiated for ‘concealing the particulars of income and for furnishing inaccurate particulars of taxable income’. Though, Section 270A of the Act was mentioned there was no reference to under-reporting or misreporting of income. In the subsequent notice dated 18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

ITA 7070/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Jan 2026AY 2020-21

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

36. Thus, the penalty proceedings were initiated for ‘concealing the particulars of income and for furnishing inaccurate particulars of taxable income’. Though, Section 270A of the Act was mentioned there was no reference to under-reporting or misreporting of income. In the subsequent notice dated 18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

ITA 7064/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Jan 2026AY 2014-15

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

36. Thus, the penalty proceedings were initiated for ‘concealing the particulars of income and for furnishing inaccurate particulars of taxable income’. Though, Section 270A of the Act was mentioned there was no reference to under-reporting or misreporting of income. In the subsequent notice dated 18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

ITA 7068/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

36. Thus, the penalty proceedings were initiated for ‘concealing the particulars of income and for furnishing inaccurate particulars of taxable income’. Though, Section 270A of the Act was mentioned there was no reference to under-reporting or misreporting of income. In the subsequent notice dated 18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

ITA 7069/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

36. Thus, the penalty proceedings were initiated for ‘concealing the particulars of income and for furnishing inaccurate particulars of taxable income’. Though, Section 270A of the Act was mentioned there was no reference to under-reporting or misreporting of income. In the subsequent notice dated 18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing

BHOOMI CONSTRUCTION ,MUMBAI vs. ACIT, CENTRAL CIRCLE-2, MUMBAI

Appeals are dismissed

ITA 1782/MUM/2023[2010-2011]Status: DisposedITAT Mumbai19 Oct 2023AY 2010-2011
For Appellant: Shri Satyaprakash SinghFor Respondent: Shri S.K. Jain
Section 143(3)Section 36(1)(iii)

bogus purchases to 12.5% of the purchase amount while confirming the disallowance of INR 13,17,884/- made by the Assessing Officer under Section 36(1

INCOME TAX OFFICER-19(2)(2), MUMBAI vs. MUKESH HIRACHAND SANGHVI, MUMBAI

In the result, the appeal filed by the revenue stands\ndismissed

ITA 3510/MUM/2023[2009-10]Status: DisposedITAT Mumbai11 Jun 2024AY 2009-10
Section 133(6)Section 143(3)Section 145(3)Section 147Section 148Section 250Section 263Section 271(1)(C)Section 36(1)(iii)

bogus purchases to 5% was reasonable given the nature of the business, and that the deletion of interest disallowance was justified as the advances were made for commercial expediency. The revenue's appeal was dismissed.", "result": "Dismissed", "sections": ["Section 147", "Section 148", "Section 145(3)", "Section 271(1)(C)", "Section 36