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

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Key Topics

Addition to Income72Section 143(3)49Section 14743Disallowance43Section 153A42Section 153C42Section 6842Section 14838Section 13234

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

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

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

Showing 1–20 of 649 · Page 1 of 33

...
Section 14A30
Reopening of Assessment22
Long Term Capital Gains21

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

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

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

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)

iii. Whether on facts and in the circumstances of the case, the Tribunal was right in law in allowing a loss of Rs. 16,84,481/-on revaluation of on account of loss permanent category investments, even though the same is a notional loss and inadmissible in law? iv. on Whether the facts and in the circumstances of the case

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)

iii. Whether on facts and in the circumstances of the case, the Tribunal was right in law in allowing a loss of Rs. 16,84,481/-on revaluation of on account of loss permanent category investments, even though the same is a notional loss and inadmissible in law? iv. on Whether the facts and in the circumstances of the case

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(1)(iii

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)

iii) of sub-section (3) of section\n194A of the Income-tax Act, 1961 (43 of 1961), the Central Government\nhereby notify with effect from the 19th July, 1969, the following banks for\nthe purposes of the said sub-clause:-\n1. Indian Overseas Bank, 151, Mount Road, Madras-\n2. Indian Bank, Indian Chamber Building, Madras-1.\n3. Allahabad Bank

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)

iii) of sub-section (3) of section\n194A of the Income-tax Act, 1961 (43 of 1961), the Central Government\nhereby notify with effect from the 19th July, 1969, the following banks for\nthe purposes of the said sub-clause:-\n1. Indian Overseas Bank, 151, Mount Road, Madras-\n2. Indian Bank, Indian Chamber Building, Madras-1.\n3. Allahabad Bank

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)

iii) of sub-section (3) of section\n194A of the Income-tax Act, 1961 (43 of 1961), the Central Government\nhereby notify with effect from the 19th July, 1969, the following banks for\nthe purposes of the said sub-clause:-\n1. Indian Overseas Bank, 151, Mount Road, Madras-\n2. Indian Bank, Indian Chamber Building, Madras-1.\n3. Allahabad Bank

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)

iii) of sub-section (3) of section\n194A of the Income-tax Act, 1961 (43 of 1961), the Central Government\nhereby notify with effect from the 19th July, 1969, the following banks for\nthe purposes of the said sub-clause:-\n1. Indian Overseas Bank, 151, Mount Road, Madras-\n2. Indian Bank, Indian Chamber Building, Madras-1.\n3. Allahabad Bank

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)(iii

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

iii & iv. xx xx 17. As already stated, learned CIT – A passed a consolidated order for assessment year 2014–15 to assessment year 2020–21. The effect of the above order is as under: assessment addition made by the AO addition year on account of bogus confirmed by the purchases learned

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

iii & iv. xx xx 17. As already stated, learned CIT – A passed a consolidated order for assessment year 2014–15 to assessment year 2020–21. The effect of the above order is as under: assessment addition made by the AO addition year on account of bogus confirmed by the purchases learned

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

iii & iv. xx xx 17. As already stated, learned CIT – A passed a consolidated order for assessment year 2014–15 to assessment year 2020–21. The effect of the above order is as under: assessment addition made by the AO addition year on account of bogus confirmed by the purchases learned

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

iii & iv. xx xx 17. As already stated, learned CIT – A passed a consolidated order for assessment year 2014–15 to assessment year 2020–21. The effect of the above order is as under: assessment addition made by the AO addition year on account of bogus confirmed by the purchases learned

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

iii & iv. xx xx 17. As already stated, learned CIT – A passed a consolidated order for assessment year 2014–15 to assessment year 2020–21. The effect of the above order is as under: assessment addition made by the AO addition year on account of bogus confirmed by the purchases learned

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

iii & iv. xx xx 17. As already stated, learned CIT – A passed a consolidated order for assessment year 2014–15 to assessment year 2020–21. The effect of the above order is as under: assessment addition made by the AO addition year on account of bogus confirmed by the purchases learned

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

iii & iv. xx xx 17. As already stated, learned CIT – A passed a consolidated order for assessment year 2014–15 to assessment year 2020–21. The effect of the above order is as under: assessment addition made by the AO addition year on account of bogus confirmed by the purchases learned

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(1), MUMBAI vs. M/S SKYWAY INFRA PROJECTS PRIVATE LIMITED, MUMBAI

In the result, cross objections of the assessee are dismissed, cross objections of the assessee are dismissed, cross objections of the assessee are dismissed, whereas appeals of the revenue are par...

ITA 2665/MUM/2022[2013-14]Status: HeardITAT Mumbai28 Feb 2023AY 2013-14

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2013-14 & Assessment Year: 2014-15 & Assessment Year: 2015-16 & Assessment Year: 2016-17 & Assessment Year: 2017-18 & Assessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21

1,33,78,824 35,24,070 Enterprises Vimalnath 36,10,050 17,62,298 19,40,968 14,13,598 58,81,762 58,81,762 35,81,809 Associates Divya 31,01,660 23,04,423 22,59,068 16,87,727 65,10,522 65,10,522 30,24,057 Corporation Total