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

Sorted by relevance

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Key Topics

Section 14A44Depreciation11Disallowance11Section 115J9Section 36(1)(viia)8Section 2507Addition to Income7Section 36(1)(viii)6Deduction6Section 104Section 324Section 904

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

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

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)

viia) as follows: "Rural branch" means a branch of a scheduled bank or a non-scheduled bank situated in a place which has a population of not more than ten thousand according to the last preceding census of which the relevant figures have been published before the first day of the previous year." What is clear from the above

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)

viia) as follows: "Rural branch" means a branch of a scheduled bank or a non-scheduled bank situated in a place which has a population of not more than ten thousand according to the last preceding census of which the relevant figures have been published before the first day of the previous year." What is clear from the above

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)

viia) of the Act and it can only claim deduction under section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso

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)

viia) of the Act and it can only claim deduction under section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso

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)

viia) of the Act and it can only claim deduction under section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso

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)

viia) of the Act and it can only claim deduction under section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(3)(1), MUMBAI, MUMBAI vs. TMF HOLDINGS LIMITED, MUMBAI

In the result, the appeal of the revenue bearing ITA No

ITA 2983/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Jul 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhrideputy Commissioner Of Vs Tmf Holdings Limited 14, 4Th Floor, Sir H C Dinshaw Income Tax, Circle 1(3)(1), Mumbai Building, 16, Horniman Circle, Fort, Room No.535, 5Th Floor, Aaykar Mumbai-400 001 Bhavan, M.K. Road, Mumbai- Pan: Aacct4644A 400 020 Appellant Respondent

For Appellant: Shri Rajan Vora a/w Shri Nikhil TiwariFor Respondent: Shri Ritesh Mishra, CIT DR
Section 115JSection 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

bogus transaction, the disclosures made could not be said to be all "true" and "full" Relying upon the said judgment the High Court held that merely because the transaction of convertible bonds was disclosed at the time of original assessment does not mean that there is true and full disclosure of facts. 28. We are unable to agree with this