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16 results for “TDS”+ Exemptionclear

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Key Topics

Section 20119Section 201(1)16Section 10(5)15Section 14A14TDS12Section 4010Exemption8Disallowance8Addition to Income7Section 154

STATE BANK OF INDIA,BELGAUM vs. ITO, (TDS), BELGAUM

In the result, all these appeals of the assessee are dismissed

ITA 34/PAN/2018[2014-15]Status: DisposedITAT Panaji31 Mar 2022AY 2014-15

Bench: Dr. M. L. Meena & Shri Anikesh Banerjeei.T.A. No. 32 To 34/Pan/2018 Assessment Years: 2012-13 To 2014-15 State Bank Of India Vs. Income Tax Officer (Tds) Regional Branch Office Belgaum Goaves, Hindwadi Belgaum – 590 011 [Aaacs8577K] (Appellant) (Respondent) Appellant By None Respondent By Smt. Rijula Uniyal, Sr. D/R Date Of Hearing 28.03.2022 Date Of Pronouncement 31.03.2022 Order Per Bench: These Captioned Appeals Are Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) - Belagavi, [Hereinafter The “Ld. Cit(A)] Even Dt. 08/11/2017, For The Assessment Years 2012-13, 2013-14 & 2014-15, Challenging The Non-Compliance Of Provisions U/S 201(1)/(1A) Of The Income Tax Act, 1961 [Hereinafter “The Act’]. 2. Facts In Brief Are That The Appellant/Assessee State Bank Of India, Regional Business Office Is A Banking Company Engaged In The Business Of Banking. A Survey U/S 133A Of The Act Was Conducted At The Bank Premises To Verify Compliance With Tds/Tcs Provisions. The Ito Held That The Assessee Has Failed To Deduct Tax At Source On The Reimbursement Made Against Foreign Ltc To The Officers Of The Bank & Accordingly He Applied The Provisions Of Section 201(1) & 201(1A) Of The Act Treating The Assessee In Default U/S 201(1) & Charged Interest U/S 201(1A) Of The Act. In Respect Of The Assessment Year 2012-13, 2013-14 & 2014-15. 2.1. Aggrieved The Assessee Preferred An Appeal Before The Ld. Cit(A) Who Has Confirmed The Finding Of The Ao By Observing As Under:-

Section 10(5)Section 133ASection 201Section 201(1)
6
Section 9(1)(vii)4
Deduction4

exemption available u/s 10(5) in case of travel outside India, and consequently the assessee is in default for not deducting TDS

STATE BANK OF INDIA,BELGAUM vs. ITO, (TDS), BELGAUM

In the result, all these appeals of the assessee are dismissed

ITA 33/PAN/2018[2013-14]Status: DisposedITAT Panaji31 Mar 2022AY 2013-14

Bench: Dr. M. L. Meena & Shri Anikesh Banerjeei.T.A. No. 32 To 34/Pan/2018 Assessment Years: 2012-13 To 2014-15 State Bank Of India Vs. Income Tax Officer (Tds) Regional Branch Office Belgaum Goaves, Hindwadi Belgaum – 590 011 [Aaacs8577K] (Appellant) (Respondent) Appellant By None Respondent By Smt. Rijula Uniyal, Sr. D/R Date Of Hearing 28.03.2022 Date Of Pronouncement 31.03.2022 Order Per Bench: These Captioned Appeals Are Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) - Belagavi, [Hereinafter The “Ld. Cit(A)] Even Dt. 08/11/2017, For The Assessment Years 2012-13, 2013-14 & 2014-15, Challenging The Non-Compliance Of Provisions U/S 201(1)/(1A) Of The Income Tax Act, 1961 [Hereinafter “The Act’]. 2. Facts In Brief Are That The Appellant/Assessee State Bank Of India, Regional Business Office Is A Banking Company Engaged In The Business Of Banking. A Survey U/S 133A Of The Act Was Conducted At The Bank Premises To Verify Compliance With Tds/Tcs Provisions. The Ito Held That The Assessee Has Failed To Deduct Tax At Source On The Reimbursement Made Against Foreign Ltc To The Officers Of The Bank & Accordingly He Applied The Provisions Of Section 201(1) & 201(1A) Of The Act Treating The Assessee In Default U/S 201(1) & Charged Interest U/S 201(1A) Of The Act. In Respect Of The Assessment Year 2012-13, 2013-14 & 2014-15. 2.1. Aggrieved The Assessee Preferred An Appeal Before The Ld. Cit(A) Who Has Confirmed The Finding Of The Ao By Observing As Under:-

Section 10(5)Section 133ASection 201Section 201(1)

exemption available u/s 10(5) in case of travel outside India, and consequently the assessee is in default for not deducting TDS

STATE BANK OF INDIA,BELGAUM vs. ITO, (TDS), BELGAUM

In the result, all these appeals of the assessee are dismissed

ITA 32/PAN/2018[2012-13]Status: DisposedITAT Panaji31 Mar 2022AY 2012-13

Bench: Dr. M. L. Meena & Shri Anikesh Banerjeei.T.A. No. 32 To 34/Pan/2018 Assessment Years: 2012-13 To 2014-15 State Bank Of India Vs. Income Tax Officer (Tds) Regional Branch Office Belgaum Goaves, Hindwadi Belgaum – 590 011 [Aaacs8577K] (Appellant) (Respondent) Appellant By None Respondent By Smt. Rijula Uniyal, Sr. D/R Date Of Hearing 28.03.2022 Date Of Pronouncement 31.03.2022 Order Per Bench: These Captioned Appeals Are Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) - Belagavi, [Hereinafter The “Ld. Cit(A)] Even Dt. 08/11/2017, For The Assessment Years 2012-13, 2013-14 & 2014-15, Challenging The Non-Compliance Of Provisions U/S 201(1)/(1A) Of The Income Tax Act, 1961 [Hereinafter “The Act’]. 2. Facts In Brief Are That The Appellant/Assessee State Bank Of India, Regional Business Office Is A Banking Company Engaged In The Business Of Banking. A Survey U/S 133A Of The Act Was Conducted At The Bank Premises To Verify Compliance With Tds/Tcs Provisions. The Ito Held That The Assessee Has Failed To Deduct Tax At Source On The Reimbursement Made Against Foreign Ltc To The Officers Of The Bank & Accordingly He Applied The Provisions Of Section 201(1) & 201(1A) Of The Act Treating The Assessee In Default U/S 201(1) & Charged Interest U/S 201(1A) Of The Act. In Respect Of The Assessment Year 2012-13, 2013-14 & 2014-15. 2.1. Aggrieved The Assessee Preferred An Appeal Before The Ld. Cit(A) Who Has Confirmed The Finding Of The Ao By Observing As Under:-

Section 10(5)Section 133ASection 201Section 201(1)

exemption available u/s 10(5) in case of travel outside India, and consequently the assessee is in default for not deducting TDS

MRS VINI P. KENI,PANAJI vs. INCOME TAX OFFICER, WARD - 1(3), PANAJI

In the result, the appeal filed by the assessee is partly allowed for statistical purpose

ITA 112/PAN/2022[2014-15]Status: DisposedITAT Panaji20 Mar 2025AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 112/Pan/2022 (A.Y. 2014-15 ) Vini Prasad Keni, Vs Ito-Ward-1(3), Keni Building, Aayakar Bhavan, . Dr.Dada Vaidhya Road, Panaji-403001, Panjim-403001, Goa. Goa. . Pan .No. Adppk9767N (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri D.E.Robinson.Ar Revenue By Sri Narender Reddy.Sr.Dr सुनवाई क" तार"ख/Date Of Hearing 25.02.2025 घोषणा क" तार"ख/Date Of Pronouncement 20.03.2025 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/ Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. 2. At The Time Of Hearing, The Ld.Ar Of The Assessee Submitted That There Is A Delay Of 13 Days In Filing The Appeal Before The Hon’Ble Tribunal & The Assesse Has Filed The Affidavit For Condonation Of Delay. Whereas, The Facts Mentioned In The Affidavit Are Reasonable & The Ld. Dr Has No Specific Objections. Accordingly, We Condone The Delay & Admit The Appeal. The Assessee Has Raised

Section 14ASection 194CSection 40

exempt income and with respect to disputed issue of non deduction of TDS u/sec194C of the Act, the ld.AR emphasized

VIJAYA BANK,BELAGAVI vs. ITO, TDS, WARD - 1, BELAGAVI

In the result, the appeal filed by the assessee in ITA

ITA 208/PAN/2018[2013-14]Status: DisposedITAT Panaji25 Aug 2023AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.207 To 209/Pan/2018 िनधा"रण वष" / Assessment Years : 2012-13 To 2014-15 Vijaya Bank, Vs. Ito, Tds, Ward-1, Tilakwadi Branch, Belagavi, Belagavi. Karnataka – 590001. Pan : Aaacv4791J Appellant Respondent Assessee By : P.G. G. & Co. Revenue By : Shri N. Shrikanth Date Of Hearing : 16.08.2023 Date Of Pronouncement : 25.08.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Assessee Directed Against The Separate Orders Of Ld. Commissioner Of Income Tax (Appeals), Belagavi [‘The Cit(A)’] Dated 14.03.2018 For The Assessment Years 2012-13 To 2014-15 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Assessee In Ita No.207/Pan/2018 For The Assessment Year 2012-13 Are Stated Herein.

For Appellant: P.G. G. & CoFor Respondent: Shri N. Shrikanth
Section 10Section 154Section 201Section 201(1)

TDS Officer, an appeal was filed before the ld. CIT(A), who vide impugned order dated 10.03.2017 considering the fact that the payee i.e. Vishveshvaraya Technological University, Belagavi does not enjoy the exemption

VIJAYA BANK,BELAGAVI vs. ITO, TDS, WARD - 1, BELAGAVI

In the result, the appeal filed by the assessee in ITA

ITA 207/PAN/2018[2012-13]Status: DisposedITAT Panaji25 Aug 2023AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.207 To 209/Pan/2018 िनधा"रण वष" / Assessment Years : 2012-13 To 2014-15 Vijaya Bank, Vs. Ito, Tds, Ward-1, Tilakwadi Branch, Belagavi, Belagavi. Karnataka – 590001. Pan : Aaacv4791J Appellant Respondent Assessee By : P.G. G. & Co. Revenue By : Shri N. Shrikanth Date Of Hearing : 16.08.2023 Date Of Pronouncement : 25.08.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Assessee Directed Against The Separate Orders Of Ld. Commissioner Of Income Tax (Appeals), Belagavi [‘The Cit(A)’] Dated 14.03.2018 For The Assessment Years 2012-13 To 2014-15 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Assessee In Ita No.207/Pan/2018 For The Assessment Year 2012-13 Are Stated Herein.

For Appellant: P.G. G. & CoFor Respondent: Shri N. Shrikanth
Section 10Section 154Section 201Section 201(1)

TDS Officer, an appeal was filed before the ld. CIT(A), who vide impugned order dated 10.03.2017 considering the fact that the payee i.e. Vishveshvaraya Technological University, Belagavi does not enjoy the exemption

VIJAYA BANK,BELAGAVI vs. ITO, TDS, WARD - 1, BELAGAVI

In the result, the appeal filed by the assessee in ITA

ITA 209/PAN/2018[2014-15]Status: DisposedITAT Panaji25 Aug 2023AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.207 To 209/Pan/2018 िनधा"रण वष" / Assessment Years : 2012-13 To 2014-15 Vijaya Bank, Vs. Ito, Tds, Ward-1, Tilakwadi Branch, Belagavi, Belagavi. Karnataka – 590001. Pan : Aaacv4791J Appellant Respondent Assessee By : P.G. G. & Co. Revenue By : Shri N. Shrikanth Date Of Hearing : 16.08.2023 Date Of Pronouncement : 25.08.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Assessee Directed Against The Separate Orders Of Ld. Commissioner Of Income Tax (Appeals), Belagavi [‘The Cit(A)’] Dated 14.03.2018 For The Assessment Years 2012-13 To 2014-15 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Assessee In Ita No.207/Pan/2018 For The Assessment Year 2012-13 Are Stated Herein.

For Appellant: P.G. G. & CoFor Respondent: Shri N. Shrikanth
Section 10Section 154Section 201Section 201(1)

TDS Officer, an appeal was filed before the ld. CIT(A), who vide impugned order dated 10.03.2017 considering the fact that the payee i.e. Vishveshvaraya Technological University, Belagavi does not enjoy the exemption

FABRICA DA IGRE JA DE NAVELIM,NAVELIM vs. INCOME TAX OFFICER (EXEMPTION), WARD - 1, PANAJI

In the result, the appeal filed by assesse is allowed for statistical purposes

ITA 192/PAN/2025[2015-16]Status: DisposedITAT Panaji13 Feb 2026AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.192/Pan/2025 (A.Y. 2015-16) Fabrica Da Igreja De Navelim, Vs I T O, Our Lady Of Rosary Church, National E Assessment . Navelim, Salcete, Centre, South Goa-403707. Delhi. Goa. Pan.No.Aaatf0452H (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 11Section 12A

exemption u/sec11 of the Act made by the Assessing Officer. 2 ITA. No.192/PAN/2025 Fabrica Da Igreja De Navelim.. 2. The brief facts of the case are that, the assessee is a trust and is registered under section12A of the Act The income tax department based on the NMS portal found financial transactions (i) cash deposits in corporation bank account

SHRI NITIN A SHIRGURKAR,BELGAVI vs. PR. CIT, HUBBALI

In the result, the appeal of the assessee is allowe

ITA 77/PAN/2020[2015-16]Status: DisposedITAT Panaji13 May 2022AY 2015-16

Bench: Dr. M. L. Meena & Shri Anikesh Banerjee

Section 143(3)Section 14ASection 194A(3)(iii)Section 194A(3)(iv)Section 263Section 40

TDS on subcontract payments subcontract payments evidenced by Tax Audit Report and verified evidenced by Tax Audit Report and verified by A.O in assessment proceedings. by A.O in assessment proceedings. 11. The Pr.CIT erred in directing A.O to verify chargeability to erred in directing A.O to verify chargeability to Wealth Tax of flat at Wealth Tax of flat at Bangalore

THE KERI URBAN CO-OP. CREDIT SOCIETY LTD.,KERI, GOA vs. THE INCOME TAX OFFICER, WARD-2(3), PANAJI

Appeal is allowed in above terms

ITA 140/PAN/2019[2015-16]Status: DisposedITAT Panaji19 Dec 2022AY 2015-16

Bench: Shri Satbeer Singh Godara

For Appellant: Shri S.J. KamatFor Respondent: Smt. Neelima Nadkarni, Sr.DR
Section 143(3)Section 40Section 80PSection 80P(2)(a)Section 80P(2)(d)

exempt from the Income Tax Act u/s 80P(2)(d) of the Act. Therefore, we hold that the lower authorities was not justified in denying the claim of deduction u/s 80P(2)(d) of the Act. Accordingly, we direct the Assessing Officer to allow the same as deduction u/s 80P(2)(d) of the Act.” 5.1. I thus accept

ACIT, CENTRAL CIRCLE, PANAJI vs. M/S SOCIADADE DE FOMENTO INDUSTRIAL P. LTD, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

ITA 116/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR
Section 143(1)Section 143(2)Section 14A

exempt income during the year. Therefore, we are unable to see any reason to interfere with the findings arrived at by the ld. First appellate authority on this issue in partly allowing the claim of the assessee in accordance with the judgement of the ITAT Special Bench (supra). Accordingly, ground No.3 of the assessee is dismissed

SOCIEADADE DE FOMENTO INDL. PVT. LTD.,MARGAO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

ITA 105/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR
Section 143(1)Section 143(2)Section 14A

exempt income during the year. Therefore, we are unable to see any reason to interfere with the findings arrived at by the ld. First appellate authority on this issue in partly allowing the claim of the assessee in accordance with the judgement of the ITAT Special Bench (supra). Accordingly, ground No.3 of the assessee is dismissed

M/S CHOWGULE AND COMPANY (SALT) PVT. LTD,MORMUGAO vs. THE ACIT, CIRCLE - 2, MARGAO

The appeal of the assessee is partly allowed in terms of aforesaid observation

ITA 390/PAN/2017[2012-13]Status: DisposedITAT Panaji29 Apr 2022AY 2012-13

Bench: Shri Ravish Sood & Shri Jamlappa D. Battullआयकर अपील सं. / Ita No. : 390/Pan/2017 करधििाारण वर्ा / Assessment Year : 2012-2013 M/S Chowgule & Company (Salt) Pvt Ltd., Chowgule House, Mormugao Harbour, Goa – 403803. Pan: Aabcc 5595 J . . . . . . . अपीलार्थी / Appellant बिाम / V/S Asstt. Commissioner Of Income Tax, Circle-2, Margao, Goa. . . . . . . . प्रत्यर्थी / Respondent द्वारा / Appearances Assessee By : Ms Hiral Sejpal Revenue By : Shri Sourabh Nayak सुनवाई की तारीख / Date Of Conclusive Hearing : 24/02/2022 घोषणा की तारीख / Date Of Pronouncement : 29/04/2022 आदेश / Order Per Jamlappa D Battull Am; The Present Appeal Filed By The Appellant Assessee Is Directed Against The Order Of Commissioner Of Income Tax- Appeals, Panaji-1 [For Short “Cit(A)”] Dt. 09/10/2017 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which In Turn Tousled Out Of Order Of Assessment Of Assistant Commissioner Of Income Tax-Circle-2, Margoa [For Short “Ao”] Dt. 27/07/2014 Passed U/S 143(3) Of The Act, For The Assessment Year [For Short “Ay”] 2012-2013. Itat-Panaji Page 1 Of 23

For Appellant: Ms Hiral SejpalFor Respondent: Shri Sourabh Nayak
Section 10(35)Section 115JSection 143(3)Section 14ASection 14A(1)Section 250

exempt income is earned without incurring expenditure when in fact the circumstances in which such income is earned is already submitted on record. ITAT-Panaji Page 3 of 23 M/s Chowgule and Company (Salt) Pvt Ltd ITA No.: 390/PAN/2017, AY : 2012-2013, AABCC5595J II. Disallowance of 80% depreciation claimed on Diesel Generators: 1) The learned CIT(A) has erred

TUMKUR MINERALS PVT. LTD,VASCO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, appeal of the assessee is allowed

ITA 401/PAN/2018[2011-12]Status: DisposedITAT Panaji20 Sept 2023AY 2011-12

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri P.J. Pardiwalla, AdvFor Respondent: Smt. Ashwini Hosmani, Sr.DR
Section 195Section 40Section 5Section 9(1)(vii)

TDS does not arise. The assessee had made payment of destination sampling charges to non- resident service providers for the services rendered by them outside India, which were utilized by the assessee-company for the purpose of earning income from the source outside India. Therefore, the assessee had submitted that services were rendered outside India and in fact the services

M/S SHREE BALAJI CONCEPTS,MARGAO vs. INCOME TAX OFFICER (INTERNATIONAL TXATION), WARD -1, PANAJI

The appeal of the assessee is allowed in the terms indicated as above

ITA 73/PAN/2018[2012-13]Status: DisposedITAT Panaji13 May 2022AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 73/Pan/2018 Assessment Year: 2012-13

For Appellant: Shri M. R. Hegde, CA &For Respondent: Smt. Rijula Uniyal, Sr. DR
Section 156Section 191Section 195Section 201Section 201(1)Section 205

TDS under Chapter XVII B and thus invocation of section 156 of the Act to levy a demand on the Appellant is totally misplaced and without any foundation. 6. The learned authorities below failed to appreciate that the provisions of section 191 and section 205 construct a mandate not to recover tax from the deductor in the event of failure

SOCIAL CLUB AND KREEDA BHAVAN,BELGAVI vs. ITO, WARD - 2(1), BELGAVI

In the result, appeal of the assessee is partly allowed

ITA 385/PAN/2017[2013-14]Status: DisposedITAT Panaji07 Oct 2021AY 2013-14

Bench: Shri Laliet Kumar, Jm & Dr. Mitha Lal Meena, Am Social Club & Kreeda Bhavan, Vs Ito, Ward-2(1), Belagavi College Road, Belagavi-590002 Pan No.Aacas 6996 A (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधााररती की ओर से /Assessee By : Shri B.B.Chandargi, Ca राजस्व की ओर से /Revenue By : Shri Sourabh Nayak, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 07/10/2021 घोषणा की तारीख/Date Of Pronouncement : 07/10/2021 आदेश / O R D E R Per Bench : This An Appeal Filed By The Revenue Against The Order Passed By The Cit(A), Gulbarga, Dated 19.10.2017 For The Assessment Year 2013- 2013, On The Following Grounds :- 1. The Learned Commissioner Of Income Tax (Appeals), Belgaum Has Erred In Upholding The Order Assessing Officer Disallowing Expenses Under The Head Business Or Profession Even Though Income Is Exempted As Mutual Concern By The Assessing Officer. This Is Opposed To Law & Facts Of The Case.

For Appellant: Shri B.B.Chandargi, CAFor Respondent: Shri Sourabh Nayak, Sr.DR
Section 40Section 40aSection 43BSection 56

exempt on the principle of mutuality and any income which is received other than members is offered for taxation under the head Income from other sources (Section 56) and Tax is paid on the same. It was further submitted by the ld. AR that the Assessing officer has assessed the income under the head Income from other sources