VEERENDRA BASAVARAJ KOUJALAGI,BELAGAVI vs. PCIT HUBBALLI, HUBBALLI

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshaliita Nos. 103/Pan/2024 Assessment Year : 2018-19 Veerendra Basavaraj Koujalagi C/O. Shri Laxmi Complex, Sadashiv Nagar, Belgavi-590001 Pan : Agrpk3086D . . . . . . . Appellant V/S The Pr. Commissioner Of Income Tax, Hubali. . . . . . . . Respondent Appearances Assessee By : Mr Shivanand Halbhavi [‘Ld. Ar’] Revenue By : Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 24/06/2025 Date Of Pronouncement : 28/07/2025 Order Per G. D. Padmahshali; The Assessee’S Captioned Appeal Impugns Din & Order 1063626985(1) Dt. 29/03/2024 Passed By Pr. Commissioner Of Income Tax, Hubali [‘Ld. Pcit’] U/S 263 Of The Income-Tax Act, 1961 [‘The Act’] Which Sought To Revise Order Of Assessment Dt. 26/04/2021 Passed U/S 143(3) R.W.S. 144B Of The Act By National Faceless E-Asstt. Centre, Delhi [‘Ld. Ao’] Anent To Assessment Year 2018-19 [‘Ay’].

exempt income vis-à-vis disallowance of expenditure (if any) incurred towards earning of such exempt income, by issue of notice

EDC LIMITED.,PANAJI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), NFAC, DELHI, PANAJI

In the result, the appeal of assessee is allowed for statistical purpose

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

exempt income. According to the AO, the assessee itself disallowed an amount of Rs.53,562/- for the purpose of expenditure

BANDEKAR BROTHERS PRIVATE LIMITED,VASCO GOA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NATIONAL E ASSESSMENT CENTRE, NEW DELHI

The appeal is partly allowed for statistical purpose

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

disallowance computed without reducing average investment which did not yield exempt income. Without touching merits, we have heard rival 5. party

M/S. AHILIABAI SARDESSAI, ,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1), PANAJI

In the result, the appeal of assessee is allowed for statistical purpose

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

exempt income. It is settled principle that the disallowance of expenditure should be relating to those investments which yielded exempt

M/S. AHILIABAI SARDESSAI, ,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1), PANAJI

In the result, the appeal of assessee is allowed for statistical purpose

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

exempt income. It is settled principle that the disallowance of expenditure should be relating to those investments which yielded exempt

SHRI VARDHAMAN URBAN CREDIT SOUHARDA SAHAKARI NIYAMIT,KUDCHI vs. INCOME TAX OFFICER, WARD - 1, BELAGAVI

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

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.91/Pan/2023 िनधा"रण वष" / Assessment Year : 2017-18 Shri Vardhaman Urban Vs. Ito, Ward-1, Belgaum. Credit Souharda Sahakari Niyamit, Post- Kudchi, Tal- Raibag, Dist.- Belgaum, Karnataka- 591005. Pan : Aaaas5599R Appellant Respondent S.A. No.07/Pan/2023 (Arising Out Of Ita No.91/Pan/2023) िनधा"रण वष" / Assessment Year : 2017-18 Shri Vardhaman Urban Vs. Ito, Ward-1, Belgaum. Credit Souharda Sahakari Niyamit, Post- Kudchi, Tal- Raibag, Dist.- Belgaum, Karnataka- 591005. Pan : Aaaas5599R Appellant Respondent Assessee By : Shri U. G. Ammangi Revenue By : Shri Ashwini D. Hosmani Date Of Hearing : 04.09.2023 Date Of Pronouncement : 08.09.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of The National Faceless Appeal Centre, Delhi [‘Nfac’] Dated

exemption u/s 80P(2)(a)(i)/80P(2)(d) of the Act. 4. Being aggrieved by the above disallowances, an appeal

FOMENTO KARNATAKA MINING COMPANY PRIVATE LIMITED (NOW AMALGAMATED WITH FOMENTO RESOURCES PRIVATE LIMITED,PANAJI vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.26/Pan/2021 िनधा"रण वष" / Assessment Year : 2009-10 Fomento Karnataka Mining Vs. Jcit, Margao Range, Company Private Limited, Margao, Goa. (Now Amalgamated With Fomento Resources Private Limited), 102, 1St Floor, Kamat Metropolis-I, Behind Caculo Mall, St. Inez, Panaji, Goa- 403001. Pan : Aaacf7487K Appellant Respondent Assessee By : Shri Nishant Thakkar Revenue By : Shri N. Shrikanth Date Of Hearing : 17.08.2023 Date Of Pronouncement : 29.08.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-2, Panaji [‘The Cit(A)’] Dated 27.08.2021 For The Assessment Year 2009-10. 2 2. Briefly, The Facts Of The Case Are That The Appellant Is A Company Incorporated Under The Provisions Of The Companies Act, 1956. It Is Engaged In The Business Of Processing & Trading In The Iron Ore. The Return Of Income For The Assessment Year 2009-10 Was Filed On 30.09.2009 Declaring Total Income Of Rs.26,40,77,220/-. Against The Said Return Of Income, The Assessment Was Completed By The Joint Commissioner Of Income Tax, Margao Range, Margao (‘The Assessing Officer’) Vide Order Dated 30.12.2011 Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’) At A Total Income Of Rs.26,63,57,955/-. While Doing So, The Assessing Officer Made Disallowance U/S 14A Of Rs.15,49,787/-, Disallowance On Account Of Sundry Creditors Extracting As Fictitious Of Rs.7,30,948/-. 3. Being Aggrieved, An Appeal Was Filed Before The Ld. Cit(A) Contending That No Disallowance U/S 14A Is Required To Be Made In The Absence Of Any Expenditure Incurred To Earn The Exempt Income. It Was Also Contended That No Addition On Account Of Outstanding Creditors Is Required To Be Made, As The Credits Represent The Opening

disallowance u/s 14A is required to be made in the absence of any expenditure incurred to earn the exempt income

CENTRE FOR INCUBATION AND BUSINESS ACCELERATION,VERNA vs. CENTRALIZE PROCESSING CENTRE, INCOME TAX DEPARTMENT, BENGALURU

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.152/Pan/2025 (A.Y.2024-25 ) Centre For Incubation & Vs. I T O- Exemption, Business Acceleration, Ward-1, Angel Charities, Pundalik Niwas, Angel Ashram, Panaji-403001, Verna, Salcete, Goa. Goa-403722. Pan/Gir No. Aafcc5621B (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By Shri.Mahendra Gohel.Ar Revenue By Smt. Rijula Uniyal. Sr.Dr सुनवाई की तारीख/Date Of Hearing 18.11.2025 घोषणा की तारीख/Date Of Pronouncement 26.11.2025 Order Per Pavan Kumar Gadale, Jm:

exemption u/sec 11 of the Act and the return of income was processed u/sec 143(1) of the Act on 28.01.2025 determining the total income of Rs.29,62,131/- by disallowing

DEARHOOD FOUNDATION,BELAGAVI vs. THE DEPUTY DIRECTOR OF INCOME TAX, CPC, BENGALURU

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

Bench: Shri Pavan Kumar Gadalei T A. No.202/Pan/2025 (A.Y.2022-23 ) Dear Hood Foundation, Ddit, Vs. Plot.No.1/S,Kanbargi Cpc, Industrial Area, Bengaluru-560500. Kanabargi.S.O, Karnataka. Belgaum-590015, Karnataka. Pan/Gir No. Aaicd1005D (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By Shri.Pramod Y Vaidya.Ar Revenue By Shri.Sanket Deshmukh.Sr.Dr सुनवाई की तारीख/Date Of Hearing 23.12.2025 घोषणा की तारीख/Date Of Pronouncement 23.12.2025 Order Per Pavan Kumar Gadale, Jm:

exemption u/sec 11 of the Act and the return of income was processed u/sec 143(1) of the Act on 17.03.2023 determining the total income of Rs.14,62,003/- by disallowing

GANGADHAR NARSINGDAS AGRAWAL,MARGAO vs. INCOME TAX OFFICER, WARD - 2, , MARGAO

In the result, the appeal is allowed for statistical purposes

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.444/Pan/2018 "नधा"रण वष" / Assessment Year : 2012-13

disallowance u/s.14A qua the exempt income. Without going into further details and in the absence of any discussion made by the ld. CIT(A) on this

M/S. AHILIABAI SARDESSAI, ,PANAJI vs. INCOME TAX OFFICER, WARD 2(4), PANAJI

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

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.08/Pan/2021 िनधा"रण वष" / Assessment Year : 2014-15 M/S. Ahiliabai Sardessai, Vs. Ito, Ward-2(4), Panaji. 301, Lotus Court, M. G. Road, St. Inez Junction, Panaji- 403001. Pan : Aagfa9044G Appellant Respondent Assessee By : Shri N. J. Prabhudesai Revenue By : Shri N. Shrikanth Date Of Hearing : 17.08.2023 Date Of Pronouncement : 29.08.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of The National Faceless Appeal Centre, Delhi [‘Nfac’] Dated 26.03.2021 For The Assessment Year 2014-15. 2. Briefly, The Facts Of The Case Are That The Appellant Is A Partnership Firm Engaged In The Business Of Mining. The Return Of Income For The Assessment Year 2014-15 Was Filed On 30.09.2014 Declaring A Loss Of Rs.4,92,14,101/- & The Same Was Revised At Loss

disallowance u/s 14A r.w. Rule 8(D)(2)(iii), the appellant is in appeal before us in the present appeal. 5. Before us, it is contended that the appellant had not incurred any expenditure to earn the exempt

SHRI LOKESHWAR CO-OPERATIVE CREDIT SOCIETY NIYAMIT,LOKAPUR vs. INCOME TAX OFFICER, WARD - 1 & TPS, BAGALKOT

In the result, stay application of the assessee is dismissed as withdrawn and that the appeal stands allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshali(Through Virtual Hearing) S.A.No. 05/Pan/2023 & Shri Lokeshwar Co-Operative Vs Ito, Ward-1 & Tps, Credit Society Niyamit Bagalkot. Lokapur, Tq. Mudhol, Dist. Bagalkot Pan: Aaals 2253 H Appellant Respondent Assessee By : Shri Saidappa Gadadi, Ca Revenue By : Shri N. Shrikanth, Dr Date Of Hearing : 14/08/2023 Date Of Pronouncement : 21/08/2023 O R D E R Per Partha Sarathi Chaudhury, Jm: The Stay Application & The Appeal Preferred By The Assessee Emanates From The Order Of National Faceless Appeal Centre [Nfac], Delhi, Dated 23.02.2023 For A.Y.2013-14 As Per The Grounds Of Appeal On Record.

exemption of interest income u/sec. 80P(4) and disallowing the same, order was passed u/sec. 143(3). Aggrieved by the action

GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE INCOME TAX OFFICER, WARD - 1(1), PANAJI

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.344/Pan/2017 (A.Y.2013-14 ) Guala Closures(India) Vs. I T O Ward1(1), Private Limited, Aaykar Bhavan, D-1, Sesa Ghor, Edc, Patto, 20,Edc Complex, Panjim-403001. Patto, Goa. Panaji-403001, Goa Pan/Gir No.:Aaacg4447J Appellant .. Respondent

exempt income by way of dividend was to be disallowed under Section 14A pf the Act. The Assessee argued that

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

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

exempted. Whereas the A.O. found that the assessee has not made disallowance u/sec 14A of the Act on the expenditure

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, UDUPI., UDUPI vs. M/S MANIPAL FINANCE CORPORATION LIMITED., UDUPI

In the result, the appeal is dismissed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.332 & 333/Pan/2016 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14

exempt dividend income of Rs.2,82,640/- and offered suo motu disallowance u/s.14A at Rs.7,075/-. On a specific query

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, UDUPI., UDUPI vs. M/S MANIPAL FINANCE CORPORATION LIMITED., UDUPI

In the result, the appeal is dismissed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.332 & 333/Pan/2016 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14

exempt dividend income of Rs.2,82,640/- and offered suo motu disallowance u/s.14A at Rs.7,075/-. On a specific query

ZUARI INDUSTRIES LIMITED (FORMERLY KNOWN AS ZUARI GLOBAL LTD),ZUARINAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), PANAJI

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.71/Pan/2025 (A.Y. 2018-19 ) Zuari Industries Limited, Vs National Faceless Jai Kisaan Bhawan, Assessment Centre, Zuarinagar, Delhi. Mormugo, Goa-403728. Pan/Gir No. Aaacz0306P (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri.Ankit Goyal.Ar Revenue By Shri.Captain Pradeep Arya.Dr सुनवाई क" तार"ख/Date Of Hearing 10.06.2025 घोषणा क" तार"ख/Date Of Pronouncement 11.06.2025 Order Per Pavan Kumar Gadale Jm: The Appeal Is Filed By The Assesse Against The Order Of National Faceless Appeal Centre (Nfac) Delhi /Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Disallowance U/Sec14Aof The Act & Not Condoning The Delay In Filling The Appeal. 2. The Brief Facts Of The Case Are That, The Assesse Company Is Engaged In The Business. The Assesse Has Filed The Return Of Income For A.Y.2018-19 On 29.11.2018 Disclosing

exempted u/sec10(34) of the Act. Whereas the A.O. found that the assessee has made disallowance u/sec 14A of the Act of Rs.5

SANJAY ATCHUT POY RAITURCAR,MARGAO vs. ITO, WARD - 4 , MARGAO

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon. & (Through Virtual Hearing)

exemption u/sec. 54F, 54F(4) and interest paid to M/s. Fabrica De Gas Pvt. Ltd. The total LTCG offered to tax by the assessee was Rs. 2,30,62,021/- in the hands of the communion and 50% thereof in the hands of the assessee. The AO disallowed

THE ATHANI CREDIT CO-OPERATIVE SOCIETY LIMITED,ATHANI vs. INCOME TAX OFFICER, WARD - 1, BELAGAVI

Appeal is partly allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak Ripote

exempt from the Income Tax Act. Therefore, we remand the matter back to the file of the Assessing Officer with a direction to allow the deduction u/s 80P(2)(d) of the Act after satisfying himself that the interest income is earned on investment from the cooperative societies. Thus, the grounds of appeal raised by the assessee are partly allowed