PRIME MINERAL EXPORTS PRIVATE LIMITED (NOW AMALGAMATED WITH FOMENTO RESOURCES PRIVATE LIMITED),PANAJI vs. JOINT COMMISSIONER OF INCOME TAX, RANGE - 1, PANAJI

The appeal stands partly allowed for statistical purpose in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 003/Pan/2023 Assessment Year : 2009-10 Prime Mineral Exports Pvt. Ltd. (Now Amalgamated With Fomento Resources Pvt. Ltd.) 102, 1St Fl. Kamat Metropolis-1, Behind Caculo Mall, St. Inez, Panaji, Goa-403001. . . . . . . .Appellant Pan : Aadcp1647E V/S Jt. Commissioner Of Income Tax, . . . . . . . Respondent Range-1, Panaji, Goa

10 of 42 Prime Mineral Exports Pvt. Ltd.(Now Amalgamated with Fomento Resources Pvt. Ltd.) Vs JCIT, Panaji ITA Nos.003/PAN/2023 AY: 2009-10 & disallow the expenditure u/c (iii) of rule 8D(2) r.w.s. 14A of the Act towards indirect expenditure, which the tax authorities have rightly done. For the reasons the disallowance made in the assessment and sustained in first

SHRI BASAVESHWAR PRATHAMIK KRISHI PATTIN SAHAKARI SANGHA N SUNADHOLI,SUNADHOLI vs. INCOME TAX OFFICER, GOKAK

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 030/Pan/2025 Assessment Year : 2018-19 Shri Basaveshwar Prathamik Krishi Pattin Sahakari Sangha At Post: Sundholi, Ta.: Sundholi Dist. Belagavi.-591310 Pan : Aahas0468A . . . . . . . Appellant

section 80AC of the Act, however there was complete absence of authority vested with the Ld. CPC to carry out the disallowance u/s 143(1)(a)(v) of the Act. Therefore, the impugned action of denial of 80P deduction to the appellant by the Ld. CPC was barred by jurisdiction, hence unlawful. And in the absence of any explicit power

PRIYADARSHANI MAHILA CO-OP CR. SOCIETY LTD,BELAGAVI vs. DCIT, CPC, BANGALORE

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 032/Pan/2025 Assessment Year : 2019-20 Priyadarshani Mahila Co-Op. Society Ltd. At Post: Kognoli, Ta.: Nippani Dist. Belagavi. Pan : Aabap2582L . . . . . . . Appellant

10 of 12 Priyadarshani Mahila Co-op. Society Ltd. Vs DCIT, CPC ITA Nos.032/PAN/2025 AY: 2019-20 provisions of clause (ii) of section 80AC of the Act, however there was complete absence of authority vested with the Ld. CPC to carry out the disallowance u/s 143(1)(a)(v) of the Act. Therefore, the impugned action of denial

ALLAMAPRABHU VUSS NI, KALLOLI,KALLOLI vs. INCOME TAX OFFICER, WARD - 1, GOKAK

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 063/Pan/2025 Assessment Year : 2018-19 Allamaprabhu Vuss Niyamit Kalloli 09, Allamaprabhu Vuss Niyamit Kalloli, Kalloli So Dist. Belagavi. Pan : Aafaa8818E . . . . . . . Appellant

section 80AC of the Act, however there was complete absence of authority vested with the Ld. CPC to carry out the disallowance u/s 143(1)(a)(v) of the Act. Therefore, the impugned action of denial of 80P deduction to the appellant by the Ld. CPC was barred by jurisdiction, hence unlawful. And in the absence of any explicit power

M/S SHIRAGAO PRATHAMIK KRISHI PATTIN SAHAKARI BANK NIYAMIT,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1(3), BELAGAVI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara

disallowed the deduction for violation of Section 80P(2)(d) of the Income Tax Act (in brevity the Act). In relation to restriction u/s 80P(4) of the Act. The interest was added back with the total income as income amount of Rs.857,533/- as income from other sources. The Revenue authorities had relied on the order

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. INCOME TAX OFFICER, WARD-1, BAGALKOT., BAGALKOT

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance made by the AO shall stand confirmed.” 10. Thus, from perusal of the relevant extract of the order passed by the Income Tax Appellate Tribunal, it is evident that the Tribunal has merely referred to the decision of the Vector Shipping Services Pvt. Ltd. and has not adverted to the facts of the case. The Tribunal has not recorded

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. INCOME TAX OFFICER, TDS WARD, BELGAUM., BELGAUM

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance made by the AO shall stand confirmed.” 10. Thus, from perusal of the relevant extract of the order passed by the Income Tax Appellate Tribunal, it is evident that the Tribunal has merely referred to the decision of the Vector Shipping Services Pvt. Ltd. and has not adverted to the facts of the case. The Tribunal has not recorded

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. INCOME TAX OFFICER, TDS WARD, BELGAUM., BELGAUM

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance made by the AO shall stand confirmed.” 10. Thus, from perusal of the relevant extract of the order passed by the Income Tax Appellate Tribunal, it is evident that the Tribunal has merely referred to the decision of the Vector Shipping Services Pvt. Ltd. and has not adverted to the facts of the case. The Tribunal has not recorded

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1. BIJAPUR., BIJAPUR

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance made by the AO shall stand confirmed.” 10. Thus, from perusal of the relevant extract of the order passed by the Income Tax Appellate Tribunal, it is evident that the Tribunal has merely referred to the decision of the Vector Shipping Services Pvt. Ltd. and has not adverted to the facts of the case. The Tribunal has not recorded

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1. BIJAPUR., BIJAPUR

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance made by the AO shall stand confirmed.” 10. Thus, from perusal of the relevant extract of the order passed by the Income Tax Appellate Tribunal, it is evident that the Tribunal has merely referred to the decision of the Vector Shipping Services Pvt. Ltd. and has not adverted to the facts of the case. The Tribunal has not recorded

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1. BIJAPUR., BIJAPUR

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance made by the AO shall stand confirmed.” 10. Thus, from perusal of the relevant extract of the order passed by the Income Tax Appellate Tribunal, it is evident that the Tribunal has merely referred to the decision of the Vector Shipping Services Pvt. Ltd. and has not adverted to the facts of the case. The Tribunal has not recorded

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. INCOME TAX OFFICER, TDS WARD, BELGAUM., BELGAUM

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance made by the AO shall stand confirmed.” 10. Thus, from perusal of the relevant extract of the order passed by the Income Tax Appellate Tribunal, it is evident that the Tribunal has merely referred to the decision of the Vector Shipping Services Pvt. Ltd. and has not adverted to the facts of the case. The Tribunal has not recorded

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. INCOME TAX OFFICER, WARD-1, BAGALKOT., BAGALKOT

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance made by the AO shall stand confirmed.” 10. Thus, from perusal of the relevant extract of the order passed by the Income Tax Appellate Tribunal, it is evident that the Tribunal has merely referred to the decision of the Vector Shipping Services Pvt. Ltd. and has not adverted to the facts of the case. The Tribunal has not recorded

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. INCOME TAX OFFICER, TDS WARD, BELGAUM., BELGAUM

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance made by the AO shall stand confirmed.” 10. Thus, from perusal of the relevant extract of the order passed by the Income Tax Appellate Tribunal, it is evident that the Tribunal has merely referred to the decision of the Vector Shipping Services Pvt. Ltd. and has not adverted to the facts of the case. The Tribunal has not recorded

GOA ELECTRONICS LIMITED,PANAJI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CPC, BENGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपीलसं. / Ita No. 41/Pan/2021 धििाारण वर्ा / Assessment Year : 2018-19 Goa Electronics Ltd., Ground Floor, Sharma Shakti Bhavan, Edc Complex, Patto, Panaji, Goa – 403 001 . . . . . . . अपीलाथी / Appellant Pan:Aaacg7029G

13,15,486/-, u/s. 36(1)(va) of the Act for delayed payment of employees’ contribution towards PF & ESI. 4. Briefly stated, the facts of ITA No. 47/PAN/2021 4.1 The appellant is a Private Limited Company having dealership of M/s. Mahindra & Mahindra Ltd., whereby they sell Mahindra & Mahindra brand vehicles in the state of Goa. ITAT-Panaji Page

MUKTAR AUTOMOBILES PRIVATE LIMITED,VERNA vs. DCIT, CPC, BENGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपीलसं. / Ita No. 41/Pan/2021 धििाारण वर्ा / Assessment Year : 2018-19 Goa Electronics Ltd., Ground Floor, Sharma Shakti Bhavan, Edc Complex, Patto, Panaji, Goa – 403 001 . . . . . . . अपीलाथी / Appellant Pan:Aaacg7029G

13,15,486/-, u/s. 36(1)(va) of the Act for delayed payment of employees’ contribution towards PF & ESI. 4. Briefly stated, the facts of ITA No. 47/PAN/2021 4.1 The appellant is a Private Limited Company having dealership of M/s. Mahindra & Mahindra Ltd., whereby they sell Mahindra & Mahindra brand vehicles in the state of Goa. ITAT-Panaji Page

VIRUPAXAPPA SIDRAMAPPA BEMBALGI,BELAGAVI vs. INCOME TAX OFFICER, BELGAVU

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 011/Pan/2025 Assessment Year : 2017-18 M/S Virupakaxappa Sidramappa Bembalgi 580, Saraf Katta, Shahapur, Belgaum-590003. Pan : Aadfv3936F . . . . . . . Appellant

disallowance of (i) total URD purchases of ₹1,61,75,480/- and (ii) Labour charges paid for ornamentation ₹3,86,340/- or Option- (B) addition of ₹45,29,674/- on account of estimation of gross profit @40% of estimated ad-hoc sales/turnover of ₹250Lakhs. Since the first option(A) will result into profit of more than the turnover

RAJA BHAT AND KUMUDA FOUNDATION,BELAGAVI vs. PR.COMMISSIONER OF INCOME TAX , BELAGAVI

The appeal of the assessee is ALLOWED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2022-23 Raja Bhat & Kumuda Foundation Plot No. 4, Rs No1368, Kumudini, Sadashiv Nagar, Belgavi-590001 Pan:Aajcr6351B . . . . . . . Appellant

10 of 16 Raja Bhat & Kumuda Foundation Vs ITO ITA No.0270/PAN/2024 AY:2022-23 13. The aforestated proposition has been fostered by catena of judicial precedents including ‘CIT(E) Vs Anjana Foundation’(supra), ‘Nav Chetna Charitable Trust Vs CIT(E)’[2024, 169 taxmann.com 543 (Bom)], ‘Shree Bhairav Seva Samiti Vs ITO’[2023, 101 ITR 708(Mum)] & ‘Sirur Shikshan Prasarak Mandal

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

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

disallow only 30% of such labour charges paid to karigars/artisans as excessive. Au contraire, in first appellate proceedings, these additions were deleted in tandem for all the years without vouching key evidences & merits of the cases but by outdoing the provisions of rule 46A (supra) and section 250(6) of the Act. ITAT-Panaji Page 9 of 16 M/s Potdar