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

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

22. Still aggrieved, the assessee is in appeal before the Tribunal contending, inter alia, that the AO may be directed to calculate the disallowance attributable to exempted income as per Rule 8D (2)(iii) of the I.T. Rules 1962 by considering the average investment value calculated by taking into consideration only those investments which yielded the assessee-company

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

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

22. Still aggrieved, the assessee is in appeal before the Tribunal contending, inter alia, that the AO may be directed to calculate the disallowance attributable to exempted income as per Rule 8D (2)(iii) of the I.T. Rules 1962 by considering the average investment value calculated by taking into consideration only those investments which yielded the assessee-company

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

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

10 Crores on 17/09/2011. The appellant while making the payment towards purchase of the property did not deduct TDS as per the provisions of section 195 of the Act under a bonafide belief that the said sellers of the property were residents as per the Income-tax Act. Noticing the non-deduction of TDS as per section

SHREE AMBEY FORGING PRIVAT LIMITED,PANAJI vs. ITO, WARD - (4), PANAJI

In the result, both appeals of the assessee are allowed

disallowance made by the Assessing Officer has been remitted back to the Assessing Officer which finding is based on factual aspects which would not call for interference by us, that too, by formulating substantial question of law. The Assessing Officer has to undertake the exercise of factual determination. As such, without expressing any opinion on merits with regard to question

SCORPIO IRON LTD,PANAJI vs. ITO, WARD - 1(4), PANAJI

In the result, both appeals of the assessee are allowed

disallowance made by the Assessing Officer has been remitted back to the Assessing Officer which finding is based on factual aspects which would not call for interference by us, that too, by formulating substantial question of law. The Assessing Officer has to undertake the exercise of factual determination. As such, without expressing any opinion on merits with regard to question

M/S SOVA,PANAJI vs. PR. COMMISSIONER OF INCOME TAX, PANAJI

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2018-19 M/S Sova Salgaocar Bhavan, Altinho, Panaji, Goa-403001. Pan: Aacfs8862Q . . . . . . . Appellant V/S Pr. Commissioner Of Income Tax, Panaji, Goa. . . . . . . . Respondent

22,65,10,180/- allowed in computation of income by the Ld. NFeAC. The assessee vide its reply dt. 12/12/2023 per contra requested to rectify the c/f current business loss to ₹27,38,53,538/-. Upon a specific query about the status of such rectification proceedings, the appellant submitted that same was still pending before the Ld. AO. Upon direction

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

INFRASTRUCTURE LOGISTICS PVT. LTD.,DONA PAULA vs. JOINT COMM. OF INCOME TAX, RANGE - 1, PANAJI

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 380/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 Infrastructure Logistics Pvt. Ltd. Cidade De Goa, Vainguinim Beach, Dona Paula, Goa-403 004. Pan : Aaaci9107R .......अपीलाथ" / Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Range-1, Panaji-Goa, ……""यथ" / Respondent आयकर अपील सं. / Ita No. 381/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 The Assistant Commissioner Of Income Tax, Central Circle, Panaji-Goa, .......अपीलाथ" / Appellant बनाम / V/S.

section 14A of the Act, but had failed to give any reason as to why the claim of the assessee that no part of the expenditure could be attributed towards earning of exempt income was not to be accepted. Although, the CIT(Appeals) in his order had tried to improve upon the aforesaid lapse of the A.O, but a perusal

ASSTT. COMM. OF INCOME TAX, CENTRAL CIRCLE, PANAJI vs. INFRASTRUCTURE LOGISTICS PVT. LTD., DONA PAULA

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 380/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 Infrastructure Logistics Pvt. Ltd. Cidade De Goa, Vainguinim Beach, Dona Paula, Goa-403 004. Pan : Aaaci9107R .......अपीलाथ" / Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Range-1, Panaji-Goa, ……""यथ" / Respondent आयकर अपील सं. / Ita No. 381/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 The Assistant Commissioner Of Income Tax, Central Circle, Panaji-Goa, .......अपीलाथ" / Appellant बनाम / V/S.

section 14A of the Act, but had failed to give any reason as to why the claim of the assessee that no part of the expenditure could be attributed towards earning of exempt income was not to be accepted. Although, the CIT(Appeals) in his order had tried to improve upon the aforesaid lapse of the A.O, but a perusal

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

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 any finding on the issue whether the provisions

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

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 any finding on the issue whether the provisions

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

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 any finding on the issue whether the provisions

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

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 any finding on the issue whether the provisions

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

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 any finding on the issue whether the provisions

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

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 any finding on the issue whether the provisions

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

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 any finding on the issue whether the provisions

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

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 any finding on the issue whether the provisions

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

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 any finding on the issue whether the provisions

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

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

10 of additional evidence taken us through the reconciliation / bifurcation of value of investment made by the appellant and submitted that, computation should have been carried out excluding value of investment earning or capable of earning taxable income only. The Ld. DR after going through the details of additional evidence, conceded to the revised computation of the appellant regarding