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

10-15 years without any borrowings. When we analyse the facts and circumstances of the present case, we clearly noted that on the issue involved in the present case, the AO has noted certain reason to dislodge the contention of the assessee in para 3 of the assessment order (supra) and, thereafter, by relying on the judgements

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

10-15 years without any borrowings. When we analyse the facts and circumstances of the present case, we clearly noted that on the issue involved in the present case, the AO has noted certain reason to dislodge the contention of the assessee in para 3 of the assessment order (supra) and, thereafter, by relying on the judgements

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

27[(not being interest referred to in section 194LB or section 194LC)I 28[or section 194LD] 29[***] or any other sum chargeable under the provisions of this Act (not being income chargeable under the head "Salaries" 31[***]) shall, at the time of credit of such income to the account of the payee or at the time of payment thereof

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

In the result, the appeal of the assessee is allowe

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

27,36,096/- to co-operative societies without TDS is liable to be disallowed societies without TDS is liable to be disallowed @30% u/s 40(a)(ia) ignoring the @30% u/s 40(a)(ia) ignoring the provisions of section 194A(3)(iii)(a) and possible view thereon. 194A(3)(iii)(a) and possible view thereon. 7. The Pr.CIT erred

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.

27,504/- that was made by the A.O towards unpaid creditors/advances, therefore, the additional ground of appeal so raised by the assessee before us merits admission. 10. Adverting to the merits of the case, we shall first take up the grievance of the assessee company as regards the upholding of the disallowance of administrative expenses under Sec. 14A r.w Rule

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.

27,504/- that was made by the A.O towards unpaid creditors/advances, therefore, the additional ground of appeal so raised by the assessee before us merits admission. 10. Adverting to the merits of the case, we shall first take up the grievance of the assessee company as regards the upholding of the disallowance of administrative expenses under Sec. 14A r.w Rule

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

In the result, both appeals of the assessee are allowed

disallowance on such deduction. Hence, it cannot be held that Assessing Officer has not conducted any enquiry or investigated the issue which he was required to do so before allowing the claim of deduction u/s 80 IA or has allowed without examining the assessee's transaction with its subsidiary, Noida Towers Private Limited. 24. One of the key allegations

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

In the result, both appeals of the assessee are allowed

disallowance on such deduction. Hence, it cannot be held that Assessing Officer has not conducted any enquiry or investigated the issue which he was required to do so before allowing the claim of deduction u/s 80 IA or has allowed without examining the assessee's transaction with its subsidiary, Noida Towers Private Limited. 24. One of the key allegations

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) The Learned CIT(A) has erred in upholding that the appellant has failed to establish how 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

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PANAJI vs. M/S MILROC GOOD EARTH PROPERTY AND DEVELOPERS LLP, PANAJI

In the result, cross-objection filed by the assessee in CO No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं./Ita No. 26/Pan/2018 ""या"ेपसं./Co.No.06/Pan/2018 (Arising Out Of Ita No.26/Pan/2018) "नधा"रण वष" /Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax Circle-1(1), Panaji, Goa .......अपीलाथ" / Appellant बनाम / V/S. M/S. Milroc Good Earth Property & Developers Llp, 501, 5Th Floor Milroc Lar Menezes, S.V. Road, Panaji-Goa - 403001 Pan : Aaacg7222M ……""यथ" / Respondent

disallowance, though only to the said extent. As regards the balance outstanding liability of Rs.2,01,609/-(supra) that was added by the Assessing Officer u/s.41(1) of the Act, though the assessee had in the course of the proceedings before the CIT(A) produced confirmations from the parties for an amount of Rs.1,27,306/- but the CIT(Appeals

VGM EXPORT,VASCO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 114/Pan/2023 Assessment Year : 2010-11 Vgm Export Suvarn Bandekar Building, Swatantra Path, Vasco, Goa Pan : Aaafv6197P . . . . . . . Applicant V/S Joint Commissioner Of Income Tax, Margao Range, Margao. . . . . . . . Respondent Appearances Assessee By : Mr P B Deshpande [‘Ld. Ar’] Revenue By : Mr Ravindra Hattalli [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 20/02/2025 घोषणा की तारीख / Date Of Pronouncement : 25/02/2025

27,447/- disallowance u/s 40(a) r.w.s. 195 of the Act for non-deduction of tax at source from sampling charges paid to Hongkong Party and (c) ₹1,14,11,643/- disallowance of forex fluctuation loss claimed in respect of closing balance of sale proceeds held in Exchange Earners Foreign Currency Account [‘EEFC A/c’ hereinafter] maintained with two IDBI banks

THE BELGAUM URBAN CREDIT SOUHARDA SAHAKARI LIMITED,BELGAVI vs. INCOME TAX OFFICER, WARD - 2(1), BELGAVI

In the result, appeal in ITA No

Bench: Shri Partha Sarathi Chaudhury, Jm

27-08-2013 disallowing the claim of deduction u/s 80P(2)(a)(i) of the Act. The ld. A.O observed vide para 4 of his decision that if the income of a Co-operative Society includes profits and gains of banking including providing credit facilities carried on by such Co-operative Society it will not be exempt from

THE BELGAUM URBAN CREDIT SOUHARDA SAHAKARI LIMITED,BELGAVI vs. INCOME TAX OFFICER, WARD - 2(1), BELGAVI

In the result, appeal in ITA No

Bench: Shri Partha Sarathi Chaudhury, Jm

27-08-2013 disallowing the claim of deduction u/s 80P(2)(a)(i) of the Act. The ld. A.O observed vide para 4 of his decision that if the income of a Co-operative Society includes profits and gains of banking including providing credit facilities carried on by such Co-operative Society it will not be exempt from

INCOME TAX OFFICER, WARD 1(2), BELAGAVI vs. SH. GIRISH PRAKASH VERNEKAR, BELAGAVI

In the result, the appeal filed by the Revenue is dismissed and the cross objection

Bench: Shri Shamim Yahya, Am & Shri Ram Lal Negi, Jm

27,99,180 Total Rs.28,73,78,360 Rs. 4,37,07,261 Entire Credit Purchases of Rs.28,73,78,360/- which are duly accounted in the appellants Books of accounts. Hence, there is absolutely no reason for Cash Purchases of Rs.4,37,07,261/-. [B] Since appellant is one of the regular major customer of RAJESH EXPORTS they might

BANDEKAR BROTHERS PRIVATE LIMITED,VASCO-DA-GAMA, GOA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PANAJI, GOA

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2013-14 Bandekar Brothers Pvt. Ltd. Post Box No. 11, Suvarna Bandekar Bldg., Swatantra Path, Vasco-Da-Gama Goa-403802 Pan: Aaacb5502B . . . . . . . Appellant V/S Asstt. Commissioner Of Income Tax, Circle-2(1), Panaji, Goa. . . . . . . . Respondent Represented Assessee By: Mr Pramod & Mr Shriniwas Deshpande [‘Ld. Ar’] Revenue By: Mr M Satish & Mr Renga Rajan [‘Ld. Dr’] Date Of Conclusive Hearing : 12/01/2026 Date Of Pronouncement : 11/02/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income-

disallowance of Renewal Charges of Mining Lease of Rs16,00,00,000/- He failed to appreciate that the learned Assessing Officer was wrong in holding the expenditure as Capital Expenditure. He ignored the fact that the appellant was in mining business since past several years in the same mine, hence charges for renewal of mining lease was entirely a revenue

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI , BELAGAVI vs. SHRI IDREES MOHAMMED, KALABURAGI

The appeal of the Revenue is partly allowed in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2017-2018 Dy. Commissioner Of Income Tax, Central Circle, Belagavi, . . . . . . . Appellant V/S Idrees Mohammed Shop No. 4Cc, New Vegetable Market, Main Road, Kalaburagi, Karnataka-585101. Pan: Aajpi7572E . . . . . . . Respondent Represented Assessee By: Mr Ramesh Mudhol [‘Ld. Ar’] Revenue By: Mr Sashi Saklani [‘Ld. Dr’] Date Of Conclusive Hearing : 11/03/2026 Date Of Pronouncement : 01/04/2026 Order Per G. D. Padmahshali; This Appeal Is Filed By The Revenue U/S 253(2) Of The Income-Tax

disallowance of agricultural income and treating ITAT-Panaji Page 4 of 30 DCIT Vs Idrees Mohammed ITA No. 149/PAN/2023 AY: 2017-18 the same as Income from Other Sources without appreciating that the assessee did not produce any documentary evidence in support of his agricultural income during the course of assessment proceeding and the agricultural income offered by the assessee

M/S R. S. SHETYE & BROS,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), PANAJI

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.37/Pan/2023 (A.Y.2016-17) R.S.Shetye & Bros, Vs Acit 1(1), Flat.No.14, 1 St Floor, Aaykar Bhavan, . Trionara Apartments, Edc, Patto, New Muncipal Market, Panjim Panaji- Goa-403001. Goa-403001. Pan .No.Aabfr9785N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

disallowance of community development and village welfare 7 ITA. No.37/PAN/2023 R.S.Shetye and Bros. expenses and this ground of appeal allowed in favour of the assessee. 7.On the second disputed issue, the Ld.AR mentioned that the expenses on stamp duty and registration charges of renewal of mining lease, paid as part payment towards second renewal of mining lease for the period

THE CAMP MULTIPURPOSE PRIMARY AGRICULTURE COOPERATIVE SOCIETY LIMITED,PERNEM, GOA vs. INCOME TAX OFFICER, WARD 2 (1), PANAJI, GOA

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

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

27 numbers/PAN/20223/24&25 dated 28-11-2025 –Akshaya Co-Op Credit society & others Vs ITO dealt at Para 7 of the order on the subject matter of interest income from cooperative banks is eligible for deduction u/s 80P(2)(d) of the Act read as under: “7.------“The Third disputed issue, where the AO and CIT(A) has not allowed

M/S SANKAMTAL HOTEL PRIVATE LTD.,BELAGAVI vs. THE ASST. COMMISSIONER OF INCOME TAX CIRCLE - 2 (1), BELAGAVI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2008-09 M/S Sankamtal Hotel Acit, Circle-1, Pvt. Ltd. Belagavi S. Parthasarathi, Advocate, 3/1, Pranava Vs. Complex, 5Th Cross, Malleswaram, Bangalore- 560 003. Pan: Aadcs 5106 P (Appellant) (Respondent) Present For: Appellant By : Smt. Pratibha R., Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 14.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Arising Out Of The Order Of Ld. Cit(A), -Belagavi In Ita No.51/Bgm/2016-17 Dated 25.02.2018 Against The Assessment Order Passed By Acit, Circle-2(1), Belagavi U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The ‘Act’) Dated 14.03.2016 For A.Y. 2008-09. 2. There Is A Delay Of Five Days In Filing The Present Appeal For Which The Petition For Condonation Of Delay & Affidavit Are Placed On Record. From The Affidavit, We Note That The Assessee Was Out Of Station When The Appeal Memo Was Sent To Him By The Counsel For Its Signature & Therefore A Short Delay Of 5 Days Occurred. Considering The Petition & In The Interest Of Justice & Fair Play, We Find It Proper To Admit The Appeal & Proceed To Adjudicate Thereon.

disallowances as made by the learned CIT(A) are arbitrary excessive and ought to be reduced substantially. 3. Before us, Smt. Pratibha R. Advocate appeared on behalf of the assessee and Shri Mayur Kamble, Sr. DR represented the Department. 4. Brief facts as culled out from the records are that the assessee is running a hotel under the name