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

In the result, appeal of assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2015-16 M/S. Ahiliabai Sardessai Assistant Commissioner Of 301, Lotus Court, M. G. Income-Tax, Circle-1(1), Vs. Road, St. Inwz Junction, Panaji. Panaji, Goa-403001. (Pan: Aagfa9044G) (Appellant) (Respondent) Present For: Appellant By : Shri N. J. Prabhudesai, Ar Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 17.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Directed Against The Order Of Ld. Cit(A), Panaji-1 Vide Ita No. Cit(A), Pnj-1/10391/2017-18 Dated 14.09.2018 For A.Y. 2015-16 Passed Against The Assessment Order U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Acit, Circle-1(1), Panaji, Goa Dated 13.12.2017. 2. Shri N. J. Prabhudesai, Ar Appeared On Behalf Of The Assessee & Shri Mayur Kamble, Sr. Dr Appeared On Behalf Of The Revenue.

disallowance of Rs.5,29,273/- made by the Ld. AO under Rule 8D(2)(iii) of the Income-tax Rules, 1962 (hereinafter referred to as the “Rules”) read with section 14A of the Act. 4. Brief facts as culled out from records are that assessee is a partnership firm engaged in the business of iron ore mining, cargo handling

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

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2013-14 Dcit, Circle-1, Udupi M/S. Manipal Technologies Limited, Vs. Udayavani Building, Manipal- 576104. Pan: Aabcm 9516 H (Appellant) (Respondent) Present For: Assessee By : Smt. Sheetal Borkar, Advocate Revenue By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 13.06.2022 Date Of Pronouncement : 15.06.2022 O R D E R Per Girish Agrawal: The Present Appeal Filed By The Department Is Arising Out Of The Order Of Commissioner Of Income Tax (Appeals), Mangaluru In Appeal No. Ita No. 10030/Udp/Cit(A)Mng/2016-17 Dated 27.11.2017 Against The Order Of Dcit, Circle- 1, Udupi Passed U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 29.03.2016. 2. There Are Six Grounds Of Appeal Taken By The Department In The Present Appeal, All Of Which Relate To The Disallowance Made U/S 14A Of The Act R.W.R. 8D(2)(Ii) & 8D(2)(Iii) Of The Income-Tax Rules, 1962 (Hereinafter Referred To As ‘The Rules), Amounting To Rs. 1,61,65,201/-.

10(34) of the Act. In the course of assessment proceeding, ld. AO noted that assessee has not disallowed any amount towards expenses incurred in relation to earning the said exempted income. Ld. AO show caused the assessee to explain as to why a disallowance u/s 14A read with Rule 8D should not be made, in response to which

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

10% under Article 11 of the India -UK Tax Treaty. Upon the said question being answered the Department is at liberty to gross up the tax rate in an appropriate manner.” (Emphasis suppled) . Thus, 5. We considering the facts, submissions and ratio of the judicial decision restore this disputed issue for limited purpose to the file of the Assessing officer

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

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

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

REMOTE SOFTWARE SOLUTIONS PVT. LTD,ALTO BETIM vs. ASSESSING OFFICER, WARD - 2(4), PANAJI

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

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.34 & 35/Pan/2022 िनधा"रण वष" / Assessment Years : 2018-19 To 2019-20 Remote Software Solutions Vs. Assessing Officer, Pvt. Ltd., Ward-2(4), Panaji. H.No.1661, Near Tarun Bharat, Alto Betim, Penha De Franca-Goa- 403521. Pan : Aadcr0144G Appellant Respondent Assessee By : None Revenue By : Shri Ashwini D. Hosmani Date Of Hearing : 04.09.2023 Date Of Pronouncement : 06.09.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Assessee Directed Against The Separate Orders Of The National Faceless Appeal Centre, Delhi [‘Nfac’] Dated 16.03.2022 For The Assessment Years 2018-19 & 2019-20 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned 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.34/Pan/2022 For The Assessment Year 2018-19 Are Stated Herein.

section 139(1) of the Act. On appeal before the NFAC, the NFAC confirmed the said disallowance. 5. Being aggrieved, the appellant is in appeal before us in the present appeal. 6. We heard the rival submissions and perused the material on record. The only issue relates to the confirmation of disallowance of Rs.40,29,887/- made

REMOTE SOFTWARE SOLUTIONS PVT. LTD,ALTO BETIM vs. ASSESSING OFFICER, WARD - 2(4), PANAJI

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

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.34 & 35/Pan/2022 िनधा"रण वष" / Assessment Years : 2018-19 To 2019-20 Remote Software Solutions Vs. Assessing Officer, Pvt. Ltd., Ward-2(4), Panaji. H.No.1661, Near Tarun Bharat, Alto Betim, Penha De Franca-Goa- 403521. Pan : Aadcr0144G Appellant Respondent Assessee By : None Revenue By : Shri Ashwini D. Hosmani Date Of Hearing : 04.09.2023 Date Of Pronouncement : 06.09.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Assessee Directed Against The Separate Orders Of The National Faceless Appeal Centre, Delhi [‘Nfac’] Dated 16.03.2022 For The Assessment Years 2018-19 & 2019-20 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned 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.34/Pan/2022 For The Assessment Year 2018-19 Are Stated Herein.

section 139(1) of the Act. On appeal before the NFAC, the NFAC confirmed the said disallowance. 5. Being aggrieved, the appellant is in appeal before us in the present appeal. 6. We heard the rival submissions and perused the material on record. The only issue relates to the confirmation of disallowance of Rs.40,29,887/- made

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

SHRI VENANCIO GONSALVES,CHIMBEL, GOA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PANAJI

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Rao

section 5A of I.T. Act are applicable to them. Similar additions have been made to the returned income of both spouses. The appeal in the case of the wife Smt. Alicia Fialho was passed on 22.12.2017 by CIT (Appeals). Same grounds have been 4 ITA.No.251/PAN./2019 raised in the case of husband, who is the appellant in this case

PRATHAMIK KRISHI PATTIN SAHAKARI NIYAMIT,SALAPUR vs. ITO, WARD - 1(5), 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

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

29,452/- made by the AO is deleted. (Emphasis supplied) ITAT-Panaji Page 6 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025 4 Aggrieved by like action adopted by the Ld. CIT(A) in granting the relief to respondent assessee for the assessment years 2018-19 to 2022-23, the Revenue came in present bunch

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

29,452/- made by the AO is deleted. (Emphasis supplied) ITAT-Panaji Page 6 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025 4 Aggrieved by like action adopted by the Ld. CIT(A) in granting the relief to respondent assessee for the assessment years 2018-19 to 2022-23, the Revenue came in present bunch

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, 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

29,452/- made by the AO is deleted. (Emphasis supplied) ITAT-Panaji Page 6 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025 4 Aggrieved by like action adopted by the Ld. CIT(A) in granting the relief to respondent assessee for the assessment years 2018-19 to 2022-23, the Revenue came in present bunch

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

29,452/- made by the AO is deleted. (Emphasis supplied) ITAT-Panaji Page 6 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025 4 Aggrieved by like action adopted by the Ld. CIT(A) in granting the relief to respondent assessee for the assessment years 2018-19 to 2022-23, the Revenue came in present bunch

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

29,452/- made by the AO is deleted. (Emphasis supplied) ITAT-Panaji Page 6 of 16 M/s Potdar Brothers ITA Nos.175 to 177 & 179 to 180/PAN/2025 4 Aggrieved by like action adopted by the Ld. CIT(A) in granting the relief to respondent assessee for the assessment years 2018-19 to 2022-23, the Revenue came in present bunch

SALGAOCAR MINING INDUSTRIES PVT. LTD,PANAJI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, MARGAO

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2006-2007 M/S Salgaocar Mining Industries Pvt Ltd. Salgaonkar Bhava, Altino, Panaji, Goa-403001. Pan: Aabcs8862N . . . . . . . Appellant V/S Dy. Commissioner Of Income Tax, Circle-1, Margao, Goa. . . . . . . . Respondent Represented Assessee By: Mr Sukhsagar Syal [‘Ld. Ar’] Revenue By: Ms Rijjula Uniyal [‘Ld. Dr’] Date Of Conclusive Hearing : 20/01/2026 Date Of Pronouncement : 29/01/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income- Tax Act, 1961 [‘The Act’] Impugns The Order Dt. 20/03/2025 Passed U/S 250 Of The Act By Commissioner Of Income Tax(Appeals-2), Panaji [‘Ld. Cit(A)’] Which In Turn Dealt With Order Dt. 20/12/2011 Passed U/S 144 Of The Act By Dcit, Circle-1, Margao Goa [‘Ld. Ao’] Anent To Assessment Year 2006-07.[‘Ay’]

disallowance of excess depreciation of 1,82,643/- . 2.4 Aggrieved assessee company preferred an appeal u/s 246A r.w.s. 249 of the Act before the Ld. CIT(A) on 25/01/2012 which was instituted for first appellate adjudication vide Appeal No : CIT(A)/PNJ/10310/2019-20 and dismissed by the Ld. CIT(A) by an order dt. 17/03/2025. ITAT-Panaji Page

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