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

38 taxmann.com 77 and the consequential dismissal of the SLP filed before the Hon'ble Supreme Court by the Revenue 5 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka no disallowance u/s 40(a)(ia) of the Act was called for. On a specific query from the Bench as to show that there

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

38 taxmann.com 77 and the consequential dismissal of the SLP filed before the Hon'ble Supreme Court by the Revenue 5 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka no disallowance u/s 40(a)(ia) of the Act was called for. On a specific query from the Bench as to show that there

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

38 taxmann.com 77 and the consequential dismissal of the SLP filed before the Hon'ble Supreme Court by the Revenue 5 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka no disallowance u/s 40(a)(ia) of the Act was called for. On a specific query from the Bench as to show that there

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

38 taxmann.com 77 and the consequential dismissal of the SLP filed before the Hon'ble Supreme Court by the Revenue 5 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka no disallowance u/s 40(a)(ia) of the Act was called for. On a specific query from the Bench as to show that there

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

38 taxmann.com 77 and the consequential dismissal of the SLP filed before the Hon'ble Supreme Court by the Revenue 5 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka no disallowance u/s 40(a)(ia) of the Act was called for. On a specific query from the Bench as to show that there

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

38 taxmann.com 77 and the consequential dismissal of the SLP filed before the Hon'ble Supreme Court by the Revenue 5 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka no disallowance u/s 40(a)(ia) of the Act was called for. On a specific query from the Bench as to show that there

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

38 taxmann.com 77 and the consequential dismissal of the SLP filed before the Hon'ble Supreme Court by the Revenue 5 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka no disallowance u/s 40(a)(ia) of the Act was called for. On a specific query from the Bench as to show that there

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

38 taxmann.com 77 and the consequential dismissal of the SLP filed before the Hon'ble Supreme Court by the Revenue 5 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka no disallowance u/s 40(a)(ia) of the Act was called for. On a specific query from the Bench as to show that there

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

38 taxmann.com 77 and the consequential dismissal of the SLP filed before the Hon'ble Supreme Court by the Revenue 5 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka no disallowance u/s 40(a)(ia) of the Act was called for. On a specific query from the Bench as to show that there

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

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

DAMODAR MANGALJI & COMPANY LIMITED,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), PANAJI

Appeals stands DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 034 & 035/Pan/2025 Assessment Year : 2011-12 & 2014-15 Damodar Mangalji & Company Ltd. Damodar Niwas, 1St Floor, Mc Road, Panaji, Goa-403001. Pan : Aaacd6880G . . . . . . . Appellant V/S Jt./Asstt. Commissioner Of Income Tax, Range-1/Circle-1(1), Goa. . . . . . . . Respondent Appearances Assessee By : Adv Rahul Sarda [‘Ld. Ar’] Revenue By : Mr M Satish [‘Ld. Dr’] Date Of Conclusive Hearing : 20/11/2025 Date Of Pronouncement : 18/12/2025 Order Per G. D. Padmahshali; The Captioned Twin Appeals Of Assessee Instituted U/S 253(1) Of The Income-Tax Act, 1961 [‘The Act’] Are Directed Against Separate Din & Order 1070138041(1) Dt. 08/11/2024 & 1070321994(1) Dt. 13/11/2024 Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Ld. Nfac/Cit(A)’] Which Sprang From Assessment Orders Passed U/S 143(3) Of The Act Anent To Assessment Years 2011-12 & 2014-15 [‘Ay’].

38,465/- and (4) addition of ₹36,73,895/- being difference in closing inventory due to incorrect valuation which remain unexplained satisfactorily to the Ld. AO. ITA No 035/PAN/2025, AY : 2014-15; 5. Similarly for AY 2014-15 the assessee filed its return of income online on 29/11/2014 declaring ITAT-Panaji Page 3 of 32 Damodar Mangalji & Company

DAMODAR MANGALJI & COMPANY LIMITED,PANAJI vs. THE JOINT COMMISSIONER OF INCOME TAX, RANGE - 1, PANAJI

Appeals stands DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 034 & 035/Pan/2025 Assessment Year : 2011-12 & 2014-15 Damodar Mangalji & Company Ltd. Damodar Niwas, 1St Floor, Mc Road, Panaji, Goa-403001. Pan : Aaacd6880G . . . . . . . Appellant V/S Jt./Asstt. Commissioner Of Income Tax, Range-1/Circle-1(1), Goa. . . . . . . . Respondent Appearances Assessee By : Adv Rahul Sarda [‘Ld. Ar’] Revenue By : Mr M Satish [‘Ld. Dr’] Date Of Conclusive Hearing : 20/11/2025 Date Of Pronouncement : 18/12/2025 Order Per G. D. Padmahshali; The Captioned Twin Appeals Of Assessee Instituted U/S 253(1) Of The Income-Tax Act, 1961 [‘The Act’] Are Directed Against Separate Din & Order 1070138041(1) Dt. 08/11/2024 & 1070321994(1) Dt. 13/11/2024 Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Ld. Nfac/Cit(A)’] Which Sprang From Assessment Orders Passed U/S 143(3) Of The Act Anent To Assessment Years 2011-12 & 2014-15 [‘Ay’].

38,465/- and (4) addition of ₹36,73,895/- being difference in closing inventory due to incorrect valuation which remain unexplained satisfactorily to the Ld. AO. ITA No 035/PAN/2025, AY : 2014-15; 5. Similarly for AY 2014-15 the assessee filed its return of income online on 29/11/2014 declaring ITAT-Panaji Page 3 of 32 Damodar Mangalji & Company

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

ACIT, CIRCLE - 2(1), PANAJI vs. M/S JAY RAM ORE CARRIERS, VASCO

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

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.227/Pan/2018 िनधा"रण वष" / Assessment Year : 2014-15 Acit, Circle-2(1), Panaji, Vs. M/S. Jay Ram Ore Goa. Carriers, 2Nd Floor, Sunflower Appts, Opp. St. Andrew Church, Vasco, Goa. Pan : Aaffj0752R Appellant Respondent Revenue By : Shri N. Shrikanth Assessee By : Shri R. D. Onkar Date Of Hearing : 16.08.2023 Date Of Pronouncement : 29.08.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Revenue Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-2, Panaji [‘The Cit(A)’] Dated 30.03.2018 For The Assessment Year 2014-15. 2. Briefly, The Facts Of The Case Are That The Respondent-Assessee Is A Partnership Firm Engaged In The Business Of Operation Of Barge Of Contract. The Return Of Income For The Assessment Year 2014-15 Was Filed By The Appellant Firm On 29.07.2014 Declaring Total Income

disallowances, the appellant firm had filed an appeal before the ld. CIT(A) contending that the quantum of remuneration allowable u/s 40(b)(v) read with Explanation 3 thereto should be computed based on the net profit as disclosed in Profit & Loss Account, irrespective of under which head of income is to be taxed. As regards

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

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, the Revenue

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, UDUPI., UDUPI vs. M/S SYNDICATE BANK,, UDUPI

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

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.337/Pan/2016 िनधा"रण वष" / Assessment Year : 2002-03 Dcit, Circle-1, Udupi. Vs. M/S. Syndicate Bank, Central Accounts Department, Tax Cell, Head Officer, Manipal. Pan : Aaccs4699E Appellant Respondent C.O. No.01/Pan/2023 (Arising Out Of Ita No.337/Pan/2016) िनधा"रण वष" / Assessment Year : 2002-03 Canara Bank (Erstwhile Vs. Dcit, Circle-1, Udupi. Syndicate Bank), F.M. Wing, Head Office, 112, J. C. Road, Bengaluru- 560002. Pan : Aaacc6106G Appellant Respondent Revenue By : Smt. Ashwini D. Hosmani Assessee By : Shri S. Ananthan Smt. S. Lalitha R. Date Of Hearing : 07.09.2023 Date Of Pronouncement : 09.10.2023

section 115JB of the Act. While doing so, the Assessing Officer made addition of Rs.98,38,14,000/- being the amount of provision for bad and doubtful debts debited to the Profit & Loss Account as against the actual provision for bad and doubtful debts of Rs.84,10,28,000/-. The Assessing Officer also made addition of Rs.16

M/S ESTEEM INDUSTRIES (P) LTD.,SATTARI GOA vs. INCOME TAX, WARD - 2,, MARGAO

In the result, appeal of the assessee in ITA No

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) Vic Industries, Vs Ito, Ward-2(5), Plot No.78, Pissurlem Panaji - Goa Industrial Estate, Sattari, Goa. Pan: Aacfv 8626 M Appellant Respondent M/S. Esteem Industries P. Vs Ito, Ward-2, Ltd., Plot No.76-77, Margao - Goa Pissurlem Industrial Estate, Sattari, Goa. Pan: Aaace 9474 F Appellant Respondent

38,870/- and had claimed deduction u/sec. 80IB of Rs.1,06,02,371/-. The Assessing Officer (AO) disallowed deduction claimed u/sec. 80IB on Sales Tax Incentives of Rs.27,54,214/-, Bank Interest of Rs.11,02,117/-, Excise Refund received of Rs.1,47,99,719/-; and Entry Tax refund of Rs.11,08,224/-. Against the order of AO, assessee had preferred

M/S VIC INDUSTRIES.,SATTARI, GOA vs. INCOME TAX OFFICER, WARD-2 (5), PANAJI

In the result, appeal of the assessee in ITA No

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) Vic Industries, Vs Ito, Ward-2(5), Plot No.78, Pissurlem Panaji - Goa Industrial Estate, Sattari, Goa. Pan: Aacfv 8626 M Appellant Respondent M/S. Esteem Industries P. Vs Ito, Ward-2, Ltd., Plot No.76-77, Margao - Goa Pissurlem Industrial Estate, Sattari, Goa. Pan: Aaace 9474 F Appellant Respondent

38,870/- and had claimed deduction u/sec. 80IB of Rs.1,06,02,371/-. The Assessing Officer (AO) disallowed deduction claimed u/sec. 80IB on Sales Tax Incentives of Rs.27,54,214/-, Bank Interest of Rs.11,02,117/-, Excise Refund received of Rs.1,47,99,719/-; and Entry Tax refund of Rs.11,08,224/-. Against the order of AO, assessee had preferred