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8 results for “disallowance”+ Section 164(2)clear

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Key Topics

Section 15514Section 80P(2)(a)9Section 143(1)9Section 1546Section 5A4Section 114Section 12A4Deduction4Condonation of Delay4Section 143(3)

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

The appeal of the assessee is ALLOWED

ITA 270/PAN/2024[2022-23]Status: DisposedITAT Panaji19 Mar 2025AY 2022-23

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

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr S Manikandan [‘Ld. DR’]
Section 11Section 12ASection 143(1)Section 246A(1)Section 250Section 253(1)Section 8

164 (as the case may be) of the Act in a representative capacity. Thus, duty to cause & get account/books audited although casted upon the trust/institution and the obligation to file the audit report however continues to be on the trustees. 11. As noted earlier that, the accounts/books of the appellant trust was audited and report thereof was obtained much before

3
Disallowance3
Revision u/s 2633

MAHAVEER CO-OPERATIVE CREDIT SOCIETY LIMITED,ALAGUR, BAGALKOT vs. INCOME TAX OFFICER, WARD - 2, BAGALKOT

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 9/PAN/2019[2012-13]Status: DisposedITAT Panaji10 Nov 2022AY 2012-13

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.09/Pan/2019 िनधा"रण वष" / Assessment Year: 2012-13 Mahaveer Co-Operative Vs. Ito, Ward-2, Bagalkot. Credit Society Limited, Post : Alagur, Taluka : Jamakhandi, Dist. Bagalkot- 587301. Pan : Aabam6275F Appellant Respondent Assessee By : Shri Pramod Y. Vaidya Revenue By : Shri N. Shrikanth Date Of Hearing : 09.11.2022 Date Of Pronouncement : 10.11.2022 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Hubballi [‘The Cit(A)’] Dated 26.11.2018 For The Assessment Year 2012-13. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. On The Facts & Circumstances Of The Case & In Law The Learned Cit(A) Erred In Disallowing The Deduction U/S 80P(2)(A)(I) Of The Act, In Respect Of Income Earned From Associate Members/ Nominal Members. The Cit(A) Erred In Not Appreciating That — I) The Citizen’S Case Is Distinguishable On Facts As In The Present Case The Dealings Are With Members & There Are No Dealings With Public At Large.

For Appellant: Shri Pramod Y. VaidyaFor Respondent: Shri N. Shrikanth
Section 143(3)Section 80PSection 80P(2)(a)

disallowing the deduction u/s 80P(2)(a)(i) of the Act, in respect of income earned from Associate members/ Nominal members. The CIT(A) erred in not appreciating that — i) the Citizen’s case is distinguishable on facts as in the present case the dealings are with members and there are no dealings with public at large. 2 ii) regular

SHRI JINNAPPANNA CHOUGULE LALBAHADUR CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,BELGAUM vs. INCOME TAX OFFICER, BELGAUM

In the result, the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 274/PAN/2025[2015-16]Status: DisposedITAT Panaji07 Jan 2026AY 2015-16

Bench: Shri Pavan Kumar Gadalei T A. Nos.274,275 & 276/Pan/2025 (A.Y. 2015-16,2017-18 & 2018-19 ) Shri Jinnappanna Chougule Vs I T O, Lalbahadur Credit Souhard National E Assessment . Sahakari Niyamit, Centre, 2471,Lalbahadur Delhi. Akkamahadevi Chowk, Shirguppi Athani, Belagavi-591242, Karnataka. Pan .No. Aagas8466F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

section 80P(2)(a)(i) of the Act of Rs.22,60,074/- and similarly find that the assessee has debited to profit & loss account income tax paid of Rs.6,08,090/- and provision for bad and doubtful debts of Rs.8,00,000/- which is not admissible claim and made disallowance and assessed the total income of Rs.36,68,164

SHRI JINNAPPANNA CHOUGULE LALBAHADUR CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,BELGAUM vs. INCOME TAX OFFICER, BELGAUM

In the result, the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 276/PAN/2025[2018-19]Status: DisposedITAT Panaji07 Jan 2026AY 2018-19

Bench: Shri Pavan Kumar Gadalei T A. Nos.274,275 & 276/Pan/2025 (A.Y. 2015-16,2017-18 & 2018-19 ) Shri Jinnappanna Chougule Vs I T O, Lalbahadur Credit Souhard National E Assessment . Sahakari Niyamit, Centre, 2471,Lalbahadur Delhi. Akkamahadevi Chowk, Shirguppi Athani, Belagavi-591242, Karnataka. Pan .No. Aagas8466F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

section 80P(2)(a)(i) of the Act of Rs.22,60,074/- and similarly find that the assessee has debited to profit & loss account income tax paid of Rs.6,08,090/- and provision for bad and doubtful debts of Rs.8,00,000/- which is not admissible claim and made disallowance and assessed the total income of Rs.36,68,164

SHRI JINNAPPANNA CHOUGULE LALBAHADUR CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,2471, LALBAHADUR AKKAMAHADEVI CHOWK, SHIRGUPPI ATH vs. INCOME TAX OFFICER, BELGAUM

In the result, the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 275/PAN/2025[2017-18]Status: DisposedITAT Panaji07 Jan 2026AY 2017-18

Bench: Shri Pavan Kumar Gadalei T A. Nos.274,275 & 276/Pan/2025 (A.Y. 2015-16,2017-18 & 2018-19 ) Shri Jinnappanna Chougule Vs I T O, Lalbahadur Credit Souhard National E Assessment . Sahakari Niyamit, Centre, 2471,Lalbahadur Delhi. Akkamahadevi Chowk, Shirguppi Athani, Belagavi-591242, Karnataka. Pan .No. Aagas8466F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

section 80P(2)(a)(i) of the Act of Rs.22,60,074/- and similarly find that the assessee has debited to profit & loss account income tax paid of Rs.6,08,090/- and provision for bad and doubtful debts of Rs.8,00,000/- which is not admissible claim and made disallowance and assessed the total income of Rs.36,68,164

DEARHOOD FOUNDATION,BELAGAVI vs. THE DEPUTY DIRECTOR OF INCOME TAX, CPC, BENGALURU

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 202/PAN/2025[2022-23]Status: DisposedITAT Panaji23 Dec 2025AY 2022-23

Bench: Shri Pavan Kumar Gadalei T A. No.202/Pan/2025 (A.Y.2022-23 ) Dear Hood Foundation, Ddit, Vs. Plot.No.1/S,Kanbargi Cpc, Industrial Area, Bengaluru-560500. Kanabargi.S.O, Karnataka. Belgaum-590015, Karnataka. Pan/Gir No. Aaicd1005D (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By Shri.Pramod Y Vaidya.Ar Revenue By Shri.Sanket Deshmukh.Sr.Dr सुनवाई की तारीख/Date Of Hearing 23.12.2025 घोषणा की तारीख/Date Of Pronouncement 23.12.2025 Order Per Pavan Kumar Gadale, Jm:

Section 11Section 119(2)(b)Section 8

164 days in filing the appeal before the Hon’ble Tribunal and the assesse has filed an affidavit for condonation of delay. 2 DearHood Foundation. Whereas, the facts mentioned in the affidavit are reasonable and the Ld. DR has no specific objections. Accordingly, condone the delay and admit the appeal. 3. The Brief facts of the case are that

JENNY ELTON VALES,DONA PAULA vs. ITO, WARD - 5, MARGAO

In the result, the appeal of assessee in ITA No

ITA 64/PAN/2020[2007-08]Status: DisposedITAT Panaji30 Jan 2023AY 2007-08

Bench: Shri S.S. Viswanethra Ravi

For Appellant: Shri D. E. RobinsonFor Respondent: Shri N. Shrikanth
Section 143(1)Section 143(3)Section 154Section 155Section 5A

164/- was equally divided between the assessee and spouse as they are governed by the Portuguese Civil Code. He argued that there was no mistake apparent in the intimation u/s. 143(1) of the Act passed in the case of assessee to rectify the same and it is only the AO made addition being 50% of share in the hands

JENNY ELTON VALES,DONA PAULA vs. ITO, WARD - 5, MARGAO

In the result, the appeal of assessee in ITA No

ITA 65/PAN/2020[2009-10]Status: DisposedITAT Panaji30 Jan 2023AY 2009-10

Bench: Shri S.S. Viswanethra Ravi

For Appellant: Shri D. E. RobinsonFor Respondent: Shri N. Shrikanth
Section 143(1)Section 143(3)Section 154Section 155Section 5A

164/- was equally divided between the assessee and spouse as they are governed by the Portuguese Civil Code. He argued that there was no mistake apparent in the intimation u/s. 143(1) of the Act passed in the case of assessee to rectify the same and it is only the AO made addition being 50% of share in the hands