PRIME MINERAL EXPORTS PRIVATE LIMITED (NOW AMALGAMATED WITH FOMENTO RESOURCES PRIVATE LIMITED),PANAJI vs. JOINT COMMISSIONER OF INCOME TAX, RANGE - 1, PANAJI

The appeal stands partly allowed for statistical purpose in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 003/Pan/2023 Assessment Year : 2009-10 Prime Mineral Exports Pvt. Ltd. (Now Amalgamated With Fomento Resources Pvt. Ltd.) 102, 1St Fl. Kamat Metropolis-1, Behind Caculo Mall, St. Inez, Panaji, Goa-403001. . . . . . . .Appellant Pan : Aadcp1647E V/S Jt. Commissioner Of Income Tax, . . . . . . . Respondent Range-1, Panaji, Goa

1) of the Act. The whole of the addition amounting to Rs.12,05,828,/- be deleted in full. (b) The CIT(A) further erred in confirming the addition made by the 40 under section 4I(I) of the Act when no remission or cessation of the liability has been expressly granted by the concerned creditor and that the said liability

TUMKUR MINERALS PVT. LTD,VASCO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, appeal of the assessee is allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

disallowed u/sec. 40(a). The assessee company submitted that the payments were made for the services rendered outside India. The above income is neither received nor deemed to have been received in India nor accrues or arises in India. Hence, it falls outside the purview of sec.5 of the Act. The assessee also stated that its case is covered within

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

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

40(a)(ia) on such amounts. However, if any amount is found to be payable as on the year end the disallowance made by the A.O. shall stand confirmed. 7 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka 7. In regard to the levy u/s 201(1) & 201 (1A) of the Act, the issues

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

40(a)(ia) on such amounts. However, if any amount is found to be payable as on the year end the disallowance made by the A.O. shall stand confirmed. 7 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka 7. In regard to the levy u/s 201(1) & 201 (1A) of the Act, the issues

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

40(a)(ia) on such amounts. However, if any amount is found to be payable as on the year end the disallowance made by the A.O. shall stand confirmed. 7 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka 7. In regard to the levy u/s 201(1) & 201 (1A) of the Act, the issues

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

40(a)(ia) on such amounts. However, if any amount is found to be payable as on the year end the disallowance made by the A.O. shall stand confirmed. 7 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka 7. In regard to the levy u/s 201(1) & 201 (1A) of the Act, the issues

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

40(a)(ia) on such amounts. However, if any amount is found to be payable as on the year end the disallowance made by the A.O. shall stand confirmed. 7 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka 7. In regard to the levy u/s 201(1) & 201 (1A) of the Act, the issues

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

40(a)(ia) on such amounts. However, if any amount is found to be payable as on the year end the disallowance made by the A.O. shall stand confirmed. 7 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka 7. In regard to the levy u/s 201(1) & 201 (1A) of the Act, the issues

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

40(a)(ia) on such amounts. However, if any amount is found to be payable as on the year end the disallowance made by the A.O. shall stand confirmed. 7 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka 7. In regard to the levy u/s 201(1) & 201 (1A) of the Act, the issues

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

40(a)(ia) on such amounts. However, if any amount is found to be payable as on the year end the disallowance made by the A.O. shall stand confirmed. 7 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka 7. In regard to the levy u/s 201(1) & 201 (1A) of the Act, the issues

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

40(a)(ia) on such amounts. However, if any amount is found to be payable as on the year end the disallowance made by the A.O. shall stand confirmed. 7 ITA.Nos.152 to 161/PAN./2015 Ryatar Sahakari Sakkare Karkhane Niyamit, Timmapur Bagalkot Tq Karnataka 7. In regard to the levy u/s 201(1) & 201 (1A) of the Act, the issues

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

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’].

40(1)(i) ₹3,69,331/- (3) disallowance of sampling & analysis charges ₹23,38,465/- 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

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’].

40(1)(i) ₹3,69,331/- (3) disallowance of sampling & analysis charges ₹23,38,465/- 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

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

The appeal of the assessee is ALLOWED

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

disallowance u/s 40 or u/s 43B of the Act. We also see eye to eye to the proposition that, the ‘specified date’ as defined in explanation (ii) to section 44AB of the Act sets time clock for audit and is not sacrosanct because it stands erected on the borrowed shoulders of section 139(1

MRS VINI P. KENI,PANAJI vs. INCOME TAX OFFICER, WARD - 1(3), 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. Nos. 112/Pan/2022 (A.Y. 2014-15 ) Vini Prasad Keni, Vs Ito-Ward-1(3), Keni Building, Aayakar Bhavan, . Dr.Dada Vaidhya Road, Panaji-403001, Panjim-403001, Goa. Goa. . Pan .No. Adppk9767N (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri D.E.Robinson.Ar Revenue By Sri Narender Reddy.Sr.Dr सुनवाई क" तार"ख/Date Of Hearing 25.02.2025 घोषणा क" तार"ख/Date Of Pronouncement 20.03.2025 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/ Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. 2. At The Time Of Hearing, The Ld.Ar Of The Assessee Submitted That There Is A Delay Of 13 Days In Filing The Appeal Before The Hon’Ble Tribunal & The Assesse Has Filed The Affidavit For Condonation Of Delay. Whereas, The Facts Mentioned In The Affidavit Are Reasonable & The Ld. Dr Has No Specific Objections. Accordingly, We Condone The Delay & Admit The Appeal. The Assessee Has Raised

section 40(a)(ia) of the Act.(iii) the A.O found that the assesse has claimed social and welfare expenses under six categories of expenses aggregating to Rs.8,06,753/-and the assesse was called to substantiate that the expenses are incurred for business purpose. Whereas the A.O was not satisfied with the claims and observed that they

MAGSONS SUPERCENTRE,PANAJI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CPC, BENGALURU (JURISDICTIONAL AO: CIRCLE - 1(1), PANAJI

The appeal of the assessee is DISMISSED

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपीलसं. / Ita No. 14/Pan/2021 धििाारण वर्ा / Assessment Year : 2018-19 Magsons Supercentre, 707, Dayanand Bandodkar Marg, Miramar, Panaji Goa – 403001. . . . . . . . अपीलाथी / Appellant Pan: Aacfm4886A बिाम / Vs Deputy Commissioner Of Income Tax Officer . . . . . . .प्रत्यथी / Respondent Cpc, Bengaluru.

40,95,320/-. The said return of income was processed u/s 143(1) of the Act with an addition u/s 36(1)(va) of the Act thus determined the total income at ₹54,19,3330/- vide intimation dt. 30/09/2019. While doing so, the Ld. AO made a disallowance u/s 36(1)(va) of the Act with

THE TISK USGAO URBAN CO-OPERATIVE CREDIT SOCIETY LIMITED,PONDA vs. INCOME TAX OFFICER, WARD - 2(3), PANAJI

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

Bench: Shri Satbeer Singh Godara

40(a)(ia) is not applicable to the interest paid as no tax is deductible on such payments under section 194A of the act. 4. In the facts and circumstances of the case, the Commissioner of Income Tax (Appeals) has erred in not considering, while deciding that the appellant is not a co-operative bank, the fact that the appellant