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12 results for “disallowance”+ Section 67(1)clear

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Key Topics

Section 43B21Disallowance10Section 143(3)9Addition to Income8Section 14A7Deduction7Section 80P(2)(d)6Section 2635Section 253(1)3Section 80P(4)

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, MARGAO., MARGAO vs. M/S SALGAONCAR MINING INDUSTRIES PVT. LTD., PANAJI

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

ITA 135/PAN/2016[2011-12]Status: DisposedITAT Panaji05 Oct 2023AY 2011-12

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Prabhakar Anand
Section 143(3)Section 14ASection 41(1)

section 41(1) made addition of Rs.59,03,90,714/-. Similarly, during the course of assessment proceedings, the Assessing Officer had called for the details of the provisions for expenses debited to Profit & Loss Account which remains unpaid as on 31.03.2011. The details of such provisions are set out by the Assessing Officer vide para 6 of the assessment order

SALGAOCAR MINING INDUSTRIES PRIVATE LIMITED.,PANAJI vs. THE JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE., MARGAO

3
Section 2502
Depreciation2

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

ITA 118/PAN/2016[2011-12]Status: DisposedITAT Panaji05 Oct 2023AY 2011-12

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Prabhakar Anand
Section 143(3)Section 14ASection 41(1)

section 41(1) made addition of Rs.59,03,90,714/-. Similarly, during the course of assessment proceedings, the Assessing Officer had called for the details of the provisions for expenses debited to Profit & Loss Account which remains unpaid as on 31.03.2011. The details of such provisions are set out by the Assessing Officer vide para 6 of the assessment order

THE BRAHMALING MULTIPURPOSE CO-OP SOCIETY LTD,BELGAUM vs. INCOME TAX OFFICER, WARD -3, BELGAUM

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

ITA 254/PAN/2025[2017-18]Status: DisposedITAT Panaji22 Dec 2025AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80PSection 80P(2)(a)Section 80P(2)(d)

1) of the Act are issued calling for details in support of return of income filed. The assesse has filed the information of members of the society along with interest income on deposits with the cooperative banks, cooperative society and scheduled bank. The Assessing Officer (A.O) has dealt on the submissions/details of regular members and associate/nominal members and find that

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

ITA 38/PAN/2025[2013-14]Status: DisposedITAT Panaji11 Feb 2026AY 2013-14

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-

For Appellant: Mr Pramod & Mr Shriniwas Deshpande [‘Ld. AR’]For Respondent: Mr M Satish & Mr Renga Rajan [‘Ld. DR’]
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 2(14)Section 246ASection 250Section 253(1)Section 37(1)

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

M/S SOVA,PANAJI vs. PR. COMMISSIONER OF INCOME TAX, PANAJI

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

ITA 24/PAN/2024[2018-19]Status: DisposedITAT Panaji10 Mar 2026AY 2018-19

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

For Appellant: Mr Sukhsagar Syal [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 143(2)Section 143(3)Section 253(1)Section 263Section 56

67 (SC)], ‘Aditya Minerals (P) Ltd. Vs CIT’ [1999, 106 Taxman 337 (SC)], ‘Gobind Sugar Mills Ltd. Vs CIT’ [1998, 117 ITR 747 (Cal)], culminated the revisionary proceedings by directing the Ld. AO to pass a consequential order by; (i) treating sums paid on renewal of mining lease as capital in nature (ii) denying set-off of losses against

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

ITA 37/PAN/2023[2016-17]Status: DisposedITAT Panaji27 Feb 2026AY 2016-17

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)

Section 3

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

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PANAJI vs. M/S SALITHO ORES PVT. LTD, PANAJI

In the result, appeal of the assessee is allowed

ITA 99/PAN/2018[2012-13]Status: DisposedITAT Panaji21 Sept 2023AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent

For Appellant: Shri P.J. Pardiwalla, CAFor Respondent: Shri Prabhakar Anand DJ, DR
Section 43B

disallowance made by the AO u/s. 43B of the Act amounting to Rs.5,85,17,297/- cannot be sustained and hence, is deleted. Ground No.2 is allowed.” 4. The Department in this ground substantially had contended that there has been a violation of Rule 46A(3) of the Income Tax Rules, 1962 by the ld. CIT(A) in admission

M/S SALITHO ORES PRIVATE LIMITED,PANAJI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE - M1, MARGAO

In the result, appeal of the assessee is allowed

ITA 72/PAN/2018[2014-15]Status: DisposedITAT Panaji21 Sept 2023AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent

For Appellant: Shri P.J. Pardiwalla, CAFor Respondent: Shri Prabhakar Anand DJ, DR
Section 43B

disallowance made by the AO u/s. 43B of the Act amounting to Rs.5,85,17,297/- cannot be sustained and hence, is deleted. Ground No.2 is allowed.” 4. The Department in this ground substantially had contended that there has been a violation of Rule 46A(3) of the Income Tax Rules, 1962 by the ld. CIT(A) in admission

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PANAJI vs. M/S SALITHO ORES PVT. LTD, PANAJI

In the result, appeal of the assessee is allowed

ITA 100/PAN/2018[2013-14]Status: DisposedITAT Panaji21 Sept 2023AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent

For Appellant: Shri P.J. Pardiwalla, CAFor Respondent: Shri Prabhakar Anand DJ, DR
Section 43B

disallowance made by the AO u/s. 43B of the Act amounting to Rs.5,85,17,297/- cannot be sustained and hence, is deleted. Ground No.2 is allowed.” 4. The Department in this ground substantially had contended that there has been a violation of Rule 46A(3) of the Income Tax Rules, 1962 by the ld. CIT(A) in admission

THE ORGAON URBAN CO-OPERATIVE CREDIT SOCIETY LIMITED,MARCELA vs. INCOME TAX OFFICER, WARD - 1(2), PANAJI

ITA 74/PAN/2025[2017-18]Status: DisposedITAT Panaji05 Aug 2025AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 074/Pan/2025 Assessment Year : 2017-18 The Orgaon Urban Co-Operative Credit Society Limited. Devulwada, Mercela, Goa-403 107. Pan : Aaaat6227D . . . . . . . Appellant

For Appellant: Ms Eesha Dukle [‘Ld. AR’]For Respondent: Ms Rijjula Uniyal [‘Ld. DR’]
Section 143(1)Section 143(3)Section 2(19)Section 250Section 253(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

67,228/- owning to denial of deduction u/s 80P(2)(d) r.w.s. 80P(4) of the Act in relation to interest income earned by the assessee on its term deposits held with Goa State Co- operative Bank Limited[‘GSCBL’]. Aggrieved assessee taken the matter up in appeal, wherein the Ld. NFAC confirmed the denial in line with the notings

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

In the result, the appeal is dismissed

ITA 332/PAN/2016[2012-13]Status: DisposedITAT Panaji04 Jul 2023AY 2012-13

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.332 & 333/Pan/2016 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14

Section 14A

section 14A of the Act. 4. Briefly stated, the facts of this ground are that the assessee earned exempt dividend income of Rs.2,82,640/- and offered suo motu disallowance u/s.14A at Rs.7,075/-. On a specific query, the assessee failed to furnish the working of such disallowance. The AO computed the disallowance under Rule

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

In the result, the appeal is dismissed

ITA 333/PAN/2016[2013-14]Status: DisposedITAT Panaji04 Jul 2023AY 2013-14

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.332 & 333/Pan/2016 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14

Section 14A

section 14A of the Act. 4. Briefly stated, the facts of this ground are that the assessee earned exempt dividend income of Rs.2,82,640/- and offered suo motu disallowance u/s.14A at Rs.7,075/-. On a specific query, the assessee failed to furnish the working of such disallowance. The AO computed the disallowance under Rule