FOMENTO KARNATAKA MINING COMPANY PRIVATE LIMITED (NOW AMALGAMATED WITH FOMENTO RESOURCES PRIVATE LIMITED,PANAJI vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.26/Pan/2021 िनधा"रण वष" / Assessment Year : 2009-10 Fomento Karnataka Mining Vs. Jcit, Margao Range, Company Private Limited, Margao, Goa. (Now Amalgamated With Fomento Resources Private Limited), 102, 1St Floor, Kamat Metropolis-I, Behind Caculo Mall, St. Inez, Panaji, Goa- 403001. Pan : Aaacf7487K Appellant Respondent Assessee By : Shri Nishant Thakkar Revenue By : Shri N. Shrikanth Date Of Hearing : 17.08.2023 Date Of Pronouncement : 29.08.2023 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)-2, Panaji [‘The Cit(A)’] Dated 27.08.2021 For The Assessment Year 2009-10. 2 2. Briefly, The Facts Of The Case Are That The Appellant Is A Company Incorporated Under The Provisions Of The Companies Act, 1956. It Is Engaged In The Business Of Processing & Trading In The Iron Ore. The Return Of Income For The Assessment Year 2009-10 Was Filed On 30.09.2009 Declaring Total Income Of Rs.26,40,77,220/-. Against The Said Return Of Income, The Assessment Was Completed By The Joint Commissioner Of Income Tax, Margao Range, Margao (‘The Assessing Officer’) Vide Order Dated 30.12.2011 Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’) At A Total Income Of Rs.26,63,57,955/-. While Doing So, The Assessing Officer Made Disallowance U/S 14A Of Rs.15,49,787/-, Disallowance On Account Of Sundry Creditors Extracting As Fictitious Of Rs.7,30,948/-. 3. Being Aggrieved, An Appeal Was Filed Before The Ld. Cit(A) Contending That No Disallowance U/S 14A Is Required To Be Made In The Absence Of Any Expenditure Incurred To Earn The Exempt Income. It Was Also Contended That No Addition On Account Of Outstanding Creditors Is Required To Be Made, As The Credits Represent The Opening

section 14A(2) of the Act, read with rule 8D of the Rules, we also make it clear that before applying the theory of apportionment, the Assessing Officer needs to record satisfaction that having regard to the kind of the assessee, suo motu disallowance

VEERENDRA BASAVARAJ KOUJALAGI,BELAGAVI vs. PCIT HUBBALLI, HUBBALLI

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshaliita Nos. 103/Pan/2024 Assessment Year : 2018-19 Veerendra Basavaraj Koujalagi C/O. Shri Laxmi Complex, Sadashiv Nagar, Belgavi-590001 Pan : Agrpk3086D . . . . . . . Appellant V/S The Pr. Commissioner Of Income Tax, Hubali. . . . . . . . Respondent Appearances Assessee By : Mr Shivanand Halbhavi [‘Ld. Ar’] Revenue By : Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 24/06/2025 Date Of Pronouncement : 28/07/2025 Order Per G. D. Padmahshali; The Assessee’S Captioned Appeal Impugns Din & Order 1063626985(1) Dt. 29/03/2024 Passed By Pr. Commissioner Of Income Tax, Hubali [‘Ld. Pcit’] U/S 263 Of The Income-Tax Act, 1961 [‘The Act’] Which Sought To Revise Order Of Assessment Dt. 26/04/2021 Passed U/S 143(3) R.W.S. 144B Of The Act By National Faceless E-Asstt. Centre, Delhi [‘Ld. Ao’] Anent To Assessment Year 2018-19 [‘Ay’].

disallowance of expenditure in earning such exempt income in terms of section 14A of the Act r.w.r 8D of IT-Rules

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

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 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 8D

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

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 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 8D