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72 results for “disallowance”+ Section 145(2)clear

Sorted by relevance

Mumbai838Delhi626Jaipur259Chennai201Bangalore173Hyderabad160Ahmedabad152Kolkata139Surat110Chandigarh104Raipur79Cochin74Pune72Rajkot68Indore55Lucknow50Visakhapatnam45Agra44Allahabad37Ranchi37Nagpur30Amritsar28Jodhpur22Cuttack22SC18Patna16Dehradun14Varanasi9Guwahati6Panaji4Jabalpur3H.L. DATTU S.A. BOBDE1

Key Topics

Section 143(3)57Addition to Income57Section 12A39Section 26330Section 143(2)28Disallowance27Section 1126Section 10(20)24Section 14823Deduction

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD.,PUNE vs. ACIT, CIRCLE-5, PUNE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1423/PUN/2025[2019-20]Status: DisposedITAT Pune22 Dec 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

Showing 1–20 of 72 · Page 1 of 4

23
Section 40A(3)19
Exemption19

DY. COMMISSIONER OF INCOME-TAX, CIRCLE-5, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD., PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 114/PUN/2025[2020]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 154/PUN/2025[2016-17]Status: DisposedITAT Pune22 Dec 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

ACIT, CIRCLE-5, PUNE, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1844/PUN/2024[2019]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 156/PUN/2025[2018-19]Status: DisposedITAT Pune22 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD6(1), PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 157/PUN/2025[2020-21]Status: DisposedITAT Pune22 Dec 2025AY 2020-21
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

disallowance u/s.36(1)(va) of the Act, 1d. CIT(A) affirmed\nthe action of the Assessing Officer placing reliance on the\njudgment of Hon'ble Apex Court in the case of Checkmate\nServices Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as\nthe issue raised by the assessee against the addition made by\nld. AO treating

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD 6(1), PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 155/PUN/2025[2017-198]Status: DisposedITAT Pune22 Dec 2025AY 2017-198
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

disallowance u/s.36(1)(va) of the Act, 1d. CIT(A) affirmed\nthe action of the Assessing Officer placing reliance on the\njudgment of Hon'ble Apex Court in the case of Checkmate\nServices Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as\nthe issue raised by the assessee against the addition made by\nld. AO treating

ACIT, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 1843/PUN/2024[2018]Status: DisposedITAT Pune22 Dec 2025
Section 2(24)(xviii)Section 43

disallowance u/s.36(1)(va) of the Act, 1d. CIT(A) affirmed\nthe action of the Assessing Officer placing reliance on the\njudgment of Hon'ble Apex Court in the case of Checkmate\nServices Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as\nthe issue raised by the assessee against the addition made by\nld. AO treating

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

ITA 1012/PUN/2023[2018-19]Status: DisposedITAT Pune27 Jun 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

For Appellant: 2. The ld.AR submitted written submissions, relevant part of the same is reprodu
Section 11Section 12ASection 143(3)Section 250

145 taxmann.com 278 (Amritsar - Trib.)] (iii) Alpha Educational Trust v. DCIT (Exemption) - [2023] 150 taxmann.com 20 (Chennai - Trib.) III. Proposition 3: If an Application for Registration is not disposed off within 6 months, then same isdeemed to be accepted/approved, in terms of section 12AA(2). Sardari Lai Oberoi memorial Charitable Trust v. ITO [2005] 3 SOT 229 (Delhi)] SambandhOrganisation

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE vs. ADVIK HI-TECH PVT. LTD., PUNE

In the result, the cross appeal filed by the Revenue in ITA\nNo

ITA 1330/PUN/2023[2020-21]Status: DisposedITAT Pune18 Feb 2025AY 2020-21
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 35Section 35(1)Section 80GSection 80I

145.\n\n(2) For the purposes of sub-section (1), gain or loss arising on\naccount of the effects of change in foreign exchange rates shall be in\nrespect of all foreign currency transactions, including those relating\nto-\n\n(i) monetary items and non-monetary items;\n(ii) translation of financial statements of foreign operations;\n(iii) forward

ADVIK HI TECH PVT LTD,PUNE vs. DY.COMM.OF INCOME TAX, CIRCLE 8, PUNE, AKURDI PUNE

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

ITA 1158/PUN/2023[2020-21]Status: DisposedITAT Pune18 Feb 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1158/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 Advik Hi Tech Pvt. Ltd., Vs. Dcit, Circle-8, Pune. Gat No.357, Plot No.99, Village- Kharabwadi, Tal.- Khed, Chakan- 410501. Pan : Aacca3106E Appellant Respondent आयकर अपील सं. / Ita No.1330/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 Dcit, Circle-8, Pune. Vs. Advik Hi Tech Pvt. Ltd., Gat No.357, Plot No.99, Village- Kharabwadi, Tal.- Khed, Chakan- 410501. Pan : Aacca3106E Appellant Respondent Assessee By : Shri Sharad A. Shah & Shri Rohit S. Tapadiya Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement : 18.02.2025 आदेश / Order Per Vinay Bhamore, Jm: These Cross Appeals Filed By The Assessee As Well As By The Revenue Are Directed Against The Order Dated 16.10.2023 Passed By Ld.Cit(A)/Nfac For The Assessment Year 2020-21 Respectively.

For Appellant: Shri Sharad A. Shah &For Respondent: Shri Amol Khairnar
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 35Section 35(1)Section 80GSection 80I

145. 18 ITA No.1158/PUN/2023 [A] ITA No.1330/PUN/2023 [R] (2) For the purposes of sub-section (1), gain or loss arising on account of the effects of change in foreign exchange rates shall be in respect of all foreign currency transactions, including those relating to— (i) monetary items and non-monetary items; (ii) translation of financial statements of foreign operations

PRAJ INDUSTRIES LIMITED,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of assessee is allowed

ITA 1413/PUN/2023[2017-18]Status: DisposedITAT Pune27 Jun 2024AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Paresh ShapariaFor Respondent: Shri Sourabh Nayak
Section 115JSection 143(2)Section 143(3)Section 14ASection 35

disallowance voluntarily made by the assessee was not acceptable. Hence, we find that the Assessing Officer had rightly followed the procedure under section 14A(2) of the Act and only thereafter, recorded his dis-satisfaction on the correctness of the claim made by the assessee and having regard to the accounts of the assessee, proceeded to follow the procedure under

THE PRAKASHCHAND JAIN MULTI STATE CO OPERATIVE CREDIT SOCIETY LTD.,JAMNER vs. ITO WARD 1(4) JALGAON, JALGAON

In the result, appeal of the assessee is allowed

ITA 1791/PUN/2024[2020-21]Status: DisposedITAT Pune21 Nov 2024AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1791, 1801 & 1802/Pun/2024 िनधा"रण वष" / Assessment Years: 2020-21, 2014-15 & 2018-19 The Prakashchand Jain Multi V The Income Tax Officer, State Co-Operative Credit S Ward-1(4), Jalgaon. Society Ltd., Mayur Complex, Bajrangpura Road, Jamner, Jalgaon – 424206. Pan: Aaaap4677K Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay Kawdia – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 18/11/2024 Date Of Pronouncement 21/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 10.07.2024, A.Y.2014-15 & A.Y.2018-19 Dated 09.07.2024 Respectively. Since The Issue Involved Is Common & Facts Are Identical, All The Three Appeals

Section 250Section 80PSection 80P(2)(a)

disallowed the assessee’s claim of deduction under section 80P(2)(a) of the Act. Ld.AR further submitted that there was a delay in filing appeal before the ld.CIT(A) of 145

PRAKASHCHAND JAIN MULTI STATE CO.OPERATIVE CREDIT SOCIETY LTD.,JAMNER vs. ITO WARD 1(4), JALGAON, JALGAON

In the result, appeal of the assessee is allowed

ITA 1802/PUN/2024[2018-19]Status: DisposedITAT Pune21 Nov 2024AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1791, 1801 & 1802/Pun/2024 िनधा"रण वष" / Assessment Years: 2020-21, 2014-15 & 2018-19 The Prakashchand Jain Multi V The Income Tax Officer, State Co-Operative Credit S Ward-1(4), Jalgaon. Society Ltd., Mayur Complex, Bajrangpura Road, Jamner, Jalgaon – 424206. Pan: Aaaap4677K Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay Kawdia – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 18/11/2024 Date Of Pronouncement 21/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 10.07.2024, A.Y.2014-15 & A.Y.2018-19 Dated 09.07.2024 Respectively. Since The Issue Involved Is Common & Facts Are Identical, All The Three Appeals

Section 250Section 80PSection 80P(2)(a)

disallowed the assessee’s claim of deduction under section 80P(2)(a) of the Act. Ld.AR further submitted that there was a delay in filing appeal before the ld.CIT(A) of 145

THE PRAKASHCHAND JAIN MULTI STATE CO OPERATIVE SOCIETY LTD.,JAMNER vs. ITO WARD 1(4), JALGAON, JALGAON

In the result, appeal of the assessee is allowed

ITA 1801/PUN/2024[2014-15]Status: DisposedITAT Pune21 Nov 2024AY 2014-15

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1791, 1801 & 1802/Pun/2024 िनधा"रण वष" / Assessment Years: 2020-21, 2014-15 & 2018-19 The Prakashchand Jain Multi V The Income Tax Officer, State Co-Operative Credit S Ward-1(4), Jalgaon. Society Ltd., Mayur Complex, Bajrangpura Road, Jamner, Jalgaon – 424206. Pan: Aaaap4677K Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay Kawdia – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 18/11/2024 Date Of Pronouncement 21/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 10.07.2024, A.Y.2014-15 & A.Y.2018-19 Dated 09.07.2024 Respectively. Since The Issue Involved Is Common & Facts Are Identical, All The Three Appeals

Section 250Section 80PSection 80P(2)(a)

disallowed the assessee’s claim of deduction under section 80P(2)(a) of the Act. Ld.AR further submitted that there was a delay in filing appeal before the ld.CIT(A) of 145

AZIZUDDIN LATIPHODDIN KAZI L/H OF DECEASED LATIPHODDIN AJIMODDIN KAZI,LATUR vs. THE INCOME TAX OFFICER, WARD-4, LATUR

Appeal is dismissed

ITA 835/PUN/2023[2013-14]Status: DisposedITAT Pune18 Aug 2023AY 2013-14

Bench: Shri S.S.Godaraआयकर अपीलसं. / Ita No.835/Pun/2023 िनधा"रण वष" / Assessment Year : 2013-14 Azizuddin Latiphoddin Kazi, The Income Tax Officer, L/H Of Deceased Latiphoddin Vs Ward-4, Latur. Ajimoddin Kazi, . Block No.71, Kazi Nivas, Dastagir Galli, Tal. Ahmedpur, Latur – 413515. Pan: Aynpk5231E Appellant / Assessee Respondent / Revenue Assessee By Shri P P Kulkarni – Ar Revenue By Shri B.S.Rajpurohit - Dr Date Of Hearing 17/08/2023 Date Of Pronouncement 18/08/2023

Section 234ASection 250Section 28Section 56(2)(viii)Section 96

disallowance. 4. On the facts and in the circumstances of the case and in law the Central Board of Direct Taxes issued a benevolent circular to all the authorities working under the Act that such receipt of additional compensation u/s 28 of the Land Acquisition Act 1894 as the it was not interest but additional compensation and also was exempt

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since