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98 results for “disallowance”+ Section 145(3)clear

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Key Topics

Section 143(3)77Section 14A69Addition to Income67Disallowance47Section 12A39Deduction37Section 26332Section 143(2)28Section 1126Section 148

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

In the result, the appeal filed by the Revenue is dismissed

ITA 97/PUN/2024[2009-10]Status: DisposedITAT Pune17 Sept 2024AY 2009-10

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

For Appellant: Shri Nikhil PathakFor Respondent: Shri Sourabh Nayak, Addl. CIT
Section 143(3)Section 147Section 148Section 40A(3)

145 taxmann.com 228 (Bom), he submitted that the Hon’ble High Court in the said decision has held that when initially Assessing Officer had not accepted audit objection that as assessee was not satisfying condition of an industrial undertaking as prescribed under section 72A, set-off of brought forward losses on amalgamating company on amalgamation with assessee

Showing 1–20 of 98 · Page 1 of 5

25
Section 10(20)24
Exemption19

R. K. WINES,PEN vs. ITO, WARD 4, PANVEL, PANVEL

In the result, appeal of the assessee is partly allowed

ITA 301/PUN/2025[2022-23]Status: DisposedITAT Pune29 May 2025AY 2022-23
Section 133(6)Section 145(3)Section 250

section (2), has not been\nregularly followed by the assessee.\nIt is submitted that none of the above-mentioned twin conditions\nprescribed by u/s 145(3) are attracted in the present case.\n3.5 The appellant accordingly prays that the rejection of book results\nu/s 145(3) is not justified and the said action may kindly not be upheld.\nGround

DCIT, CIRCLE-5, PUNE vs. SHRI PURUSHOTTAM R MOGHE, PUNE

ITA 73/PUN/2021[2005-06]Status: DisposedITAT Pune09 Oct 2023AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: Shri Sharad A VazeFor Respondent: Shri Keyur Patel, CIT-DR with Shri Ramnath P Murkunde, Sr. AR
Section 148Section 40A(3)

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

DCIT CIRCLE- 5, PUNE vs. SAILAB MARKETING SERVICES PVT. LTD., PUNE

ITA 72/PUN/2021[2005-06]Status: DisposedITAT Pune09 Oct 2023AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: Shri Sharad A VazeFor Respondent: Shri Keyur Patel, CIT-DR with Shri Ramnath P Murkunde, Sr. AR
Section 148Section 40A(3)

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

PURUSHOTTAM R MOGHE,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), PUNE, PUNE

ITA 850/PUN/2023[2006-07]Status: DisposedITAT Pune09 Oct 2023AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: Shri Sharad A VazeFor Respondent: Shri Keyur Patel, CIT-DR with Shri Ramnath P Murkunde, Sr. AR
Section 148Section 40A(3)

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

SAILAB MARKETING SERVICES PVT LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), PUNE, PUNE

ITA 851/PUN/2023[2005-06]Status: DisposedITAT Pune09 Oct 2023AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: Shri Sharad A VazeFor Respondent: Shri Keyur Patel, CIT-DR with Shri Ramnath P Murkunde, Sr. AR
Section 148Section 40A(3)

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

DCIT, CIRCLE-5, PUNE vs. SHRI PURUSHOTTAM R MOGHE, PUNE

ITA 66/PUN/2021[2006-07]Status: DisposedITAT Pune09 Oct 2023AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: Shri Sharad A VazeFor Respondent: Shri Keyur Patel, CIT-DR with Shri Ramnath P Murkunde, Sr. AR
Section 148Section 40A(3)

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

PURUSHOTTAM R MOGHE,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), PUNE, PUNE

ITA 849/PUN/2023[2005-06]Status: DisposedITAT Pune09 Oct 2023AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: Shri Sharad A VazeFor Respondent: Shri Keyur Patel, CIT-DR with Shri Ramnath P Murkunde, Sr. AR
Section 148Section 40A(3)

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

WOCKHARDT LIMITED,,AURANGABAD vs. ASSISTAMT COMMISSIONER OF INCOME TAX, CIRCLE -3,, AURANGABAD

In the result, the appeal filed by Revenue is partly allowed, the appeal filed by assessee is partly allowed and the CO filed by assessee is dismissed as withdrawn

ITA 758/PUN/2019[2013-14]Status: DisposedITAT Pune10 May 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.775/Pun/2019 निर्धारण वषा / Assessment Year : 2013-14 Acit, Circle-3, Aurangabad .......अऩीऱाथी / Appellant बिधम / V/S. Wockhardt Ltd., R&D Centre, D-4, Midc, Chikalthana, Aurangabad. Pan: Aaacw2472M ……प्रत्यथी / Respondent आयकर अपीऱ सं. / Ita No.758/Pun/2019 निर्धारण वषा / Assessment Year : 2013-14 Wockhardt Ltd., R&D Centre, D-4, Midc, Chikalthana, Aurangabad. Pan: Aaacw2472M .......अऩीऱाथी / Appellant बिधम / V/S. Acit, Circle-3, Aurangabad ……प्रत्यथी / Respondent Co No.43/Pun/2019 निर्धारण वषा / Assessment Year : 2013-14 Wockhardt Ltd., R&D Centre, D-4, Midc, Chikalthana, Aurangabad. Pan: Aaacw2472M .......Cross Objector बिधम / V/S. Acit, Circle-3, Aurangabad ……प्रत्यथी / Respondent Co No.43/Pun/2019

For Appellant: Shri Rajan VoraFor Respondent: Shri Anurag Shivastava
Section 143(3)Section 14ASection 35Section 80ISection 92B

3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). While doing so, the AO made TP adjustment as suggested by the Transfer Pricing Officer (TPO) of Rs.109,81,22,628/-, disallowance of excess claim of deduction u/s 80IC of Rs.9,61,86,526/-, disallowance under provisions of section 35(2AB) of Rs.65,55,77,068/-, disallowance

BAJAJ FINANCE LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

ITA 767/PUN/2018[2013-14]Status: DisposedITAT Pune09 Dec 2022AY 2013-14

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

For Appellant: Shri Percy Pardiwala and Ms. Vasanti B. Patel
Section 14ASection 37Section 37(1)

Section 145 of the Income Tax Act, 1961, since both the Acts operate in different fields and therefore, assessee cannot recognize interest income on NPA and yet not offer it in Profit and Loss account? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of Rs.71

DCIT, CIRCLE-8 vs. M/S. BAJAJ FINANCE LTD. PUNE, AKURDI PUNE

ITA 819/PUN/2018[2013-14]Status: DisposedITAT Pune09 Dec 2022AY 2013-14

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

For Appellant: Shri Percy Pardiwala and Ms. Vasanti B. Patel
Section 14ASection 37Section 37(1)

Section 145 of the Income Tax Act, 1961, since both the Acts operate in different fields and therefore, assessee cannot recognize interest income on NPA and yet not offer it in Profit and Loss account? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of Rs.71

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE vs. M/S. BAJAJ FINANACE LTD,, PUNE

ITA 818/PUN/2018[2012-13]Status: DisposedITAT Pune09 Dec 2022AY 2012-13

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

For Appellant: Shri Percy Pardiwala and Ms. Vasanti B. Patel
Section 14ASection 37Section 37(1)

Section 145 of the Income Tax Act, 1961, since both the Acts operate in different fields and therefore, assessee cannot recognize interest income on NPA and yet not offer it in Profit and Loss account? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of Rs.71

BAJAJ FINANCE LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

ITA 766/PUN/2018[2012-13]Status: DisposedITAT Pune09 Dec 2022AY 2012-13

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

For Appellant: Shri Percy Pardiwala and Ms. Vasanti B. Patel
Section 14ASection 37Section 37(1)

Section 145 of the Income Tax Act, 1961, since both the Acts operate in different fields and therefore, assessee cannot recognize interest income on NPA and yet not offer it in Profit and Loss account? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of Rs.71

INCOME TAX OFFICER, WARD-1, JALNA, INCOME TAX OFFICE, JALNA vs. THE BEED DISTRICT CENTRAL CO-OP. BANK LTD., BEED

In the result, the appeal of the Revenue in ITA No

ITA 802/PUN/2024[2015-16]Status: DisposedITAT Pune21 Feb 2025AY 2015-16
For Appellant: \nDepartment by
Section 143(2)Section 143(3)Section 263Section 43BSection 43D

3) r.w.s.263 of\nthe IT Act, 1961 dated 30/12/2018 for the A.Y. 2013-14 of the AO of making an\naddition of RS. 34,94,01,100/- by disallowing the claim of deduction u/s 43B of\nthe Act. I have carefully considered the submissions made by the Appellant. It is\nobserved that the AO disallowed the provision on account

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED (SUCCESSOR TO LIQUIDHUB INDIA PRIVATE LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the Appeal filed by the Assessee is allowed

ITA 2753/PUN/2025[2020-21]Status: DisposedITAT Pune19 Jan 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2753/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Capgemini Technology V Assessment Unit, Services India S Income Tax Limited(Successor To Liquid Department. Hub India Private Limited), Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase Iii, Midc Sez, Village Man, Taluka Mulshi, District Pune – 411057. Pan: Aaacl8943J Appellant/ Assessee Respondent /Revenue Assessee By Shri Sudin Sabnis & Shri Siddhesh Khandalkar Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 05/01/2026 Date Of Pronouncement 19/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 02.09.2025 Emanating From The Penalty Order Passed Under Section

Section 115JSection 143(3)Section 155Section 155(18)Section 18Section 250Section 270ASection 270A(6)(a)Section 40

3. Less: Tax impact on account of other 32,27,62,439 retrospective amendments [e.g section 40(a)(ii) and section 36(1)(va) of Capgemini (other than sr. no. 2) 5 4. Balance MAT Credit brought forward 5,67,32,85,499 ITA No.2753/PUN/2025 [A] 2.2 Ld.AR for the Assessee relied on the following case laws : “i. Copy

BAJAJ FINANCE LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

ITA 1394/PUN/2018[2014-15]Status: DisposedITAT Pune23 Dec 2022AY 2014-15

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Respondent: Assessee by Ms. Vasanti B. Patel
Section 143(3)Section 14ASection 37Section 37(1)

Section 145 of the Income Tax Act, 1961, since both the Acts operate in different fields and therefore, assessee cannot recognize interest income on NPA and yet not offer it in Profit and Loss account? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of Rs.71

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE vs. M/S. BAJAJ FINANCE LTD,, PUNE

ITA 1722/PUN/2018[2014-15]Status: DisposedITAT Pune23 Dec 2022AY 2014-15

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Respondent: Assessee by Ms. Vasanti B. Patel
Section 143(3)Section 14ASection 37Section 37(1)

Section 145 of the Income Tax Act, 1961, since both the Acts operate in different fields and therefore, assessee cannot recognize interest income on NPA and yet not offer it in Profit and Loss account? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of Rs.71

GOEL EISHA CAPITALS,PUNE vs. PCIT(CENTRAL), PUNE, PUNE

ITA 1006/PUN/2024[AY 2019 - 20]Status: DisposedITAT Pune07 Apr 2025
Section 132Section 142(1)Section 143(2)Section 143(3)Section 263

disallow the same during the\nassessment proceedings for the year under consideration.\n04. In view of the above, it is found that the no verification on the aforesaid issues\nhas been done in the assessment proceedings by the AO. As per explanation (2) to\nsection 263(1) of the Act an order without making inquiries or verification which\nshould have

INCOME TAX OFFICER, WARD-1, JALNA, INCOME TAX OFFICE, JALNA vs. THE BEED DISTRICT CENTRAL CO-OP. BANK LTD., BEED

In the result, the appeal of the Revenue in ITA No

ITA 801/PUN/2024[2014-15]Status: DisposedITAT Pune21 Feb 2025AY 2014-15
For Appellant: Shri Shubham N. RathiFor Respondent: Shri Amol Khairnar
Section 143(2)Section 143(3)Section 263Section 43BSection 43D

3) r.w.s.263 of\nthe IT Act, 1961 dated 30/12/2018 for the A.Y. 2013-14 of the AO of making an\naddition of RS. 34,94,01,100/- by disallowing the claim of deduction u/s 43B of\nthe Act. I have carefully considered the submissions made by the Appellant. It is\nobserved that the AO disallowed the provision on account

SANT DAMAJI SAHAKARI SAKHAR KARKHANA LTD,,SOLAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, SOLAPUR

The appeal is dismissed

ITA 205/PUN/2018[2013-14]Status: DisposedITAT Pune26 Aug 2022AY 2013-14

Bench: Shri S.S. Godara & G.D. Padmahshalim/S. Sant Damaji Sahakari Acit, Circle -1 Sakhar Karkhana Ltd. Aaykar Bhavan A/P. Mangalwedha Vs. Hotgi Road Tal. Mangalwedha Solapur 413003 Dist. Soalpur 413305 Pan –Aaats5265K Appellant Respondent Appellant By: None Respondent By: Shri Sardar Singh Meena Date Of Hearing: 17.08.2022 Date Of Pronouncement: 26.08.2022 O R D E R Per S.S. Godara, Jm This Assessee’S Appeal For Ay 2013-14 Arises Against The Cit(A) 7, Pune’S Order Dated 25.10.2017 Passed In Case No. Pn/Cit (A)-7/Cir-1/10570/2016- 17, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961 (In Short The Act).

For Appellant: NoneFor Respondent: Shri Sardar Singh Meena
Section 143(3)Section 40Section 40A(3)

145/- on account of Income was not offered for Tax belong to Cattle camps/ fodder depot.” 3. It emerges at the outset that the assessee’s former twin substantive grounds of excess cane price paid to members/non members as well as sale of sugar at concessional rate to them; involving disallowances of Rs.32