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74 results for “disallowance”+ Section 254(1)clear

Sorted by relevance

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Key Topics

Section 143(3)76Section 271(1)(c)60Addition to Income56Section 14A54Section 12A51Disallowance49Section 1138Section 115B33Section 155(19)31Deduction

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRAHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

ITA 1940/PUN/2024[2021-22]Status: DisposedITAT Pune26 Dec 2024AY 2021-22

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Amol Khairnar, CIT-DR
Section 131Section 143Section 143(1)(a)Section 143(2)Section 270ASection 270A(3)(i)Section 270A(6)(a)Section 270A(9)

disallowed the excess claim of capital expenditure of Rs.1,42,54,268/-. In our considered view there is no intentional misrepresentation of expenditure as alleged. By no stretch of imagination it can be said to be a case of attempted tax evasion as even after revision of computation, the taxable income remained Nil which is same as returned income

Showing 1–20 of 74 · Page 1 of 4

25
Section 10(20)24
Exemption23

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRADHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

ITA 1939/PUN/2024[2020-21]Status: DisposedITAT Pune26 Dec 2024AY 2020-21

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Amol Khairnar, CIT-DR
Section 131Section 143Section 143(1)(a)Section 143(2)Section 270ASection 270A(3)(i)Section 270A(6)(a)Section 270A(9)

disallowed the excess claim of capital expenditure of Rs.1,42,54,268/-. In our considered view there is no intentional misrepresentation of expenditure as alleged. By no stretch of imagination it can be said to be a case of attempted tax evasion as even after revision of computation, the taxable income remained Nil which is same as returned income

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,KOLHAPUR vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2173/PUN/2025[2012-13]Status: DisposedITAT Pune22 Dec 2025AY 2012-13

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

254 of the IT Act and penalty u/s 271(1)(c) of the IT Act was initiated. Against the above quantum assessment order, the assessee cooperative society preferred an appeal before Ld. CIT(A)/NFAC which was dismissed by Ld. CIT(A)/NFAC on 29.12.2023. However, till date no second appeal against the order dated 29.12.2023 passed

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,KOLHAPUR vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2175/PUN/2025[2013-14]Status: DisposedITAT Pune22 Dec 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

254 of the IT Act and penalty u/s 271(1)(c) of the IT Act was initiated. Against the above quantum assessment order, the assessee cooperative society preferred an appeal before Ld. CIT(A)/NFAC which was dismissed by Ld. CIT(A)/NFAC on 29.12.2023. However, till date no second appeal against the order dated 29.12.2023 passed

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,KOLHAPUR vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2170/PUN/2025[2008-09]Status: DisposedITAT Pune22 Dec 2025AY 2008-09

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

254 of the IT Act and penalty u/s 271(1)(c) of the IT Act was initiated. Against the above quantum assessment order, the assessee cooperative society preferred an appeal before Ld. CIT(A)/NFAC which was dismissed by Ld. CIT(A)/NFAC on 29.12.2023. However, till date no second appeal against the order dated 29.12.2023 passed

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,SHIROL vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2169/PUN/2025[2007-08]Status: DisposedITAT Pune22 Dec 2025AY 2007-08

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

254 of the IT Act and penalty u/s 271(1)(c) of the IT Act was initiated. Against the above quantum assessment order, the assessee cooperative society preferred an appeal before Ld. CIT(A)/NFAC which was dismissed by Ld. CIT(A)/NFAC on 29.12.2023. However, till date no second appeal against the order dated 29.12.2023 passed

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,KOLHAPUR vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2172/PUN/2025[2010-11]Status: DisposedITAT Pune22 Dec 2025AY 2010-11

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

254 of the IT Act and penalty u/s 271(1)(c) of the IT Act was initiated. Against the above quantum assessment order, the assessee cooperative society preferred an appeal before Ld. CIT(A)/NFAC which was dismissed by Ld. CIT(A)/NFAC on 29.12.2023. However, till date no second appeal against the order dated 29.12.2023 passed

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

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

ITA 334/PUN/2021[2016-17]Status: DisposedITAT Pune31 May 2023AY 2016-17

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Naveen Gupta
Section 92C

1 (SC) had agreed with the observations made by the Hon‟ble Delhi High Court in CIT Vs. Dalmia Cement (Bhart) Ltd. 254 ITR 377 (Del) that the Revenue cannot justifiably claim to put itself in the arm-chair of the businessman or in the position of the C.O. No.14/PUN/2021 board of directors to take business decisions. The income

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

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

ITA 273/PUN/2021[2016-17]Status: DisposedITAT Pune31 May 2023AY 2016-17

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Naveen Gupta
Section 92C

1 (SC) had agreed with the observations made by the Hon‟ble Delhi High Court in CIT Vs. Dalmia Cement (Bhart) Ltd. 254 ITR 377 (Del) that the Revenue cannot justifiably claim to put itself in the arm-chair of the businessman or in the position of the C.O. No.14/PUN/2021 board of directors to take business decisions. The income

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

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 1153/MUM/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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

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 545/PUN/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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

ASSISTANT COMMISSIONER OF INCOME TAX, PUNE vs. PERSISTENT SYSTEMS LIMITED, PUNE

In the result, appeal of the Revenue in ITA

ITA 595/PUN/2024[2015-16]Status: DisposedITAT Pune24 Oct 2024AY 2015-16

Bench: Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.590, 595 & 1478/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17, 2014-15 & 2015-16 The Assistant V Persistent Systems Limited, Commissioner Of Income S 402, Bhageerath, Senapati Tax,Pune. Bapat Road, Pune – 411016. Pan: Aabcp1209Q Appellant/ Revenue Respondent / Assessee Assessee By Shri R.D.Onkar – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 17/09/2024 Date Of Pronouncement 24/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Revenue Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 31.01.2024 & 06.05.2024, For The A.Y.2015-16, 2016-17 & 2014-15; Respectively. The Revenue For A.Y.2016- 17Has Raised The Following Grounds Of Appeal : “1. Whether In. The Facts & Circumstances Of The Case & In Law

Section 14Section 14ASection 250

1 & 2 was regarding disallowance made u/s14A read with rule 8D and the Ground Number 3 was regarding disallowance made u/s.10AA(9) of the Act. The ITAT in 499/PUN/2020 has held as under for disallowance made u/s 14A read with Rule 8D : Quote, “12. First of all, we observe that nowhere in the assessment order it has been stated that

ASSISTANT COMMISSIONER OF INCOME TAX, PUNE vs. PERSISTENT SYSTEMS LIMITED, PUNE

In the result, appeal of the Revenue in ITA

ITA 590/PUN/2024[2016-17]Status: DisposedITAT Pune24 Oct 2024AY 2016-17

Bench: Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.590, 595 & 1478/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17, 2014-15 & 2015-16 The Assistant V Persistent Systems Limited, Commissioner Of Income S 402, Bhageerath, Senapati Tax,Pune. Bapat Road, Pune – 411016. Pan: Aabcp1209Q Appellant/ Revenue Respondent / Assessee Assessee By Shri R.D.Onkar – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 17/09/2024 Date Of Pronouncement 24/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Revenue Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 31.01.2024 & 06.05.2024, For The A.Y.2015-16, 2016-17 & 2014-15; Respectively. The Revenue For A.Y.2016- 17Has Raised The Following Grounds Of Appeal : “1. Whether In. The Facts & Circumstances Of The Case & In Law

Section 14Section 14ASection 250

1 & 2 was regarding disallowance made u/s14A read with rule 8D and the Ground Number 3 was regarding disallowance made u/s.10AA(9) of the Act. The ITAT in 499/PUN/2020 has held as under for disallowance made u/s 14A read with Rule 8D : Quote, “12. First of all, we observe that nowhere in the assessment order it has been stated that

ASSISTANT COMMISSIONER OF INCOME-TAX, PUNE vs. PERSISTENT SYSTEMS LIMITED, PUNE

In the result, appeal of the Revenue in ITA

ITA 1478/PUN/2024[2014-15]Status: DisposedITAT Pune24 Oct 2024AY 2014-15

Bench: Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.590, 595 & 1478/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17, 2014-15 & 2015-16 The Assistant V Persistent Systems Limited, Commissioner Of Income S 402, Bhageerath, Senapati Tax,Pune. Bapat Road, Pune – 411016. Pan: Aabcp1209Q Appellant/ Revenue Respondent / Assessee Assessee By Shri R.D.Onkar – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 17/09/2024 Date Of Pronouncement 24/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Revenue Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 31.01.2024 & 06.05.2024, For The A.Y.2015-16, 2016-17 & 2014-15; Respectively. The Revenue For A.Y.2016- 17Has Raised The Following Grounds Of Appeal : “1. Whether In. The Facts & Circumstances Of The Case & In Law

Section 14Section 14ASection 250

1 & 2 was regarding disallowance made u/s14A read with rule 8D and the Ground Number 3 was regarding disallowance made u/s.10AA(9) of the Act. The ITAT in 499/PUN/2020 has held as under for disallowance made u/s 14A read with Rule 8D : Quote, “12. First of all, we observe that nowhere in the assessment order it has been stated that

RANAJIT SURESH RAJAMANE,SOLAPUR vs. ITO, WARD 1, PANDHARPUR, PANDHARPUR

In the result, the appeal of the assessee is allowed

ITA 1678/PUN/2024[2014-15]Status: DisposedITAT Pune13 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1678/Pun/2024 धििाारण वर्ा / Assessment Year: 2014-15 Ranajit Suresh Rajamane, Vs Ito Ward 1, Shukrawar Peth, Pandharpur Tembhurni Madha Solapur- 413211 Maharashtra Pan-Bmepr3878N Appellant Respondent

For Appellant: Smt. Deepa KhareFor Respondent: Shri Aviyogi Ambadkar
Section 139Section 147Section 148Section 250Section 54Section 548Section 54BSection 54B(1)Section 69A

disallowance of exemption u/s 548 in respect of investment in agricultural land and all the conditions have been complied with (iv) The Id CIT(A) erred in law and on facts in not appreciating that the appellant had made substantial payments towards consideration for purchase of the new agricultural land and possession was obtained in prescribed time thereby proving

KRANTIAGANI DR G D BAPU LAD SAHAKARI SAKHAR KARKHANA LIMITED,SANGALI vs. ACIT, SANGALI

Appeals are allowed for statistical purposes in above terms

ITA 69/PUN/2024[2010-11]Status: DisposedITAT Pune12 Jun 2024AY 2010-11

Bench: Shri R.K. Panda & Shri Satbeer Singh Godara

For Appellant: Shri Shubhada A. KoppaFor Respondent: Shri Keyur Patel
Section 1Section 154Section 155(19)Section 36(1)(xvii)

254 24/1057863123(1), Dt.10.11.2023 6 74/PUN/2024 2017-18 NFAC, DIN & Order No. 143(3) ITBA/NFAC/S/250/2023- 24/1057864899(1), Dt.10.11.2023 7 75/PUN/2024 2018-19 NFAC, DIN & Order No. 143(3) ITBA/NFAC/S/250/2023- 24/1057865672(1), Dt.10.11.2023 8 76/PUN/2024 2020-21 NFAC, DIN & Order No. 143(3) ITBA/NFAC/S/250/2023- 24/1057866159(1), Dt.10.11.2023 Heard both the parties at length. Case file perused. 2. It emerges during