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455 results for “disallowance”+ Section 94(4)clear

Sorted by relevance

Mumbai3,509Delhi2,829Bangalore1,016Chennai835Ahmedabad791Kolkata741Hyderabad495Jaipur475Pune455Indore330Surat288Chandigarh241Cochin154Visakhapatnam142Raipur134Rajkot112Cuttack102Lucknow80Amritsar62Nagpur55Guwahati45Calcutta42Karnataka42Allahabad40Agra31Telangana28Jodhpur27Patna23Panaji22Dehradun21SC17Ranchi17Jabalpur14Varanasi6Punjab & Haryana4Kerala3Rajasthan2Gauhati1ASHOK BHAN DALVEER BHANDARI1A.K. SIKRI ROHINTON FALI NARIMAN1Orissa1

Key Topics

Section 143(3)94Addition to Income75Disallowance55Section 14A51Deduction48Section 143(2)36Section 3536Section 153A27Section 80P(2)(a)23Section 115B

T AND T INFRA LIMITED,PUNE vs. ASST.COMMISSIONER OF INCOME-TAX, CIRCLE-7, PUNE

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

ITA 291/PUN/2020[2016-17]Status: DisposedITAT Pune01 Oct 2024AY 2016-17

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2016-17 T & T Infra Limited Acit, Circle – 7, Pune A-1, Vishnu Vihar, Bibwewadi Vs. Kondhwa Road, Market Yard, Pune – 411037 Pan: Aaect3902H (Appellant) (Respondent) Assessee By : Shri Tarun Ghia Department By : S/Shri Ajay Kumar Keshari & Sourabh Nayak Date Of Hearing : 10-07-2024 Date Of Pronouncement : 01-10-2024 O R D E R Per Astha Chandra, Jm :

For Appellant: Shri Tarun GhiaFor Respondent: S/Shri Ajay Kumar Keshari and Sourabh Nayak
Section 143(2)Section 80I

disallowed and added to the returned income.” 9. In appeal, the Ld. CIT(A) upheld the action of the Assessing Officer by observing as under: “[7] I have perused the material on record and the contention of the Appellant carefully, in the assessment order, the AD has carried out a detailed analysis on why the deduction claimed

Showing 1–20 of 455 · Page 1 of 23

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Section 271(1)(c)22
Penalty18

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7 PUNE, PUNE vs. L B KUNJIR, PUNE

In the result, appeal of the Revenue is dismissed

ITA 1255/PUN/2023[2020-21]Status: DisposedITAT Pune26 Mar 2024AY 2020-21

Bench: Shri Partha Sarathi Chaudhury & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1255/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 The Deputy Commissioner L B Kunjir, Of Income Tax, V S.No.52/1 Swanand Circle-7, Pune. S Building, Shree Ram Hsg Society, Kharadi, Chandanagar, Pune – 411037. Pan: Aabfl9816E Appellant / Revenue Respondent / Assessee Assessee By Shri Nikhil Pathak – Ar Revenue By Shri R.Y.Balawade – Addl.Cit Date Of Hearing 12/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order

Section 250Section 80Section 80I

disallow deduction under section 80IA(4) when facts are similar. Findings &Analysis : 6. We have heard both the parties and perused the records. Ground No.1 & 2 of the Revenue are related to deduction under section 80IA(4) computed in such a way that each wind mill was treated as a separate undertaking. It is a fact that ITAT by consolidated

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

In the result, the appeal of assessee is allowed and the appeal of Revenue is partly allowed

ITA 1244/PUN/2015[2008-09]Status: DisposedITAT Pune31 Jul 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1176/Pun/2015 यििाारण वषा / Assessment Year : 2008-09

For Appellant: S/Shri M.K. Kulkarni and S.N. PuranikFor Respondent: Shri S.B. Prasad, CIT
Section 143(3)Section 14ASection 80I

disallowance made under section 14A of the Act read with Rule 8D of the Rules at ₹ 2,47,716/-. The grounds of appeal raised by assessee are thus, allowed. 11. Now, coming to the appeal filed by Revenue, wherein the issue is against eligibility of claim of deduction under section 80IA(4) of the Act on Miscellaneous receipts

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

In the result, the appeal of assessee is allowed and the appeal of Revenue is partly allowed

ITA 1176/PUN/2015[2008-09]Status: DisposedITAT Pune31 Jul 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1176/Pun/2015 यििाारण वषा / Assessment Year : 2008-09

For Appellant: S/Shri M.K. Kulkarni and S.N. PuranikFor Respondent: Shri S.B. Prasad, CIT
Section 143(3)Section 14ASection 80I

disallowance made under section 14A of the Act read with Rule 8D of the Rules at ₹ 2,47,716/-. The grounds of appeal raised by assessee are thus, allowed. 11. Now, coming to the appeal filed by Revenue, wherein the issue is against eligibility of claim of deduction under section 80IA(4) of the Act on Miscellaneous receipts

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

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

ITA 725/PUN/2022[2018-19]Status: DisposedITAT Pune28 Jun 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

For Appellant: Shri Ratan SamalFor Respondent: Shri Keyur Patel
Section 132(4)Section 139(1)

disallowances, the assessee had filed an appeal before the ld. CIT(A) contenting inter alia that the Assessing Officer ought not to have treated the unsecured loans of Rs.13,27,54,925/- as bogus loans, are merely accommodation entries since the interest was paid on such loans after deducting the TDS and the loans were accepted through the mode

ASSISTANT COMMISSIONER OF INCOME-TAX,CENTRAL CIRCLE - 2(2),, PUNE vs. M/S SINHGAD TECHNICAL EDUCATION SOCIETY (TRUST), PUNE

In the result, the appeal of the Revenue in ITA

ITA 1654/PUN/2017[2014-15]Status: DisposedITAT Pune01 Apr 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl. It(Ss)A No./ Name Of Appellant Name Of Respondent Asst. No.

For Appellant: Shri Chetan A. KariaFor Respondent: Shri Abhinay Kumbhar
Section 11Section 12ASection 132Section 153A

94 of the assessment order. 14. The Assessing Officer had further proceeded to hold that the capitation fees so collected by the appellant society was siphoned off by the President of the appellant society, namely, Shri Maruti N. Navale. According to the AO, the funds so siphoned off by Shir M.N. Navale were introduced by him in the accommodation bills

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 230/PUN/2025[2014-15]Status: DisposedITAT Pune23 Oct 2025AY 2014-15

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

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 80

disallowed the deduction claimed u/s 80IA(4) of the Act for all the three years mainly on two grounds i.e. (a) the projects undertaken by the assessee do not fall under the category of “new infrastructure facility” as envisaged in section 80IA(4) and (b) the assessee in respect of the impugned projects acted as contractor and not as developer

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 229/PUN/2025[2013-14]Status: DisposedITAT Pune23 Oct 2025AY 2013-14

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

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 80

disallowed the deduction claimed u/s 80IA(4) of the Act for all the three years mainly on two grounds i.e. (a) the projects undertaken by the assessee do not fall under the category of “new infrastructure facility” as envisaged in section 80IA(4) and (b) the assessee in respect of the impugned projects acted as contractor and not as developer

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 231/PUN/2025[2015-16]Status: DisposedITAT Pune23 Oct 2025AY 2015-16

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

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 80

disallowed the deduction claimed u/s 80IA(4) of the Act for all the three years mainly on two grounds i.e. (a) the projects undertaken by the assessee do not fall under the category of “new infrastructure facility” as envisaged in section 80IA(4) and (b) the assessee in respect of the impugned projects acted as contractor and not as developer

VIJAY ARVIND RAYKAR,,PUNE vs. INCOME-TAX OFFICER, WARD - 6(2),, PUNE

In the result, the Ground No

ITA 3010/PUN/2017[2014-15]Status: DisposedITAT Pune22 Apr 2022AY 2014-15

Bench: Shri Satbeer Singh Godara, Jm & Dr. Dipak P. Ripote, Am आयकरअपीलसं. / Ita No.3010/Pun/2017 िनधा"रणवष" / Assessment Year : 2014-15 Vijay Arvind Raykar, The Income Tax Officer, Ward- S.No.33, Wadgaon(Bk), Vs 6(2), Pune. Singhagad Road, Haveli, Pune – 411041. Pan: Adqpr 1950 F Appellant/ Revenue Respondent/ Assessee Assessee By Shri Abhay A.Avchat– Ar Revenue By Shri S P Walimbe - Dr Date Of Hearing 19/04/2022 Date Of Pronouncement 22/04/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-4, Pune Dated 29.09.2017 For The Assessment Year 2014-15. The Assessee Raised The Following Grounds Of Appeal: “1. The Income Tax Officer, Ward 6(2), Pune, Has Erred In Disallowing An Amount To The Extent Of Rs. 94,526/- Under The Provisions Of Section 14A Of The Act Read With Rule 8D & The Commissioner Of Income Tax (Appeals)-4, Pune Has Erred In Confirming The Same. 2. There Is Error In Making Aggregate Addition Of Rs.27,30,900/- Under Section 43Ca Of The Act & Appropriate Relief Should Be Granted To The Assessee In Respect Thereof. 3. The Assessee Requests For Grant Of Appropriate Relief From Additions Made Under Section 14A & 43Ca Of The Income Tax Act, 1961. 4. The Order Of The Income Tax Officer, Ward 6(2), Pune, Under Section 143(3) Dated September 29, 2017 Is Bad In Law & Learned Commissioner Of Income Tax Officer (Appeals)-V, Pune Has Erred In Confirming The Same. 5. The Appellant Craves Leave To Add, Amend Or Alter Any Of The Grounds Of Appeal.”

Section 143(2)Section 143(3)Section 14ASection 43C

section 14A r.w.rule 8D in para 4 of the assessment order. The same is reproduced here as under: “4. Disallowance u/s 14A: During the course of assessment proceedings, AR of the assessee was asked to submit note on applicability of sec 14A and working of disallowance u/s 14A read with rule 8D. AR submitted the details on 30.11.2016. AR contended

JAIN IRRIGATION SYSTEMS LTD.,JALGAON vs. DY. CIT, JALGAON

In the result, the appeal of assessee is partly allowed

ITA 1070/PUN/2013[2008-09]Status: DisposedITAT Pune28 Feb 2018AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

For Appellant: Shri Nikhil PathakFor Respondent: Shri Dr. Vivek Aggarwal
Section 143(3)Section 253Section 28Section 36Section 37

disallowed the expenses of Rs.4,94,72,088/-. Aggrieved by the order of AO, assessee carried the matter before Ld.CIT(A), who confirmed the action of AO. Aggrieved by the order of Ld.CIT(A), assessee is now in appeal before us. 5. Before us, at the outset, Ld.A.R. submitted that on identical facts in assessee’s own case

M/S GIRIRAJ ENTERPRISES,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

In the result, the appeal filed by the assessee is allowed and the appeals filed by the Revenue are dismissed

ITA 427/PUN/2024[2015-16]Status: DisposedITAT Pune17 Oct 2024AY 2015-16

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2015-16

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(35)Section 132Section 133ASection 143(1)Section 143(2)Section 153A

section 94 (7) of the act holding it to be sham and fictitious transaction is devoid of any merit. Accordingly on the merits also, orders of the lower authorities are reversed and ground number 4 – 7 of the appeal are allowed.” 20. We find Jaipur Bench of the Tribunal in the case of Agencies Rajasthan Pvt. Ltd. vs. ITO (supra

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

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

ITA 1179/PUN/2015[2011-12]Status: DisposedITAT Pune26 Jun 2020AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

For Appellant: Shri Dr. P. Daniel, AdvFor Respondent: Shri B. Kishore
Section 132Section 132(4)Section 143(3)

disallowance.” 38. Similarly, the reliance placed by the AO on Explanation to S. 69C of the Act would not be of any relevance as S. 69C would be applicable only in a case where the source of expenditure is not established and the assessee has claimed deduction in respect of such expenditure. In the present case, the source of expenditure

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

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

ITA 1246/PUN/2015[2010-11]Status: DisposedITAT Pune26 Jun 2020AY 2010-11

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

For Appellant: Shri Dr. P. Daniel, AdvFor Respondent: Shri B. Kishore
Section 132Section 132(4)Section 143(3)

disallowance.” 38. Similarly, the reliance placed by the AO on Explanation to S. 69C of the Act would not be of any relevance as S. 69C would be applicable only in a case where the source of expenditure is not established and the assessee has claimed deduction in respect of such expenditure. In the present case, the source of expenditure

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

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

ITA 1245/PUN/2015[2009-10]Status: DisposedITAT Pune26 Jun 2020AY 2009-10

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

For Appellant: Shri Dr. P. Daniel, AdvFor Respondent: Shri B. Kishore
Section 132Section 132(4)Section 143(3)

disallowance.” 38. Similarly, the reliance placed by the AO on Explanation to S. 69C of the Act would not be of any relevance as S. 69C would be applicable only in a case where the source of expenditure is not established and the assessee has claimed deduction in respect of such expenditure. In the present case, the source of expenditure

ASSISTANT COMMISSIONER OF INCOME-TAX,, KOLHAPUR vs. VIJAYKUMAR RAJARAM SHAH,, KOLHAPUR

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

ITA 608/PUN/2016[2011-12]Status: DisposedITAT Pune26 Jun 2020AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

For Appellant: Shri Dr. P. Daniel, AdvFor Respondent: Shri B. Kishore
Section 132Section 132(4)Section 143(3)

disallowance.” 38. Similarly, the reliance placed by the AO on Explanation to S. 69C of the Act would not be of any relevance as S. 69C would be applicable only in a case where the source of expenditure is not established and the assessee has claimed deduction in respect of such expenditure. In the present case, the source of expenditure

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

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

ITA 1247/PUN/2015[2011-12]Status: DisposedITAT Pune26 Jun 2020AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

For Appellant: Shri Dr. P. Daniel, AdvFor Respondent: Shri B. Kishore
Section 132Section 132(4)Section 143(3)

disallowance.” 38. Similarly, the reliance placed by the AO on Explanation to S. 69C of the Act would not be of any relevance as S. 69C would be applicable only in a case where the source of expenditure is not established and the assessee has claimed deduction in respect of such expenditure. In the present case, the source of expenditure

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

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

ITA 1177/PUN/2015[2009-10]Status: DisposedITAT Pune26 Jun 2020AY 2009-10

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

For Appellant: Shri Dr. P. Daniel, AdvFor Respondent: Shri B. Kishore
Section 132Section 132(4)Section 143(3)

disallowance.” 38. Similarly, the reliance placed by the AO on Explanation to S. 69C of the Act would not be of any relevance as S. 69C would be applicable only in a case where the source of expenditure is not established and the assessee has claimed deduction in respect of such expenditure. In the present case, the source of expenditure

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

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

ITA 1178/PUN/2015[2010-11]Status: DisposedITAT Pune26 Jun 2020AY 2010-11

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

For Appellant: Shri Dr. P. Daniel, AdvFor Respondent: Shri B. Kishore
Section 132Section 132(4)Section 143(3)

disallowance.” 38. Similarly, the reliance placed by the AO on Explanation to S. 69C of the Act would not be of any relevance as S. 69C would be applicable only in a case where the source of expenditure is not established and the assessee has claimed deduction in respect of such expenditure. In the present case, the source of expenditure

FCA INDIA AUTOMOBILES PRIVATE LIMITED (SURVIVING ENTITY AFTER THE MERGER OF PCA MOTORS PVT LTD),PUNE vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE

In the result, the appeal filed by the assessee is allowed

ITA 1781/PUN/2024[AY 2020-21]Status: DisposedITAT Pune23 Apr 2025

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Siddhesh ChauguleFor Respondent: Ms. Shilpa N. C
Section 10ASection 143(1)Section 143(3)Section 250Section 253Section 36(1)(va)Section 37

94,172/-. Remaining amount of Rs.10,03,384/- pertains to disallowance as per section 40(a)(ia) of the IT Act. It was further submitted that the above amount of Rs.10,03,384/- was voluntarily disallowed in the return of income since it relates to payments on which TDS was not deducted. It was further submitted that the adjustment