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9 results for “disallowance”+ Section 144C(10)clear

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Key Topics

Section 143(3)15Section 2638Section 44B6Section 271(1)(c)5Section 172(3)4Section 144C(13)4Section 37(1)4Transfer Pricing4Addition to Income4

ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 429/RJT/2018[2017-18]Status: DisposedITAT Rajkot21 Nov 2019AY 2017-18
For Appellant: Shri Porus Kaka, A.RFor Respondent: Shri Jitendra Kumar, CIT-D.R
Section 172(3)Section 172(4)

144C of the act. Further, it is also submitted that article 24 of the tax treaty are not applicable to income governed by article 8 of the tax treaty and the provisions of article 24 apply only to such income which is either exempt from tax in India or taxed at reduced rate in India as per tax treaty

ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

In the result, both the appeals of the assessee are allowed for statistical purposes

Survey u/s 133A4
Comparables/TP4
TP Method4
ITA 430/RJT/2018[2017-18]Status: DisposedITAT Rajkot21 Nov 2019AY 2017-18
For Appellant: Shri Porus Kaka, A.RFor Respondent: Shri Jitendra Kumar, CIT-D.R
Section 172(3)Section 172(4)

144C of the act. Further, it is also submitted that article 24 of the tax treaty are not applicable to income governed by article 8 of the tax treaty and the provisions of article 24 apply only to such income which is either exempt from tax in India or taxed at reduced rate in India as per tax treaty

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 85/RJT/2017[2012-13]Status: DisposedITAT Rajkot04 Aug 2023AY 2012-13

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

For Appellant: Shri S.N. Soparkar, ld.ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR
Section 143(3)Section 144C(13)Section 92C

144C(13) of the Income Tax Act, 1961 ("the Act" for short) pertaining to Asst.Year 2011-12, 2012-13 and 2013-14. Since identical issues are involved in these appeals, they are disposed of by this common order for the sake of convenience. 2. It was common ground that the issues involved in all the appeals was identical

AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 97/RJT/2016[2011-12]Status: DisposedITAT Rajkot04 Aug 2023AY 2011-12

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

For Appellant: Shri S.N. Soparkar, ld.ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR
Section 143(3)Section 144C(13)Section 92C

144C(13) of the Income Tax Act, 1961 ("the Act" for short) pertaining to Asst.Year 2011-12, 2012-13 and 2013-14. Since identical issues are involved in these appeals, they are disposed of by this common order for the sake of convenience. 2. It was common ground that the issues involved in all the appeals was identical

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 287/RJT/2017[2013-14]Status: DisposedITAT Rajkot04 Aug 2023AY 2013-14

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

For Appellant: Shri S.N. Soparkar, ld.ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR
Section 143(3)Section 144C(13)Section 92C

144C(13) of the Income Tax Act, 1961 ("the Act" for short) pertaining to Asst.Year 2011-12, 2012-13 and 2013-14. Since identical issues are involved in these appeals, they are disposed of by this common order for the sake of convenience. 2. It was common ground that the issues involved in all the appeals was identical

AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

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

ITA 437/RJT/2018[2014-15]Status: DisposedITAT Rajkot20 Dec 2023AY 2014-15

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita No. 437/Rjt/2018 धििाधरणणवध/Asstt. Year:2014-2015 Ahlstrom Munksjo Vs. D.C.I.T, Fibercomposites(India) Pvt. Ltd., Gandhidham Circle, Mundra Sez Integrated Textile & Gandhidham. Apparel Park (Mitap), Plot No.07, Survey No.141, Mundra, Kutch-370421. Pan: Aagca9137M (Applicant) (Respondent) Assessee By : Shri Tushar Hemani, A.R Revenue By : Shri Shramdeep Sinha, C.I.T Dr सुिणाईकीतारीख/Date Of Hearing : 06/12/2023 घोवणाकीतारीख/Date Of Pronouncement: 20/12/2023 आदेश/O R D E R Per Waseem Ahmed:

For Appellant: Shri Tushar Hemani, A.RFor Respondent: Shri Shramdeep Sinha, C.I.T DR
Section 143(3)Section 144C(13)Section 37(1)Section 40Section 92

144C(13) of the Income- tax Act, 1961 ('the Act') and Transfer Pricing order passed by the Deputy Commissioner of Income-tax, Transfer Pricing Officer 2, Ahmedabad ('TPO') and in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel - 2, Mumbai ('DRP') on the following grounds: 1. Transfer Pricing ('TP') adjustment in relation to international transaction

THE DCIT, (INTL. TAXN.), RAJKOT vs. M/S. KOREA SOUTH EAST POWER CO. LTD., MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 132/RJT/2019[2011-12]Status: DisposedITAT Rajkot15 Dec 2023AY 2011-12

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar(Conducted Through Virtual Court) Assessment Year: 2011-12 The Dcit (Intl. Taxn.) M/S.Korea South East Power Amruta Estate Co.Ltd. Room No.312 Mg Road बनाम/ C/O. P.V. Page & Co., Girnar Cinema 201, Sardar Griha, 198 L.T. Marg Vs. Rajkot Mumbai – 400 002 (Appellant) (Respondent) Pan: Pan : Ahvps 3555Q Assessee By None Revenue By Shri Ashish Kumar Pandey, Sr.Dr Date Of Hearing 25/09/2023 Date Of Pronouncement 15/12/2023

Section 115ASection 271(1)(c)Section 44B

10% of the gross income. • That there were no adverse findings as to any inaccurate particulars of income in the books of accounts maintained by the assessee or as to any other claim of deduction. • That initially the assessee had returned its income computed in terms of section 28 of the Act and paid taxes at the normal rates

SHRI RAJKOT DISTRICT CO-OPERATIVE BANK LTD.,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2), RAJKOT , RAJKOT

The appeal is dismissed

ITA 196/RJT/2024[2011-12]Status: DisposedITAT Rajkot04 Nov 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.196/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2011-12) Shri Rajkot District Co-Operative Vs. The Deputy Commissioner Of Bank Ltd., Income-Tax, Circle-1(1), Jilla Bank Bhavan, Kasturba Road, Aayakar Bhavan, Race Course Ring Opp. Chaudhary High School, Road, Rajkot-360001 Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afups2094H (Appellant) (Respondent) Appellant By : Shri D.M. Rindani, Ld. Ar Respondent By : Smt. Pallavi, Ld. Cit(Dr) : 06/08/2025 Date Of Hearing Date Of Pronouncement : 04/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay)-2018-19, Is Directed Against The Order Passed By The Commissioner Of Income Tax Office [(In Short “Ld.Cit(A)”] Vide Order Dated 29.12.2023, Which In Turn Assessment Order Passed By Income Tax Department / Assessing Officer Under Section 144C(1) Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 30.03.2023 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Smt. Pallavi, Ld. CIT(DR)
Section 143(3)Section 144C(1)Section 263Section 271(1)(c)Section 36(1)Section 36(1)(viia)

144C(1) of the Income Tax Act, 1961 (in short “the Act”), vide order dated 30.03.2023 2. Grounds of appeal raised by the assessee, are as follows: 1. The learned CIT(A) erred in upholding action of assessing officer in disallowing provision of Rs. 60,00,000/- made for standard asset contingency fund by the Appellant. Rajkot Dist

SAURASHTRA CEMENT LIMITED,PORBANDAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee is allowed

ITA 307/RJT/2024[2018-19]Status: DisposedITAT Rajkot08 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.307/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2018-19 Saurashtra Cement Ltd. Principal Commissioner Of Near Railway Station, बनाम Income Tax, Jamnagar, Saurashtra Cement Factory, Jamnagar Vs. P.O. Ranavav, Adityana Road, Porbandar, Gujarat-360560 Pan : Aahfs5211J (अपीलाथ"/Assessee) : (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Vimal Desai, Ld.Ar राज" की ओर से/Revenue By : Shri Sanja Punglia, Ld. Cit-Dr सुनवाई की तारीख/Date Of Hearing : 16/10/2025 घोषणा की तारीख/Date Of Pronouncement : 08/01/2026 Order

For Appellant: Shri Vimal Desai, ld.ARFor Respondent: Shri Sanja Punglia, Ld. CIT-DR
Section 143(3)Section 14ASection 263Section 36(1)(iii)

144C(3) of the Act, for the AY 2018-19 is erroneous in so far as it is prejudicial to the interest of revenue within the meaning of section 263 of the Act and therefore, ld PCIT set aside the assessment order to the extent of the issues mentioned and discussed in the foregoing paragraphs and directed the assessing officer