The Prl Commissioner of Income Tax (Exemptions) vs. Institute of Development and Research in Banking Technology

Bench: ABHINAND KUMAR SHAVILI,V RAMASUBRAMANIAN

disallowed under Section 40(a) of the Act. Further, assessee did not make any payment and reversed the provision during the year ending March 31, 2008. In substance, assessee's case is, the original provision was not allowed as deduction and therefore reversal of the same cannot be taxed again. I.T.A No.71/2017 C/W I.T.A No.785/2017 13 16. Shri. Suryanarayana contended

Commissioner of Income Tax-2, vs. Agricultural Market Committee,

Bench: : The Hon’Ble Justice Surya Prakash Kesarwani & The Hon’Ble Justice Rajarshi Bharadwaj Date : 28Th February 2024. Appearance: Mr. J. P. Khaitan, Senior Advocate Mr. Somak Basu, Advocate … For The Appellant. Mr. Vipul Kundalia, Advocate Mr. Anurag Roy, Advocate Ms. Oindrila Ghosal, Advocate … For The Respondent. 1. Heard Sri J. P. Khaitan, Learned Senior Advocate Assisted By Sri Somak Basu, Learned Counsel For The Appellant Assessee & Vipul Kundalia, Learned Senior Standing Counsel For The Respondent. 2. This Appeal Was Admitted By This Court By Order Dated 19.08.2011 On Four Substantial Questions Of Law. Learned Counsel For The Appellant Has Stated That The Appellant Does Not Want To Press The Substantial

10 SCC 153 (paragraphs 31 and 32) Hon’ble Supreme Court again explained the provisions of Section 14A of the Act 1961, in the matter and held as under: 17 “31. The aforesaid discussion and the cited judgements advise this Court to conclude that the proportionate disallowance

COMMISSIONER OFINCOEMETAX vs. M/S. V.SATYANARAYANA AND OTHERS

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

The Commissioner of Income tax vs. M/s.V.Satyanrayana AND Others

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

Commissioner of Income Tax, Rajahmundry. vs. m/s Ganesh Arrack Contractors,

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

The Commissioner of Income Tax vs. M/s GRK Prasad AND others

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

The Commissioner of Income Tax-II vs. m/S.M.Ventakteswara Rao AND Others

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

The Commissioner of income tax, vs. M/s.Y.Ramulu and Others

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

COMMR.OF I.T. RKAJAHMUNDRY vs. T.RAMI REDDY AND ORS

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

Commissioner of Income Tax vs. Ms. B.krishna Murthy AND Others

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

COMMISSISONER OF I.T. RAJAHMUNDRY vs. M/S.Y RAMAKRISHNA AND OTHERS

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

Commissioner of Income Tax, vs. M/s Y.Ramakrishna and Others

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

The Commissioner of Income Tax vs. M/s.B.Satyanarayana AND Others

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

COMMISSIONER OF INCOME TAX, vs. M/S G.R.K.PRASAD AND OTHERS

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

The Commissioner of Income Tax vs. M/s.G.V.Krishna Reddy AND Others

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

The commissioner of Income Tax vs. M/s.M.Narayana Choudary and Others

In the result, for the above reasons, we set aside the orders

Bench: V.V.S.RAO,RAMESH RANGANATHAN

disallowances of expenditure is arbitrary and excessive. We further hold that sales, which are admittedly unverifiable should be estimated at eight times of purchase price and net profit should be estimated at 1% of such estimated sales or declared sales whichever is more clear of all deductions and allowances, and if the profit so estimated is less than the profit

The Commissioner of Income Tax (Exemptions0 vs. Kalinga Cultural Trust

In the result, we do not find any

Bench: ANIS,SANJAY KUMAR

disallowed the assessee's claim for deduction under Section 10B of the Act. 5. The Assessing Officer inter alia held that assessee is entitled to deduction under Section 10B of the Act only after verification and the contention of the assessee that old machinery from FFIPL was transferred to it only in April 2007 does not deserve acceptance

Principal Commissioner of Income Tax-5 vs. M/s. VBC Industries Limited

In the result, we do not find any

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

disallowed the assessee's claim for deduction under Section 10B of the Act. 5. The Assessing Officer inter alia held that assessee is entitled to deduction under Section 10B of the Act only after verification and the contention of the assessee that old machinery from FFIPL was transferred to it only in April 2007 does not deserve acceptance