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48 results for “TDS”+ Section 115Jclear

Sorted by relevance

Delhi18Mumbai14Kolkata7Jaipur6Ahmedabad1Chennai1SC1

Key Topics

Section 115J41Section 80I36Section 14A31Section 92C29Section 143(3)28Disallowance23Addition to Income23Section 8020Section 145A18Deduction18Transfer Pricing17Comparables/TP9

MALAYALA MANORAMA CO LTD. vs. COMMR.OF INCOME TAX, TRIVANDRUM

The appeals are allowed and the

C.A. No.-005420-005423 - 2002Supreme Court10 Apr 2008
For Respondent: Commissioner of Income Tax,Trivandrum
Section 115JSection 33Section 80Section 80V

TDS deducted, the Assessing Officer created a total demand of Rs.26,83,327/-. It is relevant to mention here that since the provision of section 80VV stood deleted with effect from 01.4.1988 the claim made under that section was rejected. It was submitted that Chapter XII-B containing \023special provisions relating to certain companies\024 was introduced in the Income

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

Showing 1–20 of 48 · Page 1 of 3

ITA 623/KOL/2018[2012-13]Status: Disposed
ITAT Kolkata
20 Jan 2026
AY 2012-13
Section 115JSection 250

115J.” 4.6 As the disallowance is covered under clause (c) of Explanation (1) to section 115JB of the Act, the same is liable to be added to the book profit for the purpose of section 115JB of the Act. Hence, the finding of the Ld. CIT(A) is confirmed and Ground No. 1 of the appeal is dismissed. 5. Ground

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

ITA 1697/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15
Section 115J

115J.”\n4.6 As the disallowance is covered under clause (c) of Explanation (1)\nto section 115JB of the Act, the same is liable to be added to the book\nprofit for the purpose of section 115JB of the Act. Hence, the finding of\nthe Ld. CIT(A) is confirmed and Ground No. 1 of the appeal is\ndismissed.”\n5. Ground

COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

ITA 467/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13
Section 115J

115J.”\n4.6 As the disallowance is covered under clause (c) of Explanation (1)\nto section 115JB of the Act, the same is liable to be added to the book\nprofit for the purpose of section 115JB of the Act. Hence, the finding of\nthe Ld. CIT(A) is confirmed and Ground No. 1 of the appeal is\ndismissed.\nPage

M/S. COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

ITA 1406/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14
Section 115J

115J.”\n4.6 As the disallowance is covered under clause (c) of Explanation (1)\nto section 115JB of the Act, the same is liable to be added to the book\nprofit for the purpose of section 115JB of the Act. Hence, the finding of\nthe Ld. CIT(A) is confirmed and Ground No. 1 of the appeal is\ndismissed.\nPage

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

ITA 1696/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14
Section 115J

115J.”\n4.6 As the disallowance is covered under clause (c) of Explanation (1)\nto section 115JB of the Act, the same is liable to be added to the book\nprofit for the purpose of section 115JB of the Act. Hence, the finding of\nthe Ld. CIT(A) is confirmed and Ground No. 1 of the appeal is\ndismissed.\n5.\nGround

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

In the result, the appeals filed by the assessee in ITA Nos

ITA 622/KOL/2018[2011-12]Status: DisposedITAT Kolkata20 Jan 2026AY 2011-12
Section 115J

115J.”\n4.6 As the disallowance is covered under clause (c) of Explanation (1)\nto section 115JB of the Act, the same is liable to be added to the book\nprofit for the purpose of section 115JB of the Act. Hence, the finding of\nthe Ld. CIT(A) is confirmed and Ground No. 1 of the appeal is\ndismissed.\n5.\nGround

ASSISSTANT COMMISSIONER OF INCOME TAX, AJMER vs. SHREE CEMENT LTD, BEAWAR

Accordingly, the same is dismissed

ITA 490/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

115J would be concluded exclusively on the basis of the book profits as adjusted by the items set out in the Explanation thereunder, in an assessment in terms of sections 115JA or JB, the adjusted book profits would be further subjected to the effect of other provisions of the Act that are specifically brought into play by virtue

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DEPUTY COMMISSIONEROF INCOME TAX, CIRCLE -2, AJMER, AJMER

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

ITA 496/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

115J would be concluded exclusively on the basis of the book profits as adjusted by the items set out in the Explanation thereunder, in an assessment in terms of sections 115JA or JB, the adjusted book profits would be further subjected to the effect of other provisions of the Act that are specifically brought into play by virtue

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

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

ITA 500/JPR/2023[215-16]Status: DisposedITAT Jaipur21 Feb 2024

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

115J would be concluded exclusively on the basis of the book profits as adjusted by the items set out in the Explanation thereunder, in an assessment in terms of sections 115JA or JB, the adjusted book profits would be further subjected to the effect of other provisions of the Act that are specifically brought into play by virtue

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT ASSESSMENT CENTRE, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, AJMER, AJMER

ITA 497/JPR/2023[2017-18]Status: DisposedITAT Jaipur21 Feb 2024AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

115J would be concluded exclusively on the basis of the book profits as adjusted by the items set out in the Explanation thereunder, in an assessment in terms of sections 115JA or JB, the adjusted book profits would be further subjected to the effect of other provisions of the Act that are specifically brought into play by virtue

MEGA ENGINEERS & BUILDERS,PORT BLAIR vs. DCIT, CIR. 3(2) , PORT BLAIR

In the result, the appeal of assessee is allowed

ITA 312/KOL/2024[2017-18]Status: DisposedITAT Kolkata09 Oct 2024AY 2017-18

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 194C

TDS should have been deducted at the rate of 10% u/s 194A of the Act. Finally, the AO disallowed 30% of the above interest payment being disallowance u/s 40a(ia) of the Act. In our opinion the provisions of Section 40a(ia) cannot be invoked where there is a short deduction of tax at source but in a case, where

ASSISSTANT COMMISSIONER OF INCOME TAX, AJMER vs. SHREE CEMENT LTD, BEAWAR

ITA 489/JPR/2023[2015-16]Status: DisposedITAT Jaipur21 Feb 2024AY 2015-16
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

115J would be concluded exclusively on the\nbasis of the book profits as adjusted by the items set out in the\nExplanation thereunder, in an assessment in terms of sections 115JA\nor JB, the adjusted book profits would be further subjected to the effect\nof other provisions of the Act that are specifically brought into play by\nvirtue

ACC LTD ( FORMERLY KNOWN AS THE ASSOCIATES CEMENT COMPANIES LTD),MUMBAI vs. ADDL CIT LTU, MUMBAI

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

ITA 4669/MUM/2012[2007-08]Status: DisposedITAT Mumbai28 Feb 2023AY 2007-08

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 145A

115J of the Act, as it defies the basic intention behind introduction of provisions of section 115JB of the Act. The ITAT Jaipur bench, in case of Shree Cement Ltd. (supra) had considered an identical issue and held that incentives granted to the assessee is capital receipt and hence, cannot be part of book profit computed u/s 115JB

ADDL.C.I.T. LTU, MUMBAI vs. ACC LTD., MUMBAI

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

ITA 4556/MUM/2012[2007-08]Status: DisposedITAT Mumbai28 Feb 2023AY 2007-08

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 145A

115J of the Act, as it defies the basic intention behind introduction of provisions of section 115JB of the Act. The ITAT Jaipur bench, in case of Shree Cement Ltd. (supra) had considered an identical issue and held that incentives granted to the assessee is capital receipt and hence, cannot be part of book profit computed u/s 115JB

ACC LTD,MUMBAI vs. ASST CIT LTU, MUMBAI

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

ITA 6082/MUM/2014[2007-08]Status: DisposedITAT Mumbai28 Feb 2023AY 2007-08

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 145A

115J of the Act, as it defies the basic intention behind introduction of provisions of section 115JB of the Act. The ITAT Jaipur bench, in case of Shree Cement Ltd. (supra) had considered an identical issue and held that incentives granted to the assessee is capital receipt and hence, cannot be part of book profit computed u/s 115JB

M/S GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT,, NEW DELHI

ITA 2539/DEL/2017[2005-06]Status: DisposedITAT Delhi16 Jul 2025AY 2005-06
Section 92C

115J of the Act. Further, the assessee relied upon various judgements as mentioned in the synopsis filed by the assessee. Considering the totality of facts and circumstances of the case, we observe that the AO has passed a very cryptic order while deciding this issue, therefore, in the interest of justice, we restore this issue to the file

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),MUMBAI vs. ACIT,. CIRCLE-26(2), NEW DELHI

In the result, all above said grounds are allowed for statistical purpose

ITA 8361/DEL/2019[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shriyogesh Kumar U.S.Vodafone Idea Ltd Vs. Acit, (Earlier Known As Vodafone Circle-26(2), Mobile Services Ltd) New Delhi 10Th Floor, Birla Centurion, Century Mills Compound, Pandurang Budhkar Marg, Worli, Mumbai, Maharastra (Appellant) (Respondent) Pan: Aaacb2100P

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri S. K,. Jadav, CIT DR
Section 115JSection 143(3)Section 144C(5)Section 92C

TDS-2) v. M/s Tata Teleservices [ITA No. 1417 of 2018 dated 30.05.2022] (Assessment Year 2005-06 to 2012- 13) (Delhi HC) 10.3 The ld CIT DR vehemently relied upon the orders of the ld AO and prayed for confirmation of addition made by the ld AO. Vodafone Idea Ltd 10.4 On careful perusal of the above decisions relied upon

ADDL CIT RG 1(1), MUMBAI vs. ACC LTD, MUMBAI

ITA 5692/MUM/2011[2006-07]Status: DisposedITAT Mumbai28 Feb 2023AY 2006-07

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Limited V. Addl. Cit -Range 1(1) (Formerly Known As The Associated Cement Mumbai Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) M/S. Acc Limited V. Asst. Cit-Ltu (Formerly Known As The Associated Mumbai Cement Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) Acit – Ltu V. M/S. Acc Limited 28Th Floor, Centre-1 (Formerly Known As The Associated Cement Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai - 400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 145ASection 251Section 44A

115J of the Act, as it defies the basic intention behind introduction of provisions of section 115JB of the Act. The ITAT Jaipur bench, in case of Shree Cement Ltd. (supra) had considered an identical issue and held that incentives granted to the assessee is capital receipt and hence, cannot be part of book profit computed u/s 115JB

ACC LIMITED (FORMERLY KNOWN AS THE ASSOCIATED CEMENT COMPANIES LTD.),MUMBAI vs. ACIT - LTU, MUMBAI

ITA 417/MUM/2014[2006-07]Status: DisposedITAT Mumbai28 Feb 2023AY 2006-07

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Limited V. Addl. Cit -Range 1(1) (Formerly Known As The Associated Cement Mumbai Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) M/S. Acc Limited V. Asst. Cit-Ltu (Formerly Known As The Associated Mumbai Cement Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) Acit – Ltu V. M/S. Acc Limited 28Th Floor, Centre-1 (Formerly Known As The Associated Cement Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai - 400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 145ASection 251Section 44A

115J of the Act, as it defies the basic intention behind introduction of provisions of section 115JB of the Act. The ITAT Jaipur bench, in case of Shree Cement Ltd. (supra) had considered an identical issue and held that incentives granted to the assessee is capital receipt and hence, cannot be part of book profit computed u/s 115JB