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Jcit (Osd) Ltu 2, Chennai vs Saint Gobain Glass India India Limited, ... on 28 July, 2023

4.1 The learned CIT(A) has erred and held that the disallowance u/s 14A cannot be added in the book profit u/s 115JB of the I.T. Act. 4.2 The learned CIT(A) has failed to appreciate the ruling in the case of DCIT, Central Circle 18 and 19, Mumbai Vs Viraj Profiles Limited in 64 Taxmann.com 52(2015) (Mumbai-Trib) wherein it was held that A0 has rightly disallowed the expenditure u/s 14A of the Act read with Rule 8D of the Income Tax Rules for computing book profit u/s 115JB(2) of the Act read with clause (f) to Explanation 1 to Section 115JB(2) of the Act.
Income Tax Appellate Tribunal - Chennai Cites 15 - Cited by 1 - Full Document

Gujarat Urja Nigam Ltd.,, Baroda vs Dcit, Circle-1(1)(1), Baroda on 31 July, 2023

18. We have duly considered rival contentions and gone through the record carefully. We find that ld. DRP has relied upon the order of the ITAT, Mumbai in the case of DCIT Vs. Viraj Profiles Ltd., (2016) 46 ITR (Trib) 0626 (Mum) and held that addition required to be made in the book profit could be calculated as per Rule 8D of the Income Tax Rules.
Income Tax Appellate Tribunal - Ahmedabad Cites 35 - Cited by 0 - Full Document

Dcit, Circle-1(1)(1), Baroda vs Gujarat Urja Vikas Nigam Ltd.,, Baroda on 31 August, 2023

18. We have duly considered rival contentions and gone through the record carefully. We find that ld. DRP has relied upon the order of the ITAT, Mumbai in the case of DCIT Vs. Viraj Profiles Ltd., (2016) 46 ITR (Trib) 0626 (Mum) and held that addition required to be made in the book profit could be calculated as per Rule 8D of the Income Tax Rules.
Income Tax Appellate Tribunal - Ahmedabad Cites 46 - Cited by 0 - Full Document

The Principal Commissioner Of Income ... vs M/S Gujarat Flurochemicals Ltd on 5 September, 2023

18. We have duly considered rival contentions and gone through the record carefully. We find that ld. DRP has relied upon the order of the ITAT, Mumbai in the case of DCIT Vs. Viraj Profiles Ltd., (2016) 46 ITR (Trib) 0626 (Mum) and held that addition required to be made in the book profit could be calculated as per Rule 8D of the Income Tax Rules.
Gujarat High Court Cites 35 - Cited by 0 - B Vaishnav - Full Document

The Dcit, Circle-1(1)(1), Vadodara vs Gujarat Urja Vikas Nigam Ltd, Vadodara on 29 February, 2024

18. We have duly considered rival contentions and gone through the record carefully. We find that ld. DRP has relied upon the order of the ITAT, Mumbai in the case of DCIT Vs. Viraj Profiles Ltd., (2016) 46 ITR (Trib) 0626 (Mum) and held that addition required to be made in the book profit could be calculated as per Rule 8D of the Income Tax Rules.
Income Tax Appellate Tribunal - Ahmedabad Cites 43 - Cited by 0 - Full Document

Gujarat Urja Vikas Nigam Ltd, Vadodara vs The Acit, Cirecle-1(1)(1), Vadodara on 29 February, 2024

18. We have duly considered rival contentions and gone through the record carefully. We find that ld. DRP has relied upon the order of the ITAT, Mumbai in the case of DCIT Vs. Viraj Profiles Ltd., (2016) 46 ITR (Trib) 0626 (Mum) and held that addition required to be made in the book profit could be calculated as per Rule 8D of the Income Tax Rules.
Income Tax Appellate Tribunal - Ahmedabad Cites 43 - Cited by 0 - Full Document

Gujarat Urja Vikas Nigam Limited, ... vs The Dy. Commissioner Of Income Tax, ... on 15 March, 2024

18. We have duly considered rival contentions and gone through the record carefully. We find that ld. DRP has relied upon the order of the ITAT, Mumbai in the case of DCIT Vs. Viraj Profiles Ltd., (2016) 46 ITR (Trib) 0626 (Mum) and held that addition required to be made in the book profit could be calculated as per Rule 8D of the Income Tax ITA Nos.139&178/Ahd/2023 Gujarat Urja Vikas Nigam Ltd. vs. DCIT/ACIT Asst.Year- 2018-19
Income Tax Appellate Tribunal - Ahmedabad Cites 43 - Cited by 0 - Full Document

The Acit, Circle-1(1)(1), Vadodara vs Gujarat Urja Vikas Nigam Limited, ... on 15 March, 2024

18. We have duly considered rival contentions and gone through the record carefully. We find that ld. DRP has relied upon the order of the ITAT, Mumbai in the case of DCIT Vs. Viraj Profiles Ltd., (2016) 46 ITR (Trib) 0626 (Mum) and held that addition required to be made in the book profit could be calculated as per Rule 8D of the Income Tax ITA Nos.139&178/Ahd/2023 Gujarat Urja Vikas Nigam Ltd. vs. DCIT/ACIT Asst.Year- 2018-19
Income Tax Appellate Tribunal - Ahmedabad Cites 43 - Cited by 0 - Full Document

Dcit 3(3)(1), Mumbai vs Sp Port Maintenance Private Limited, ... on 25 June, 2024

16.Regarding the observation of the Ld. AO with respect to the applicability of clause F of explanation 1 to Section 115JB of "the Act", wherein it was observed that the disallowance amount has to be added back for the purpose of arriving at figure of book profit. The finding of the Hon'ble Page | 15 ITA No. 3895/Mum/2023 & 3896 of 2023 SP Port Maintenance Pvt. Ltd.; A.Y. 2017-18 & 2018-19 jurisdictional High Court in M/s. Bengal Finance Investment Pvt. Ltd. case referred (supra), the amount of disallowance u/s. 14A of "the Act" cannot be added for arriving at book profit for the purpose of Section 115JB of "the Act". Para 4 of the judgment can be quoted and relied with profit which is as under: -
Income Tax Appellate Tribunal - Mumbai Cites 25 - Cited by 0 - Full Document
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