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19 results for “disallowance”+ Revision u/s 263clear

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Key Topics

Section 26373Section 143(3)26Section 14717Addition to Income11Section 115J9Section 1548Section 80I7Section 106Section 250(6)6Disallowance

SHRIMATI. LATA NARANG,JALANDHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessee is allowed

ITA 35/ASR/2021[2011-12]Status: DisposedITAT Amritsar02 Mar 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Ashray Sarna, CAFor Respondent: Smt. Rajinder Kaur, CIT- DR
Section 143(3)Section 147Section 263Section 5(2)Section 6

revise it u/s 263 of the I. T. Act. Reference is also invited to the following judgments in this regard. Braham Dev Gupta v. PCIT— [2017] 88 taxmann.com 831 (1TAT Delhi) CIT v. Nirav Modi - [2016] 71 taxmann.com 272 (Bombay) [’s SLP dismissed by SC] Further reference is invited to the decision of the Punjab and Haryana High Court

5
Reassessment5
Deduction5

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

In the result, the appeal filed by assessee is allowed

ITA 306/ASR/2024[2019-20]Status: DisposedITAT Amritsar09 Jan 2025AY 2019-20
Section 115BSection 143(3)Section 263Section 263(1)Section 69

u/s 143(3)\nwithout making any addition by stating that the appellant had duly considered the amount\nsurrendered in the return of income filed.\nThat the same facts were presented before the PCIT and it was submitted that even if the\ncorrect excess stock amounting to Rs. 1777416/- is considered and tax is calculated as per\nthe provisions of section

SHRI SUKHJINDER SINGH,JALANDHAR vs. PRINICPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessee is allowed

ITA 71/ASR/2022[2017-18]Status: DisposedITAT Amritsar20 Mar 2023AY 2017-18

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. P. N. Arora, AdvFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 263

u/s 69A is concerned, could not be taken as an unexplained amount particularly when no defect whatsoever has been pointed out in the said bank statement and evidences filed by the appellant in support of its claim. In our view, the decision of Ld. PCIT proposing disallowance of entire amount of Rs. 12,38,000/- is not justified

SHRI GAGANDEEP GARG. PROP,BATHINDA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, AMRITSAR

In the result, the appeal of the assessee is allowed

ITA 39/ASR/2021[2015-16]Status: DisposedITAT Amritsar07 Jun 2023AY 2015-16

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 263

revised u/s 263 of the Act. The Ld. PCIT being not satisfied with the explanation furnished by the appellant assessee held the assessment order dated 31.03.2015 passed by the ITO, Ward-1(1), Bathinda in present case for the A.Y. 2015- 16 as erroneous and prejudicial to the interest of revenue u/s 263

SHRI AMRITPAL SINGH (PROP),JALANDHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX- 1, JALANDHAR

In the result, appeal of the assessee ITA No

ITA 425/ASR/2019[2014-15]Status: DisposedITAT Amritsar13 Sept 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 110Section 263Section 54D

disallowed.” I.T.A. No. 425/Asr/2019 22 Assessment Year: 2014-15 6. The ld. DR vehemently argued and fully relied on the order of the ld. PCIT u/s 263. The relevant paragraph 3 of the said order is reproduced as below: “3. I have carefully considered written submissions and documents filed by the counsel of the assessee during the proceeding u/s 263

JALALABAD SOLVEX PRIVATE LTD,JALALABAD vs. PR COMMISSIONER OF INCOME TAX , AMRITSAR-1, PR COMMISSIONER OF INCOME TAX

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

ITA 117/ASR/2024[2014-2015]Status: DisposedITAT Amritsar29 Jan 2025AY 2014-2015

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: Sh. Ashwani Kalia, C.A
Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 263Section 263(1)

263 of the Act’61 , on the ground that the proper investigation and enquiry has not been made 5 I.T.A. No. 117/Asr/2024 Jalalabad Solvex Pvt. Ltd. v. Pr. CIT by the Assessing Officer, which has resulted in the order passed being erroneous and prejudicial to the interest of Revenue. The relevant portion of the shows cause notice is reproduced

THE NBI EMPLOYEES CO-OP NON-AGRICULTURAL THRIFT & CREDIT SOCIETY LIMITED ,JALANDHAR vs. PRINCIPAL COMMISIONER OF INCOME TAX-2, JALANDHAR

ITA 275/ASR/2018[2013-14]Status: DisposedITAT Amritsar21 Feb 2022AY 2013-14

Bench: Sh. Ravish Sood & Dr. M. L. Meena

For Appellant: Sh. Ashray Sarna, CAFor Respondent: Shri Sunil Gautam, CIT-DR
Section 143(3)Section 263Section 8Section 80PSection 80P(2)(a)Section 80P(2)(d)

263 holding the assessment order erroneous and prejudicial to the interest of the revenue in view of the Hon’ble Juridiction High Court and the Apex Court (Supra), and directing the Assessing Officer so. 7. We have heard both the sides and perused the impugned orders, and the case law cited. It is admitted fact that the assessee society

WALIA CONSTRUCATION COMPANY ,PATHANKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, AMRITSAR

In the result, appeal of the assessee ITA No

ITA 139/ASR/2023[2017-18]Status: DisposedITAT Amritsar21 Aug 2023AY 2017-18

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143Section 143(3)Section 263

263 the assessee filed the submission before the ld. PCIT which was duly ignored. 5.1 The ld. AR invited our attention in the order of the ld. PCIT in pages 2 to 3 paragraphs 3 to 5 which are duly reproduced as below: “03. On 21-03-2022 the reply of the assessee received through ITBA which is reproduced

M/S ACTIVE TOOLS (P). LIMITED,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -II, JALANDHAR

ITA 260/ASR/2019[2014-15]Status: DisposedITAT Amritsar16 Aug 2021AY 2014-15

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 115Section 133ASection 142(1)Section 154Section 68Section 69Section 69ASection 69BSection 69CSection 69D

revision disallowing the special deduction was not valid." 9. The Hon,ble Chandigarh Tribunal in the case of Khushi Ram & Sons Pvt. Ltd. (supra) has decided similar issue wherein the assessee had surrendered an amount of Rs. 80 lacs during the course of survey on account of building renovation, office equipment and sundry receivables and claimed set off of unabsorbed

M/S TORRENT ROOFING SYSTEM,HOSHIARPUR vs. INCOME TAX OFFICER WARD-4, HOSHIARPUR

In the result, the appeal of the assesse is allowed for statistical

ITA 84/ASR/2023[2014-15]Status: DisposedITAT Amritsar12 May 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143Section 263Section 40(1)(ia)

Disallowed the expanses to the tune of Rs 676050/- 25% of the total royalty paid in view of the Judgment of M/s Southern Switch Gear Ltd (232 ITR 359) But the facts of our case are entirety different from the facts of the case law relied on by the Pr CIT and A.O. We submitted many case law decided

OSAKA ALLOYS & STEEL PRIVATE LIMITED,JALANDHAR vs. DCIT/ACIT, CIRCLE-1, JLD, JALANDHAR

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

ITA 60/ASR/2025[2012-13]Status: DisposedITAT Amritsar07 Aug 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 115Section 115JSection 143(1)Section 154Section 154oSection 2(24)Section 250Section 250oSection 80I

revision u/s 263 of the Act, and ultimately the issue travelled to the tribunal, and in ITA No. 257/Asr/2019 dated 26.06.2024the Hon’ble bench opined against assumption of jurisdiction u/s 263 by the Ld PCIT . 14. It is further argued by the ld. AR of the assessee that only mistakes which are apparent from the record can be rectified

SWAMI GANGA GIRI JANTA GIRLS COLLEGE,RAIKOT vs. INCOME TAX OFFICER (EXEMPTIONS) WARD, JALANDHAR

In the result,the appeal of the assessee ITA No

ITA 715/ASR/2019[2016-17]Status: DisposedITAT Amritsar20 Jun 2023AY 2016-17

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10Section 143(1)Section 143(3)Section 147Section 250(6)Section 263Section 43(1)

U/s 263 & 250(6) of Income Tax Act, 1961(in brevity the Act) respectively. The assessment orders were framed by the ld. CPC & ITO, Exemption, Jalandhar (in brevity the AO). ITA 87/ASR/2022 2. The assessee has taken the following grounds: “1. That the order dated 29.03.2022 passed under section 263 of the Income Tax Act, 1961 by the Ld. Commissioner

SHRI SWAMI GANGA GIRI JANTA GIRLS COLLEGE,RAIKOOT vs. DEPUTY COMMISSIONER OF INCOME TAX (CPC), BANGALORE

In the result,the appeal of the assessee ITA No

ITA 454/ASR/2019[2015-16]Status: DisposedITAT Amritsar20 Jun 2023AY 2015-16

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10Section 143(1)Section 143(3)Section 147Section 250(6)Section 263Section 43(1)

U/s 263 & 250(6) of Income Tax Act, 1961(in brevity the Act) respectively. The assessment orders were framed by the ld. CPC & ITO, Exemption, Jalandhar (in brevity the AO). ITA 87/ASR/2022 2. The assessee has taken the following grounds: “1. That the order dated 29.03.2022 passed under section 263 of the Income Tax Act, 1961 by the Ld. Commissioner

SWAMI GANGA GIRI JANTA GIRLS COLLEGE ,RAIKOT vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CHANDIGARH

In the result,the appeal of the assessee ITA No

ITA 87/ASR/2022[2012-13]Status: DisposedITAT Amritsar20 Jun 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10Section 143(1)Section 143(3)Section 147Section 250(6)Section 263Section 43(1)

U/s 263 & 250(6) of Income Tax Act, 1961(in brevity the Act) respectively. The assessment orders were framed by the ld. CPC & ITO, Exemption, Jalandhar (in brevity the AO). ITA 87/ASR/2022 2. The assessee has taken the following grounds: “1. That the order dated 29.03.2022 passed under section 263 of the Income Tax Act, 1961 by the Ld. Commissioner

MEASAGE.OSAKA ALLOYS AND STEEL (P) LTD,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, JALANDHAR

The appeal stand dismissed

ITA 347/ASR/2019[2013-14]Status: DisposedITAT Amritsar20 Feb 2026AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm आयकर अपील सं. / Ita No.347/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Osaka Alloys & Steel (P) Ltd. Dcit Circle - Ii बनाम/ 428, Mota Singh Nagar, Jalandhar Jalandhar Punjab - 144001 C/O Bhagat & Co. (Ca) Vs. 16 Brij Nagar, Jalandhar, Punjab - 144001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-7097-G (अपीलाथ"/Appellant) (" थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Adjournment Request " थ"कीओरसे/Respondent By : Sh. Farhat Khan (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 03-02-2026 घोषणाकीतारीख /Date Of Pronouncement 20.02.2026 : आदेश / O R D E R

For Appellant: Adjournment requestFor Respondent: Sh. Farhat Khan (CIT) - Ld. DR
Section 115JSection 143(3)Section 263Section 263(1)Section 264Section 80I

disallowances and framed an assessment. Subsequently, Ld. Pr. CIT, upon perusal of case records, observed that the assessee worked out book profits of Rs.1,716/- after claiming deduction u/s 80IB for Rs.3,11,72,422/- which was not permissible deduction u/s 115JB. Such omission resulted in short computation of book profit. The Ld. AO failed to work out correct book

SHRI SHAM SUNDER AGGARWAL,KAPURTHALA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, the appeal of the assessee bearing ITA No

ITA 17/ASR/2021[2011-12]Status: DisposedITAT Amritsar27 Apr 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 147Section 148Section 151Section 263Section 263o

u/s 151 of the Act. During hearing before he ld. PCIT, the ld. AR submitted the following details which are enclosed in APB page 1 to 16. The relevant paragraph of assessee’s submission is extracted as below: 13. Now coming to the issues raised in the SCN as regards the alleged bogus purchases of Rs.1,97,93,175/- from

M/S. SATIA INDUSTRIES LIMITED,MUKTSAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

In the result, the appeal of the assessee bearing ITA No

ITA 193/ASR/2022[2018-19]Status: DisposedITAT Amritsar13 Jun 2023AY 2018-19

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 115BSection 143(3)Section 144C(8)Section 250oSection 69C

revision: It is not open to the Appellate Commissioner to introduce in the Assessment a new source of income and the assessment must be confined to those items of income which were the subject-matter of the original assessment. 50. In course of time, Union Tyres was doubted. In. Sardari Lal &Co.,(supra) the same issue—whether the appellate authority

MESERS SUPERTECH FORGINGS(INDIA) PVT.LTD.,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE IV, JALANDHAR

In the result, the appeal of the Assessee is allowed

ITA 563/ASR/2018[2010-11]Status: DisposedITAT Amritsar02 Aug 2021AY 2010-11
Section 143(3)Section 147

263 (Delhi) wherein it has been held that evidence found as a result of search would not take within its sweep statements recorded during search and seizure operations unless they are related to any material found during the course of search. He therefore submitted that there should be a nexus between the statement recorded u/s 132 (4) and evidence/material which

M/S JAMMU COOPERATIVE WHOLE SALE LIMITED,JAMMU vs. INCOME TAX OFFICER WARD-2 (1), JAMMU

ITA 150/ASR/2020[2005-06]Status: DisposedITAT Amritsar13 Jun 2023AY 2005-06

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 150/Asr/2020 Assessment Year: 2005-06 M/S Jammu Cooperative Whole Sale The Ito Limited (Super Bazar) Old Hospital Ward-2(1) Road, City Chowk, Jammu- Jammu 180001(J&K)-180001

For Appellant: None
Section 147Section 148Section 152Section 40A(3)

revision, in disguise and seek relief or claim relief in respect of items not claimed in the original assessment proceedings, unless relatable to "escaped income" and re-agitate the concluded matters. Even in cases where the claims of the assessee during the course of re-assessment proceedings relating to the escaped assessment are accepted, still the allowance of such claims