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9 results for “disallowance”+ Section 246clear

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Key Topics

Addition to Income8Section 1477Section 41(1)5Disallowance5Section 1484Section 364Section 143(3)4Section 36(1)(iii)4Section 153D4Section 271(1)(c)

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE- 3, SRINAGAR vs. MEASAGE SAIFCO CEEMENTS PRIVATE LIMITED, SRINAGAR

In the result, the appeal of the Department and CO of the Assesse is 23

ITA 451/ASR/2019[2013-14]Status: DisposedITAT Amritsar23 Aug 2023AY 2013-14

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

For Appellant: NoneFor Respondent: Sh. Rajiv Wadhera, Sr. DR
Section 143(3)Section 36Section 36(1)(iii)

disallowed under section 36(1)(iii) - Held, yes [Paras 7 & 11][In favour of revenue] (f) The Hon'ble High Court of Karnataka in the case of CIT vs. K.s. Dattatreya [2011) 197 taxman 151 has held that- "as a revisional authority commissioner appeals can revise not only the ultimate computation arrived at but every process which lead

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

4
Reassessment3
Reopening of Assessment2
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)

246 to 248 or under section 264, to claim that the proceedings under section 147 should be dropped on his showing that he had been assessed on an amount or to a sum not lower than what he would be rightly liable for even if the income alleged to have escaped assessment had been taken into account, or the assessment

SHRI AMRIK SINGH,AMRITSAR vs. INCOME TAX OFFICER WARD-4 (1), AMRITSAR

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

ITA 170/ASR/2023[2012-13]Status: DisposedITAT Amritsar13 Sept 2023AY 2012-13

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

Section 144Section 147Section 250Section 36Section 36(1)(iii)

246 which is exercised in accordance with procedure with Section 250 indicate and amplitude and width which is no less wide than that of an ITO and the Appellate Authority could substitute the order of the ITO by one of his own.". From the above, it is very clear that the powers of CIT(A) are coterminous with that

M/S KASHMIR STEEL ROLLING MILLS,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAMMU

In the result, the assessee’s appeal is partly allowed

ITA 548/ASR/2016[2009-10]Status: DisposedITAT Amritsar09 May 2018AY 2009-10

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 548/(Asr)/2016 Assessment Year: 2009-10

For Appellant: Sh. Tarun Bansal (Adv.)For Respondent: Sh. Charan Dass (D.R.)
Section 143(3)Section 271Section 271(1)(c)

disallowed in computing the total income or loss of an assessee in any order of assessment or reassessment and the said order contains a direction for initiation of penalty proceedings under clause (c) of sub-section (1), such an order of assessment or reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings

M/S. BRIGHT ENTERPRISES PVT. LTD.,JALANDHAR vs. ASSTT. COMMISSIONER OF INCOME-TAX, JALANDHAR

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

ITA 126/ASR/2015[2012-13]Status: DisposedITAT Amritsar17 Jan 2019AY 2012-13

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.354/Asr./2014 : Asstt. Year : 2010-11 Ita No.126/Asr./2015 : Asstt. Year : 2012-13 M/S Bright Enterprises Pvt. Ltd., Vs Deputy Commissioner Of Income Mbd House, Railway Road, Tax, Central Circle-Ii, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Aaacb9469K Assessee By : Sh. Sudhir Sehgal, Adv. Revenue By : Sh. Pawan K. Kumar, Cit Dr Date Of Hearing : 08.01.2019 Date Of Pronouncement : 17.01.2019 Order Per N. K. Saini: These Two Appeals By The Assessee Are Directed Against The Orders Dated 08.05.2014 & 15.01.2015 Of The Ld. Cit(A)-5, Ludhiana For The Assessment Years 2010-11 & 2012-13 Respectively. 2. Since, The Issues Involved Are Common & The Appeals Were Heard Together, So These Are Being Disposed Off By This Consolidated Order For The Sake Of Convenience & Brevity.

For Appellant: Sh. Sudhir Sehgal, AdvFor Respondent: Sh. Pawan K. Kumar, CIT DR
Section 40A(2)(b)Section 4G

246 (Jodhpur ITAT) ITA No. 354/Asr./2014 13 Bright Enterprises Pvt. Ltd. " Lavrids KnudsenMaskinfabrik (India) Ltd. Vs ACIT (2006) 102 TTJ 882 (Pune ITAT) " Surface Furnishing Equipment Vs DCIT (2003) 81 TTJ 448 (Jodhpur ITAT) 10. The ld. CIT(A) after considering the submissions of the assessee upheld the disallowance made by the AO by observing in para

M/S BRIGHT ENTERPRISES PVT. LTD,,JALANDHAR vs. THE DY. COMMISSIONER OF INCOME-TAX, JALANDHAR

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

ITA 354/ASR/2014[2010-11]Status: DisposedITAT Amritsar17 Jan 2019AY 2010-11

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.354/Asr./2014 : Asstt. Year : 2010-11 Ita No.126/Asr./2015 : Asstt. Year : 2012-13 M/S Bright Enterprises Pvt. Ltd., Vs Deputy Commissioner Of Income Mbd House, Railway Road, Tax, Central Circle-Ii, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Aaacb9469K Assessee By : Sh. Sudhir Sehgal, Adv. Revenue By : Sh. Pawan K. Kumar, Cit Dr Date Of Hearing : 08.01.2019 Date Of Pronouncement : 17.01.2019 Order Per N. K. Saini: These Two Appeals By The Assessee Are Directed Against The Orders Dated 08.05.2014 & 15.01.2015 Of The Ld. Cit(A)-5, Ludhiana For The Assessment Years 2010-11 & 2012-13 Respectively. 2. Since, The Issues Involved Are Common & The Appeals Were Heard Together, So These Are Being Disposed Off By This Consolidated Order For The Sake Of Convenience & Brevity.

For Appellant: Sh. Sudhir Sehgal, AdvFor Respondent: Sh. Pawan K. Kumar, CIT DR
Section 40A(2)(b)Section 4G

246 (Jodhpur ITAT) ITA No. 354/Asr./2014 13 Bright Enterprises Pvt. Ltd. " Lavrids KnudsenMaskinfabrik (India) Ltd. Vs ACIT (2006) 102 TTJ 882 (Pune ITAT) " Surface Furnishing Equipment Vs DCIT (2003) 81 TTJ 448 (Jodhpur ITAT) 10. The ld. CIT(A) after considering the submissions of the assessee upheld the disallowance made by the AO by observing in para

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

disallowance was based on third party information gathered by Investigation Wing of Department, which had not been independently subjected to further verification by Assessing Officer and he had not provided copy of such statements to appellant, thus, denying opportunity of cross examination to appellant, who on other hand, had prima facie discharged initial burden of substantiating purchases through various documentation

SHRI OM PARKASH LEGAL HEIAR SMT PUSHPA VERMA,JALANDHAR vs. INCOME TAX OFFICER WARD-1(3), JALANDHAR

In the result, the assessee’s appeal is dismissed

ITA 756/ASR/2017[2014-15]Status: DisposedITAT Amritsar31 Oct 2018AY 2014-15

Bench: Sh. Sanjay Arorai.T.A. No. 756/Asr/2017 Assessment Year: 2014-15

For Appellant: Sh. Ashray Sarna (C.A.)For Respondent: Sh. Charan Dass (D.R.)
Section 143(3)Section 145(3)Section 41(1)Section 41(1)(a)Section 68

246 (P&H), to the effect that once the net profit rate is applied for estimating income, no separate addition on account of cash credit, or for payment of purchases, could be made. He, however, fairly conceded that the said decision stands rendered without considering the decision in Devi Prasad Vishwanath Prasad (supra), so that if and to the extent

SHRI MADAL LAL,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JALANDHAR

In the result, all the appeals of the Assessee are allowed

ITA 112/ASR/2018[2007-08]Status: DisposedITAT Amritsar16 Aug 2021AY 2007-08

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

Section 153B(1)Section 153D

246 ITR 363 (MP), the same question has been considered by a Coordinate Bench of this Court and the following principles are laid down:— 'The Commissioner acted, of course, mechanically in order to discharge his statutory obligation properly in the matter of recording sanction as he merely wrote on the format "Yes, I am satisfied" which indicates