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6 results for “disallowance”+ Section 245D(4)clear

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Key Topics

Section 153C12Section 6912Section 1326Addition to Income5Section 10A4Section 143(3)3Unexplained Investment3Search & Seizure2

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

ITA 725/BANG/2018[2013-14]Status: DisposedITAT Bangalore31 Jul 2020AY 2013-14

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Percy Pardiwala, Sr. Advocate along with Ajay Roti, C.AFor Respondent: Shri K.V Arvind, Advocate
Section 10ASection 143Section 143(3)Section 144C(1)Section 92C

4. The foundation of the action of the authorities below for the denial of deduction is premised on the understanding that the modified return cannot breach the mandate of the APA, which, in turn, restricts its scope only to the determination of the ALP and nothing more than that. 5. In order to appreciate the rival contentions, it would

THE SENATE,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals of the assessee are allowed

ITA 1475/BANG/2013[2003-04]Status: DisposedITAT Bangalore18 Mar 2016AY 2003-04

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri S.Ramasubramanian, CAFor Respondent: Shri T.N.Prakash, Addl.CIT(DR)
Section 132Section 143(3)Section 153CSection 36

245D is received by the Commissioner under sub-section (2) of that section, ITA Nos.1475 to 1481/Bang/2013 Page 11 of 23 shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred to in clause (a) or clause (b) of this section available to the Assessing Officer for making an order

SLN COFFEE CURING WORKS,KUDLOOR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MYSORE

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 571/BANG/2022[2014-15]Status: DisposedITAT Bangalore20 Jan 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Vasudevan, A.RFor Respondent: Shri Manjunath Karkihalli, D.R
Section 132Section 153CSection 69

245D(4) on 02-12-2022 and advised to submit the written submissions on or before 12-12-2022. 3.12. Further, the ld AR submitted that the cash availability in the hands of the partners can also be explained by the Wealth Tax Returns filed by the two partners. Mr.N.Viswanathan and Mr.N.Sathappan in their wealth tax returns filed

SLN COFFEE CURING WORKS,KUDLOOR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MYSORE

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 570/BANG/2022[2013-14]Status: DisposedITAT Bangalore20 Jan 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Vasudevan, A.RFor Respondent: Shri Manjunath Karkihalli, D.R
Section 132Section 153CSection 69

245D(4) on 02-12-2022 and advised to submit the written submissions on or before 12-12-2022. 3.12. Further, the ld AR submitted that the cash availability in the hands of the partners can also be explained by the Wealth Tax Returns filed by the two partners. Mr.N.Viswanathan and Mr.N.Sathappan in their wealth tax returns filed

SLN COFFEE CURING WORKS,KUDLOOR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MYSORE

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 569/BANG/2022[2012-13]Status: DisposedITAT Bangalore20 Jan 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Vasudevan, A.RFor Respondent: Shri Manjunath Karkihalli, D.R
Section 132Section 153CSection 69

245D(4) on 02-12-2022 and advised to submit the written submissions on or before 12-12-2022. 3.12. Further, the ld AR submitted that the cash availability in the hands of the partners can also be explained by the Wealth Tax Returns filed by the two partners. Mr.N.Viswanathan and Mr.N.Sathappan in their wealth tax returns filed

DR. P. DAYANANDA PAI,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2(2), BANGALORE

In the result, appeal of the Assessee is partly allowed for statistical purpose

ITA 150/BANG/2020[2005-06]Status: DisposedITAT Bangalore26 Jul 2022AY 2005-06

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sassessment Year :2005-06 Dr. P Dayananda Pai, Vs. Dcit, 10/1, Lakshminarayana Complex, Circle – 2(2), Palace Road, Bengaluru. Bengaluru – 560 052. Pan : Abapp 4418 Q Appellant Respondent Assessee By : Shri. R. Ramakrishnan, Ca Revenue By : Smt. Susan Dolores George, Cit(Osd)(Itat), Bengaluru. Date Of Hearing : 19.07.2022 Date Of Pronouncement : 26.07.2022 O R D E R Per N. V. Vasudevan: This Is An Appeal By The Assessee Against The Order Dated 9.12.2019 Of Cit(A)-11, Bengaluru, Relating To Ay 2005-06. 2. The Assessee Is An Individual. He Is Also Referred To As “Pdp” In This Order. He Is In The Business Of Real Estate For Over Four Decades. He Carried On Business Of Real Estate In His Individual Capacity. From Ay 95-96 He Transferred All The Rights In Properties Under Various Agreements To A Partnership Firm “M/S.P.Dayanand Pai”, Vide Deed Of Partnership Dated 1-4-1994. In This Firm Mr.P.Dayanand Pai & His Brother Mr.P.Satish & 9 Other Individuals Were Partners. Thereafter By A Deed Of Partnership Dated 9.6.2000 The Firm “M/S.P.Dayanada Pai” Merged Its Business With Another Partnership Firm “M/S.Canara Housing Development Company” (Hereinafter Page 2 Of 39

For Appellant: Shri. R. Ramakrishnan, CAFor Respondent: Smt. Susan Dolores George, CIT(OSD)(ITAT), Bengaluru
Section 10Section 132Section 139Section 143(3)Section 147Section 148Section 149Section 151Section 153Section 153A

disallowance is worked out as per the entries in the seized documents that are handwritten and also as per the payments in the DTTE (Dummy Tally Training Environment). The payments as per" DTTE, the sum total of business payments is Rs. 30,57,64,000/-, miscellaneous payments of Rs 50.53,000/- and loans repaid