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13 results for “disallowance”+ Unexplained Investmentclear

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Key Topics

Addition to Income12Section 6810Disallowance6Section 143(3)5Section 153C4Section 134Section 40A(2)4Section 1474Section 56(2)(vii)4Unexplained Investment

ASSITANT COMMISSIONER OF INCOME TAX , DEHRADUN vs. POWER MACHINES, NEW DELHI

In the result, appeal preferred by the revenue is dismissed

ITA 133/DDN/2024[2013-14]Status: DisposedITAT Dehradun27 Feb 2026AY 2013-14

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Ansaul Sachar, AdvFor Respondent: Sh. Mohan Lal Joshi, Sr. DR
Section 143(3)Section 144Section 271(1)(c)Section 69

unexplained Investment as the entire money is appearing in the books of accounts of the company and received through proper banking challan from outside India. The addition thus made by the AO is hereby deleted and the ground allowed to the appellant.” 6. Aggrieved, the revenue is in appeal before us raising following grounds: “1 (i) On the facts

4
Search & Seizure4
Section 40A(3)3

DIGVIJAY SINGH,DEHRADIM vs. DCIT,CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee for assessment year

ITA 117/DEL/2019[2016-17]Status: DisposedITAT Dehradun28 Jun 2023AY 2016-17
Section 132Section 153C

unexplained investment made by the assessee in the sum of Rs. 1 crore in the facts and circumstances of the instant case. Page 6 of 14 ITA Nos.2336 & 117/Del/2019 AYs: 2015-16 & 2016-17 8. Since the search assessment order of Sh. Rameshwar Havelia for assessment year 2015-16 could not be placed on record by the assessee before

DIGVIJAY SINGH,DEHRADUN vs. DCIT,CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee for assessment year

ITA 2336/DEL/2019[2015-16]Status: DisposedITAT Dehradun28 Jun 2023AY 2015-16
Section 132Section 153C

unexplained investment made by the assessee in the sum of Rs. 1 crore in the facts and circumstances of the instant case. Page 6 of 14 ITA Nos.2336 & 117/Del/2019 AYs: 2015-16 & 2016-17 8. Since the search assessment order of Sh. Rameshwar Havelia for assessment year 2015-16 could not be placed on record by the assessee before

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), DEHRADUN, DEHRADUN vs. STONEFIELD CONSTRUCTION, DEHRADUN, DEHRADUN

In the result, appeal of the Revenue is partly allowed

ITA 215/DDN/2025[2023-24]Status: DisposedITAT Dehradun08 Apr 2026AY 2023-24
Section 115BSection 133ASection 139Section 143(3)Section 250Section 250(2)Section 40A(3)Section 40aSection 69ASection 69C

Disallowance u/s 40A(3) of the Act INR 30,000/- 3. Besides this, AO treated the income declared in the return of income filed at INR 3.89 crores on account of difference in survey during the course of search as unexplained investment

SHRI VIBHU GROVER,KOTDWARA vs. PCIT, DEHRADUN

In the result appeal of the assessee is allowed

ITA 110/DDN/2024[2015-16]Status: DisposedITAT Dehradun26 Sept 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalvibhu Grover, Pcit, M/S Grover Sales Corporation, Dehradun. Garage Road, Kotdwara, Vs. Pauri-246169 Pan:Agdpg5842R (Appellant) (Respondent) Assessee By Shri Anil Jain, Adv. Department By Shri S.K. Chaterjee, Cit-Dr

Section 142(1)Section 147Section 148Section 263

Unexplained investments (Unsecured loans) - Assessment year 2013-14 - Assessee-company had received unsecured loans from two different companies - Commissioner noting that said loans were shown as investment in assessee's name in balance sheet of respective companies exercised revisionary powers and passed an order without giving an opportunity to assessee of being heard, invoking Explanation 2 to section 263 - High

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, DEHRADUN vs. OM PRAKASH GUPTA, DEHRADUN

Appeal of the assessee is allowed

ITA 160/DDN/2025[2023-24]Status: DisposedITAT Dehradun13 Jan 2026AY 2023-24

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 160/Ddn/2025 : Asstt. Year: 2023-24 Dcit, Vs Om Prakash Gupta, Central Circle, 19/A, Raj Vihar, Dehradun-2488001 Dehradun-248001 (Appellant) (Respondent) Pan No. Abipg9323M Assessee By : Sh. S. K. Matta, Ca Revenue By : Ms. Poonam Sharma, Cit-Dr Date Of Hearing: 13.01.2026 Date Of Pronouncement: 13.01.2026 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2023-24, Arises Against The Cit(A)-3, Noida’S Din & Order No. Itba/Apl/M/250/2025-26/1076723333(1) Dated 04.06.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961. 2. Heard Both The Parties At Length. Case File Perused.

For Appellant: Sh. S. K. Matta, CAFor Respondent: Ms. Poonam Sharma, CIT-DR
Section 143(3)

disallowance is found to be based on mere conjecture and surmises. Rejected accordingly. 5. Next comes the second substantive issue between the parties regarding correctness of the CIT(A)’s action partly upholding the assessment findings making unexplained investment

AJAY THAKUR ,DEHRADUN vs. ITO, WARD-1(1)(1)1, DEHRADUN, DEHRADUN

Appeal is partly allowed

ITA 60/DDN/2023[2017-18]Status: DisposedITAT Dehradun27 Jan 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing) Assessment Year: 2017-18 Vs. Income Tax Officer, Sh. Ajay Thakur, S/O- Sh. Surendra Singh, 31-Purbiya Ward-1(1)(1)1, Lines, Hospital Road, Dehradun Vikas Nagar, Dehradun Pan: Afkpt5059D (Appellant) (Respondent) Assessee By Sh. Rajiv Sahni, Ca Department By Sh. A.S. Rana, Sr. Dr Date Of Hearing 10.01.2025 Date Of Pronouncement 27.01.2025 Order

Section 115BSection 147Section 2(14)Section 56(2)(vii)Section 69

unexplained investment addition of Rs.12 lakhs which has been held liable to be assessed under section 115BBE of the Act. He seeks to buttress the point on the quantification aspect thereof that some of the corresponding cheques had bever been encashed during the land transaction in question. 8. The Revenue’s case, on the other hand, is that there

INSTITUTE OF CLINICAL RESEARCH (INDIA) SOCIETY,DEHRADUN vs. ACIT, DEHRADUN

In the result, the appeal filed by the assessee in ITA No

ITA 4207/DEL/2010[2006-07]Status: DisposedITAT Dehradun15 Jan 2025AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri A.S. Rana, Sr. DR
Section 11Section 13Section 36(1)(iii)Section 40A(2)Section 40A(2)(b)Section 68

unexplained cash credit inspite of the facts that the assessee did not fully discharged its onus u/s 68 of the Act." 6. At the very outset, the ld. counsel for the assessee fairly conceded that Ground No. 1 relating to invocation of provisions of section 13 of the Income-tax Act, 1961 [the Act for short] is to be allowed

DCIT, DEHRADUN vs. M/S INSTITUTE OF CLINICAL RESEARCH (INDIA) SOCIETY,, DEHRADUN

In the result, the appeal filed by the assessee in ITA No

ITA 3927/DEL/2012[2008-09]Status: DisposedITAT Dehradun15 Jan 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri A.S. Rana, Sr. DR
Section 11Section 13Section 36(1)(iii)Section 40A(2)Section 40A(2)(b)Section 68

unexplained cash credit inspite of the facts that the assessee did not fully discharged its onus u/s 68 of the Act." 6. At the very outset, the ld. counsel for the assessee fairly conceded that Ground No. 1 relating to invocation of provisions of section 13 of the Income-tax Act, 1961 [the Act for short] is to be allowed

MRS. DHOOMI DEVI,CHAMOLI vs. ITO, W-1(4)4, SRINAGAR, CHAMOLI

In the result, appeal of the assessee is partly allowed

ITA 149/DDN/2024[2022-23]Status: DisposedITAT Dehradun13 Feb 2026AY 2022-23

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2022-23] Mrs. Dhoomi Devi Vs Ito C/O-Hotel Udai Palace Near . Ward-1(4)4 Narsingh Temple Srignagar, Chamoli Joshimath Chamoli, Uttarakhand-246174 Uttarakhand-246443 Pan-Adkpd6984B Appellant Respondent Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri A.S. Rana, Sr. Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 13.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.08.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2021-22/10329482 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 05.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Is An Individual & The Case Was Selected For Scrutiny Under Cass For Reason I.E. “Large Investment In Immovable Property As Compared To The Total Income”. The Ao Than Passed The Assessment Order U/S 143(3) R.W.S. 144B On 05.03.2024 At A Total Income Of Inr 2,70,31,224/- As Against The Total Income Declared At Inr 29,45,000/- In The Return Of Income Filed By The Assessee.

Section 143(3)Section 250Section 54FSection 54F(1)

investment in NHAI Bond of INR 50 Lakhs and further claimed deduction of INR 1,90,86,224/- u/s 54F of the Act proportionately out of total cost of acquisition of new house property for INR 2,10,19,420/-. The AO disallowed the deduction claimed u/s 54F of the Act by holding that assessee is having more than

DCIT, CIRCLE- 2, DEHRADUN vs. V K AGARWAL & CO., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 3390/DEL/2018[2014-15]Status: DisposedITAT Dehradun23 Jun 2023AY 2014-15

Bench: The Ao During The Course Of Assessment Proceedings. 2. The Ld. Cit(A) Has Erred In Law & On Facts In Deleting The Addition Of Rs.34,00,000/- Made On Account Of Unsecured Loan U/S 68 Of The I.T. Act, 1961 As The Assessee Could Not Furnish/Produce The Confirmation Of Unsecured Loan From M/S Tirupati Investment. 3. The Order Of The Ld. Cit(A) Be Set-A-Side & The Order Of The Ao Be Restored.

Section 37(1)Section 40Section 44ASection 68

Investment, for which the assessee had not furnished PAN or address or confirmation from the lender. Accordingly, the learned AO concluded that since the assessee had not proved the three necessary ingredients of section 68 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), viz., identity of the creditors, creditworthiness of the creditors and genuineness

DCIT, CC, , DEHRADUN vs. SRIVAAS PROJECTS PRIVATE LTD, RISHIKESH

ITA 21/DDN/2019[2012-13]Status: DisposedITAT Dehradun23 Jun 2023AY 2012-13

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

For Appellant: Sh. Rajesh Malhotra, CAFor Respondent: Sh. N.S. Jangpangi, CIT-DR
Section 153ASection 68

disallowed amounts of Rs.42,74,9900/- and Rs.6,74,250/- for the assessment years 2013-14 and 2014-15 respectively by invoking the provisions of section 56(2)(viib) of the Act. Being aggrieved, the Revenue is before us. 7. We have considered rival submissions and perused materials on record. Undisputedly, in course of assessment proceedings

SRIVAAS PROJECTS PRIVATE LTD,NEW DELHI vs. DCIT, CC, , DEHRADUN

ITA 3077/DEL/2019[2014-15]Status: DisposedITAT Dehradun23 Jun 2023AY 2014-15

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

For Appellant: Sh. Rajesh Malhotra, CAFor Respondent: Sh. N.S. Jangpangi, CIT-DR
Section 153ASection 68

disallowed amounts of Rs.42,74,9900/- and Rs.6,74,250/- for the assessment years 2013-14 and 2014-15 respectively by invoking the provisions of section 56(2)(viib) of the Act. Being aggrieved, the Revenue is before us. 7. We have considered rival submissions and perused materials on record. Undisputedly, in course of assessment proceedings