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8,481 results for “disallowance”+ Section 11(1)(c)clear

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Key Topics

Addition to Income81Disallowance54Section 143(3)50Section 153A46Section 14A30Deduction30Section 6824Section 153C24Section 143(1)20Section 271(1)(c)

RICHMOND EDUCATIONAL SOCIETY,NOIDA vs. DCIT/ACIT CENTRAL CIRCLE, GHAZIABAD, GHAZIABAD

ITA 4779/DEL/2025[2024-25]Status: DisposedITAT Delhi11 Mar 2026AY 2024-25

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Revenue byFor Respondent: Shri Gaurav Jain, Adv
Section 12ASection 132Section 143(3)Section 2(15)

c) of sub-section (1) of section 11. (Emphasis supplied by us) 9. The Learned AR before us submitted that Clause (e) of Explanation to Section 12AB(4) of the Act per se is wholly inapplicable and could not have been validly invoked in the facts and circumstances of the instant case. The Learned AR submitted that Clause

DCIT, CIRCLE 22(2), NEW DELHI, NEW DELHI vs. SAHIL VACHANI, DELHI

Showing 1–20 of 8,481 · Page 1 of 425

...
19
Section 153D17
Limitation/Time-bar13

Appeal of the Revenue stands dismissed

ITA 2604/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Jun 2025AY 2016-17

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy& Shriavdhesh Kumar Mishraआअसं.2604/िद"ी/2023(िन.व. 2016-17)

For Appellant: S/Shri Anuj Garg & Narpat Singh, Sr.DRFor Respondent: S/Shri Rohan Khare & Priyam
Section 271(1)(c)Section 54F

1)(c) of the Act. It was again reiterated that 10 there was absolutely no concealment, nor were any inaccurate particular ever submitted by the assessee-company. (Emphasis supplied) 6. The crucial facts of Reliance Petroproducts Pvt. Ltd. (supra) are that the AO levied penalty on the disallowance of interest incurred on the loans which was used

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

ITA 812/DEL/2019[2012-13]Status: DisposedITAT Delhi28 Mar 2023AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

ITA 2631/DEL/2018[2008-09]Status: DisposedITAT Delhi28 Mar 2023AY 2008-09

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

ITA 942/DEL/2019[2012-13]Status: DisposedITAT Delhi28 Mar 2023AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

ITA 940/DEL/2019[2010-11]Status: DisposedITAT Delhi28 Mar 2023AY 2010-11

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

ITA 939/DEL/2019[2009-10]Status: DisposedITAT Delhi28 Mar 2023AY 2009-10

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

ITA 943/DEL/2019[2013-14]Status: DisposedITAT Delhi28 Mar 2023AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

ITA 811/DEL/2019[2011-12]Status: DisposedITAT Delhi28 Mar 2023AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

ITA 941/DEL/2019[2011-12]Status: DisposedITAT Delhi28 Mar 2023AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

ADIT(E), NEW DELHI vs. M/S. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2872/DEL/2014[2010-11]Status: DisposedITAT Delhi24 Dec 2020AY 2010-11

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

1)(C) read with section 13(3); thirdly, computation of income consequent to denial of exemption under section 11/ 12 of the Act; fourthly, ad hoc disallowance

IILM FOUNDAION,NEW DELHI vs. ADIT (EXEMPTION), NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 1142/DEL/2011[2007-08]Status: DisposedITAT Delhi24 Dec 2020AY 2007-08

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

1)(C) read with section 13(3); thirdly, computation of income consequent to denial of exemption under section 11/ 12 of the Act; fourthly, ad hoc disallowance

ITO (E), NEW DELHI vs. M/S. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 1131/DEL/2016[2011-12]Status: DisposedITAT Delhi24 Dec 2020AY 2011-12

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

1)(C) read with section 13(3); thirdly, computation of income consequent to denial of exemption under section 11/ 12 of the Act; fourthly, ad hoc disallowance

ADIT(E), NEW DELHI vs. M/S. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2871/DEL/2014[2009-10]Status: DisposedITAT Delhi24 Dec 2020AY 2009-10

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

1)(C) read with section 13(3); thirdly, computation of income consequent to denial of exemption under section 11/ 12 of the Act; fourthly, ad hoc disallowance

ADIT (E), NEW DELHI vs. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2675/DEL/2013[2008-09]Status: DisposedITAT Delhi24 Dec 2020AY 2008-09

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

1)(C) read with section 13(3); thirdly, computation of income consequent to denial of exemption under section 11/ 12 of the Act; fourthly, ad hoc disallowance

DIRECTOR OF INCOME TAX (EXEMPTION) vs. CHARANJIV CHARITABLE TRUST

In the result both aspects of the first substantial question of law

ITA/321/2013HC Delhi18 Mar 2014

Bench: It, Two By The Assessee Relating To The Assessment Years 2006-07 & 2007-08 & One By The Revenue Relating To The Assessment Year 2006-07. In Other Words, In Respect Of The Assessment Year 2006-07, There Were Cross- 2014:Dhc:1467-Db

Section 11Section 12ASection 13(1)(c)Section 13(3)Section 143(1)Section 260A

disallowance of the exemption under Section 11 on the ground of violation of Section 13(1)(c)(ii) read with

ACIT, NEW DELHI vs. M/S. RESURGERE MINES AND MINERALS INDIA LTD., MUMBAI

In the result, the appeal filed by the Revenue is dismissed

ITA 1531/DEL/2017[2008-09]Status: DisposedITAT Delhi18 Jul 2019AY 2008-09

Bench: Shri Kuldip Singh & Shri Anadee Nath Misshra

For Appellant: Shri Ved Jain, CA and Shri Ashish Jain, CAFor Respondent: Shri Surender Pal, Sr. DR
Section 143(3)Section 14ASection 271(1)(c)

Disallowance under the said section have been subject matter of debate and different views have been expressed. A legal contention which was plausible and merited consideration was raised. Accordingly, the appellate authorities have applied the explanation to Section 271(1)(c) of the Act. Looking at the nature of explanation offered and the provision in question i.e. Section 14A, which

MOHAIR INVESTMENT AND TRADING COMPANY (P) LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result the appeal of the assessee is allowed

ITA 4677/DEL/2009[2001-02]Status: DisposedITAT Delhi27 Nov 2015AY 2001-02

Bench: Shri A.T. Varkey & Shri O.P. Kant

For Appellant: Shri Gaurav Jain, Advocate and Bhavita Kumar, AdvocateFor Respondent: Shri P. Dam Kanunjna, Senior DR
Section 115Section 143Section 14ASection 271(1)(c)Section 275(1)(a)

11. Thereafter we find that the aforesaid disallowance was sustained in the quantum appeals. The assessing officer imposed penalty under section 271(1) (c

ADIT (E), NEW DELHI vs. FORTUNE SOCIETY FOR DEVELOPMENT AND PROMOTION OF INTERNATIONAL BUSINESS, NEW DELHI

In the result ground No. 2

ITA 2698/DEL/2012[2007-08]Status: DisposedITAT Delhi18 Sept 2017AY 2007-08

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit(E), Vs. Fortune Society For Tc-Ii, New Delhi Development & Promotion Of International Business, G-4, Community Centre, Naraina Vihar, New Delhi Pan:Aaatf0849L (Appellant) (Respondent)

For Appellant: Shri Anshu Prakash, Sr. DRFor Respondent: Shri Satish Khosla, Adv
Section 11Section 11(1)Section 12Section 143Section 2

c to Section 35(2B) is conspicuous and entirely different and wordings are clear and lucid. The language of Section 11(1), as noticed above, is distinguished and not worded in a similar manner. In Escorts Ltd. (supra), the Supreme Court was considering the said specific provision and the wordings therein. While dealing with the term "expenditure" and noticing

M/S. OIL INDUSTRY DEVELOPMENT BOARD,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals filed by the assessee are allowed

ITA 4664/DEL/2014[2007-08]Status: DisposedITAT Delhi04 Apr 2019AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 154Section 271Section 271(1)(c)Section 35Section 36

disallowance under section 35(1) and section 14A were contested by the assessee before the Ld. CIT(A), but not allowed in the appeal. The assessee, did not contest these issues in the Tribunal. 11. Thus, we find that the hundred percent claim of the grant to notified institution was allowed under section 36(1)(xii) but the balance