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73 results for “disallowance”+ Section 148Aclear

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Key Topics

Section 148191Section 147127Section 148A81Section 153C48Addition to Income48Section 143(3)40Reassessment29Disallowance28Section 25027Section 68

INTERNATIONAL HOSPITAL LIMITED vs. DCIT CIRCLE 12 (2)

ITA/116/2023HC Delhi26 Sept 2024

Bench: HON'BLE MR. JUSTICE RAVINDER DUDEJA,HON'BLE MR. JUSTICE YASHWANT VARMA

148A(b) as introduced by virtue of Finance Act, 2021 and for proceedings to be taken forward in accordance with law. 10. It becomes pertinent to note that although Instruction No. 1/2022 dated 11 May 2022 issued by the Central Board of Direct Taxes13 12 (2023) 1 SCC 617 13 CBDT Digitally Signed By:KAMLESH KUMAR Signing Date

M/S CARE INDIA SOLUTION FOR SUSTAINABLE DEVELOPMENT,DELHI vs. DCIT, CENTRAL CIRCLE-14, DELHI

In the result, the appeals of the assessee are allowed for\nstatistical purpose

ITA 7437/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Mar 2026AY 2016-17
For Appellant: Sh. Pratik Arora, CAFor Respondent: Sh. Amit Jain, CIT-DR
Section 11

Showing 1–20 of 73 · Page 1 of 4

27
Bogus Purchases19
Section 15118
Section 12A
Section 147
Section 148
Section 148A
Section 151
Section 25
Section 250

148A and section 151 of the Act.\n5.1 That the Ld. CIT(A) has erred in law and on facts in\nupholding the order of Ld. AO, thereby denying the benefit of\nexemption under Section 11 of the Income-tax Act, 1961 (`the\nAct'). That the Ld. CIT(A) has erred in law and on facts in\nconfirming the order

M/S CARE INDIA SOLUTIONS FOR SUSTAINABLE DEVELOPMENT,DELHI vs. DCIT, CENTRAL CIRCLE-14, DELHI

In the result, the appeals of the assessee are allowed for\nstatistical purpose

ITA 7439/DEL/2025[2023-24]Status: DisposedITAT Delhi09 Mar 2026AY 2023-24
For Appellant: Sh. Pratik Arora, CAFor Respondent: Sh. Amit Jain, CIT-DR
Section 11Section 12ASection 147Section 148Section 148ASection 151Section 25Section 250

148A and section 151 of the Act.\n5.1 That the Ld. CIT(A) has erred in law and on facts in\nupholding the order of Ld. AO, thereby denying the benefit of\nexemption under Section 11 of the Income-tax Act, 1961 (`the\nAct'). That the Ld. CIT(A) has erred in law and on facts in\nconfirming the order

HARISH BANGA,HISAR vs. ASSESSMENT UNIT, NEW DELHI

In the result, both the substantial ground of appeal is allowed

ITA 4893/DEL/2025[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Pawan Singhassessment Year: 2018-19 (Physical Hearing) Harish Banga, Assessment Unit, 264, Bank Colony, Hisar, Vs. Faceless Assessment Unit Haryana – 125001. Income Tax Department, Pan – Abqpb 8845 F New Delhi-110001. (Appellant) (Respondent) Present For: Assessee By : Shri H.K. Batra, Ca & Shri Naman Chawla, Ca Revenue By : Shri Virender Kumar Singh, Sr. D.R. Date Of Hearing : 04.12.2025 Date Of Pronouncement : 19.12 .2025 O R D E R Per : Pawan Singh: This Appeal By The Assessee Is Directed Against The Order Of Cit (A) Dated 08.07.2025 Vide Assessment Year 2018-19. The Assessee Has Raised Following Grounds Of Appeal:-

For Appellant: Shri H.K. Batra, CA &For Respondent: Shri Virender Kumar Singh, SR. D.R
Section 147Section 148Section 148ASection 151ASection 56Section 57

148A(b) was issued solely for disallowance of expenses, and no new income was alleged to have escaped assessment. 2.1 The Ld. CIT(A) erred in law and on facts in confirming the disallowance of commission expenses of Rs. 9,00,000/- paid to Smt. Suman Devi, treating the same as non-genuine and not allowable under section

MAMRAJ AGGARWAL,DELHI SADAR BAZAR, DELHI vs. INCOME TAX OFFICER WARD 47(1), DELHI, DELHI

In the result the appeal of the assessee is allowed

ITA 3864/DEL/2025[2017-18]Status: DisposedITAT Delhi21 Jan 2026AY 2017-18
Section 115BSection 131(1)Section 144BSection 147Section 148Section 148ASection 151Section 250Section 69C

disallowance arbitrary and unsustainable.\n7. That the Ld. CIT(A) as well as ld. AO erred in relying upon\ndocuments/statements seized from a third party which are not binding on the\nassessee and cannot form the basis of addition in the absence of any\nincriminating material found.\n8. That the impugned order under section 250 of the Act has been

INCOME TAX OFFICER, INCOME TAX OFFICE vs. RITU BALA, FARIDABDA

In the result, the appeal of Revenue is dismissed

ITA 3621/DEL/2024[2018-19]Status: DisposedITAT Delhi27 Oct 2025AY 2018-19

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2018-19 Income Tax Officer, Ritu Bala, Vs. Faridabad 4237 Indra Prashtha Colony, Haryana Faridabad – 121 001 Haryana Pan :Bdhpb1495B (Appellant) (Respondent)

Section 142(1)Section 144Section 144BSection 148Section 148ASection 250Section 250(4)Section 69C

148A(d) of the Act dated 31.03.2022 was passed with approval of specified authority along with notice under Section 148 of the Act. In case of assessee, specific information was flagged as per Risk Management Strategy formulated by the CBDT under clause (i) to explanation (1) to section 148 of the Act. As per the specific information, Assessee has taken

INCOME TAX OFFICER, WARD-14(3), NEW DELHI vs. KOLAHAI INFOTECH PRIVATE LIMITED , NEW DELHI

In the result the appeal of the Revenue is dismissed

ITA 3399/DEL/2025[2015-16]Status: DisposedITAT Delhi19 Nov 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2015-16 Income Tax Officer, Vs. Kolahai, Infotech Private Limited Ward-14(3) , Room 129, First Floor Transport Centre No.305 Cr Building I.P. Punjabi Bagh New Delhi, Delhi- Estate New Delhi -110002 110034

Section 139Section 143(3)Section 147Section 148Section 148ASection 149(1)Section 14ASection 68

disallowance and allowed the appeal of the assessee. The case of the assessee was reopened and notice u/s 148 of the Act dated 22-04-2021 was issued. In the pursuance of the Hon’ble supreme Court judgment in the case of Union of India v. Ashish Agarwal [2022] 444ITR 1(SC) a notice under 3 Income Tax officer, Ward

ITO WARD-58(3), DELHI vs. B.C.ENTERPRISES, VIVEK VIHAR, DELHI

ITA 4975/DEL/2024[2019]Status: DisposedITAT Delhi30 May 2025

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Dr. Kapil Goel, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, SR. DR
Section 143(2)Section 145(3)Section 147Section 148Section 148ASection 151

disallowed the purchases made by the assessee as unexplained / non-existent purchase of Rs. 4,22,78,376/- and added back under the head PGBP, and also treated the sales of Rs. 2,53,351/- made by the assessee as unexplained credits under section 68 of the Act. 3.1 The Learned AO relied upon information regarding transactions caried

DCIT, VIKASH BHAWAN vs. RAJAN KUMAR, DELHI

In the result, the Revenue’s appeal is dismissed

ITA 136/DEL/2025[2013-14]Status: DisposedITAT Delhi09 Jan 2026AY 2013-14

Bench: Shri Mahavir Singh & Shri Amitabh Shukladcit, Vs. Rajan Kumar Room No. 218, 2Nd Floor, 31, Vijay Block, D-Block, Vikas Bhawan, Laxmi Nagar, New Delhi Delhi (Pan: Caapk8381E) (Appellant) (Respondent)

For Appellant: Sh. Mukesh Jain, CA & Sh. Samyak Jain, AdvFor Respondent: Sh. Jitender Singh, CIT(DR)
Section 144BSection 147Section 148Section 148ASection 149

section 149 of the Act. 3. Brief facts of the case are that the assessee, an individual filed his return of income for the AY 2013-14 declaring total income of Rs. 40,48,410/-. As per the information available with the department AO noted that the assessee has made bogus purchases to the tune

HARISH KUMAR,DELHI vs. NFAC, DELHI

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

ITA 4602/DEL/2024[2015-16]Status: DisposedITAT Delhi18 Jun 2025AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manish Agarwal, Hon’Bleasstt. Year : 2015-16 Harish Kumar Vs. Nfac, Delhi 5/21, Shanti Niketan, Chankaya Puri, South West Delhi, New Delhi – 21 (Pan: Aaipk9783G) (Appellant) (Respondent) & Asstt. Year : 2015-16 Acit, Vs. Harish Kumar, Room No. 1505, 15Th Floor, E-2 1/7, West Patel Nagar Tower, Dr. Sp Mukherjee New Delhi – 8 Civic Centre, New Delhi – 2 (Pan: Aaipk9783G) (Appellant) (Respondent) Appellant By : Shri Sanjay Agarwal, Ca & Sh. Sumaksh Mahajan, Ca Respondent By : Shri Surender Pal, Cit(Dr) Date Of Hearing 20.03.2025 Date Of Pronouncement 18.06.2025 Order Per Mahavir Singh, Vp : These Are Cross Appeals Filed By The Assessee As Well As Revenue Against The Order Dated 06.8.2024 Passed By The Ld. Cit(A)/Nfac, Delhi

For Appellant: Shri Sanjay Agarwal, CA &For Respondent: Shri Surender Pal, CIT(DR)
Section 144BSection 147Section 148Section 149Section 149(1)(b)Section 3Section 94(7)

disallowing the short term capital loss u/s. 94(7) of the Act and adding the said amount. In appeal, Ld. CIT(A) partly allowed the appeal of the assessee. Aggrieved, assessee and revenue both are in cross appeals before us. 3. At the time of hearing, ld. Counsel for the assessee submitted that Ld. Commissioner of Income Tax (Appeals), National

ASSISTANT COMMISSIONER OF INCOME TAX, CIVIC CENTRE, NEW DELHI vs. HARISH KUMAR, DELHI

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

ITA 4676/DEL/2024[2015-16]Status: DisposedITAT Delhi18 Jun 2025AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manish Agarwal, Hon’Bleasstt. Year : 2015-16 Harish Kumar Vs. Nfac, Delhi 5/21, Shanti Niketan, Chankaya Puri, South West Delhi, New Delhi – 21 (Pan: Aaipk9783G) (Appellant) (Respondent) & Asstt. Year : 2015-16 Acit, Vs. Harish Kumar, Room No. 1505, 15Th Floor, E-2 1/7, West Patel Nagar Tower, Dr. Sp Mukherjee New Delhi – 8 Civic Centre, New Delhi – 2 (Pan: Aaipk9783G) (Appellant) (Respondent) Appellant By : Shri Sanjay Agarwal, Ca & Sh. Sumaksh Mahajan, Ca Respondent By : Shri Surender Pal, Cit(Dr) Date Of Hearing 20.03.2025 Date Of Pronouncement 18.06.2025 Order Per Mahavir Singh, Vp : These Are Cross Appeals Filed By The Assessee As Well As Revenue Against The Order Dated 06.8.2024 Passed By The Ld. Cit(A)/Nfac, Delhi

For Appellant: Shri Sanjay Agarwal, CA &For Respondent: Shri Surender Pal, CIT(DR)
Section 144BSection 147Section 148Section 149Section 149(1)(b)Section 3Section 94(7)

disallowing the short term capital loss u/s. 94(7) of the Act and adding the said amount. In appeal, Ld. CIT(A) partly allowed the appeal of the assessee. Aggrieved, assessee and revenue both are in cross appeals before us. 3. At the time of hearing, ld. Counsel for the assessee submitted that Ld. Commissioner of Income Tax (Appeals), National

CHAUDHARY CHARAN SINGH HARYANA AGRICULTURAL UNIVERSITY,HISSAR vs. ITO,EXEMPTION, ROHTAK

In the result, the appeal of the assessee is allowed

ITA 2225/DEL/2024[2018-19]Status: DisposedITAT Delhi14 May 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year 2018-19]

Section 10Section 139Section 147Section 148Section 148ASection 151

148A(d) and notice under section 148 by the AO have been issued and passed without obtaining valid statutory prior approval from thespecified authority as provided under section 151 of the Act. 7. On the facts and circumstances of the case, the learned CIT(A), ITD has erred both on fad and in law in confirming the disallowance

M/S JHS SVENDGAARD LABORATORIES LTD.,NEW DELHI vs. DCIT CC-31, NEW DELHI

In the result, Appeal of the Assessee is allowed

ITA 3454/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Jhs Svendgaard Vs. Dcit Laboratories Ltd. B1/E-23, Central Circle-31, New Mohan Cooperative Delhi Tuhglakabad, Badarpur, New Delhi New Delhi Pan: Aabcj5766G Appellant Respondent Assessee By Sh. Gaurav Jain, Adv & Sh. Tarun Chanana, Adv Revenue By Ms.Amisha S. Gupt, Cit (Dr) Date Of Hearing 09/10/2025 Date Of Pronouncement 07/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-30, New Delhi [‘Ld. Cit(A)’

Section 147Section 148Section 151ASection 37

disallowed the same under Section 37 of the Act. 4. Aggrieved by the assessment order dated 31/03/2023, Assessee preferred an Appeal before the Ld. CIT(A). The Ld. CIT(A) vide order dated 31/03/2025, dismissed the Appeal of the Assessee. As against the order of the Ld. CIT(A) dated 31/03/2025, Assessee preferred the present Appeal on the grounds mentioned

ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

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

ITA 3632/DEL/2025[2015-16]Status: DisposedITAT Delhi06 Nov 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

148A for a notice issued under the old provisions of section 148 of the Act. The same cannot be upheld as the old provisions ceased to have force of law post 31.03.2021.” 4. Since the above grounds of appeal are purely legal, do not require fresh facts to be investigated and go to the root of the matter

ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

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

ITA 3633/DEL/2025[2017-18]Status: DisposedITAT Delhi06 Nov 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

148A for a notice issued under the old provisions of section 148 of the Act. The same cannot be upheld as the old provisions ceased to have force of law post 31.03.2021.” 4. Since the above grounds of appeal are purely legal, do not require fresh facts to be investigated and go to the root of the matter

DIAMOND REALCON PRIVATE LIMITED,NEW DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeal in ITA

ITA 1259/DEL/2025[2011-12]Status: DisposedITAT Delhi05 Dec 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1260/Del/2025 (A.Y. 2012-13) M/S Diamond Realcon Private Vs Assistant Commissioner Of Limited, Income Tax, Central Circle-Ii, Shop No. 68, Building No. 38, Faridabad, Surya House, Near Pnb, Devli, Haryana-121001 Khanpur, New Delhi-110062 Pan: Aadcd6696H Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 05/12/2025

Section 143(2)Section 147Section 148Section 151Section 153CSection 68

disallowance, imposition of tax, and interest with reference thereto, as well as the quantification of taxable income and tax liability, are unjustified, erroneous, and unsustainable, and it is prayed that necessary directions be issued to the Learned Assessing Officer (Ld. AO) to grant appropriate relief in accordance with the law. 2.0 That, on the facts and in the circumstances

DIAMOND REALCON PRIVATE LIMITED,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeal in ITA

ITA 1260/DEL/2025[2012-13]Status: DisposedITAT Delhi05 Dec 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1260/Del/2025 (A.Y. 2012-13) M/S Diamond Realcon Private Vs Assistant Commissioner Of Limited, Income Tax, Central Circle-Ii, Shop No. 68, Building No. 38, Faridabad, Surya House, Near Pnb, Devli, Haryana-121001 Khanpur, New Delhi-110062 Pan: Aadcd6696H Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 05/12/2025

Section 143(2)Section 147Section 148Section 151Section 153CSection 68

disallowance, imposition of tax, and interest with reference thereto, as well as the quantification of taxable income and tax liability, are unjustified, erroneous, and unsustainable, and it is prayed that necessary directions be issued to the Learned Assessing Officer (Ld. AO) to grant appropriate relief in accordance with the law. 2.0 That, on the facts and in the circumstances

GDR FINANCE AND LEASING P. LTD,DELHI vs. INCOME TAX OFFICER, DELHI

In the result, the appeal of the assessee is allowed

ITA 802/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2018-19 M/S Gdr Finance & Leasing Vs. Assessment Unit, Pvt. Ltd., Income Tax Officer, 323, Agrawal Plaza, Nfac. Dda Community Centre, Shalimar Bagh, New Delhi – 110 088. Pan: Aaacg2363D (Appellant) (Respondent) Assessee By : Shri C.S. Aggarwal, Sr. Advocate; Shri Rupinder Aggarwal, Shri R.P. Mall, Shri Uma Shankar, Ms Suman Verma & Ms Vidushi Aggarwal, Advocates Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 23.12.2025 Order Per Vimal Kumar, Jm:

For Appellant: Shri C.S. Aggarwal, Sr. AdvocateFor Respondent: Shri Om Parkash, Sr. DR
Section 133(6)Section 142Section 143(2)Section 147Section 148Section 148ASection 151ASection 250

148A(d) of the Act had been initialed by '‘jurisdictional assessing officer” and not by “faceless assessing officer”, which is against the mandate of section 151A of the Act and also, the E Assessment Scheme, 2022. Thus as such, the impugned proceedings and assessment thereto made were without jurisdiction and untenable in law. 4. That the findings of the learned

MARVELOUS CEMENT PRIVATE LIMITED ,NEW DELHI vs. NATIONAL E-ASSESSMENT CENTRE, NEW DELHI

In the result, appeal filed by the assessee is allowed

ITA 4100/DEL/2024[2018-19]Status: DisposedITAT Delhi30 Jun 2025AY 2018-19
Section 139(1)Section 143(3)Section 147Section 148Section 250

disallowance was deleted.", "result": "Allowed", "sections": [ "147", "148", "143(3)", "250", "143(3A)", "143(3B)", "139(1)", "143(2)", "151", "148A

DHARAMPAL SATYAPAL LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE 29, NEW DELHI

ITA 5519/DEL/2024[2015-16]Status: DisposedITAT Delhi15 Oct 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2015-16 Dharampal Satyapal Ltd., Vs. Acit, 98, Okhla Industrial Estate Central Circle-29, Phase Iii, New Delhi. Tehkhand, New Delhi – 110 020. Pan: Aaacd0132H (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi; Shri Satya Jeet Goel; & Shri Rajat Garg, Cas Revenue By : Shri Amit Jain, Cit-Dr Date Of Hearing : 11.09.2025 Date Of Pronouncement : 15.10.2025 Order

For Appellant: Shri R.S. SinghviFor Respondent: Shri Amit Jain, CIT-DR
Section 115JSection 144CSection 147Section 148Section 148ASection 149Section 69ASection 80ISection 92C

148A(d) of the Act appears to be without independent application of mind or tangible material, in the hands of AO. It has been alleged that appellant company has deposited 100 crores of VAT liability which proves its involvement in alleged VAT evasion. 9. In regard to these grounds ld. Counsel has also pointed out that even after the addition