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15 results for “disallowance”+ Section 151Aclear

Sorted by relevance

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Key Topics

Section 14734Section 14830Section 148A17Addition to Income14Section 153A9Disallowance8Section 151A7Reopening of Assessment7Section 143(3)6Reassessment

KRISHAN PAL,GURGAON vs. ITO,WARD 2(2)-GURGAON, GURGAON

Appeal is allowed

ITA 139/DEL/2026[2014-15]Status: DisposedITAT Delhi10 Feb 2026AY 2014-15

Bench: Sh. Satbeer Singh Godaraita No. 139/Del/2026 : Asstt. Year: 2014-15 Krishan Pal, Vs Income Tax Officer, C/O Ca M R Sahu, Ward-2(2), House No. 651, 1St Floor, Sector- Gurgaon, 10A, Near G. D. Goenka Public Haryana-22001 School, Gurgaon-122001 (Appellant) (Respondent) Pan No. Asqpk6236J Assessee By: Sh. M. R. Sahu, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2014-15 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1068016367(1) Dated 27.08.2024, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. R. Sahu, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 142(1)Section 147Section 148Section 151ASection 80C

disallowed the assessee’s section 80C claim of Rs.1,00,000/- as not accepted which stands upheld in the lower appellate discussion. It is in this factual backdrop that the assessee’s case before us is that given the fact that the faceless regime in question got notified on 29.03.2022, the faceless assessment framed in his case

6
Section 1545
Limitation/Time-bar5

FLINT POWER TOOLS (P) LTD,GURUGRAM vs. ACIT , CENTRAL CIRCLE-1, FARIDABAD

In the result, the appeal of the assessee is allowed

ITA 5642/DEL/2024[2019-20]Status: DisposedITAT Delhi27 Oct 2025AY 2019-20

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 M/S. Flint Power Tools (P) Vs. Assistant Commissioner Of Ltd., Income Tax, Plot Nos. 594, 595, Central Circle-1, Sector 8 Imt Manesar, Faridabad-I, New-1 Gurugram, Haryana Pan: Aadcn0078K (Appellant) (Respondent)

For Appellant: Shri Lalit Mohan, CA & Shri AnkitFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 132Section 142(1)Section 147Section 148Section 151Section 151ASection 250(6)Section 37

section 151A of the Act; and therefore the assumption of jurisdiction was not in accordance with law. 4. That the learned Commissioner of Income Tax (Appeals) has also erred both in law and on facts in upholding a disallowance

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

section 151A. The reopening process, including the issuance of notice u/s 148, was not compliant with the prescribed faceless mechanism, rendering it invalid. 2 Harish Banga 1.4 The Ld. CIT(A) failed to consider that the order u/s 148A(d) dated 26/03/2022 was passed mechanically, without independent application of mind, and did not address the Appellant's submissions that

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

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 CIT(A) in order in para 5.1, 5.2, & 5.3 are not only perverse but overlooks the fact that the assessee had paid the interest

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

section 151A of the Act, read with Notification No. 18/2022 dated 29.03.2022, which should have been issued by National Faceless Assessment Centre under e-Assessment of Income Escaping Assessment Scheme, 2022. 5. That the CIT(A) has erred on facts and in law in confirming the addition of Rs. 11,05,348/ by estimating 2% commission on alleged bogus sales

MANAK CHAND DAGA,FARIDABAD vs. ITO,WARD-1(3), FARIDABAD

In the result, the appeal filed by the assessee for Assessment

ITA 16/DEL/2024[2013-14]Status: DisposedITAT Delhi14 Jun 2024AY 2013-14

Bench: the Ld. CIT(A) and filed the detailed submissions before him with grounds of appeal. In the appellate proceedings, the assessee has not complied to the various notices for hearing issued by the Ld. CIT(A), since, no representation was forthcoming from the assessee side, the Ld. CIT(A) decided the issue based on the information available on record. Accordingly, he sustained the addition made by the Assessing Officer.

Section 143(2)Section 147Section 148

section 151A of the Act along with e-Assessment of Income Escaping Assessment Scheme, 2022. 6. (i) On the facts and circumstances of the case, the learned CIT(A), ITD has erred both on facts and in law in confirming the disallowance

MANAK CHAND DAGA,FARIDABAD vs. ITO,WARD-1(3), FARIDABAD

In the result, the appeal filed by the assessee for Assessment

ITA 17/DEL/2024[2014-15]Status: DisposedITAT Delhi14 Jun 2024AY 2014-15
Section 143(2)Section 147Section 148

section 151A of the Act along with e-Assessment of Income Escaping Assessment Scheme, 2022. 6. (i) On the facts and circumstances of the case, the learned CIT(A), ITD has erred both on facts and in law in confirming the disallowance

INCOME TAX OFFICER, ROHTAK vs. PANKAJ JAIN, ROHTAK

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

ITA 2295/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmaincome Tax Officer, Vs. Pankaj Jain, Rohtak. 123/34, Vishwakarma Kathmandi, Rohtak – 124 001 (Haryana). (Pan : Azupj6345A) (Appellant) (Respondent) Assessee By : Shri Shri Naveen Gupta, Advocate Shri Nakul Gupta, Advocate Revenue By : Shri Ajay Kumar Arora,Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 30.12.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 04.02.2025 For The Assessment Year 2018-19 Raising Following Grounds Of Appeal :- “1. The Learned Cit(A) Has Erred In Law & On Facts In Not Upholding The Validity Of The Notice Issued Under Section 148 Of The Income Tax Act, 1961 (The Act) Without The Proper & Mandatory Compliance With The Provisions Of Section 148A(B). 2. The Learned Cit(A) Has Further Erred In Law & On Facts By Failing To Consider That The Then Ao Has Given Notice U/S 148A(B) To Assessee On 31.03.2022

For Appellant: Shri Shri Naveen Gupta, AdvocateFor Respondent: Shri Ajay Kumar Arora,Sr. DR
Section 133(6)Section 142(1)Section 143Section 147Section 148Section 148ASection 151Section 151ASection 292BSection 37(1)

disallowed the same u/s 37(1) of the Act. The AO completed the assessment u/s 147 r.w.s 144B of the Act on 25.03.2024 by assessing the total income at Rs.5,41,69,809/-. 4. Aggrieved with the above order, assessee preferred an appeal before the NFAC, Delhi and filed grounds of appeal and detailed submissions. Before

SARIKA SACHDEVA,NEW DELHI vs. ACIT CENTRAL CIRCLE-01, NEW DELHI

In the result, Appeal filed by the Assessee in ITA Nos

ITA 64/DEL/2021[2013-14]Status: DisposedITAT Delhi27 Feb 2024AY 2013-14

Bench: or during the course of hearing of the appeal.”

Section 143Section 143(3)Section 153ASection 69A

151A read with section 1433) of the Act, which are not based on any incriminating material found during the course of search on the appellant, and contrary to the ratio of various judicial precedents which have held that the scope of assessment which are not pending at the time of conducting of search wis 153A of the Act, encompasses additions

SARIKA SACHDEVA,NEW DELHI vs. ACIT CENTRAL CIRCLE-01, NEW DELHI

In the result, Appeal filed by the Assessee in ITA Nos

ITA 65/DEL/2021[2014-15]Status: DisposedITAT Delhi27 Feb 2024AY 2014-15

Bench: or during the course of hearing of the appeal.”

Section 143Section 143(3)Section 153ASection 69A

151A read with section 1433) of the Act, which are not based on any incriminating material found during the course of search on the appellant, and contrary to the ratio of various judicial precedents which have held that the scope of assessment which are not pending at the time of conducting of search wis 153A of the Act, encompasses additions

SARIKA SACHDEVA,NEW DELHI vs. ACIT CENTRAL CIRCLE-01, NEW DELHI

In the result, Appeal filed by the Assessee in ITA Nos

ITA 63/DEL/2021[2012-13]Status: DisposedITAT Delhi27 Feb 2024AY 2012-13

Bench: or during the course of hearing of the appeal.”

Section 143Section 143(3)Section 153ASection 69A

151A read with section 1433) of the Act, which are not based on any incriminating material found during the course of search on the appellant, and contrary to the ratio of various judicial precedents which have held that the scope of assessment which are not pending at the time of conducting of search wis 153A of the Act, encompasses additions

ADESH KUMAR GUPTA,DELHI vs. INCOME TAX OFFICER, WARD 62(1), DELHI, DELHI

In the result, ground no. 2 & 3 of the appeal is partly

ITA 6930/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Dec 2025AY 2019-20

Bench: Shri Pawan Singh(Physical Hearing) Adesh Kumar Gupta Ito, Ward-62(1), Delhi House No. 6, Sector -11, Pocket-C- Vs Civic Centre, Delhi – 110002. 5, Rohini, Delhi – 110085. [Pan: Aaipg9669H] Appellant / Assessee Respondent / Revenue

Section 145Section 147Section 254(1)Section 69C

151A of the Income Tax Act therefore such assessment is void ab initio and liable to be quashed. 2. The Ld. CIT appeal has erred both in law and on facts in the case in upholding the addition on account of aggregate purchases of Rs. 13,01,2016/- made from entities allegedly controlled by Sh Sanjay Jain as bogus purchase

ACIT CENTRAL CIRCLE-18, NEW DELHI vs. INDEX SECURITIES & RESEARCH PVT. LTD., NEW DELHI

ITA 1957/DEL/2019[2010-11]Status: DisposedITAT Delhi18 Jun 2025AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2010-11 Acit, Vs M/S Index Security & Research Pvt. Central Circle-18, Ltd., New Delhi. 287, Tarun Enclave, Pitampura, New Delhi – 110 034. Pan: Aaaci2919K Co No.126/Del/2023 (Ita No.1957/Del/2019) Assessment Year: 2010-11 Assessment No.2010-11 M/S Index Security & Research Vs. Acit, Pvt. Ltd., Central Circle-18, 287, Tarun Enclave, New Delhi Pitampura, New Delhi – 110 034. Pan: Aaaci2919K

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT-DR
Section 147Section 148Section 151Section 153CSection 271(1)(c)Section 40A(2)

disallowing the part salary of two directors on adhoc basis on the grounds of being excessive which is contrary to the provisions of Section 40A(2) of the Act.” 3. As with regard to these grounds, heard at first, we find that the assessee’s return of income was filed by the assessee on 31.03.2011 and earlier a notice

INDEX SECURITIES & RESEARCH PVT. LTD.,NEW DELHI vs. ACIT CC-18,, NEW DELHI

ITA 7032/DEL/2019[2010-11]Status: DisposedITAT Delhi18 Jun 2025AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2010-11 Acit, Vs M/S Index Security & Research Pvt. Central Circle-18, Ltd., New Delhi. 287, Tarun Enclave, Pitampura, New Delhi – 110 034. Pan: Aaaci2919K Co No.126/Del/2023 (Ita No.1957/Del/2019) Assessment Year: 2010-11 Assessment No.2010-11 M/S Index Security & Research Vs. Acit, Pvt. Ltd., Central Circle-18, 287, Tarun Enclave, New Delhi Pitampura, New Delhi – 110 034. Pan: Aaaci2919K

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT-DR
Section 147Section 148Section 151Section 153CSection 271(1)(c)Section 40A(2)

disallowing the part salary of two directors on adhoc basis on the grounds of being excessive which is contrary to the provisions of Section 40A(2) of the Act.” 3. As with regard to these grounds, heard at first, we find that the assessee’s return of income was filed by the assessee on 31.03.2011 and earlier a notice

JYOTI CHAUHAN,NEW DELHI vs. ASSESSING OFFICER WARD 6(1), DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 6368/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Jan 2026AY 2014-15

Bench: Shri Mahavir Singh, Hon’Ble & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Gautam Swaroop, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 10(38)Section 144BSection 147Section 148Section 148ASection 149Section 151ASection 154Section 250Section 68

151A of the Act. 8. That the Notice issued u/s 148 of the Act is invalid in law as no DIN was generated while issuing notice for the AY 2014-15. 9. That having regards to the facts and circumstances of the case, the Ld. AO has erred in law and on facts in making an addition