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18 results for “disallowance”+ Section 245Cclear

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Key Topics

Addition to Income18Search & Seizure16Section 26315Section 15312Section 153A11Section 14810Bogus Purchases10Section 132(1)9Section 1329Section 143(3)

M/S RADIC KHAITAN LTD.,,DELHI vs. DCIT, NEW DELHI

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

ITA 4355/DEL/2015[2005-06]Status: DisposedITAT Delhi11 Apr 2019AY 2005-06

Bench: Shri N.K. Billaiya & Shri K.N. Chary[Assessment Year: 2005-06]

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Smt. Sulekha Verma, CIT(DR)
Section 132Section 153ASection 245Section 245D(4)

Section 245C. (refer page 451 - plac. E/F). (Emphasis supplied)." The judgments in R.B. Shreeram Durga Prasad v. Settlement Commission, (1989) 176 ITR169 Jyotendrasinghji v. S.I. Tripathi & Ors., (1993) 201 ITR 611 Shriyans Prasad Jain v. Income- tax Officer and others, (1993) 204 ITR 616 and Kuldeep Industrial corporation v. ITO, (1997) 223 ITR 840 are equally conclusive about the plenitude

8
Bogus/Accommodation Entry7
Section 1476

NKG INFRASTRUCTURE LTD.,NEW DELHI vs. PR.CIT, C- 3 , NEW DELHI

In the result all the three appeals of the assessee are allowed

ITA 3826/DEL/2018[2009-10]Status: DisposedITAT Delhi05 Sept 2018AY 2009-10

Bench: Shri G.D. Agrawal, Hon’Ble & Shri K.Narasimha Chary

Section 132(1)Section 143(3)Section 153Section 263Section 263(1)

245C and ending with the date on which the order under sub-section (1) of section 245D is received by the Principal Commissioner or Commissioner under sub- section (2) of that section; or xxx xxx xxx xxx xxx xxx shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred

NKG INFRASTRUCTURE LTD.,NEW DELHI vs. PR.CIT, C- 3 , NEW DELHI

In the result all the three appeals of the assessee are allowed

ITA 3827/DEL/2018[2010-11]Status: DisposedITAT Delhi05 Sept 2018AY 2010-11

Bench: Shri G.D. Agrawal, Hon’Ble & Shri K.Narasimha Chary

Section 132(1)Section 143(3)Section 153Section 263Section 263(1)

245C and ending with the date on which the order under sub-section (1) of section 245D is received by the Principal Commissioner or Commissioner under sub- section (2) of that section; or xxx xxx xxx xxx xxx xxx shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred

NKG INFRASTRUCTURE LTD.,NEW DELHI vs. PR.CIT, C- 3 , NEW DELHI

In the result all the three appeals of the assessee are allowed

ITA 3825/DEL/2018[2008-09]Status: DisposedITAT Delhi05 Sept 2018AY 2008-09

Bench: Shri G.D. Agrawal, Hon’Ble & Shri K.Narasimha Chary

Section 132(1)Section 143(3)Section 153Section 263Section 263(1)

245C and ending with the date on which the order under sub-section (1) of section 245D is received by the Principal Commissioner or Commissioner under sub- section (2) of that section; or xxx xxx xxx xxx xxx xxx shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred

PROVIDENT INV. & INDUSTRIES (P) LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result ground No. 5 of the appeal of the assessee is dismissed

ITA 1003/DEL/2015[2008-09]Status: DisposedITAT Delhi17 May 2017AY 2008-09

Bench: Shri H.S.Sidhu & Shri Prashant Maharishiprovident Inv & Industries P Ltd, Vs. Ito, Ward-14(2), 4Th Floor, Ito, A-49, Mohan Cooperative Industrial Estate, Mathura Road, New Delhi Cr Building, New Delhi Pan:Aabcj4816P (Appellant) (Respondent)

For Appellant: Sh. Venugopal Nair, CAFor Respondent: Sh. FR Meena, Sr. DR
Section 142Section 144Section 69

245C is rejected by it or is not allowed to be proceeded with by it, the period commencing from the date on which such application is made and ending with the date on which the order under sub- 24 Provident Inv & Industries Private Limited V ITO ITA No 1003/Del/2015 A Y 2008-09 section (1) of section 2450 is received

ADDL. CIT, NEW DELHI vs. M/S. IRCON INTERNATIONAL LTD., NEW DELHI

In the result, the appeal of the Revenue is accordingly dismissed

ITA 3768/DEL/2017[2009-10]Status: DisposedITAT Delhi22 Jan 2021AY 2009-10

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

Section 143(3)Section 148

245C of the Act on such terms and conditions as contained in the circular. In our opinion, it is for this purpose that s. 245F of the Act has empowered the Settlement Commission to exercise the power of an IT authority under the Act. We must clarify here that while exercising the power derived under the circulars of the board

AMQ AGRO INDIA PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 19, NEW DELHI

In the result, the appeals filed by the Revenue for A

ITA 2801/DEL/2018[2008-09]Status: DisposedITAT Delhi29 May 2020AY 2008-09

Bench: Shri R.K. Panda & Shri K.Narasimha

For Appellant: Shri Hiren Mehta, CAFor Respondent: Ms Pramita M. Biswas, CIT, DR
Section 10ASection 132(1)Section 153ASection 245D(4)

section 153A notice is concerned, the ld. Counsel for the assessee submitted that in para 17 of its written submissions, it was clearly submitted that corresponding credit in respect of income already declared in the return should be allowed otherwise it would lead to double taxation of the same income. Copies of original return and return in response to 153A

AMQ AGRO INDIA PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 19, NEW DELHI

In the result, the appeals filed by the Revenue for A

ITA 169/DEL/2018[2011-12]Status: DisposedITAT Delhi29 May 2020AY 2011-12

Bench: Shri R.K. Panda & Shri K.Narasimha

For Appellant: Shri Hiren Mehta, CAFor Respondent: Ms Pramita M. Biswas, CIT, DR
Section 10ASection 132(1)Section 153ASection 245D(4)

section 153A notice is concerned, the ld. Counsel for the assessee submitted that in para 17 of its written submissions, it was clearly submitted that corresponding credit in respect of income already declared in the return should be allowed otherwise it would lead to double taxation of the same income. Copies of original return and return in response to 153A

DCIT, CENTRAL CIRCLE- 19, NEW DELHI vs. AMQ AGRO INDIA PVT. LTD., NEW DELHI

In the result, the appeals filed by the Revenue for A

ITA 4287/DEL/2018[2008-09]Status: DisposedITAT Delhi29 May 2020AY 2008-09

Bench: Shri R.K. Panda & Shri K.Narasimha

For Appellant: Shri Hiren Mehta, CAFor Respondent: Ms Pramita M. Biswas, CIT, DR
Section 10ASection 132(1)Section 153ASection 245D(4)

section 153A notice is concerned, the ld. Counsel for the assessee submitted that in para 17 of its written submissions, it was clearly submitted that corresponding credit in respect of income already declared in the return should be allowed otherwise it would lead to double taxation of the same income. Copies of original return and return in response to 153A

DCIT, NEW DELHI vs. M/S PILOT INDUSTRIES LTD.,, NEW DELHI

In the result, all the five appeals filed by the learned assessing officer are dismissed

ITA 3259/DEL/2016[2007-08]Status: DisposedITAT Delhi19 Aug 2021AY 2007-08

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel, CAFor Respondent: Shri H. K. Choudhary, CIT DR
Section 132

245C before the settlement commission on 15/2/2012, which was found by order dated 17/4/2013 as not valid. Therefore, the learned assessing officer preceded with the assessment proceedings. The assessee filed a writ petition before the honourable Delhi High Court for stopping the assessment proceedings, which was later on withdrawn, therefore assessment proceedings continued. 8. During the course of search

DCIT, NEW DELHI vs. M/S PILOT INDUSTRIES LTD.,, NEW DELHI

In the result, all the five appeals filed by the learned assessing officer are dismissed

ITA 3258/DEL/2016[2006-07]Status: DisposedITAT Delhi19 Aug 2021AY 2006-07

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel, CAFor Respondent: Shri H. K. Choudhary, CIT DR
Section 132

245C before the settlement commission on 15/2/2012, which was found by order dated 17/4/2013 as not valid. Therefore, the learned assessing officer preceded with the assessment proceedings. The assessee filed a writ petition before the honourable Delhi High Court for stopping the assessment proceedings, which was later on withdrawn, therefore assessment proceedings continued. 8. During the course of search

DCIT, NEW DELHI vs. M/S PILOT INDUSTRIES LTD.,, NEW DELHI

In the result, all the five appeals filed by the learned assessing officer are dismissed

ITA 3261/DEL/2016[2009-10]Status: DisposedITAT Delhi19 Aug 2021AY 2009-10

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel, CAFor Respondent: Shri H. K. Choudhary, CIT DR
Section 132

245C before the settlement commission on 15/2/2012, which was found by order dated 17/4/2013 as not valid. Therefore, the learned assessing officer preceded with the assessment proceedings. The assessee filed a writ petition before the honourable Delhi High Court for stopping the assessment proceedings, which was later on withdrawn, therefore assessment proceedings continued. 8. During the course of search

DCIT, NEW DELHI vs. M/S PILOT INDUSTRIES LTD.,, NEW DELHI

In the result, all the five appeals filed by the learned assessing officer are dismissed

ITA 3257/DEL/2016[2005-06]Status: DisposedITAT Delhi19 Aug 2021AY 2005-06

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel, CAFor Respondent: Shri H. K. Choudhary, CIT DR
Section 132

245C before the settlement commission on 15/2/2012, which was found by order dated 17/4/2013 as not valid. Therefore, the learned assessing officer preceded with the assessment proceedings. The assessee filed a writ petition before the honourable Delhi High Court for stopping the assessment proceedings, which was later on withdrawn, therefore assessment proceedings continued. 8. During the course of search

DCIT, NEW DELHI vs. M/S PILOT INDUSTRIES LTD.,, NEW DELHI

In the result, all the five appeals filed by the learned assessing officer are dismissed

ITA 3260/DEL/2016[2008-09]Status: DisposedITAT Delhi19 Aug 2021AY 2008-09

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel, CAFor Respondent: Shri H. K. Choudhary, CIT DR
Section 132

245C before the settlement commission on 15/2/2012, which was found by order dated 17/4/2013 as not valid. Therefore, the learned assessing officer preceded with the assessment proceedings. The assessee filed a writ petition before the honourable Delhi High Court for stopping the assessment proceedings, which was later on withdrawn, therefore assessment proceedings continued. 8. During the course of search

DCIT, NEW DELHI vs. M/S PILOT INDUSTRIES LTD.,, NEW DELHI

In the result, both the appeals filed by the learned assessing officer are dismissed

ITA 3262/DEL/2016[2010-11]Status: DisposedITAT Delhi23 Nov 2021AY 2010-11

Bench: Ms Suchitra Raghunath Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel and ShriFor Respondent: Shri H. K. Charudahry, CIT
Section 132

section 132(1) of the Act. For AY 2010-11, Notice u/s 153 A was issued . In response to Notice u/s 153A issued by the ld. AO, the assessee company filed the return of income on 09/09/2011 declaring income of Rs. 10,81,28,140/-, The ld. AO completed the assessment at income

DCIT, NEW DELHI vs. M/S PILOT INDUSTRIES LTD.,, NEW DELHI

In the result, both the appeals filed by the learned assessing officer are dismissed

ITA 3263/DEL/2016[2011-12]Status: DisposedITAT Delhi23 Nov 2021AY 2011-12

Bench: Ms Suchitra Raghunath Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Amit Goel and ShriFor Respondent: Shri H. K. Charudahry, CIT
Section 132

section 132(1) of the Act. For AY 2010-11, Notice u/s 153 A was issued . In response to Notice u/s 153A issued by the ld. AO, the assessee company filed the return of income on 09/09/2011 declaring income of Rs. 10,81,28,140/-, The ld. AO completed the assessment at income

ASHISH KALRA,NEW DELHI vs. ACIT, CENTRAL CIRCLE-4, NEW DELHI

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

ITA 4309/DEL/2019[2009-10]Status: DisposedITAT Delhi14 Oct 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

Section 139(1)Section 147Section 148Section 153CSection 251

section 292C are also not applicable in the Ashish Kalra vs. ACIT instant case since action of search u/s 132 was not undertaken upon the 'A'. In the impugned order CIT(A) has relied upon various statements of representatives from M/s Bright. In this regard it is submitted as under: (1) Statement dated 25th November 2010 of Mr. Rashid Masood

ASHISH KALRA,NEW DELHI vs. ACIT, CENTRAL CIRCLE-4, NEW DELHI

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

ITA 4308/DEL/2019[2008-09]Status: DisposedITAT Delhi14 Oct 2025AY 2008-09

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

Section 139(1)Section 147Section 148Section 153CSection 251

section 292C are also not applicable in the Ashish Kalra vs. ACIT instant case since action of search u/s 132 was not undertaken upon the 'A'. In the impugned order CIT(A) has relied upon various statements of representatives from M/s Bright. In this regard it is submitted as under: (1) Statement dated 25th November 2010 of Mr. Rashid Masood