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38 results for “disallowance”+ Section 245D(1)clear

Sorted by relevance

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Key Topics

Section 153A46Section 14338Addition to Income32Search & Seizure28Section 26319Section 13916Section 13214Section 15312Section 143(3)11Section 132(1)

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)

1) of section 186 shall apply to the cancellation of the registration of a firm required to be made in pursuance of any such directions as aforesaid.] **************** **************** 245I. Order of settlement to be conclusive Every order of settlement passed under sub- section (4) of section 245Dshall be conclusive as to the matter stated therein and no matter covered by such

Showing 1–20 of 38 · Page 1 of 2

10
Disallowance8
Bogus Purchases8

FISERV INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE-9(1), NEW DELHI

The appeal is dismissed

ITA 6583/DEL/2019[2013-14]Status: DisposedITAT Delhi03 Jul 2020AY 2013-14

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishifiserv India Private Limited, Vs. Acit, Regus Elegance, Level-2, Jasola Circle-9(1), District Centre, Old Mathura New Delhi Road, Delhi Pan: Aaccr0787L (Appellant) (Respondent)

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Ms. Ashima Neb, Sr. DR
Section 115JSection 143Section 154Section 234B

disallowed of ₹ 989,491. Against which the assessee filed objection before the learned Dispute Resolution Panel. Consequent to the direction of the learned Dispute Resolution Panel, transfer-pricing adjustment of ₹ 202,999,837 was sustained and the credit card expenditure addition was deleted. For A. Y. 2011 – 12, because of transfer pricing adjustment of ₹ 202,999,837 made

THE BANK OF TOKYO MISTUBISHI UFJ LTD.,,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 4548/DEL/2016[2008-09]Status: DisposedITAT Delhi27 Feb 2018AY 2008-09

Bench: Shri N.K. Saini & Before Mr. Bhavnesh Saini

For Appellant: Sh. P.J. Pardiwala, Sr. AdvFor Respondent: Sh. G.K. Dhall, CIT DR (Intl
Section 139(1)Section 234DSection 44C

disallowances made by the AO and the ITAT vide its order dated 19th September, 2014 set aside the order on certain issues to the file of the AO for fresh adjudication. Thereafter in compliance to the directions given in the aforesaid order, the AO conducted the remand proceedings and passed the draft assessment order 21st December, 2015 under Section

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)

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 to in clause (a) or clause (b) of this sub-section available to the Assessing Officer for making

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)

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 to in clause (a) or clause (b) of this sub-section available to the Assessing Officer for making

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)

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 to in clause (a) or clause (b) of this sub-section available to the Assessing Officer for making

MR. INDER PAL SINGH WADHAWAN,NEW DELHI vs. JCIT, NEW DELHI

In the result ground No. 2 of the appeal of the assessee is allowed

ITA 1155/DEL/2013[2007-08]Status: DisposedITAT Delhi08 Jul 2016AY 2007-08

Bench: I.C.Sudhir & Shri Prashant Maharishiinder Pal Singh Wadhawan, Jcit, E/1/7, Ii Nd Floor, East Patel Vs. Circle-33, Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, E/1/7, Ii Nd Floor, Vs. 15Th Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, New Delhi Pan: Aarps6904L (Appellant) (Respondent) Inder Pal Singh Wadhawan, Acit, E/1/7, Ii Nd Floor, East Patel Circle-33, Vs. Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, 15Th E/1/7, Ii Nd Floor, Vs. Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, Pan: Aarps6904L New Delhi (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 143(3)Section 68

disallowances. 38. A new dimension was given by the LD DR during the course of hearing before us when he submitted that Income Tax Settlement Commission (ITSC) has passed order under section 245D (4) of the act on 29/07/2013 for assessment year 2009 – 10 to assessment year 2011 – 12 in the case of the assessee along with others

MR. INDER PAL SINGH WADHAWAN,NEW DELHI vs. ACIT, NEW DELHI

In the result ground No. 2 of the appeal of the assessee is allowed

ITA 1589/DEL/2013[2008-09]Status: DisposedITAT Delhi08 Jul 2016AY 2008-09

Bench: I.C.Sudhir & Shri Prashant Maharishiinder Pal Singh Wadhawan, Jcit, E/1/7, Ii Nd Floor, East Patel Vs. Circle-33, Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, E/1/7, Ii Nd Floor, Vs. 15Th Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, New Delhi Pan: Aarps6904L (Appellant) (Respondent) Inder Pal Singh Wadhawan, Acit, E/1/7, Ii Nd Floor, East Patel Circle-33, Vs. Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, 15Th E/1/7, Ii Nd Floor, Vs. Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, Pan: Aarps6904L New Delhi (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 143(3)Section 68

disallowances. 38. A new dimension was given by the LD DR during the course of hearing before us when he submitted that Income Tax Settlement Commission (ITSC) has passed order under section 245D (4) of the act on 29/07/2013 for assessment year 2009 – 10 to assessment year 2011 – 12 in the case of the assessee along with others

ACIT, NEW DELHI vs. SH. INDERPAL SINGH WADHAWAN, NEW DELHI

In the result ground No. 2 of the appeal of the assessee is allowed

ITA 952/DEL/2013[2007-08]Status: DisposedITAT Delhi08 Jul 2016AY 2007-08

Bench: I.C.Sudhir & Shri Prashant Maharishiinder Pal Singh Wadhawan, Jcit, E/1/7, Ii Nd Floor, East Patel Vs. Circle-33, Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, E/1/7, Ii Nd Floor, Vs. 15Th Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, New Delhi Pan: Aarps6904L (Appellant) (Respondent) Inder Pal Singh Wadhawan, Acit, E/1/7, Ii Nd Floor, East Patel Circle-33, Vs. Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, 15Th E/1/7, Ii Nd Floor, Vs. Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, Pan: Aarps6904L New Delhi (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 143(3)Section 68

disallowances. 38. A new dimension was given by the LD DR during the course of hearing before us when he submitted that Income Tax Settlement Commission (ITSC) has passed order under section 245D (4) of the act on 29/07/2013 for assessment year 2009 – 10 to assessment year 2011 – 12 in the case of the assessee along with others

DCIT, CC-31, NEW DELHI vs. REALTIME MARKETING PVT. LTD., DELHI

In the result, the addition made u/s 68 and u/s 56(2)(viib) in the case of M/s Realtime Marketing Pvt

ITA 1839/DEL/2021[2015-16]Status: DisposedITAT Delhi05 Jul 2024AY 2015-16

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

For Appellant: Sh. Neeraj Jain, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 132Section 132(4)Section 143(1)Section 143(2)Section 153ASection 68

1), read with section 158B(b), it is at once clear that a statement recorded under section 132(4) can be used in evidence for making a block assessment only if the said statement is made in the context of other evidence or material discovered during the search. A statement of a person, which is not relatable to any incriminating

ENN VEE HOLDINGS PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE 31, NEW DELHI

In the result, the addition made u/s 68 and u/s 56(2)(viib) in the case of M/s Realtime Marketing Pvt

ITA 1195/DEL/2023[2016-17]Status: DisposedITAT Delhi05 Jul 2024AY 2016-17

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

For Appellant: Sh. Neeraj Jain, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 132Section 132(4)Section 143(1)Section 143(2)Section 153ASection 68

1), read with section 158B(b), it is at once clear that a statement recorded under section 132(4) can be used in evidence for making a block assessment only if the said statement is made in the context of other evidence or material discovered during the search. A statement of a person, which is not relatable to any incriminating

M/S VARDAAN FASHION,NEW DELHI vs. JCIT, NEW DELHI

In the result ground No. 3 of the appeal of the assessee is dismissed

ITA 1143/DEL/2013[2007-08]Status: DisposedITAT Delhi08 Jul 2016AY 2007-08

Bench: I.C.Sudhir & Shri Prashant Maharishivardan Fashions, Jcit, E-1/7, 2Nd Floor, East Patel Range-33, Vs. Nagar, New Delhi New Delhi Pan:Aacfv0423H (Appellant) (Respondent) Acit, Vardan Fashions, Circle-33(1) E-1/7, 2Nd Floor, East Patel Vs. New Delhi Nagar, New Delhi Pan:Aacfv0423H (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 40

disallowances. 38. A new dimension was given by the LD DR during the course of hearing before us when he submitted that Income Tax Settlement Commission (ITSC) has passed order under section 245D (4) of the act on 29/07/2013 for assessment year 2009 – 10 to assessment year 2011 – 12 in the case of the assessee along with others

ACIT, NEW DELHI vs. M/S VARDAN FASHION, NEW DELHI

In the result ground No. 3 of the appeal of the assessee is dismissed

ITA 950/DEL/2013[2007-08]Status: DisposedITAT Delhi08 Jul 2016AY 2007-08

Bench: I.C.Sudhir & Shri Prashant Maharishivardan Fashions, Jcit, E-1/7, 2Nd Floor, East Patel Range-33, Vs. Nagar, New Delhi New Delhi Pan:Aacfv0423H (Appellant) (Respondent) Acit, Vardan Fashions, Circle-33(1) E-1/7, 2Nd Floor, East Patel Vs. New Delhi Nagar, New Delhi Pan:Aacfv0423H (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 40

disallowances. 38. A new dimension was given by the LD DR during the course of hearing before us when he submitted that Income Tax Settlement Commission (ITSC) has passed order under section 245D (4) of the act on 29/07/2013 for assessment year 2009 – 10 to assessment year 2011 – 12 in the case of the assessee along with others

ROHTAS PROJECTS LTD.,NEW DELHI vs. PR. CIT(C), KANPUR

In the result, the appeals of the assessees are allowed for statistical purposes

ITA 5345/DEL/2015[2012-13]Status: DisposedITAT Delhi23 Apr 2018AY 2012-13

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 5345/Del/2015 : Asstt. Year : 2012-13 Rohtas Projects Ltd., Vs Pr. Cit(C), 806-807, Indra Prakash Building, 7/81-B, Tilak Nagar, 21, Barakhamba Road, Connaught Kanpur Place, New Delhi (Appellant) (Respondent) Pan No. Aaccr7598H

For Appellant: Sh. Sanjay Kumar Garg, CA &For Respondent: Sh. Amit Jain, Sr. DR
Section 132(1)Section 245D(4)Section 263Section 263(1)

245D(4) covering the assessment year 2003-04 to 2010-11) did not have any bearing so far as assessment year 2012-13 was concerned; b) net agricultural income as disclosed by the "appellant" was not only fully verifiable from the records kept and maintained by the "appellant" in regular course/ the same was in conformity with past also

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)

1) of the Act was conducted on 15th February, 2014 in the case of the assessee along with other cases of the AMQ group at various residential and business premises. A notice u/s 153A was issued to the assessee on 14th October, 2014 requiring the assessee to file the return for the relevant assessment year within 30 days which

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)

1) of the Act was conducted on 15th February, 2014 in the case of the assessee along with other cases of the AMQ group at various residential and business premises. A notice u/s 153A was issued to the assessee on 14th October, 2014 requiring the assessee to file the return for the relevant assessment year within 30 days which

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)

1) of the Act was conducted on 15th February, 2014 in the case of the assessee along with other cases of the AMQ group at various residential and business premises. A notice u/s 153A was issued to the assessee on 14th October, 2014 requiring the assessee to file the return for the relevant assessment year within 30 days which

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. SNW SMITH CONSULTANTS PRIVATE LIMITED, DELHI

In the result, the appeal filed by the Revenue being ITA

ITA 2244/DEL/2025[2015-16]Status: DisposedITAT Delhi10 Sept 2025AY 2015-16

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: NoneFor Respondent: Shri Jitender Singh, CIT DR
Section 132Section 139Section 143(1)Section 143(2)Section 153ASection 245

disallowance Amount (in Rs.) 1. Addition on account of additional rate on 2,48,14,134/- booked LC commission income 4.3.3 The appellant argued that the addition is not valid in view of (2023) 149 taxmann.com 399 (SC) since the seized materials were not entity specific, as stated by the AO in the order and have submitted

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. ADAM SMITH CONSULTANCY PRIVATE LIMITED, DELHI

In the result, the appeal filed by the Revenue being ITA

ITA 2248/DEL/2025[2016-17]Status: DisposedITAT Delhi10 Sept 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: NoneFor Respondent: Shri Jitender Singh, CIT DR
Section 132Section 139Section 143(1)Section 143(2)Section 153ASection 245

disallowance Amount (in Rs.) 1. Addition on account of additional rate on 2,48,14,134/- booked LC commission income 4.3.3 The appellant argued that the addition is not valid in view of (2023) 149 taxmann.com 399 (SC) since the seized materials were not entity specific, as stated by the AO in the order and have submitted

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S SNW SMITH CONSULTANTS PVT. LTD., DELHI

In the result, the appeal filed by the Revenue being ITA

ITA 2243/DEL/2025[2012-13]Status: DisposedITAT Delhi10 Sept 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: NoneFor Respondent: Shri Jitender Singh, CIT DR
Section 132Section 139Section 143(1)Section 143(2)Section 153ASection 245

disallowance Amount (in Rs.) 1. Addition on account of additional rate on 2,48,14,134/- booked LC commission income 4.3.3 The appellant argued that the addition is not valid in view of (2023) 149 taxmann.com 399 (SC) since the seized materials were not entity specific, as stated by the AO in the order and have submitted