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

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Key Topics

Section 13210Section 153A10Section 1488Search & Seizure7Section 1476Section 143(1)6Section 143(2)6Section 132(4)5Addition to Income5Section 245

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

4
Reassessment2
Natural Justice2

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

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. M/S SNW SMITH CONSULTANTS PRIVATE LIMITED, DELHI

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

ITA 2245/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

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

PARKASH SACHDEVA,NEW DELHI vs. ACIT CENTRAL CIRCLE 18, NEW DELHI

ITA 2889/DEL/2023[2018-19]Status: DisposedITAT Delhi05 Aug 2025AY 2018-19
Section 143(3)Section 69A

SECTIONS MENTIONED IN THE ORDER ARE OF INCOME TAX ACT,\nUNLESS MENTIONED OTHERWISEJ\n2 001\n5\nITA No. 2889/Del/2023\nMs. Laxmi Reminte Inasa Private Llinted $.A. No. DL/DC-52/2019-20/52-IT\nORDER\nOrder .245)(4)\nThe applicant company is engaged in the business of manufacturing tind ante of remote contro's,\nset top boxes, adapters, etc. in the open market, deles as Originat

INDU BANSAL,KARNAL vs. DCIT, CENTRAL CIRCLE, KARNAL

In the result, the addition of Rs

ITA 2863/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri Saktijit Dey & Shri Brajesh Kumar Singh[Assessment Year: 2017-18] Smt. Indu Bansal, Dcit, House No. L-506, Model Central Circle, Town, Karnal, Haryana- Vs Karnal. 132001. Pan- Ahopb3289R Assessee Revenue Assessee By Shri Ved Jain, Adv. & Shri Aman Garg, Ca Revenue By Shri Shravan Kumar Cit(Dr)

Section 132(4)Section 142(1)Section 143(3)Section 153CSection 69

section 115BBE of the Income Tax Act. 9.1 In this regard, the learned AR submitted as under. “12. In the present case, assessing officer in notice u/s 142(1) of the Act dated 11.09.2019 (PB Pg. 12-18) alleged assessee has received 11 ITA No.- 2863/Del/2024 Smt. Indu Bansal gift of Rs 22,40,000/-, however in the assessment order

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