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871 results for “disallowance”+ Section 46Aclear

Sorted by relevance

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Key Topics

Addition to Income90Disallowance62Section 6849Section 143(3)39Deduction31Section 153A25Section 4020Section 14820Section 14419Section 80I

ACIT, NEW DELHI vs. M/S NIIT TECHNOLOGIES LTD.,, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5492/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

46A and are taken on record. 2.4.2 Having decided the question of admission of additional evidence, now the substantive issues are to be decided. The same are discussed in the following paragraphs. 2.4.3 The first substantive issue is whether the appellant was correct in claiming deduction under section 108 of the Act with reference to separate and independent profits

ACIT, NEW DELHI vs. M/S NIIT TECHNOLOGIES LTD.,, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

Showing 1–20 of 871 · Page 1 of 44

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Section 14717
TDS12
ITA 5491/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

46A and are taken on record. 2.4.2 Having decided the question of admission of additional evidence, now the substantive issues are to be decided. The same are discussed in the following paragraphs. 2.4.3 The first substantive issue is whether the appellant was correct in claiming deduction under section 108 of the Act with reference to separate and independent profits

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5525/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

46A and are taken on record. 2.4.2 Having decided the question of admission of additional evidence, now the substantive issues are to be decided. The same are discussed in the following paragraphs. 2.4.3 The first substantive issue is whether the appellant was correct in claiming deduction under section 108 of the Act with reference to separate and independent profits

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5524/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

46A and are taken on record. 2.4.2 Having decided the question of admission of additional evidence, now the substantive issues are to be decided. The same are discussed in the following paragraphs. 2.4.3 The first substantive issue is whether the appellant was correct in claiming deduction under section 108 of the Act with reference to separate and independent profits

SHIV SHAKTI TRADERS,GHAZIABAD vs. ACIT, CIRCLE-2, GHAZIABAD

In the result, the appeal is partly allowed

ITA 2877/DEL/2019[2013-14]Status: DisposedITAT Delhi15 Mar 2022AY 2013-14

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandraasstt. Year: 2013-14

For Appellant: NoneFor Respondent: Shri Umesh Takyar, Sr. DR
Section 143(3)Section 154Section 40A(3)

disallowed. Notice under section 154 dated 5.7.2018 was duly received by the Ld. AR of the assesee who appeared on 16.7.2018 but did not provide any reply and requested for adjournment which was granted. The hearing was adjourned to 19.7.2018 but on that date also neither the assesee nor the Ld. AR filed any reply. Ld. AO, therefore, passed

ACIT, CIRCLE-18(2), NEW DELHI vs. NTL LEMNIS INDIA P.LTD, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 6006/DEL/2019[2013-14]Status: DisposedITAT Delhi22 Jan 2024AY 2013-14

Bench: Shri Saktijit Dey & Dr. B. R. R. Kumar

For Appellant: NoneFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 143(3)Section 195Section 40Section 9Section 9(1)

disallowance under section 40(a)(1). From above submission, it is submitted that the learned AO has erred in facts as well as in law in adding to income Rs. 6,74,32,200/-. Your honour is kindly requested to allow the appeal & delete the additions made by learned AO in the interest of equity & justice. 4. Since

SAGA DEVELOPERS PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal of the Revenue are dismissed

ITA 3165/DEL/2014[2009-10]Status: DisposedITAT Delhi30 May 2018AY 2009-10

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 Dcit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2009-10 M/S. Saamag Developers Pvt. Vs. Acit, Ltd., Central Circle -10, New Delhi B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Acit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Dcit, Vs. M/S. Saga Developers Pvt. Central Circle -10, New Delhi Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4932K (Appellant) (Respondent)

Section 2(22)Section 2(22)(e)Section 69C

46A. 2. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition of Rs.23,67,367/- on account of disallowance u/s 40A(3) of the I.T. Act. 3. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition

DCIT, NEW DELHI vs. M/S. SAGA DEVELOPERS PVT. LTD., NEW DELHI

The appeal of the Revenue are dismissed

ITA 2604/DEL/2014[2009-10]Status: DisposedITAT Delhi30 May 2018AY 2009-10

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 Dcit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2009-10 M/S. Saamag Developers Pvt. Vs. Acit, Ltd., Central Circle -10, New Delhi B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Acit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Dcit, Vs. M/S. Saga Developers Pvt. Central Circle -10, New Delhi Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4932K (Appellant) (Respondent)

Section 2(22)Section 2(22)(e)Section 69C

46A. 2. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition of Rs.23,67,367/- on account of disallowance u/s 40A(3) of the I.T. Act. 3. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition

DCIT, NEW DELHI vs. M/S. SAGA DEVELOPERS PVT. LTD., NEW DELHI

The appeal of the Revenue are dismissed

ITA 2602/DEL/2014[2006-07]Status: DisposedITAT Delhi30 May 2018AY 2006-07

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 Dcit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2009-10 M/S. Saamag Developers Pvt. Vs. Acit, Ltd., Central Circle -10, New Delhi B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Acit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Dcit, Vs. M/S. Saga Developers Pvt. Central Circle -10, New Delhi Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4932K (Appellant) (Respondent)

Section 2(22)Section 2(22)(e)Section 69C

46A. 2. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition of Rs.23,67,367/- on account of disallowance u/s 40A(3) of the I.T. Act. 3. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition

ACIT, NEW DELHI vs. M/S. SAAMAG DEVELOPERS PVT. LTD., NEW DELHI

The appeal of the Revenue are dismissed

ITA 433/DEL/2014[2006-07]Status: DisposedITAT Delhi30 May 2018AY 2006-07

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 Dcit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2009-10 M/S. Saamag Developers Pvt. Vs. Acit, Ltd., Central Circle -10, New Delhi B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Acit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Dcit, Vs. M/S. Saga Developers Pvt. Central Circle -10, New Delhi Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4932K (Appellant) (Respondent)

Section 2(22)Section 2(22)(e)Section 69C

46A. 2. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition of Rs.23,67,367/- on account of disallowance u/s 40A(3) of the I.T. Act. 3. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition

ACIT, NEW DELHI vs. M/S. SAGA TOWNSHIP PVT. LTD., NEW DELHI

The appeal of the Revenue are dismissed

ITA 436/DEL/2014[2007-08]Status: DisposedITAT Delhi30 May 2018AY 2007-08

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 Dcit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2009-10 M/S. Saamag Developers Pvt. Vs. Acit, Ltd., Central Circle -10, New Delhi B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Acit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Dcit, Vs. M/S. Saga Developers Pvt. Central Circle -10, New Delhi Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4932K (Appellant) (Respondent)

Section 2(22)Section 2(22)(e)Section 69C

46A. 2. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition of Rs.23,67,367/- on account of disallowance u/s 40A(3) of the I.T. Act. 3. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition

M/S. SAGA DEVELOPERS PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal of the Revenue are dismissed

ITA 2999/DEL/2014[2006-07]Status: DisposedITAT Delhi30 May 2018AY 2006-07

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 Dcit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2009-10 M/S. Saamag Developers Pvt. Vs. Acit, Ltd., Central Circle -10, New Delhi B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Acit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Dcit, Vs. M/S. Saga Developers Pvt. Central Circle -10, New Delhi Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4932K (Appellant) (Respondent)

Section 2(22)Section 2(22)(e)Section 69C

46A. 2. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition of Rs.23,67,367/- on account of disallowance u/s 40A(3) of the I.T. Act. 3. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition

DCIT, NEW DELHI vs. M/S. SAAMAG DEVELOPERS PVT. LTD., NEW DELHI

The appeal of the Revenue are dismissed

ITA 2601/DEL/2014[2009-10]Status: DisposedITAT Delhi30 May 2018AY 2009-10

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 Dcit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2009-10 M/S. Saamag Developers Pvt. Vs. Acit, Ltd., Central Circle -10, New Delhi B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Acit, Vs. M/S. Saamag Developers Central Circle -10, New Delhi Pvt. Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4952R (Appellant) (Respondent) & Assessment Year: 2006-07 Dcit, Vs. M/S. Saga Developers Pvt. Central Circle -10, New Delhi Ltd., B-67, Sarita Vihar, New Delhi Pan : Aajcs4932K (Appellant) (Respondent)

Section 2(22)Section 2(22)(e)Section 69C

46A. 2. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition of Rs.23,67,367/- on account of disallowance u/s 40A(3) of the I.T. Act. 3. That the Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in deleting an addition

ITO, NEW DELHI vs. M/S ANSAL HOUSING & CONSTRUCTION LTD., NEW DELHI

In the result, the cross-objection filed by the assessee is dismissed

ITA 2731/DEL/2010[2007-08]Status: DisposedITAT Delhi26 Jul 2024AY 2007-08

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2007-08] Dcit, Vs Ansal Housing & Construction Ltd., Central Circle-20, Ugf-15, Indraprastha Building, 21, New Delhi. Barakhamba Road, New Delhi. Pan-Aaaca0377R Appellant Respondent

Section 143(3)Section 14ASection 80Section 80I

46A of income tax Rule 1962 and ignoring the request of AO in prescribed form ITNS -51 as required by Ld. CIT (A) before disposal of appeal. 5. On the facts and circumstances of the case, the Ld. CIT(A) has erred in law and facts of the case in allowing part relief towards disallowance of deduction under section

ACIT, NEW DELHI vs. M/S OPUS PROJECTS LTD.,, DELHI

Appeal is dismissed

ITA 5470/DEL/2016[2012-13]Status: DisposedITAT Delhi19 Jan 2021AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri C. S. Anand, AdvFor Respondent: Shri H. K. Chaudhary, CIT DR
Section 30Section 40Section 40A

disallowance u/s 14 A read with rule 8D of ₹ 450,000/– without following mandatory procedure Under rule 46A and matter had to be restored to assessing officer to decide matter afresh 4. ITA number 5470/Del/2016 is filed by learned Asst Commissioner Of Income Tax, Circle – 19 (1), New Delhi against order of The Commissioner Of Income Tax (Appeals

DCIT, NEW DELHI vs. M/S. OPUS PROJECTS LTD., NEW DELHI

Appeal is dismissed

ITA 3938/DEL/2015[2010-11]Status: DisposedITAT Delhi19 Jan 2021AY 2010-11

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri C. S. Anand, AdvFor Respondent: Shri H. K. Chaudhary, CIT DR
Section 30Section 40Section 40A

disallowance u/s 14 A read with rule 8D of ₹ 450,000/– without following mandatory procedure Under rule 46A and matter had to be restored to assessing officer to decide matter afresh 4. ITA number 5470/Del/2016 is filed by learned Asst Commissioner Of Income Tax, Circle – 19 (1), New Delhi against order of The Commissioner Of Income Tax (Appeals

DCIT, NEW DELHI vs. M/S. OPUS PROJECTS LTD., NEW DELHI

Appeal is dismissed

ITA 3939/DEL/2015[2011-12]Status: DisposedITAT Delhi19 Jan 2021AY 2011-12

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri C. S. Anand, AdvFor Respondent: Shri H. K. Chaudhary, CIT DR
Section 30Section 40Section 40A

disallowance u/s 14 A read with rule 8D of ₹ 450,000/– without following mandatory procedure Under rule 46A and matter had to be restored to assessing officer to decide matter afresh 4. ITA number 5470/Del/2016 is filed by learned Asst Commissioner Of Income Tax, Circle – 19 (1), New Delhi against order of The Commissioner Of Income Tax (Appeals

DCIT, NEW DELHI vs. M/S. CONCENTRIX DAKSH SERVICES INDIA PVT LTD., GURGAON

In the result, the appeals of the assessee are partly allowed and the appeal of the department is dismissed

ITA 2495/DEL/2015[2010-11]Status: DisposedITAT Delhi04 Feb 2019AY 2010-11

Bench: Sh. N. S. Saini & Sh. Sudhanshu Srivastavaita No. 2096/Del/2015 : Asstt. Year : 2010-11 M/S Concentrix Daksh Services India Vs Deputy Commissioner Of Pvt. Ltd., (Erstwhile Known As Ibm Income Tax, Circle-4(1), Daksh Business Process Services Pvt. New Delhi Ltd.), 4Th Floor, Tower-B, Building No. 8, Cyber City, Dlf, Phase-Ii, Gurgaon, Haryana (Appellant) (Respondent) Pan No. Aabcd4187D

For Appellant: Sh. G. C. Srivastava, AdvFor Respondent: Sh. Sanjay I. Bara, CIT DR

disallowing INR 6,00,53,106 under section 4o(a)(i) of the Act on account of non-deduction of taxes at source on reimbursements of expenses made to Associated Enterprises CAEs’). ITA Nos. 2096 & 2495Del/2015 19 Concentrix Daksh Services India Pvt. Ltd. 5.2. That on the facts and in the circumstances of the case

M/S. CONCENTRIX DAKSH SERVICES INDIA PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed and the appeal of the department is dismissed

ITA 1560/DEL/2016[2011-12]Status: DisposedITAT Delhi04 Feb 2019AY 2011-12

Bench: Sh. N. S. Saini & Sh. Sudhanshu Srivastavaita No. 2096/Del/2015 : Asstt. Year : 2010-11 M/S Concentrix Daksh Services India Vs Deputy Commissioner Of Pvt. Ltd., (Erstwhile Known As Ibm Income Tax, Circle-4(1), Daksh Business Process Services Pvt. New Delhi Ltd.), 4Th Floor, Tower-B, Building No. 8, Cyber City, Dlf, Phase-Ii, Gurgaon, Haryana (Appellant) (Respondent) Pan No. Aabcd4187D

For Appellant: Sh. G. C. Srivastava, AdvFor Respondent: Sh. Sanjay I. Bara, CIT DR

disallowing INR 6,00,53,106 under section 4o(a)(i) of the Act on account of non-deduction of taxes at source on reimbursements of expenses made to Associated Enterprises CAEs’). ITA Nos. 2096 & 2495Del/2015 19 Concentrix Daksh Services India Pvt. Ltd. 5.2. That on the facts and in the circumstances of the case

UMAR DARAJ,MEERUT vs. ITO WARD-1(2)(4), MEERUT

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

ITA 3095/DEL/2025[2015-16]Status: DisposedITAT Delhi10 Dec 2025AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Umar Daraj, Vs. Ito, Ward 1(2)(4), 153/1, Hapur Road, Meerut. Umar Nagar, Meerut – 250 001 (Uttar Pradesh). (Pan : Ainpd8766H) (Appellant) (Respondent) Assessee By : Shri Sumit Lal Chandani, Advocate Revenue By : Shri Dayainder Singh Sidhu, Citdr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman:

For Appellant: Shri Sumit Lal Chandani, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CITDR
Section 142(1)Section 143(3)Section 148Section 151Section 40A

Section 40A(3) legally untenable. CIT(A) has erred in not properly analyzing the appellant's submissions and in sustaining the disallowance. 10. That the reassessment proceedings have been carried out in violation of the principles of natural justice, as the Assessing Officer/CTT(A) failed to provide reasonable opportunity to the appellant. 11. That CIT(A) has erred in rejecting