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18 results for “disallowance”+ Section 148(1)clear

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Key Topics

Section 14828Section 143(3)24Section 14723Section 4018Addition to Income14Section 80P12Deduction10Section 2639Disallowance9Section 10

BRAHTAKAR KRISHI SAKH SAHAKARI SAMITI MARYADIT,SAHAJPUR vs. INCOME TAX OFFICER WARD 1(2), JABALPUR

In the result, all the three appeals in ITA Nos

ITA 151/JAB/2025[2015-16]Status: DisposedITAT Jabalpur28 Aug 2025AY 2015-16

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, Advocate & ShFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 147Section 148Section 250Section 80P

disallowance in the year under consideration is bad in law. ADDITIONAL GROUND 5. The AO was not justified in passing order under section 147 of the Act without issuing any notice under section 148 as the notice issued under section 148 was not issued to anybody as apparent from the portal. 6. The AO was not justified in passing order

7
Section 43B7
Reopening of Assessment5

BRAHTAKAR KRISHI SAKH SAHAKARI SAMITI MARYADIT,SAHAJPUR vs. INCOME TAX OFFICER WARD 1(2), JABALPUR

In the result, all the three appeals in ITA Nos

ITA 149/JAB/2025[2013-14]Status: DisposedITAT Jabalpur28 Aug 2025AY 2013-14

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, Advocate & ShFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 147Section 148Section 250Section 80P

disallowance in the year under consideration is bad in law. ADDITIONAL GROUND 5. The AO was not justified in passing order under section 147 of the Act without issuing any notice under section 148 as the notice issued under section 148 was not issued to anybody as apparent from the portal. 6. The AO was not justified in passing order

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1), JABALPUR vs. MADHYA PRADESH POWER GENERATING CO. LTD., JABALPUR

In the result, the Revenue's appeal is dismissed as not maintainable

ITA 251/JAB/2018[2008-09]Status: DisposedITAT Jabalpur23 Feb 2022AY 2008-09

Bench: Shri Sanjay Arora, Hon’Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Shri Rahul Bardia, CAFor Respondent: Shri S.K. Halder, DR
Section 115Section 143(3)Section 147Section 154Section 271(1)(c)

section 148; (c) in any other case, means the difference between the tax on the total income assessed and the tax that would have been chargeable had such total income been reduced by the amount of income in respect of which particulars have been concealed or inaccurate particulars have been furnished.' (emphasis, supplied) A bare reading of sec. 271(1

RAMJIDAS BUDHRAJA CHARITABLE TRUST (SGM),CHHINDWARA vs. INCOME TAX OFFICER EXEMPTION, JABALPUR

In the result, the appeal of the assessee is dismissed

ITA 235/JAB/2025[2015-16]Status: DisposedITAT Jabalpur19 Feb 2026AY 2015-16

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 10Section 11Section 11(2)Section 143(1)Section 143(3)Section 147Section 148

1) of the Income Tax Act on 20.10.2016. A demand of Rs. 18,93,058/- was raised. Later on, a 143(2) notice was issued on 02.01.2018 fixing the case on 15.01.2018 which was obviously barred by limitation and, therefore, the Assessing Officer issued a notice under Section 148 on 28.03.2018 that was served on the assessee

KRISHI UPAJ MANDI SAMITI,NARSINGPUR vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE 2(1), JABALPUR

In the result, both the appeals are partly allowed for statistical purposes

ITA 148/JAB/2024[2014-15]Status: DisposedITAT Jabalpur06 Mar 2026AY 2014-15

Bench: Shri Anadee Nath Misshra

Section 10Section 143(3)Section 154Section 40Section 43B

148 & 149/JAB/2024 Assessment Year:2014-15 2 “1. Considering the fact that Section 40(a)(iib) is not applicable in the case of assessee, learned CIT(A) erred in confirming the addition of Rs.6,12,215/- made by ld. AO towards payment of Board Fee. 2. Considering the fact that Section 40(a)(iib) is not applicable in the case

KRISHI UPAJ MANDI SAMITI ,NARSINGPUR vs. ASST. COMMISSIONER OF INCOMETAX, CIRCLE 2(1), JABALPUR

In the result, both the appeals are partly allowed for statistical purposes

ITA 149/JAB/2024[2014-15]Status: DisposedITAT Jabalpur06 Mar 2026AY 2014-15

Bench: Shri Anadee Nath Misshra

Section 10Section 143(3)Section 154Section 40Section 43B

148 & 149/JAB/2024 Assessment Year:2014-15 2 “1. Considering the fact that Section 40(a)(iib) is not applicable in the case of assessee, learned CIT(A) erred in confirming the addition of Rs.6,12,215/- made by ld. AO towards payment of Board Fee. 2. Considering the fact that Section 40(a)(iib) is not applicable in the case

SANJAY KUMAR AGRAWAL ,SATNA vs. ASST. COMMISSIONER OF INCOMETAX CIRCLE, SATNA

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

ITA 156/JAB/2024[2016-17]Status: DisposedITAT Jabalpur21 Aug 2025AY 2016-17

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2016-17 Sanjay Kumar Agarwal V. Acit Circle Satna Blooms Campus, Nh-75, Panna Aayakar Bhawan, Civil Road, Satna (Mp)-485001. Lines, Satna, Mp-485001. Tan/Pan:Ackpa2596H (Appellant) (Respondent) Appellant By: Shri Sanjay Mishra, Adv Respondent By: Shri N. M. Prasad, Sr. Dr-1 Date Of Hearing: 19 08 2025 Date Of Pronouncement: 21 08 2025 O R D E R

For Appellant: Shri Sanjay Mishra, AdvFor Respondent: Shri N. M. Prasad, Sr. Dr-1
Section 10(38)Section 143(3)Section 144BSection 147Section 148Section 250Section 68

disallowing interest Rs.42,16,333/- on loans and advances given by the assessee.” 2. Apropos to the grounds of appeal, the Ld. Counsel for the assessee reiterated the contents of written submissions for the sake of clarity the written submission of the assessee is reproduced as under: - “The Appellant respectfully submits the present appeal against the order dated 12.02.2025 passed

INCOME TAX OFFICER,WARD 1(1), JABALPUR vs. SHRI DEEPAK SINGH BANAFER, JABALPUR

In the result, the Revenue’s appeal is allowed on the aforesaid terms

ITA 92/JAB/2019[2014-15]Status: DisposedITAT Jabalpur11 Jan 2023AY 2014-15

Bench: Shri Sanjay Arora, Hon’Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Sh. L.L. Sharma, AdvocateFor Respondent: Sh. Shiv Kumar, Sr. DR
Section 131Section 143(3)Section 147Section 148(1)Section 54B

148(1) was issued on 31/01/2018, to which the assessee responded by filing a return on 02/7/2018 declaring income at Rs. 33,420, which was other than by way of capital gain. The non-returning of capital gain on the said sale was 1 | P a g e ITO v. Deepak Singh Banafer on the basis of the subject land

PRATHMIK KRISHI SAKH SAHAKARI SAMITI MARYADIT ,JERATH vs. INCOMETAX OFFICER WARD , NARSINGHPUR

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

ITA 151/JAB/2024[2019-20]Status: DisposedITAT Jabalpur30 Jun 2025AY 2019-20

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2019-20 Prathmik Krishi Sakh V. Ito Ward Narsinghpur Sahakari Samiti Maryadit Income Tax Office, Jerath Trimurti Nagar, Housing Gram Jerath, Pathariya, Board Colony, Damoh-470661. Narsinghpur-487001. Pan:Aabap7893E (Appellant) (Respondent) Appellant By: Shri Sapan Usrethe, Adv Respondent By: Shri Alok Bhura, Sr Dr Date Of Hearing: 20 05 2025 Date Of Pronouncement: 30 06 2025 O R D E R

For Appellant: Shri Sapan Usrethe, AdvFor Respondent: Shri Alok Bhura, Sr DR
Section 119(2)(b)Section 144BSection 147Section 148Section 151(1)Section 250Section 80P

section 119(2)(b) is pending.” 2. The facts of the case are that the Assessing Officer received information through ITBA software that the assessee had made cash deposits of Rs.5,89,76,696/-; made contract payments of Rs.1,40,392/-; made commission payments of Rs.3,88,381/- and received interest of Rs.12,695/- but not filed any income

M/S BINDRA WAREHOUSING CORPORATION vs. INCOME TAX OFFICER WARD 1(1),

In the result, the assessee’s appeal is allowed

ITA 153/JAB/2016[2008-09]Status: DisposedITAT Jabalpur30 Sept 2021AY 2008-09

Bench: Sh. Sanjay Arora, Hon'Bleassessment Year : 2008-09 Bindra Warehousing Income Tax Officer, Vs. Ward-1(1), Corporation, Itarsi

Section 143(3)Section 147Section 148Section 44ASection 80Section 80I

disallowing the claim of depreciation and imposing the tax on the same which is neither correct nor justified therefore same is liable to be deleted. However, prior to arguing the same, the ld. Counsel for the assessee, Shri Mishra, would plead for admission of legal Grounds (Gds. 3 & 4), reading as under, also praying for their adjudication first inasmuch

SAURABH SINGHAI L/H LATE SHRI MAHENDRA KUMAR JAIN,SAGAR vs. INCOME TAX OFFICER-3 SAGAR, SAGAR

In the result, the assessee‟s appeal is dismissed

ITA 5/JAB/2019[2010-11]Status: DisposedITAT Jabalpur29 Jul 2022AY 2010-11

Bench: Sh. Sanjay Arora, Hon'Ble & Sh. Manomohan Das, Hon‟Ble

Section 139Section 143(3)Section 147Section 148(1)Section 263

148(1) and u/s. 263, held as under: „Unlike the power of reopening an assessment under section 147 of the Act, the power of revision under section 263 is not contingent on the giving of a notice to show cause. In fact, section 263 has been understood not to require any specific show-cause notice to be served

VARSMA ENGINEERS GROUP,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), JABALPUR

In the result, the assessee’s appeal is allowed

ITA 224/JAB/2018[2008-09]Status: DisposedITAT Jabalpur22 Oct 2021AY 2008-09

Bench: Sh. Sanjay Arora, Hon'Bleassessment Year: 2008-09 Varhsma Engineer’S Group, Assistant Commissioner Of Vs. Income Tax, Vijay Nagar, Circle – 1(1), Jabalpur (M.P.) Jabalpur (M.P.) [Pan: Aaefv 7885Q] (Appellant) (Respondent) Appellant By Sh. H.S. Modh Adv. Respondent By Smt. Swati Agarwal, Sr. Dr Date Of Hearing 12/10/2021 Date Of Pronouncement 22/10/2021

Section 143(3)Section 147Section 148(1)Section 184Section 40

148(1) was issued on 29.7.2013, and its’ income reassessed at Rs.12,81,445 (Rs.12,81,450) by disallowing interest (Rs.1,98,930) 1 Varhsma Engineers’ Group v. Asst. CIT and remuneration (Rs. 4,62,705) to partners. It is the reopening of assessment as well as the disallowance on merits that is challenged in the instant appeal. The respective

KHANNA AUTOMOBILES REWA,REWA vs. INCOME TAX OFFICER, REWA

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

ITA 39/JAB/2024[2014-15]Status: DisposedITAT Jabalpur30 Jun 2025AY 2014-15

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2014-15 Khanna Automobiles V. Income Tax Officer 01 M/S Khanna Automobile, Ward-1 Bus Stand, Rewa, Madhya Income Tax Office, Kothi Pradesh-486001. Compound, Behind Customer Forum, Rewa- 486001. Pan:Aahfk4140J (Appellant) (Respondent) Appellant By: Shri Sapan Usrethe, Adv. Respondent By: Shri Alok Bhura, Sr. Cit(Dr) Date Of Hearing: 20 05 2025 Date Of Pronouncement: 30 06 2025 O R D E R

For Appellant: Shri Sapan Usrethe, AdvFor Respondent: Shri Alok Bhura, Sr. CIT(DR)
Section 143(2)Section 143(3)Section 147Section 148

148 of the Act. After assessment proceedings was conducted the Assessing Officer noticed that the assessee was required to disallow expenditure in terms of Section 14A of the Act as it had paid interest of Rs.2,04,615/- to partners and Rs.12,47,308/- to the bank. The assessee firm had earned exempt income, therefore, as per the Assessing Officer

SHRI DIGPAL JAISWAL,KATNI vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2, JABALPUR

In the result appeal of the assessee is allowed

ITA 83/JAB/2019[2011-12]Status: DisposedITAT Jabalpur30 Nov 2023AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. K P Dewani, AdvFor Respondent: Sh. Shravan Kumar Gotru, CIT-DR
Section 1Section 142(1)Section 143Section 143(3)Section 148Section 263Section 271(1)(b)Section 40

148 was issued for escapement of income for no disallowance made u/s 40(a)(ia) of I.T. Act 1961 for interest paid without deduction of tax at source at Rs.3,23,670/- to Shriram Finance Ltd. Query letter dated 06/05/2016 was issued to enquire details of interest paid at Rs.3,23,670/- and TDS thereupon. In the case of assessee

SHRI DIGPAL JAISWAL,KATNI vs. INCOME TAX OFFICER, WARD -1 , KATNI

In the result appeal of the assessee is allowed

ITA 42/JAB/2021[2011-12]Status: DisposedITAT Jabalpur30 Nov 2023AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. K P Dewani, AdvFor Respondent: Sh. Shravan Kumar Gotru, CIT-DR
Section 1Section 142(1)Section 143Section 143(3)Section 148Section 263Section 271(1)(b)Section 40

148 was issued for escapement of income for no disallowance made u/s 40(a)(ia) of I.T. Act 1961 for interest paid without deduction of tax at source at Rs.3,23,670/- to Shriram Finance Ltd. Query letter dated 06/05/2016 was issued to enquire details of interest paid at Rs.3,23,670/- and TDS thereupon. In the case of assessee

ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-CHHINDWARA, CHHINDWARA vs. SHRI SHEVENDRA SINGH PARIHAR, BALAGHAT

In the result, the appeal of the Revenue is dismissed

ITA 91/JAB/2019[2011-12]Status: HeardITAT Jabalpur01 Dec 2023AY 2011-12

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

148 of the I.T. Act on 01/03/2018 & 13/03/2018. The Assessing Officer issued notices u/s 142(1) along with questionnaire. The Assessing Officer made addition of Rs.89,72.239/- on account of bogus purchases shown in trading account, Rs.84,65,420/- on account of undisclosed receipts, Rs.89.38.780/- on account of unexplained cash deposits and Rs.14,265/- on account of unexplained interest. Aggrieved

NARENDRA AGRAWAL,JABALPUR vs. ITO-WARD 1 (2),, JABALPUR

In the result, the both the appeals filed by the assessee are allowed for statistical purposes

ITA 25/JAB/2023[2012-13]Status: DisposedITAT Jabalpur15 Sept 2023AY 2012-13

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadaleita No. 25 & 26/Jab/2023 (A.Y: 2012-13 & 2016-17) Narendra Agrawal, Vs. Ito, Ward 1(2), 932, Wright Town, Annexe Building, Jabalpur 482001, Aayakar Bhavan, Madhyapradesh. Jabalpur, Madhyapradesh. Pan/Gir No. : Adopa3476D Appellant .. Respondent Appellant By : Shri.Sapanusrethe, Adv.Ar Respondentby : Shri.Shiv Kumar.Sr. Dr Date Of Hearing 14.09.2023 Date Of Pronouncement 15.09.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: These Two Appeals Are Filed By The Assessee Against The Different Orders Of The National Faceless Appeal Centre, Delhi / Cit(A) & Passed The Order U/Sec 250 Of The Act.

For Appellant: Shri.SapanUsrethe, Adv.ARFor Respondent: Shri.Shiv Kumar.Sr. DR
Section 142(1)Section 144Section 148Section 154Section 43B

Section 43B. Since, the said challans go to the root of the matter and is the most crucial evidence involved in the case, it is humbly requested before the Hon'ble Bench to accept Additional evidence under Rule 29 of the Income Tax Act. 4. The appellant craves for leave to amend, add to or omit any ground

SHRI. NARSINGH RANGA,JABALPUR vs. DCIT, CIRCLE 2(1), JABALPUR

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

ITA 10/JAB/2025[2016-17]Status: DisposedITAT Jabalpur11 Jun 2025AY 2016-17

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2016-17 Shri Narsingh Ranga Dcit, Circle-2(1) V. Sharda Chowk, Nagpur Road, Aaykar Bhawan, Napier Jabalpur, Madhya Pradesh- Town, Jabalpur, Madhya 482001. Pradesh-482001. Pan:Acmpr1917P (Appellant) (Respondent) Appellant By: Shri Sanjay Seth, Ca Respondent By: Shri Alok Bhura, Sr. Cit(Dr) Date Of Hearing: 21 05 2025 Date Of Pronouncement: 11 06 2025 O R D E R

For Appellant: Shri Sanjay Seth, CAFor Respondent: Shri Alok Bhura, Sr. CIT(DR)
Section 147Section 148Section 54Section 54F

1. That on the facts and in the circumstances of case the addition made is patently wrong and unwarranted. That the addition of Rs. 2,28,36,750/- made by AO is not correct as the assessee has invested the amount of sale proceed of Rs. 2,64,20,000/- within the period of 3 years from the date