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20 results for “disallowance”+ Section 151Aclear

Sorted by relevance

Mumbai64Jaipur20Ahmedabad19Delhi15Hyderabad12Pune11Chandigarh10Lucknow5Visakhapatnam5Rajkot4Chennai4Raipur4Kolkata3Surat3Agra1Indore1Bangalore1Nagpur1

Key Topics

Section 14830Section 14729Section 143(3)14Addition to Income13Section 148A11Section 688Natural Justice6Section 144B5Reopening of Assessment5

SH. KAPIL TANEJA,JAIPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 578/JPR/2025[2017-18]Status: DisposedITAT Jaipur11 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Gorav Avasthi, JCIT
Section 144BSection 147Section 148Section 148ASection 151ASection 69A

151A of the Act and the same deserves to be quashed and set aside. In view of above, it is submitted that initiation of re assessment proceedings is not in accordance with law as notices u/s 148A and 148 as well as order u/s 148A(d) have been passed by JAO instead of FAO, which is not in accordance with

Limitation/Time-bar5
Section 69A4
Section 2504

SH. MUKUT BEHARI AGARWAL,JAIPUR vs. THE DCIT, CIRCLE 1, JAIPUR

In the result, the appeals of the assessee is allowed as indicated hereinabove

ITA 1067/JPR/2024[2015-2016]Status: DisposedITAT Jaipur28 Nov 2024AY 2015-2016

Bench: DR. S. SEETHA LAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Ms. Alka Gautam CIT-DR
Section 143(3)Section 144BSection 147Section 148Section 149Section 69A

disallowances. In this case, it is noted that assessment has been reopened on the basis of information received by AO from the Investigation Wing under the Project Falcon regarding claim of fictitious losses being generated through coordinated and premeditated trading in illiquid stock options, wherein it had been noticed by the department that there are several instances/internal alerts wherein

INCOME TAX OFFICER, WARD-1(2), JAIPUR, JAIPUR vs. MUKESH KUMAR SONI, JAIPUR

In the result appeal of the revenue is dismissed and the cross

ITA 656/JPR/2023[2018-19]Status: DisposedITAT Jaipur04 Mar 2024AY 2018-19

Bench: Moving Towards The Facts Of The Case We Would Like To Mention

For Appellant: Sh. S. B. Natani (FCA)For Respondent: Sh. Arvind Kumar (CIT)
Section 143(1)Section 143(3)Section 144BSection 147Section 148A

151A and CBDT Notification dated 29.03.222 are Quoted/scanned below- (i) Section 144B(5) “144B. 6[(1) Notwithstanding anything to the contrary contained in any other provision of this Act, the assessment, reassessment or recomputation under sub-section (3) of section 143 or under section 144 or under section 147, as the case may be, with respect to the cases referred

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 818/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

151A of the Act and the\nsame deserves to be quashed and set aside. It is thus prayed that the\nconsequential order passed u/s 147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 819/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

151A of the Act and the\nsame deserves to be quashed and set aside. It is thus prayed that the\nconsequential order passed u/s 147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

151A of the Act and the\nsame deserves to be quashed and set aside. It is thus prayed that the\nconsequential order passed u/s 147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 816/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

151A of the Act and the\nsame deserves to be quashed and set aside. It is thus prayed that the\nconsequential order passed u/s 147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMSSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 817/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Jul 2025AY 2016-17
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

151A of the Act and the\nsame deserves to be quashed and set aside. It is thus prayed that the\nconsequential order passed u/s 147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that

KATRATHAL GRAM SEWA SAHKARI SAMITI LIMITED ,KATRATHAL vs. ITO WARD 1 SIKAR, SIKAR

ITA 1001/JPR/2025[2019-20]Status: DisposedITAT Jaipur27 Oct 2025AY 2019-20
For Appellant: Sh. Shrawan Kumar Gupta, Adv.\rFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT\r
Section 139(1)Section 143(2)Section 144BSection 147Section 147rSection 148Section 148ASection 151Section 234ASection 250

disallowance of the deduction under Section 80P was not justified solely because the return was filed belatedly. Referring to various judicial precedents and circulars, it was noted that the provisions of Section 80AC, as amended from time to time, and the applicability of Section 143(1)(a)(v) did not support the denial of deduction in this case, especially considering

RADHAKISHAN BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

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

ITA 695/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Sept 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

151A, to impart greater efficiency, transparency and accountability by applying artificial intelligence, technological innovations, etc., but as of now, from a careful reading of the notification dated 29.03.2022, along with the statutory provisions, we find that the aforesaid notification does not cover a case where notice under Section 148 is issued by the Jurisdictional Assessing Officer (JAO) the information received

RADHAKISHNA BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

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

ITA 694/JPR/2025[2015-16]Status: DisposedITAT Jaipur10 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

151A, to impart greater efficiency, transparency and accountability by applying artificial intelligence, technological innovations, etc., but as of now, from a careful reading of the notification dated 29.03.2022, along with the statutory provisions, we find that the aforesaid notification does not cover a case where notice under Section 148 is issued by the Jurisdictional Assessing Officer (JAO) the information received

DEPUTY COMMISSIONER OF INCOME TAX , JAIPUR vs. BHARAT SPUN PIPE AND CONSTRUCTION COMPANY, JAIPUR

In the result the appeal of the revenue in ITA no

ITA 360/JPR/2025[2017-18]Status: DisposedITAT Jaipur06 Aug 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Ms. Alka Gautam, (CIT) (V.C.)
Section 144BSection 147Section 148Section 153C

151A – Whether after introduction\nof 'Faceless Jurisdiction of Income-tax Authorities Scheme, 2022' and 'e-\nAssessment of Income Escaping Assessment Scheme, 2022' it became\nmandatory for revenue to conduct/initiate proceedings pertaining to reassessment\nunder sections 147, 148 and 148A in a faceless manner Held, yes - Whether\nsince in instant case impugned proceedings under section 148A as well as\nconsequential notice

DURGA PRASAD SHARMA,JAIPUR vs. I.T.O. WARD 1(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1038/JPR/2025[A.Y. 2018-19]Status: HeardITAT Jaipur20 Nov 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. G. M. Mehta, CAFor Respondent: Sh. Ghanshyam Meena, JCIT
Section 115BSection 148Section 2Section 69C

disallowed under section 69C despite banking transactions. The appellant also relied on certain decisions including CIT v. Sunrise ToolingSystems (2014) 361 ITR 206 (Del) and Pr. CIT v. Shapoorji Pallonji & Co. Ltd. (2020) 423 ITR 220 (Bom), which are distinguishable on facts. Those cases involved parties where the suppliers were traceable, transactions were verified, and books were not rejected

DY. COMMISSIONER OF INCOME TAX , JAIPUR vs. HEM CHAND JAIN, JAIPUR

In the result, appeal of the Revenue is dismissed and Cross Objection of the assessee is allowed

ITA 670/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT &
Section 147Section 148Section 148ASection 151Section 250

disallowance made by the Ld. AO deserves to be deleted. In view of the decisions on merit, the legal issues raised were not decided. 7 ITA No.670/JPR/2025 & CO No. 24/JPR/2025 Hem Chand Jain, Jaipur Submission:- 1. The assessee rely on detailed submission made before AO and Ld. CIT(A), NFAC and the decision of Ld. CIT(A), NFAC in deleting

RAGHAV COMMODITIES,JAIPUR vs. ITO WARD 6(2), JAIPUR

In the result, the appeal of the assessee is partly allowed as indicated

ITA 943/JPR/2024[2015-2016]Status: DisposedITAT Jaipur29 Nov 2024AY 2015-2016

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Arvind Kumar, CIT-DR
Section 142(1)Section 147Section 148Section 148A

disallowance of expenses or unrecorded expenses is not covered by the term ‘assets’ as defined explanation to section 149 of the Act as the explanation to section 149 stood as on the date of issue of notice u/s 148 which in the instants case is 21.04.2021. It is submitted that, CBDT through instruction u/s 119 dt. 10.12.2021, with regard

RSD CONTAINERS PRIVATE LIMITED,JAIPUR vs. ITO, WARD 7(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1320/JPR/2024[2017-18]Status: DisposedITAT Jaipur06 Aug 2025AY 2017-18
For Appellant: Shri Mukesh Khandelwal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr.-DR
Section 115BSection 147Section 148Section 149Section 151Section 151ASection 153CSection 68

151A of the Income tax Act, 1961. Therefore the whole proceedings are liable to be quashed. Reliance is placed on Hexaware 18 RSD Containers Pvt Ltd. vs ITO Technologies Ltd. v/s ACIT and others (464 ITR 430) (Mumbai HC) , Kairos Properties P Ltd. v/s ACIT and Others (241 DTR 97) (Mumbai HC) and Nava Diganta Builders and Others

RITU DHAKA,JAIPUR vs. ITO WD 4(4), JPR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 2/JPR/2025[2017-18]Status: DisposedITAT Jaipur01 Apr 2025AY 2017-18

Bench: Him. 2. In This Appeal, The Assessee Has Raised Following Grounds: -

For Appellant: Shri R.S. Poonia, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 143(3)Section 68

disallowances, the assessee would be given a fair opportunity to explain his position on the proposed additions/disallowances in accordance with the principle of natural justice. In this regard, the Assessing Officer shall issue an 10 Ritu Dhaka vs. ITO appropriate show-cause notice duly indicating the reasons for the proposed additions/disallowances along with necessary evidences/reasons forming the basis

M/S. SUMS EXIM PVT. LTD.,JAIPUR vs. ITO, JAIPUR

In the result, the appeal of the assessee is partly allowed

ITA 31/JPR/2017[2010-11]Status: DisposedITAT Jaipur24 Apr 2023AY 2010-11

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri B.P. Mundra, CAFor Respondent: Smt. Runi Pal, Addl. CIT

section 40A(3). Hence the ground of disallowance is bad in facts. B. Office Expenses Rs. 276966/- paper Book page no. 167 to 258. 1. Daily wages of Rs. 1,74,587 is paid to tiny workers and therefore on vouchers but the signatures of all labours are available. 2. Freight & Cartages of Rs. 52089/- vehicle number is available

ASHOK KUMAR JAIN,KOTA vs. ITO WD-2(1), KOTA, KOTA

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

ITA 1225/JPR/2024[2015-16]Status: DisposedITAT Jaipur18 Mar 2025AY 2015-16
For Appellant: Sh. Mahendra Gargieya, Adv.& Sh. Devang Gargieya, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 147Section 250Section 253(3)Section 5

151A of the Act. Hence proceedings as well\nas the impugned notice deserves to be quashed. Moreover, the assessment proceeding\nconsequent thereto also deserves to quashed.\n1. 3. The impugned additions and disallowances made in the order u/s 147 r.w.s 144 of the\nAct dated 01.03.2023 are bad in law and on facts of the case, for want of jurisdiction

SUNIL CHABLANI,AJMER, RAJASTHAN vs. CIRCLE (INTL TAX), JAIPUR, JAIPUR, RAJASTHAN

ITA 68/JPR/2024[2018-19]Status: DisposedITAT Jaipur22 Jul 2024AY 2018-19
For Appellant: Shri Mahendra Gargieya &For Respondent: \nShri Anil Dhaka (CIT-DR)
Section 144Section 144CSection 144C(5)Section 147Section 148Section 234A

151A r.w.s 144B of the Act,\nmandating for the Id. AO to complete the proceeding in faceless manner only as\nagainst done manually and hence, the same deserves to be quashed.\n“10. The Id. AO further erred in law as well as on the facts of the case in imposing\ntax, surcharge, cess etc. as per provision of S.115BBE