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247 results for “disallowance”+ Section 154clear

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Key Topics

Section 15481Addition to Income71Section 143(3)70Section 143(1)67Section 26358Section 36(1)(va)56Disallowance48Section 153A42Section 6827Deduction

OM INFRA LIMITED,JAIPUR RAJASTHAN vs. DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR, RAJASTHAN

In the result, we find no substantial question of law being involved in this appeal

ITA 811/JPR/2023[2015-16]Status: DisposedITAT Jaipur31 Jul 2024AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. A. S. Nehra (Addl. CIT)
Section 115JSection 143(3)Section 154Section 80Section 801C(2)(b)Section 80I

disallowing the deduction is a matter of discussion and legal matter which cannot be rectified in order u/s 154. Thus it is debatable issue hence cannot be covered u/s 154 of I.T. Act, 1961. Section

Showing 1–20 of 247 · Page 1 of 13

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27
Section 1025
Rectification u/s 15418

ASSOCIATED SOAPSTONE DISTRIBUTING CO PRIVATE LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -2, JAIPUR, JAIPUR

ITA 243/JPR/2023[2018-19]Status: DisposedITAT Jaipur04 Mar 2024AY 2018-19
For Appellant: Shri Rohan Sogani, CAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 139(1)Section 143(2)Section 143(3)Section 14ASection 263Section 36(1)(ii)Section 37

disallow expenses as no exempt income was earned. Regarding the interest on delayed TDS, the Tribunal considered it compensatory and thus deductible, and the NFAC's view was plausible. For the excess MAT credit, the Tribunal found that rectifying the issue would fall under Section 154

DHABRIYA POLYWOOD LIMITED,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

ITA 78/JPR/2023[2015-16]Status: DisposedITAT Jaipur24 Jul 2023AY 2015-16

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

For Appellant: Shri Rajeev Sogani (C.A) &For Respondent: Ms. Runi Pal (Addl.CIT)
Section 143(3)Section 154

section 154…..” 6. Ld. A.O. while passing order u/s 154 disallowed the expenditure in relation to increase in authorized share

INCOME TAX OFFICER, JAIPUR vs. VINOD KUMAR JHARCHUR HUF, JAIPUR

In the result, the ground raised by the assessee in the application filed under rule 27

ITA 255/JPR/2021[2014-15]Status: DisposedITAT Jaipur18 Oct 2022AY 2014-15
For Appellant: Shri Nikhelesh KatariA-C.AFor Respondent: Ms. Monisha Choudhary -JCIT fu/kZkfjrh dh vksj ls@
Section 143(1)Section 143(3)Section 154Section 154(3)Section 24Section 44ASection 54Section 80C

section 154 without any mistake apparent from record and without providing opportunity of being heard 154 Disallowance of For that

M/S BALAJI CONSTRUCTION,AJMER vs. ACIT, CIRCLE-2, AJMER

In the result the appeal of the assessee is allowed

ITA 75/JPR/2022[2016-17]Status: DisposedITAT Jaipur16 Aug 2022AY 2016-17
For Appellant: NoneFor Respondent: Sh. A. S. Nehara, Add. CIT
Section 143(3)Section 154

154 of Act was not justified. As the income was assessed under section 143(3), no such disallowance under section

ADITYA CEMENT,BEHROR vs. ITO, BEHROR

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

ITA 1491/JPR/2024[2013-14]Status: DisposedITAT Jaipur13 May 2025AY 2013-14

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

For Appellant: Shri Anand Kumar Gupta, AdvFor Respondent: Mrs. Swapnil Parihar, JCIT-DR a
Section 143(3)Section 154Section 68Section 72(1)

section 154 on two counts, the first being disallowance of set off of brought forward business loss allowed in original

AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED,KOTA vs. DCIT/ACIT CIR-2, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

ITA 197/JPR/2025[2019-20]Status: DisposedITAT Jaipur12 Nov 2025AY 2019-20
For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT
Section 143(1)Section 234ASection 250Section 43B

154 w.r.t Intimation u/s 143(1) dt.\n04.10.2024.\n14-16\n5.\nCopy of at a glance chart showing working of disallowable Amount\nu/s 43B for AY 2019-20\n17\n6.\nCopy of Ledger Account of current liabilities in the books of the\nassessee for AY 2019-20.\n18\n7.\nCopy of Ledger Account of GST in the books of assessee

AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED, KOTA,KOTA vs. DCIT/ACIT CIR-2, KOTA, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

ITA 198/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT
Section 143(1)Section 234ASection 250Section 43B

154 w.r.t Intimation u/s 143(1) dt.\n04.10.2024.\n14-16\n5.\nCopy of at a glance chart showing working of disallowable Amount\nu/s 43B for AY 2019-20\n17\n6.\nCopy of Ledger Account of current liabilities in the books of\nassessee for AY 2019-20.\n18\n7.\nCopy of Ledger Account of GST in the books of assessee

AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED, KOTA,KOTA vs. DCIT/ACIT CIR-2, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

ITA 199/JPR/2025[2022-23]Status: DisposedITAT Jaipur12 Nov 2025AY 2022-23
For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT
Section 143(1)Section 234ASection 250Section 43B

154 w.r.t Intimation u/s 143(1) dt.\n04.10.2024.\n14-16\n5.\nCopy of at a glance chart showing working of disallowable Amount\nu/s 43B for AY 2019-20\n17\n6.\nCopy of Ledger Account of current liabilities in the books of the\nassessee for AY 2019-20.\n18\n7.\nCopy of Ledger Account of GST in the books of assessee

DYNAMIC POWERTECH PRIVATE LIMITED,JAIPUR vs. DCIT, CIRCLE 4, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 231/JPR/2025[2023-24]Status: DisposedITAT Jaipur08 May 2025AY 2023-24

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

For Appellant: Sh. Tarun Mittal, C.AFor Respondent: Sh. Arvind Kumar, CIT-DR
Section 154Section 250

disallowed the 6 Dynamic Powertech Pvt. Ltd. vs. DCIT assessee company's claim under Section 10AA and raised a demand of Rs.66,11,560/-. The appellant immediately filed a rectification request under Section 154

ASHOK SHARMA,KOTA vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-2 - KOTA, KOTA

ITA 359/JPR/2024[2014-2015]Status: DisposedITAT Jaipur29 Nov 2024AY 2014-2015
For Appellant: Shri Priyank Kabra (C.A.) (V.C.)For Respondent: Shri Anup Singh (Addl.CIT)
Section 143(3)Section 147Section 40A(3)

disallowance in\ncontravention to section 40A(3) of the Act. Here no estimation\ntheory was applied by the AO.”\nThus, on the same set of inputs (no fresh facts), first the estimation theory was\napplied and later in the reassessment proceedings no estimation theory was\napplied rather section 40A(3) was resorted. It is, therefore, quite evident that there\nwas

ASHA PANCHARYA,JAIPUR vs. ITO WARD 5(2), JAIPUR, JAIPUR

In the result, both the appeals of the assessee are allowed

ITA 15/JPR/2022[2018-2019]Status: DisposedITAT Jaipur24 Feb 2022AY 2018-2019
For Appellant: Shri G.M. Mehta, CAFor Respondent: Smt. Monisha Choudhary (JCIT)
Section 139(1)Section 143(1)Section 154Section 250Section 36(1)(va)Section 43B

disallowed if paid late as per period under respective laws of PF and ESI but paid on or before due date of filing Return of income u/s.139(1). 3. Ld. CIT was not justified in sustaining legality of rejection of application under section 154

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CENTRAL CIRCLE-4, JAIPUR , JAIPUR

In the result, the appeal of the assessee is allowed

ITA 96/JPR/2023[2017-18]Status: DisposedITAT Jaipur14 Jul 2023AY 2017-18

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

For Appellant: Shri Rajeev Sogani, CA &For Respondent: Shri A.S. Nehra, Addl.CIT
Section 143(1)Section 143(1)(a)Section 154Section 36(1)(va)

disallowable under section 37 (total of 7a to 7j)". 37 (total of 7a to 7j)". 9 VAIBHAV GLOBAL LTD VS DCIT, CIRCLE-4, JAIPUR 6. Therefore, the intimation issued u/s 143(1) dated 06.03.2019 and order u/s 154

SHAKTI MALT PVT. LTD.,JAIPUR vs. INCOME TAX OFFICER, WARD-4-2, JAIPUR

In the result, appeal of the assessee is allowed

ITA 172/JPR/2019[2012-13]Status: DisposedITAT Jaipur13 Oct 2020AY 2012-13

Bench: The Ld. Assessing Officer, During The Assessment Proceeding & Such Purchase Of Land Has No Relevance To Borrowed Funds.

For Appellant: NoneFor Respondent: Smt. Chanchal Meena (Addl. CIT)
Section 143(3)Section 154

section 154 of the IT Act for the assessment year 2012-13. The assessee has raised the following grounds :- “ 1. That in the facts and circumstances of the case, the order passed by learned Assessing Officer (Income-tax Officer, Ward- 4, Jaipur), u/s 154 of Income Tax Act, 1961 making disallowance

CAREER POINT LIMITED,KOTA, RAJASTHAN vs. PRINCIPAL COMMISSIONER OF INCOME TAX, UDAIPUR, RAJASTHAN

In the result, the appeal of the assessee is allowed

ITA 242/JPR/2023[2018-19]Status: DisposedITAT Jaipur22 Aug 2023AY 2018-19

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri Ajey Malik (CIT)
Section 143(2)Section 143(3)Section 14ASection 263

Section 10(38) on sale of “UTI TRANSPORTATION AND LOGISTICS FUND” which was purchased out of owned funds as assessee was having availability of ample of owned funds. So, no borrowing cost has been incurred towards purchase of this UTI TRANSPORTATION AND LOGISTICS 19 Career Point Limited, Kota. FUND. The ld PCIT proposed disallowance

K.P. AIRTECH,JAIPUR vs. DCIT, CIRCLE-6, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 42/JPR/2021[2019-20]Status: DisposedITAT Jaipur16 Aug 2021AY 2019-20
For Appellant: Shri Mukesh Khandelwal (C.A.)For Respondent: Miss. Monisha Choudhary (JCIT) a
Section 139(1)Section 143(1)Section 253(5)Section 36(1)(va)

154 cannot be taken in debatable issues as held by a large number of judicial rulings. Since the matter of allowance of employees contribution to welfare funds is highly debatable issue and hence such disallowance could not have been made u/s 143(1)(a) while processing the return u/s 143(1)(a). There are various High Courts including the jurisdictional

K.P. AIRTECH,JAIPUR vs. DCIT, CIRCLE-6, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 41/JPR/2021[2018-19]Status: DisposedITAT Jaipur16 Aug 2021AY 2018-19
For Appellant: Shri Mukesh Khandelwal (C.A.)For Respondent: Miss. Monisha Choudhary (JCIT) a
Section 139(1)Section 143(1)Section 253(5)Section 36(1)(va)

154 cannot be taken in debatable issues as held by a large number of judicial rulings. Since the matter of allowance of employees contribution to welfare funds is highly debatable issue and hence such disallowance could not have been made u/s 143(1)(a) while processing the return u/s 143(1)(a). There are various High Courts including the jurisdictional

M/S. MAHALAXMI SAWS PVT. LTD., H-39, ROAD NO.2B, RIICO INDUSTRIAL AREA, SIRSI ROAD, BINDAYAKA, JAIPUR,JAIPUR vs. INCOME TAX OFFICER WARD-4(2) JAIPUR, JAIPUR

In the result, this appeal of the assessee is allowed

ITA 280/JPR/2019[2012-13]Status: DisposedITAT Jaipur22 Feb 2022AY 2012-13
For Appellant: Shri Manish Agarwal (CA)For Respondent: Smt. Monisha Choudhary (JCIT)
Section 143(1)Section 143(2)Section 14ASection 68

disallowed the interest expenses. For ready reference, we reproduce Section 14A of the Act is as under: “[Expenditure incurred in relation to income not includible in total income. 14A. (1) For the purposes of computing the total income under this Chapter, no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income which does

LALIT KUMAR CHABRA,KOTA vs. ITO WARD 2(2), KOTA

In the result, both the appeals of the assessee are allowed

ITA 71/JPR/2022[2018-19]Status: DisposedITAT Jaipur06 May 2022AY 2018-19
For Appellant: Shri Vinod Kumar Gupta, CAFor Respondent: Smt. Monisha Choudhary, JCIT
Section 154

154 is bad in law and on the facts of the case, for want of jurisdiction and various other statutory reasons, and hence, the same may kindly be quashed and in any case, the impugned additions made there in are bad in law and on the facts Lalit Kumar Chabra, Kotavs. ITO, Kota for want of jurisdiction and various other

LALIT KUMAR CHABRA,KOTA vs. ITO WARD 2(2), KOTA

In the result, both the appeals of the assessee are allowed

ITA 72/JPR/2022[2019-20]Status: DisposedITAT Jaipur06 May 2022AY 2019-20
For Appellant: Shri Vinod Kumar Gupta, CAFor Respondent: Smt. Monisha Choudhary, JCIT
Section 154

154 is bad in law and on the facts of the case, for want of jurisdiction and various other statutory reasons, and hence, the same may kindly be quashed and in any case, the impugned additions made there in are bad in law and on the facts Lalit Kumar Chabra, Kotavs. ITO, Kota for want of jurisdiction and various other