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45 results for “disallowance”+ Section 747clear

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Key Topics

Section 14832Addition to Income25Section 143(3)20Section 14715Section 271(1)(c)15Section 14312Section 35D12Section 142(1)10Disallowance10Section 69

M/S. CHAMBAL FERTILIZERS AND CHEMICALS LIMITED,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA

In the result, appeal of the revenue is dismissed

ITA 744/JPR/2018[2014-15]Status: DisposedITAT Jaipur13 May 2022AY 2014-15
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

747/- should be allowed. 2. That the Ld. Commissioner of Income Tax, Circle-2, Kota erred in disallowing interest of Rs. 35,92,45,372/- in respect of borrowed funds alleged to be taken for investment made in the subsidiaries and the Ld. Commissioner of Income Tax (Appeals), Kota further erred in partially confirming the disallowance of interest

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. DCIT, KOTA

In the result, appeal of the revenue is dismissed

ITA 201/JPR/2017[2012-13]Status: DisposedITAT Jaipur

Showing 1–20 of 45 · Page 1 of 3

9
Deduction8
Unexplained Investment8
13 May 2022
AY 2012-13
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

747/- should be allowed. 2. That the Ld. Commissioner of Income Tax, Circle-2, Kota erred in disallowing interest of Rs. 35,92,45,372/- in respect of borrowed funds alleged to be taken for investment made in the subsidiaries and the Ld. Commissioner of Income Tax (Appeals), Kota further erred in partially confirming the disallowance of interest

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. ACIT, KOTA

In the result, appeal of the revenue is dismissed

ITA 291/JPR/2017[2013-14]Status: DisposedITAT Jaipur13 May 2022AY 2013-14
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

747/- should be allowed. 2. That the Ld. Commissioner of Income Tax, Circle-2, Kota erred in disallowing interest of Rs. 35,92,45,372/- in respect of borrowed funds alleged to be taken for investment made in the subsidiaries and the Ld. Commissioner of Income Tax (Appeals), Kota further erred in partially confirming the disallowance of interest

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

ITA 598/JPR/2024[2018-2019]Status: DisposedITAT Jaipur26 Dec 2024AY 2018-2019
For Appellant: Sh. Siddharth Ranka, AdvFor Respondent: \nSh. Saurav Harsh, Adv.&
Section 142(1)Section 143(2)Section 144oSection 14ASection 263Section 69

747-749] were again initiated vide notice dated 29.03.2024\nproposing to disallow the entire deduction u/s. 10AA. Detailed replies were filed\nby the assessee appellant, however, the Id. Assessing Officer vide its order\ndated 29.04.2024 [PB 750-762] has initiated the reassessment proceedings for\nthe assessment year 2017-2018 placing reliance upon the impugned order\npassed by the Id. PCIT

ROAD INFRASTRUCTURE DEVELOPMENT COMPANY OF RAJASTHAN LTD,,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-6, JAIPUR

ITA 669/JPR/2019[2012-13]Status: DisposedITAT Jaipur31 Jul 2020AY 2012-13
For Appellant: Shri P.P. Pareek (C.A.)For Respondent: Shri K.C. Gupta (JCIT)
Section 14ASection 244ASection 35D

section 14A of the I. T. Act read with the provisions of rule 8D and made disallowance u/s 14A of the Act. It was mentioned that no exempt income had been earned by the assessee. Therefore, determination of the amount at Rs. 20,67,741/- u/s 14A r.w.r. 8D of the Income Tax is not justified. We have also gone

ROAD INFRASTRUCTURE DEVELOPMENT COMPANY OF RAJASTHAN LTD,,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-6, JAIPUR

ITA 668/JPR/2019[2011-12]Status: DisposedITAT Jaipur31 Jul 2020AY 2011-12
For Appellant: Shri P.P. Pareek (C.A.)For Respondent: Shri K.C. Gupta (JCIT)
Section 14ASection 244ASection 35D

section 14A of the I. T. Act read with the provisions of rule 8D and made disallowance u/s 14A of the Act. It was mentioned that no exempt income had been earned by the assessee. Therefore, determination of the amount at Rs. 20,67,741/- u/s 14A r.w.r. 8D of the Income Tax is not justified. We have also gone

ROAD INFRASTRUCTURE DEVELOPMENT COMPANY OF RAJASTHAN LTD,,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-6, JAIPUR

ITA 670/JPR/2019[2013-14]Status: DisposedITAT Jaipur31 Jul 2020AY 2013-14
For Appellant: Shri P.P. Pareek (C.A.)For Respondent: Shri K.C. Gupta (JCIT)
Section 14ASection 244ASection 35D

section 14A of the I. T. Act read with the provisions of rule 8D and made disallowance u/s 14A of the Act. It was mentioned that no exempt income had been earned by the assessee. Therefore, determination of the amount at Rs. 20,67,741/- u/s 14A r.w.r. 8D of the Income Tax is not justified. We have also gone

MOHIT METALS PRIVATE LIMITED,BHIWADI vs. CIT (APPEALS), NFAC

In the result, both the appeals filed by the assessee are allowed

ITA 173/JPR/2022[2016-17]Status: DisposedITAT Jaipur14 Dec 2022AY 2016-17
For Appellant: Shri Praphull Mehta, CAFor Respondent: Mrs. Monisha Choudhary, JCIT
Section 147Section 40Section 69C

disallowance of Rs.18,000/- deserves to be deleted 3. That the ld. CIT(A) has erred in sustaining the addition of Rs.2,66,550/- made by AO u/s 69C of the I.T. Act, 1961 on the reason that the addition was made without any basis merely on conjectures and surmises. Accordingly, the impugned addition of Rs.2,66,550/- deserves

RAJASTHAN STATE GANGANAGAR SUGAR MILLS LIMITED,JAIPUR vs. ACIT, JAIPUR

In the result the appeal of the assessee is partly allowed

ITA 279/JPR/2024[2017-18]Status: DisposedITAT Jaipur08 May 2025AY 2017-18

Bench: Him The Assessment Order Passed By Acit, Circle-6, Jaipur [ For Short Ao ] U/S 143

For Appellant: Sh. Saurav Harsh, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143Section 145ASection 36(1)(va)

section 43B of the Income Tax Act if the payments were made before due date of filing of Return. We place reliance on following judgements :- CIT Vs. Aimi Lud. (3211TR508) (Delhi HC) CIT Vs. P.M. Electronics (3131TR161) (Delhi HC) CIT Vs. ANZ Information Technology Pvt. Ltd. (3181TR123) (Karnataka HC) CIT Vs. SBBJ (2014)) (365ITR 70) (Rajasthan HC) CIT VS. JVVNL

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. RAJASTHAN STATE GANGANAGAR SUGAR MILLS LIMITED, NEHRU SEHKAR BHAWAN, JAIPUR

In the result the appeal of the assessee is partly allowed

ITA 235/JPR/2024[2017-18]Status: DisposedITAT Jaipur08 May 2025AY 2017-18

Bench: Him The Assessment Order Passed By Acit, Circle-6, Jaipur [ For Short Ao ] U/S 143

For Appellant: Sh. Saurav Harsh, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143Section 145ASection 36(1)(va)

section 43B of the Income Tax Act if the payments were made before due date of filing of Return. We place reliance on following judgements :- CIT Vs. Aimi Lud. (3211TR508) (Delhi HC) CIT Vs. P.M. Electronics (3131TR161) (Delhi HC) CIT Vs. ANZ Information Technology Pvt. Ltd. (3181TR123) (Karnataka HC) CIT Vs. SBBJ (2014)) (365ITR 70) (Rajasthan HC) CIT VS. JVVNL

SHREE KRISHNA GAUSHALA,RAMGARH SHEKHAWATI SIKAR vs. INCOME TAX OFFICER (EXEMPTION), WARD-II JAIPUR

In the result, the appeal of the assessee is partly allowed for statistical purposes with no orders as to cost

ITA 399/JPR/2024[2012-2013]Status: DisposedITAT Jaipur04 Oct 2024AY 2012-2013

Bench: Hon’ble SHRI SANDEEP GOSAIN, JUDICIAL MEMBER vk;dj vihy la-@ITA No. 399/JP/2024 fu/kZkj.k o"kZ@Assessment Year : 2012-13 Shree Krishna Gaushala Ramgarh Shekhawati Sikar cuke Vs. The ITO (Exemption) Ward -II Sikar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAATS 5144H vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@Assessee by : Shri Saurv Harsh, Advocate jktLo dh vksj ls@Revenue by: Shri Gautam Singh Choudhary,JCIT-DR lquokbZ dh rkjh[k@Date of Hearing : 25/09/2024 mn?kks"k.kk

For Appellant: Shri Saurv Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR
Section 143(3)

disallowed. The total income is recomputed as below: As per receipts and payment account:- Receipts: 94,75,656/- Less opening balance: - 13,83,603/- Add income from Pratapeshwar Mahadev Mandir a/c: 1,30,747/- Add income from Nandini cow a/c: 1,21,000/- Add income from well a/c to the extent not included: 13,46,621/- Total receipts

SHRI SUNDER DAS SONKIA,JAIPUR vs. ITO, WARD 1(2), JAIPUR

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

ITA 1383/JPR/2019[2010-11]Status: DisposedITAT Jaipur18 Jan 2021AY 2010-11

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1383/Jp/2019 Assessment Year: 2010-11 Shri Sunder Das Sonkia, Cuke I.T.O., Vs. Sonkia Bhawan, Sms, Highway, Ward-1(2), Jaipur. Jaipur. Pan No.: Akhps 7413 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 09/Jp/2020 Assessment Year: 2010-11 I.T.O., Cuke Shri Sunder Das Sonkhiya, Vs. Ward-1(2), Prop.- M/S Naveen Jewellers, Jaipur. Sonkhiya Bhawan, Chaura Rasta, Jaipur. Pan No.: Akhps 7413 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri S.R. Sharma (Ca) & Shri Rajnikant Bhatra (Ca) Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 02/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 18/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeal Filed By The Assessee & The Cross Appeal Filed By The Revenue Arise Against The Order Of The Ld. Cit(A)-4, Jaipur Dated 08/11/2019 For The A.Y. 2010-11. The Grounds Taken By The Assessee & The Revenue Are As Under:

For Appellant: Shri S.R. Sharma (CA) &For Respondent: Smt. Rooni Paul (Addl.CIT)
Section 132Section 143Section 143(3)Section 145(3)Section 147Section 148

section 68. [Para 14]. It is true that the reasons recorded or the material available on record must have nexus to the subjective opinion formed by the Assessing Officer regarding the escapement of the income but then, while recording the reasons for belief formed, the Assessing Officer is not required to finally ascertain the factum of escapement

AJOY SHARMA,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

ITA 547/JPR/2024[2016-17]Status: DisposedITAT Jaipur22 Jul 2024AY 2016-17
For Appellant: Sh. Mahendra Gargieya, Adv. &For Respondent: Smt. Monisha Choudhary, Addl. CIT
Section 139(4)Section 147Section 148Section 271(1)(c)Section 274

747/-\nwas declared in the return filed, which was invalid return of income.\n6.3 The appellant has claimed that his wife was misguided by some unscrupulous\nelements who prepared the returns and made his wife invoke incorrect\ndeductions to claim the refunds. His wife was ignorant that these deductions were\nnot applicable to him and this process continued since appellant

AJOY SHARMA ,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

ITA 546/JPR/2024[2015-16]Status: DisposedITAT Jaipur22 Jul 2024AY 2015-16
For Appellant: Sh. Mahendra Gargieya, Adv. &For Respondent: Smt. Monisha Choudhary, Addl. CIT
Section 139(4)Section 147Section 148Section 271(1)(c)Section 274

747/-\nwas declared in the return filed, which was invalid return of income.\n6.3 The appellant has claimed that his wife was misguided by some unscrupulous\nelements who prepared the returns and made his wife invoke incorrect\ndeductions to claim the refunds. His wife was ignorant that these deductions were\nnot applicable to him and this process continued since appellant

AJOY SHARMA ,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

ITA 545/JPR/2024[2014-15]Status: DisposedITAT Jaipur22 Jul 2024AY 2014-15
For Appellant: Sh. Mahendra Gargieya, Adv. &For Respondent: Smt. Monisha Choudhary, Addl. CIT
Section 139(4)Section 147Section 148Section 271(1)(c)Section 274

747/-\nwas declared in the return filed, which was invalid return of income.\n6.3 The appellant has claimed that his wife was misguided by some unscrupulous\nelements who prepared the returns and made his wife invoke incorrect\ndeductions to claim the refunds. His wife was ignorant that these deductions were\nnot applicable to him and this process continued since appellant

AJOY SHARMA ,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

ITA 544/JPR/2024[2013-14]Status: DisposedITAT Jaipur22 Jul 2024AY 2013-14
For Appellant: Sh. Mahendra Gargieya, Adv. &For Respondent: Smt. Monisha Choudhary, Addl. CIT
Section 139(4)Section 147Section 148Section 271(1)(c)Section 274

747/-\nwas declared in the return filed, which was invalid return of income.\n6.3 The appellant has claimed that his wife was misguided by some unscrupulous\nelements who prepared the returns and made his wife invoke incorrect\ndeductions to claim the refunds. His wife was ignorant that these deductions were\nnot applicable to him and this process continued since appellant

AJOY SHARMA ,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

ITA 543/JPR/2024[2012-13]Status: DisposedITAT Jaipur22 Jul 2024AY 2012-13
For Appellant: Sh. Mahendra Gargieya, Adv. &For Respondent: Smt. Monisha Choudhary, Addl. CIT
Section 139(4)Section 147Section 148Section 271(1)(c)Section 274Section 80C

747/-\nwas declared in the return filed, which was invalid return of income.\n6.3 The appellant has claimed that his wife was misguided by some unscrupulous\nelements who prepared the returns and made his wife invoke incorrect\ndeductions to claim the refunds. His wife was ignorant that these deductions were\nnot applicable to him and this process continued since appellant

CHANDRA MOHAN BADAYA,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

ITA 422/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Nov 2024AY 2016-17
For Appellant: Shri S. L. GuptaFor Respondent: Shri Ajay Malik (CIT-DR)
Section 143Section 69

disallowing peak\ncredit theory by netting transaction in search record for cash loan taken\nand cash loan given and uphold the addition by own presumption\nmethod termed as incremental negative peak Rs 591812 and account of\nunexplained loan given u/s 69 Rs 2,76,00,000 without considering all\nfacts in seized documents.\n2.1 The Id CIT Appeal further erred

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR, JAIPUR vs. SUNDER DAS SONKIYA, JAIPUR

In the result, both appeals of the revenue are dismissed

ITA 453/JPR/2024[2012-13]Status: DisposedITAT Jaipur09 Oct 2024AY 2012-13
Section 132Section 143(1)Section 143(2)Section 148

section 145 (3) of the I. T. Act,\n1961 are hereby applicable as the books of accounts are not reliable, Therefore,\nthe Assessing Officer is directed to apply GP rate of 12% on total turnover of Rs.\n7,03,93,153/- which results in addition of Rs. 5,72,667/- (12% of Rs. 7,03,93,153\ndeclared and accepted

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

747/- escaped\nfrom assessment and assessee has not filed his return of income and therefore,\nnotice was issued as per provision of section 147/148 of the Act. Assessee has filed\nits Return of Income in response to that notice issued u/s 148 on 07/09/2022\ndeclaring income of Rs.78,750/-.\n6.1 Ld. AO issued required statutory notice along with the questionnaire