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20 results for “disallowance”+ Section 164(2)clear

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Key Topics

Section 1124Section 143(3)21Section 153A15Addition to Income15Section 6812Section 14811Section 13210Section 234A9Section 143(1)8Survey u/s 133A

ECONOMIC EXPLOSIVES LIMITED,NAGPUR vs. NATIONAL E ASSESSMENT CENTRE, NEW DELHI

In the result, appeal for the assessment year 2018–19 filed by the assessee is partly allowed

ITA 242/NAG/2023[2018-19]Status: DisposedITAT Nagpur09 Sept 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mani JainFor Respondent: Shri Kailash C. Kanojiya
Section 139Section 142(1)Section 143(2)

164), while dealing with the computation of book profit under section 115J of the Act held that a particular receipt, which is admittedly not an income, cannot be brought to tax under the deeming provisions of section 115J of the Act, as it defines the basic intention behind introduction of the provisions of section 115J of the Act. The specific

ECONOMIC EXPLOSIVES LIMITED,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1 (2), NAGPUR

8
Deduction5
Disallowance4

In the result, appeal for the assessment year 2018–19 filed by the assessee is partly allowed

ITA 177/NAG/2022[2017-18]Status: DisposedITAT Nagpur09 Sept 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mani JainFor Respondent: Shri Kailash C. Kanojiya
Section 139Section 142(1)Section 143(2)

164), while dealing with the computation of book profit under section 115J of the Act held that a particular receipt, which is admittedly not an income, cannot be brought to tax under the deeming provisions of section 115J of the Act, as it defines the basic intention behind introduction of the provisions of section 115J of the Act. The specific

VIDHARBHA KONKAN GRAMIN BANK ,NAGPUR vs. INCOME TAX OFFICER WARD 1(5) , NAGPUR

In the result, appeal filed by the assessee for A

ITA 7/NAG/2019[2014-15]Status: DisposedITAT Nagpur28 Nov 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri C. NareshFor Respondent: Shri Sandipkumar Salunke
Section 22Section 36(1)Section 36(1)(viia)Section 36(1)(viii)Section 80P

disallowed and added back to the total income. Penalty notice u/s 271(1) (c) is being issued separately. 6. Sections 22 and 32 of the Regional Rural Banks Act, 1976 provides as under:- 22. Regional Rural Bank to be deemed to be a cooperative society for purpose of the Income-tax Act, 1961.- For the purpose of the Income

VIDHARBHA KONKAN GRAMIN BANK ,NAGPUR vs. INCOME TAX OFFICER WARD 1(5) , NAGPUR

In the result, appeal filed by the assessee for A

ITA 8/NAG/2019[2015-2016]Status: DisposedITAT Nagpur28 Nov 2024AY 2015-2016

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri C. NareshFor Respondent: Shri Sandipkumar Salunke
Section 22Section 36(1)Section 36(1)(viia)Section 36(1)(viii)Section 80P

disallowed and added back to the total income. Penalty notice u/s 271(1) (c) is being issued separately. 6. Sections 22 and 32 of the Regional Rural Banks Act, 1976 provides as under:- 22. Regional Rural Bank to be deemed to be a cooperative society for purpose of the Income-tax Act, 1961.- For the purpose of the Income

DY. COMMISSIONER OF INCOME TAX- CENTRAL-CIRCLE-2(1), NAGPUR, NAGPUR vs. JAYMAHAKALI SHIKSHAN SANSTHA, WARDHA

In the result, Revenue’s appeal for A

ITA 336/NAG/2023[2018-19]Status: DisposedITAT Nagpur03 Apr 2025AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke
Section 11Section 12ASection 13(1)(c)Section 13(3)Section 132Section 133ASection 143(3)Section 164(2)Section 69A

disallowed the difference amount of ` 1,80,000, but also denied the assessee trust complete exemption claimed under the provisions of section 11 of the Act and accordingly brought to tax the entire surplus of trust of ` 5,07,32,612, as income taxable as per the provisions of section 164(2

DY. COMMISSIONER OF INCOME TAX- CENTRAL-CIRCLE-2(1), NAGPUR, NAGPUR vs. JAYMAHAKALI SHIKSHAN SANSTHA, WARDHA

In the result, Revenue’s appeal for A

ITA 335/NAG/2023[2017-18]Status: DisposedITAT Nagpur03 Apr 2025AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke
Section 11Section 12ASection 13(1)(c)Section 13(3)Section 132Section 133ASection 143(3)Section 164(2)Section 69A

disallowed the difference amount of ` 1,80,000, but also denied the assessee trust complete exemption claimed under the provisions of section 11 of the Act and accordingly brought to tax the entire surplus of trust of ` 5,07,32,612, as income taxable as per the provisions of section 164(2

DY. COMMISSIONER OF INCOME TAX- CENTRAL-CIRCLE-2 (1), NAGPUR, NAGPUR vs. JAYMAHAKALI SHIKSHAN SANSTHA, WARDHA

In the result, Revenue’s appeal for A

ITA 337/NAG/2023[2019-20]Status: DisposedITAT Nagpur03 Apr 2025AY 2019-20

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke
Section 11Section 12ASection 13(1)(c)Section 13(3)Section 132Section 133ASection 143(3)Section 164(2)Section 69A

disallowed the difference amount of ` 1,80,000, but also denied the assessee trust complete exemption claimed under the provisions of section 11 of the Act and accordingly brought to tax the entire surplus of trust of ` 5,07,32,612, as income taxable as per the provisions of section 164(2

DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCEL-1(2, NAGPUR vs. M/S. VIBRANT GLOBAL CAPITAL LTD., MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 229/NAG/2022[2014-15]Status: DisposedITAT Nagpur25 Oct 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Sandipkumar Salunke
Section 143(3)Section 14ASection 68

disallowance made under section 14A of the Act. The assessee 3 M/s. Vibrant Global Capital Ltd. ITA no.229/Nag./2022 has not preferred any appeal against the addition upheld by learned CIT(A). The Revenue has preferred appeal in respect to additions deleted in the appeal of the assessee and are enumerated in the grounds of appeal reproduced above

CHANDRAKUMAR MADHUSUDANJI JAJODIA,THANE vs. ASSISTANT COMMISSIONER OF INCOME TAX, AMRAVATI CIRCLE

In the result, appeal filed by the assessee is allowed

ITA 399/NAG/2023[2013-14]Status: DisposedITAT Nagpur28 Nov 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Abhay Y. Marathe
Section 143(2)Section 143(3)Section 144Section 148Section 234ASection 36(1)(iii)Section 68Section 69A

164 taxmann.com 764 (Guj.), wherein we find that the Hon’ble Gujarat High Court has concluded that when the repayment of loan is accepted by the Department in assessee’s case, the addition made under section 68 of the Act is unjustified and unsustainable. In the present case also, the loan amount has been repaid through proper banking channel along

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 57/NAG/2022[2014-15]Status: DisposedITAT Nagpur25 Feb 2025AY 2014-15
For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

disallowance of Rs. 3,10,478/-, which was made with respect to\ninterest and when the same has been confirmed by the ITAT, it cannot be said\nthat ITAT has committed any error and/or illegality, which calls for the\ninterference of this Court.\nIn paragraph 11, ITAT has observed and held as under:\n\"We have heard the rival submissions

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, NAGPUR, NAGPUR vs. MS GONDWANA ENGINEERS LIMITED, NAGPUR

In the result, the appeal of the Revenue is dismissed

ITA 387/NAG/2024[2015-16]Status: DisposedITAT Nagpur21 Mar 2025AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rachit ThakarFor Respondent: Shri Abhay Y. Marathe
Section 154Section 36

disallowance u/s.36(i)(va). 2. Any other grounds and fact to be raised at the time of hearing with the permission of Hon'ble ITAT.” 2 M/s. Gondwana Engineers Ltd. ITA no.387/Nag./2024 3. The tax effect is only ` 1,91,350, as against limit of ` 60 lakh. The learned Departmental Representative submitted that there is a Revenue Audit Objection

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

In the result, assessee' appeal for A

ITA 55/NAG/2022[2012-13]Status: DisposedITAT Nagpur25 Feb 2025AY 2012-13
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

disallowance of Rs. 3,10,478/-, which was made with respect to interest and when the same has been confirmed by the ITAT, it cannot be said that ITAT has committed any error and/or illegality, which calls for the interference of this Court. In paragraph 11, ITAT has observed and held as under: \"We have heard the rival submissions

RAVINDRA MADANLAL KHANDELWAL,AKOLA vs. DCIT/ACIT CIRCLE , AKOLA

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 375/NAG/2024[2018-19]Status: DisposedITAT Nagpur18 Nov 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke
Section 142(1)Section 143Section 144BSection 68

2,667 43 Shah Brothers 1,23,750 12,375 44 Sharad Makhanlal Agrawal HUF 15,334 1,534 45 Snehlata B Shah 1,21,667 12,167 46 Sukhdeo Sitaram 1,02,634 10,264 47 Sumit Traders 32,700 3,270 48 Tulsiram Goenka & Co 1,23,450 12,345 49 Tulsiram R Goenka

RAMKRUSHNA ZILBAJI THAKRE ,NAGPUR vs. INCOME TAX OFFICER , WRAD -4(4), NAGPUR

In the result, appeal of the assessee is allowed

ITA 207/NAG/2018[2010-11]Status: DisposedITAT Nagpur15 Jul 2022AY 2010-11
For Appellant: Dr. Milind Bhusare, AdvocateFor Respondent: Shri Vitthal M. Bhosale, Jt. CIT
Section 143(3)Section 147Section 148Section 234BSection 68

164 ITD 296(Mum) and ITO, Barabanki Vs. Kamal Jumar Mishra (2013) 33 taxmann.com 610(Lucknow) etc are discussed, considered and observed that: 9. After having gone through the facts and circumstances, we observe that credit in the ‘bank account’ of an assessee cannot be construed as a credit in the ‘books’ of the assessee, for the very reason that

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

In the result, assessee' appeal for A

ITA 58/NAG/2022[2015-16]Status: DisposedITAT Nagpur25 Feb 2025AY 2015-16
For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

disallowance of Rs. 3,10,478/-, which was made with respect to\ninterest and when the same has been confirmed by the ITAT, it cannot be said\nthat ITAT has committed any error and/or illegality, which calls for the\ninterference of this Court.\nIn paragraph 11, ITAT has observed and held as under:\n\"We have heard the rival submissions

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 54/NAG/2022[2011-12]Status: DisposedITAT Nagpur25 Feb 2025AY 2011-12
For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

disallowance of Rs. 3,10,478/-, which was made with respect to\ninterest and when the same has been confirmed by the ITAT, it cannot be said\nthat ITAT has committed any error and/or illegality, which calls for the\ninterference of this Court.\nIn paragraph 11, ITAT has observed and held as under:\n\"We have heard the rival submissions

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 56/NAG/2022[2013-14]Status: DisposedITAT Nagpur25 Feb 2025AY 2013-14
For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

disallowance of Rs. 3,10,478/-, which was made with respect to\ninterest and when the same has been confirmed by the ITAT, it cannot be said\nthat ITAT has committed any error and/or illegality, which calls for the\ninterference of this Court.\nIn paragraph 11, ITAT has observed and held as under:\n\"We have heard the rival submissions

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 59/NAG/2022[2017-18]Status: DisposedITAT Nagpur25 Feb 2025AY 2017-18
For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

disallowance of Rs. 3,10,478/-, which was made with respect to\ninterest and when the same has been confirmed by the ITAT, it cannot be said\nthat ITAT has committed any error and/or illegality, which calls for the\ninterference of this Court.\nIn paragraph 11, ITAT has observed and held as under:\n\"We have heard the rival submissions

SUNRISE STRUCTURALS & ENGINEERING PVT LTD,NAGPUR vs. ASSISTANT/ DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4 NAGPUR, NAGPUR

In the result, appeal filed by the assessee stands allowed

ITA 167/NAG/2025[2019-20]Status: DisposedITAT Nagpur10 Apr 2026AY 2019-20

Bench: Shri Pawan Singh & Shri Khettra Mohan Roysunrise Structural & Acit/Dcit, Circle-4, Engineering P. Ltd., A10, Vs Nagpur Hingna Midc, Nagpur (Urban), Nagpur-440016 Pan : Aaccs 3220 M Assessee Respondent Assessee By : Shri K.P. Dewani, Advocate Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 25.02.2026 Date Of Pronouncement : 10.04.2026 O R D E R

For Appellant: Shri K.P. Dewani, AdvocateFor Respondent: Shri Surjit Kumar Saha, Sr. DR
Section 115BSection 143(1)Section 147Section 148Section 148ASection 234BSection 250Section 69C

2) [Vol.-IV]. Detailed documentary evidence was placed on record on 09/03/2023 to explain the various observations made in the notice u/s 148A(a) of I.T. Act demonstrating genuineness and bonafides of purchase transaction (P- 3 to 7) [Vol.- IV). B) A.O. without verification and application of mind has issued notice u/s 148A(b) of I.T. Act 1961 on 10/03/2023

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

In the result, assessee' appeal for A

ITA 53/NAG/2022[2010-11]Status: DisposedITAT Nagpur25 Feb 2025AY 2010-11
For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

section 68 of the Income Tax Act,\n1961. Further, the AO did not find the explanation offered by the assessee\nsatisfactory and stated that the assessee has failed to discharge its onus\ntowards explaining the credit of Rs.15,00,000/-. We respectfully object to the\nabove observations and allegations made by the AO as the same are based on\nconjectures