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33 results for “disallowance”+ Reopening of Assessmentclear

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Key Topics

Section 14735Section 143(3)34Section 25032Addition to Income17Section 14813Deduction12Disallowance10Section 379TDS9Section 143(2)

M/S MANISH FINLEASE (P) LTD,PATNA vs. ITO, WARD-2(1), PATNA

ITA 25/PAT/2019[2010-11]Status: DisposedITAT Patna09 Aug 2019AY 2010-11

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahuassessment Year : 2010-2011 Manish Finlease Pvt Ltd., Vs. Ito, Ward 2(1), Patna Chandi House Exhibition Road, Patna Pan/Gir No.Aaccm 6252 B (Appellant) .. ( Respondent) Assessee By : Shri A.K.Rastogi & Rakesh Kumar, Ars Revenue By : Shri Indrajeet Singh, Dr Date Of Hearing : 20/06/ 2019 Date Of Pronouncement : 09/08/ 2019 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Cit(A)-1, Patna Dated 27.9.2018 For The Assessment Year 2010-2011. 2. The Appeal Filed By The Assessee Is Delayed By 51 Days. The Assessee Has Filed Application For Condonation Of Delay Stating The Reasons For Not Filing The Appeal In Time Before The Tribunal. After Hearing The Submissions Of The Parties, We Are Satisfied That The Assessee Had A Bonafide Reason For Not Filing The Appeal In Time. Therefore, We Condone The Delay & Proceed To Decide The Appeal Of The Assessee On Merits.

For Appellant: Shri A.K.Rastogi & Rakesh Kumar, ARsFor Respondent: Shri Indrajeet Singh, DR
Section 133(6)Section 143(2)Section 143(3)Section 147Section 148(1)Section 68

Showing 1–20 of 33 · Page 1 of 2

6
Section 1446
Section 80I6

disallowances. Subsequently, the Assessing Officer issued a notice under section 148 and reopened the assessment P a g e 10 | 71 Assessment

PUNRASAR JUTE PARK LIMITED,PURNEA vs. CIT, PURNEA

In the result, the appeal of the assessee is allowed

ITA 432/PAT/2024[2015-16]Status: DisposedITAT Patna05 Sept 2024AY 2015-16

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 142(2)Section 143(1)Section 143(3)Section 147Section 148

reopening completed assessment, where in the previous assessment proceedings, the then Assessing Officer has applied his mind and taken a conscious decision in respect of time usage charge component and partly disallowed

BIHAR STATE ROAD DEVELOPMENT CORPN.LTD.,PATNA vs. CIT (APPEAL), DELHI

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

ITA 335/PAT/2024[2018-19]Status: DisposedITAT Patna24 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

BIHAR STATE ROAD DEVELOPMENT CORPORATION LTD,PATNA vs. ACIT, CIR-2, P)ATNA

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

ITA 333/PAT/2024[2014-15]Status: DisposedITAT Patna24 Jul 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ITO WARD 2(1) PATNA, PATNA

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

ITA 330/PAT/2024[2012-13]Status: DisposedITAT Patna24 Jul 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ACIT, COR-2, PATNA

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

ITA 334/PAT/2024[2017-18]Status: DisposedITAT Patna24 Jul 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

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

ITA 331/PAT/2024[2013-14]Status: DisposedITAT Patna24 Jul 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

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

ITA 332/PAT/2024[2014-15]Status: DisposedITAT Patna24 Jul 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

KISHORI CAPITAL MARKETS PVT. LTD.,BBD BAGH (EAST) vs. ITO WARD 2(1), PATNA, LOK NAYAK BHAWAN

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

ITA 249/PAT/2023[2015-16]Status: DisposedITAT Patna06 Nov 2024AY 2015-16

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

Section 143(2)Section 143(3)Section 147Section 148Section 14ASection 250

disallowance of Rs. 2,05,14,580/- has been dismissed but allowed the appeal of the assessee by allowing the credit for pre-assessment taxes paid and accordingly, the appeal has been dismissed. Being aggrieved and dissatisfied with the impugned order, the present appeal has been preferred. 1.1. The ld. Counsel for the assessee challenges the impugned order on various

BIJAY KUMAR SARAF,DALDALI BAZAR, MUZAFFARPUR vs. DC/AC CIRCLE 1,MUZFFARPUR, IT-OFFICE, POLICE LINE, SIKANDERPUR MUZZAFFARPUR

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

ITA 205/PAT/2025[2014-15]Status: DisposedITAT Patna30 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(3)Section 147Section 148Section 194(7)Section 194C(6)Section 250

reopened and the Assessing Officer (“the Ld. AO”) issued a notice u/s 148, in response to ITA No.: 205/PAT/2025 Assessment Year: 2014-15 Bijay Kumar Saraf. which, the assessee did not file any return of income. Since no compliance was made to the notice issued in the course of reassessment proceedings, the Ld. AO disallowed

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

ITA 63/PAT/2021[2017-18]Status: DisposedITAT Patna30 Aug 2023AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 132Section 153Section 153C

disallowance can be made in relation to that assessment year in exercise of powers under section 153A of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur (supra). Besides, as rightly pointed

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

ITA 62/PAT/2021[2016-17]Status: DisposedITAT Patna30 Aug 2023AY 2016-17

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 132Section 153Section 153C

disallowance can be made in relation to that assessment year in exercise of powers under section 153A of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur (supra). Besides, as rightly pointed

ACIT, CENTRAL CIRCLE-1, PATNA vs. SONAMOTI AGROTECH PVT LTD, PATNA

ITA 110/PAT/2019[2012-13]Status: DisposedITAT Patna23 Feb 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 132Section 143(2)Section 153ASection 68

disallowance can be made in relation to that assessment year in exercise of powers under section 153A of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur (supra). Besides, as rightly pointed

SHEKHAR NARAYAN,PATNA vs. NFAC, DELHI

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

ITA 354/PAT/2025[2017-18]Status: DisposedITAT Patna29 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 13Section 194Section 194JSection 250Section 44A

reopening the assessment for AY 2017-18 being Salary income offered as income from business and profession. After considering all the facts of the case and submission of the assessee, the Ld. AO treated ₹14,82,260/- as salary income received from the employer for AY 2017-18 and rejected the bogus expenses claimed at ₹7,32,030/- since

SHEKHAR NARAYAN,PATNA vs. NFAC, DELHI

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

ITA 355/PAT/2025[2018-19]Status: DisposedITAT Patna29 Jan 2026AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 13Section 194Section 194JSection 250Section 44A

reopening the assessment for AY 2017-18 being Salary income offered as income from business and profession. After considering all the facts of the case and submission of the assessee, the Ld. AO treated ₹14,82,260/- as salary income received from the employer for AY 2017-18 and rejected the bogus expenses claimed at ₹7,32,030/- since

ARUN CONSTRUCTION,BHAGALPUR vs. ACIT, CIRCLE-1, BHAGALPUR

In the result, all the appeals (ITA Nos

ITA 314/PAT/2018[2009-10]Status: DisposedITAT Patna12 Aug 2022AY 2009-10
Section 143(3)Section 144Section 145(3)Section 147Section 250(6)Section 40Section 747

disallowance of Rs. 13,33,8051- as sustained by the Assessing Officer on account of salary and interest payable to the partner is arbitrary, unjustified, void ab-initio and bad in law. The addition as sustained is fit to be deleted. 4. For that the appellant reserves its right to file detailed submission at the time of hearing

ARUN CONSTRUCTION,BHAGALPUR vs. ACIT, CIRCLE-1, BHAGALPUR

In the result, all the appeals (ITA Nos

ITA 315/PAT/2018[2009-10]Status: DisposedITAT Patna12 Aug 2022AY 2009-10
Section 143(3)Section 144Section 145(3)Section 147Section 250(6)Section 40Section 747

disallowance of Rs. 13,33,8051- as sustained by the Assessing Officer on account of salary and interest payable to the partner is arbitrary, unjustified, void ab-initio and bad in law. The addition as sustained is fit to be deleted. 4. For that the appellant reserves its right to file detailed submission at the time of hearing

PAVAN KUMAR BHAGAT,SAHARSA vs. ITO, WARD-3(4), SAHARSA, SAHARA

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

ITA 281/PAT/2024[2017-18]Status: DisposedITAT Patna02 Sept 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 144Section 147Section 148Section 250Section 37Section 69A

disallowing and adding Rs.11,65,739 claimed as commission expenses by the appellant, solely on the ground that the said deduction is not allowable in view of violation of provision of section 194G of the Act and section 40(a)(ia) of the Act, without considering the fact that the commission have been paid genuinely and through banking mode

ZAIMUR RAHMAN,EAST CHAMPARAN vs. INCOME TAX DEPARTMENT, NFAC, DELHI

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

ITA 321/PAT/2025[2015-16]Status: DisposedITAT Patna07 Oct 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144BSection 147Section 148Section 149Section 250Section 68Section 69A

disallowed and added to the total income of the appellant as income from other sources. 12. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer, without giving any opportunity, much less sufficient opportunity, has erred in holding that the appellant had sold immovable property for Rs.33,20,000 and taxed the same under

ANIL KUMAR,NALANDA vs. ITO, WARD- 2 (3), BIHARSHARIF

In the result, the appeal of the assessee is allowed

ITA 361/PAT/2023[2014-15]Status: DisposedITAT Patna03 Oct 2024AY 2014-15

Bench: Shri Rajpal Yadav & Shri Dr. Manish Boradi.T.A. No. 361/Pat/2023 Assessment Year: 2014-15 Anil Kumar National Faceless Assessment Centre M/S Raj Trading Company, Nfac, Delhi Harnaut, Nalanda, Patna-803110 Vs Bihar [Pan : Azopc268H] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

For Appellant: Shri AK Rastogi, Sr. AdvFor Respondent: Shri Ashwani Kumar, Sr. DR
Section 144BSection 147Section 194JSection 40

reopening of assessment. 6. For that the Ld. CIT(A) has erred in relying on judgments for upholding the initiation of proceedings u/s 147/148 that too without confronting the appellant with the same. 7. For that the Ld. CIT(A) has erred in holding that there has been escapement to the extent of Rs. 1,44,000/- in the original