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20 results for “disallowance”+ Section 133(6)clear

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Mumbai1,274Delhi933Kolkata282Ahmedabad227Jaipur220Bangalore215Chennai170Surat106Indore105Chandigarh100Pune100Hyderabad94Raipur85Cochin75Rajkot58Visakhapatnam51Lucknow37Guwahati37Nagpur36Agra32Amritsar27Allahabad25Cuttack25Patna20SC16Ranchi16Dehradun10Jodhpur6Jabalpur4Panaji2A.K. SIKRI ROHINTON FALI NARIMAN1Varanasi1ANIL R. DAVE AMITAVA ROY L. NAGESWARA RAO1

Key Topics

Section 143(3)26Section 26325Section 80I24Addition to Income15Section 133(6)13Section 801A12Section 25011Section 40A(3)10Section 142(1)8Deduction

SRIRAM ENTERPRISES,BHAGALPUR vs. ASST COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1, PATNA, PATNA

ITA 607/PAT/2024[2021-2022]Status: DisposedITAT Patna13 Oct 2025AY 2021-2022
Section 143(2)Section 143(3)Section 250

sections": ["143(3)", "250", "133(6)", "142(1)"], "issues": "Whether disallowances made solely on the grounds that parties were non-filers

M/S PSP TRADING PVT LTD,PATNA vs. ITO, WARD- 2 (1), PATNA

In the result, the appeal of the assessee is allowed

ITA 121/PAT/2025[2018-19]Status: HeardITAT Patna09 Dec 2025AY 2018-19
Section 133(6)Section 139
6
Natural Justice6
Disallowance4
Section 147
Section 148
Section 37

sections": [ "37", "139", "147", "148", "133(6)", "143(1)", "147/1448" ], "issues": "Whether the purchases made from M/s Divine Alloys & Power Co. Ltd. were bogus and thus disallowable

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

133(6) of the Act to both the loan creditor companies to which sufficient compliance was made along with the documents asked for by the ld. Assessing Officer. In nutshell, genuineness of the unsecured loan received by the assessee during the relevant financial year stood examined by the ld. Assessing Officer in the assessment proceeding

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, PATNA, PATNA vs. SINCON INFRASTRUCTURE PRIVATE LIMITED, PATNA

In the result, the appeal of the Revenue is dismissed

ITA 212/PAT/2025[2021-22]Status: DisposedITAT Patna26 Aug 2025AY 2021-22
Section 115Section 133(6)Section 69C

section 133(6) of the Act, but only one party replied. Finally, the\nLearned AO treated the said purchases as unproved and\nunsubstantiated purchases and added the same to the income of the\nassessee.\n2.2. In the appellate proceedings, the Learned CIT (A) allowed the\nappeal of the assessee by observing that the assessee submitted all the\nevidences

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

ITA 359/PAT/2024[2020-21]Status: DisposedITAT Patna16 Oct 2024AY 2020-21

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

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

133(6) of the Act related to third party verification/ confirmation and that whether any independent inquiry has been conducted by the ld. Assessing Officer. 5. Ld. PCIT also referred to Explanation 2 to section 263 of the Act observing as under:- “12. In the instant case, it is borne out of facts that not only did the assessee fail

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL , PATNA

In the result, all the appeals of the assessee bearing

ITA 356/PAT/2024[2017-18]Status: DisposedITAT Patna16 Oct 2024AY 2017-18

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

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

133(6) of the Act related to third party verification/ confirmation and that whether any independent inquiry has been conducted by the ld. Assessing Officer. 5. Ld. PCIT also referred to Explanation 2 to section 263 of the Act observing as under:- “12. In the instant case, it is borne out of facts that not only did the assessee fail

GANADHIPATI CONSTRUCTION PVT LTD,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

ITA 357/PAT/2024[2018-19]Status: DisposedITAT Patna16 Oct 2024AY 2018-19

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

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

133(6) of the Act related to third party verification/ confirmation and that whether any independent inquiry has been conducted by the ld. Assessing Officer. 5. Ld. PCIT also referred to Explanation 2 to section 263 of the Act observing as under:- “12. In the instant case, it is borne out of facts that not only did the assessee fail

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

ITA 358/PAT/2024[2019-20]Status: DisposedITAT Patna16 Oct 2024AY 2019-20

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

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

133(6) of the Act related to third party verification/ confirmation and that whether any independent inquiry has been conducted by the ld. Assessing Officer. 5. Ld. PCIT also referred to Explanation 2 to section 263 of the Act observing as under:- “12. In the instant case, it is borne out of facts that not only did the assessee fail

GANADHIPATI CONSTRUCTION PRIVATE LTD,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

ITA 360/PAT/2024[2021-22]Status: DisposedITAT Patna16 Oct 2024AY 2021-22

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

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

133(6) of the Act related to third party verification/ confirmation and that whether any independent inquiry has been conducted by the ld. Assessing Officer. 5. Ld. PCIT also referred to Explanation 2 to section 263 of the Act observing as under:- “12. In the instant case, it is borne out of facts that not only did the assessee fail

I.T.O. vs. M/S KUMAR CONSTRUCLTION,

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

ITA 10/PAT/2015[2009-10]Status: DisposedITAT Patna17 Oct 2023AY 2009-10

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

Section 142(1)Section 143(2)Section 271(1)(b)Section 40A(3)

section 133(6). However, the cash book of the assessee made entry of the same amount as cash receipts. In response to the query during the assessment proceeding the assessee submitted as under: "Various cheques are issued in the name of working staff of the concern and taken in the cash book to meet various expenditure related to business. Hence

RAJENDRA AGRAWAL,BIROLI BAZAR vs. ITO WARD 3(1) PURNEA, PURNIA

The appeal of the assessee is allowed for statistical purposes

ITA 422/PAT/2024[2011-12]Status: DisposedITAT Patna30 Jan 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.422/Pat/2024 Assessment Year: 2011-12 Rajendra Agrawal.……………….....…..…………………....Appellant New Sipahi Tola, Maranga Road, Bihar – 85301. [Pan: Aqhpa2439E] Vs. Ito, Ward-3(1), Purnia....….…….…............................…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 27, 2025 Date Of Pronouncing The Order : January 30, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 29.02.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 18 Days In Filing The Present Appeal. The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delay Was Not Intentional. We, Therefore, Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Care Are That The Assessee Is An Individual & Is Engaged In Farming Activities. The Case Of The Assessee Was Reopened

Section 133(6)Section 143(2)Section 143(3)Section 147Section 249(2)Section 249(2)(c)Section 250

133(6) of the Act to circle officer in order to collect additional information about the agricultural land. In response, the assessee submitted land revenue receipt, land ownership certificate etc. but the assessee failed to furnish details of invoices or bills for fertilizers, pesticides and sale proceeds from agricultural produce. Due to lack of supporting documents and non-availability

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, PATNA, PATNA vs. YASHI FILMS PRIVATE LIMITED, PATNA

In the result, the appeal filed by the Revenue is dismissed

ITA 462/PAT/2024[2021-22]Status: DisposedITAT Patna28 Jan 2026AY 2021-22

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 194JSection 250

section 'professional and technical services.' The Ld. AO noted that, there was discrepancy in the reply of the assessee and the amount claimed in the profit and loss account and required further details; which were however, not filed. Therefore, professional and technical services expenses and society maintenance expenses were disallowed and the total income was assessed

DINA NATH YADAV,PATNA vs. ITO WARD - 4(2), PATNA

Appeal of the assessee is allowed for statistical purposes

ITA 303/PAT/2024[2016-17]Status: DisposedITAT Patna19 May 2025AY 2016-17

Bench: SHRI PRADIP KUAMR CHOUBEY, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 10(37)Section 131Section 133(6)Section 143(3)Section 194LSection 250Section 3ASection 96

133(6) of the Act revealed that the said land was within the municipal area even though the said land was agricultural in nature. Finally, it has been recorded that the Ld. AO issued summons u/s 131 of the Act to the District Land Acquisition Officer, Patna and his statement under oath was recorded. Through this statement, the said Officer

ITO, WARD-2(1), PATNA vs. M/S SUN COMTECH PVT LTD, PATNA

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

ITA 108/PAT/2020[2011-12]Status: DisposedITAT Patna24 Jun 2025AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115JSection 143(3)Section 148Section 250

133(6). The A.O. has not mentioned any variation or discrepancy between the copies of account as submitted by the appellant during the course of assessment proceedings and as provided by NSME, Ahmedabad. Thereafter while bringing on record and mentioning all these details and reproducing the same in the assessment order, the A.O. has concluded that the nature of intraday

SEEMA SRIVASTAVA,PATNA vs. ITO,DC/AC-6, PATNA, PATNA

In the result, the appeal is dismissed

ITA 715/PAT/2024[2017-18]Status: DisposedITAT Patna06 Jun 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 144Section 250Section 250(2)Section 48Section 54Section 54F

6. For that the Ld. CIT(A), NFAC has erred in ignoring the legislative intent behind provisions of sections 54 and 54F which are beneficial provisions promoting purchase/construction of residential houses, hence, liberal, pragmatic interpretation should be taken to the provisions and technical errors should not deprive assessee of legitimate claim of deduction/ exemption particularly in the light of circular

ITO, WARD-2(1), BEGUSARAI vs. SHRI PREM CHAND KESHRI, LAKHISARAI

In the result, the appeal filed by the Revenue is dismissed

ITA 99/PAT/2020[2015-16]Status: DisposedITAT Patna13 Jul 2023AY 2015-16

Bench: Sri Sanjay Garg & Sri Rajesh Kumar

Section 131Section 133Section 40A(3)

Section 40A(3) of the Act and submission made by AR of the assessee which revealed that the assessee has violated the provision in making the payment against the purchase of the goods only to the amount of Page 2 of 4 I.T.A. No.: 99/PAT/2020 Assessment Year: 2015-16 Shri Prem Chand Keshri. Rs. 150000/- as detailed above

DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 PATNA, PATNA vs. GANADHIPATI CONSTRUCTION PVT LTD, PATNA

In the result, all the appeals of the Revenue in ITA No

ITA 299/PAT/2023[2020-21]Status: DisposedITAT Patna15 Oct 2024AY 2020-21

Bench: Shri Rajpal Yadav & Dr. Manish Borad

For Appellant: Shri AK Rastogi, ARFor Respondent: Shri Rinku Singh, DR
Section 132Section 139Section 139(1)Section 153ASection 250Section 801ASection 80I

6. Aggrieved assessee preferred appeal before the ld. CIT (A) and submitted that in compliance to the return filed u/s 153A of the Act, assessee has submitted tax audit report u/s 44AB of the Act and also furnished audit report on form 10CCB for by claiming deduction u/s 80IA of the Act and has fulfilled all the conditions required

DY COMMISSIONER OF INCOME TAX, PATNA vs. GANADHIPATI CONSTRUCTION PVT LTD, PATNA

In the result, all the appeals of the Revenue in ITA No

ITA 298/PAT/2023[2019-20]Status: DisposedITAT Patna15 Oct 2024AY 2019-20

Bench: Shri Rajpal Yadav & Dr. Manish Borad

For Appellant: Shri AK Rastogi, ARFor Respondent: Shri Rinku Singh, DR
Section 132Section 139Section 139(1)Section 153ASection 250Section 801ASection 80I

6. Aggrieved assessee preferred appeal before the ld. CIT (A) and submitted that in compliance to the return filed u/s 153A of the Act, assessee has submitted tax audit report u/s 44AB of the Act and also furnished audit report on form 10CCB for by claiming deduction u/s 80IA of the Act and has fulfilled all the conditions required

DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1, PATNA, PATNA vs. GANADHIPATI CONSTRUCTION PVT LTD, PATNA

In the result, all the appeals of the Revenue in ITA No

ITA 297/PAT/2023[2018-19]Status: DisposedITAT Patna15 Oct 2024AY 2018-19

Bench: Shri Rajpal Yadav & Dr. Manish Borad

For Appellant: Shri AK Rastogi, ARFor Respondent: Shri Rinku Singh, DR
Section 132Section 139Section 139(1)Section 153ASection 250Section 801ASection 80I

6. Aggrieved assessee preferred appeal before the ld. CIT (A) and submitted that in compliance to the return filed u/s 153A of the Act, assessee has submitted tax audit report u/s 44AB of the Act and also furnished audit report on form 10CCB for by claiming deduction u/s 80IA of the Act and has fulfilled all the conditions required

DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1,PATNA, PATNA vs. GANADHIPATI CONSTRUCTION PVT LTD, PATNA

In the result, all the appeals of the Revenue in ITA No

ITA 294/PAT/2023[2021-22]Status: DisposedITAT Patna15 Oct 2024AY 2021-22

Bench: Shri Rajpal Yadav & Dr. Manish Borad

For Appellant: Shri AK Rastogi, ARFor Respondent: Shri Rinku Singh, DR
Section 132Section 139Section 139(1)Section 153ASection 250Section 801ASection 80I

6. Aggrieved assessee preferred appeal before the ld. CIT (A) and submitted that in compliance to the return filed u/s 153A of the Act, assessee has submitted tax audit report u/s 44AB of the Act and also furnished audit report on form 10CCB for by claiming deduction u/s 80IA of the Act and has fulfilled all the conditions required