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51 results for “disallowance”+ Section 147clear

Sorted by relevance

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Key Topics

Section 25050Section 14750Section 143(3)36Addition to Income35Section 80I30Deduction17Section 14815Section 13213Disallowance13TDS

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

disallowed the claim made under section 80-IA.” 15. Respectfully following the ratios laid down by the Hon’ble Courts referred hereinabove, we are inclined to hold that the notice under section 148 of the Act issued by the ld. Assessing Officer is illegal and invalid and, therefore, reopening proceedings carried out under section 147

Showing 1–20 of 51 · Page 1 of 3

13
Section 153A12
Section 143(2)12

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

disallowances. Subsequently, the Assessing Officer issued a notice under section 148 and reopened the assessment P a g e 10 | 71 Assessment Year : 2010 -2011 under section 147

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

ACIT, CENTRAL CIRCLE-2, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 98/PAT/2021[2016-17]Status: HeardITAT Patna07 Nov 2023AY 2016-17

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

147 of the Act by issuing notice u/s 148 on 28.03.2019 which was complied with by the assessee by filing return of income on 27.01.2019. We note that the AO has even assessed the income on the basis of return of income filed by the assessee u/s 148 (1) of the Act and even the notice was issued

KUMAR ARUNODAYA,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX - 6, PATNA [NEW – DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, PATNA], PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 96/PAT/2021[2016-17]Status: HeardITAT Patna07 Nov 2023AY 2016-17

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

147 of the Act by issuing notice u/s 148 on 28.03.2019 which was complied with by the assessee by filing return of income on 27.01.2019. We note that the AO has even assessed the income on the basis of return of income filed by the assessee u/s 148 (1) of the Act and even the notice was issued

KUMAR ARUNOSAYA,PATNA vs. A.O., CIRCLE-6, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 33/PAT/2020[2013-14]Status: HeardITAT Patna07 Nov 2023AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

147 of the Act by issuing notice u/s 148 on 28.03.2019 which was complied with by the assessee by filing return of income on 27.01.2019. We note that the AO has even assessed the income on the basis of return of income filed by the assessee u/s 148 (1) of the Act and even the notice was issued

DCIT, CIRCLE-4, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 89/PAT/2020[2012-13]Status: HeardITAT Patna07 Nov 2023AY 2012-13

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

147 of the Act by issuing notice u/s 148 on 28.03.2019 which was complied with by the assessee by filing return of income on 27.01.2019. We note that the AO has even assessed the income on the basis of return of income filed by the assessee u/s 148 (1) of the Act and even the notice was issued

ACIT, CIRCLE-4, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 94/PAT/2020[2012-13]Status: HeardITAT Patna07 Nov 2023AY 2012-13

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

147 of the Act by issuing notice u/s 148 on 28.03.2019 which was complied with by the assessee by filing return of income on 27.01.2019. We note that the AO has even assessed the income on the basis of return of income filed by the assessee u/s 148 (1) of the Act and even the notice was issued

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

Section 143(3) / 147 of the Act for Assessment Year 2012-13 by the ld. assessing officer, viz. the Income Tax Officer, Ward - 2(1), Patna, is bad both in law and on facts. 4. For that the appellant was not given any opportunity, much less sufficient opportunity, to put forth his contentions and place evidences henceforth at the time

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

Section 143(3) / 147 of the Act for Assessment Year 2012-13 by the ld. assessing officer, viz. the Income Tax Officer, Ward - 2(1), Patna, is bad both in law and on facts. 4. For that the appellant was not given any opportunity, much less sufficient opportunity, to put forth his contentions and place evidences henceforth at the time

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

Section 143(3) / 147 of the Act for Assessment Year 2012-13 by the ld. assessing officer, viz. the Income Tax Officer, Ward - 2(1), Patna, is bad both in law and on facts. 4. For that the appellant was not given any opportunity, much less sufficient opportunity, to put forth his contentions and place evidences henceforth at the time

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

Section 143(3) / 147 of the Act for Assessment Year 2012-13 by the ld. assessing officer, viz. the Income Tax Officer, Ward - 2(1), Patna, is bad both in law and on facts. 4. For that the appellant was not given any opportunity, much less sufficient opportunity, to put forth his contentions and place evidences henceforth at the time

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

Section 143(3) / 147 of the Act for Assessment Year 2012-13 by the ld. assessing officer, viz. the Income Tax Officer, Ward - 2(1), Patna, is bad both in law and on facts. 4. For that the appellant was not given any opportunity, much less sufficient opportunity, to put forth his contentions and place evidences henceforth at the time

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

Section 143(3) / 147 of the Act for Assessment Year 2012-13 by the ld. assessing officer, viz. the Income Tax Officer, Ward - 2(1), Patna, is bad both in law and on facts. 4. For that the appellant was not given any opportunity, much less sufficient opportunity, to put forth his contentions and place evidences henceforth at the time

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

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

147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted on 07.10.2009 and the notice was issued to the assessee under section 153A of the Act for assessment year 2006-07 on 04.08.2010. In response to the notice, the assessee filed return

SANGAM ALMIRAH PRIVATE LIMITED,MUZAFFARPUR vs. NFAC, DELHI

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

ITA 338/PAT/2025[2018-19]Status: DisposedITAT Patna27 Oct 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 250Section 270ASection 270A(9)

disallowance falls. However, on going through the submission of the assessee, it can be seen that the assessee stated that they themselves detected that the PF and ESI for the period of business i.e. 01.04.2017 to 30.06.2017 was by mistake debited to P & L account of the company. However, the same was being brought to the notice

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

147 I 148 is arbitrary unjustified, void ab-initio and bad in law. 3. For that the learned CIT(A) has also failed to adjudicate the following grounds:- (i) For that in the facts and circumstances of the case, there is no justification for addition of a sum of Rs. 9,43,7351- being hire charges separately. The case

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

147 I 148 is arbitrary unjustified, void ab-initio and bad in law. 3. For that the learned CIT(A) has also failed to adjudicate the following grounds:- (i) For that in the facts and circumstances of the case, there is no justification for addition of a sum of Rs. 9,43,7351- being hire charges separately. The case

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

147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted on 07.10.2009 and the notice was issued to the assessee under section 153A of the Act for assessment year 2006-07 on 04.08.2010. In response to the notice, the assessee filed return