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35 results for “disallowance”+ Section 148(1)clear

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Key Topics

Section 14742Section 143(3)35Section 25034Section 14821Addition to Income18Deduction14Disallowance13Section 1549TDS9Section 37

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 of the Act are invalid

Showing 1–20 of 35 · Page 1 of 2

8
Section 407
Section 142(1)7

SIS CASH SERVICES PRIVATE LIMITED,PATNA vs. ADIT, CPC, BANGALORE, BANGALORE

In the result, this appeal of assessee is dismissed

ITA 240/PAT/2023[2020-21]Status: DisposedITAT Patna26 May 2025AY 2020-21
For Appellant: Kavita Jha, Sr. AdvocateFor Respondent: Sh. Ashwani Kr. Singal, JCIT
Section 139(1)Section 143(1)Section 154Section 250Section 36(1)(va)Section 40Section 43B

disallowance of the deduction, even if the payment was made before the due date for filing the ROI. We need to remind ourselves that this is exactly the case in the present appeal. The judgment reinforced the distinction between employer and employee contributions. While an employer's contributions could be governed by section 43B of the Act, employees' contributions

JCIT(IN-SITU), CIRCLE-1, PATNA, PATNA vs. TECHNOCULTURE BUILDING CENTRE PRIVATE LIMITED, PATNA

In the result, appeal of the Revenue is allowed for statistical purposes\nand Cross Objection filed by the assessee is dismissed

ITA 41/PAT/2025[2020-21]Status: DisposedITAT Patna03 Jun 2025AY 2020-21
Section 142(1)Section 250Section 36(1)(va)

disallowance of the deduction, even if the payment was made before the due date\nfor filing the ROI. We need to remind ourselves that this is exactly the case in the present\nappeal. The judgment reinforced the distinction between employer and employee\ncontributions. While an employer's contributions could be governed by section 43B of the\nAct, employees' contributions

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

148 taxmann.com 132 (Delhi) [06-01-2023], wherein it has been held that - "Explanation 2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under

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

148 taxmann.com 132 (Delhi) [06-01-2023], wherein it has been held that - "Explanation 2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under

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

148 taxmann.com 132 (Delhi) [06-01-2023], wherein it has been held that - "Explanation 2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under

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

148 taxmann.com 132 (Delhi) [06-01-2023], wherein it has been held that - "Explanation 2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under

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

148 taxmann.com 132 (Delhi) [06-01-2023], wherein it has been held that - "Explanation 2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under

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

148 taxmann.com 132 (Delhi) [06-01-2023], wherein it has been held that - "Explanation 2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under

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

1), Patna. The learned AO after going over the documents filed by the assessee in support of the claim made by the assessee do not find satisfactory, as a result of which a sum of Rs. 40,34,780/- is disallowed u/s 14A of the Act read with Rule 8D of the Income Tax Rules

ACIT, CENTRAL CIRCLE-3, PATNA, PATNA vs. SMT. SIPRA GUPTA, PATNA

ITA 71/PAT/2023[2017-18]Status: HeardITAT Patna09 Dec 2025AY 2017-18
Section 148

disallowing deduction under section 80TTA\nat Rs.263 whereas in fact he has accepted the bank interest as income from other\nSources.\nFor that the charming of interest under section 234A is bad in law as original return as\nwell as return filed under section 148 is well within time. The consequential relief\nunder section 234B may be allowed in case

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 139Section 147Section 148Section 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

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

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MUZAFFARPUR, MUZAFFARPUR vs. AJIT KUMAR, BETTIAH

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

ITA 239/PAT/2024[2017]Status: DisposedITAT Patna29 Sept 2025

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115BSection 143(3)Section 148Section 250Section 40A(3)Section 69

section 40A(3) are not applicable. 2. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A)-3, Patna erred in not Including the Issue In the remand order Issued by him for examination of the undisclosed receipt from business of the assessee. 3. That on the facts and in the circumstances

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

1) passed under Section 147 read with Section 144B of the Act for the Assessment Year 2015-16, by the ld. assessing officer at Assessment Unit, Income Tax Department, 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

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

148 (1) of the Act and even the notice was issued u/s 142(1) giving show cause to the assessee as to why the capital gain on sale of property should not be added to the income of the assessee. Considering these facts and circumstances it is apparent from the records before us that no notice has been 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

148 (1) of the Act and even the notice was issued u/s 142(1) giving show cause to the assessee as to why the capital gain on sale of property should not be added to the income of the assessee. Considering these facts and circumstances it is apparent from the records before us that no notice has been 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

148 (1) of the Act and even the notice was issued u/s 142(1) giving show cause to the assessee as to why the capital gain on sale of property should not be added to the income of the assessee. Considering these facts and circumstances it is apparent from the records before us that no notice has been issued

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

148 (1) of the Act and even the notice was issued u/s 142(1) giving show cause to the assessee as to why the capital gain on sale of property should not be added to the income of the assessee. Considering these facts and circumstances it is apparent from the records before us that no notice has been 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

148 (1) of the Act and even the notice was issued u/s 142(1) giving show cause to the assessee as to why the capital gain on sale of property should not be added to the income of the assessee. Considering these facts and circumstances it is apparent from the records before us that no notice has been issued