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22 results for “disallowance”+ Section 53(1)(i)clear

Sorted by relevance

Mumbai4,530Delhi4,000Chennai1,375Bangalore1,367Ahmedabad972Kolkata950Jaipur656Hyderabad656Pune619Indore412Chandigarh371Surat272Raipur241Cochin205Visakhapatnam189Cuttack181Amritsar148Nagpur147Rajkot115Karnataka106Lucknow99Agra95Guwahati85Allahabad70Ranchi63Jodhpur47Calcutta44SC39Dehradun29Varanasi25Telangana23Patna22Panaji18Jabalpur17Kerala3Punjab & Haryana3Orissa2A.K. SIKRI ROHINTON FALI NARIMAN1ASHOK BHAN DALVEER BHANDARI1J&K1Rajasthan1

Key Topics

Addition to Income20Section 143(3)13Section 271(1)(b)10Disallowance9Section 2508Section 1477Section 40A(3)6Section 116Section 271(1)(c)6Section 23

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 22 · Page 1 of 2

5
Deduction5
Natural Justice5

disallowed nor any addition was made. On appeal, the Commissioner (Appeals) quashed the reassessment proceedings holding that the assessee had disclosed all the facts and no new fact was available to the Assessing Officer. Therefore, it was mere change of opinion on the part of the Assessing Officer and as such, the reassessment proceedings could not have been validly initiated

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

53,430/-. The facts stated above in A.Y. 2016-17 are also common. The assessee has filed its return of income in 2017-18 also but on 21.12.2019. It has declared total income of Rs.12,43,02,386/-. Assessment Years: 2016-2017 & 2017-2018 & C.O. Nos. 1 & 2/PAT/2022 (in ITA 62 & 63/PAT/2021) Assessment years: 2016-2017 & 2017-2018 Broadson Commodities

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

53,430/-. The facts stated above in A.Y. 2016-17 are also common. The assessee has filed its return of income in 2017-18 also but on 21.12.2019. It has declared total income of Rs.12,43,02,386/-. Assessment Years: 2016-2017 & 2017-2018 & C.O. Nos. 1 & 2/PAT/2022 (in ITA 62 & 63/PAT/2021) Assessment years: 2016-2017 & 2017-2018 Broadson Commodities

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)

53 ITR 225 , a three- judge Bench of this Court discussed the scope of section 31(3)(a ) of the 1922 Act, which 8 Assessment Year: 2009-2010 M/s. Kumar Construction is almost identical to section 251(1)(a) of the 1961 Act. The Court held as under: "...If an appeal lies, section 31 of the Act describes the powers

DCIT, CIRCLE-1, MUZAFFARPUR vs. M/S UTTAR BIHAR GRAMIN BANK, MUZAFFARPUR

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

ITA 30/PAT/2021[2014-15]Status: DisposedITAT Patna25 Feb 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 250Section 36(1)(viia)Section 36(1)(vila)

section 36(1)(viia) of the Act, Rule 2ABA of the Income Tax Rules, 1962 and after going through the remand report of the Ld. AO has given his findings as under: “I have gone through the submissions made by learned A/R of the appellant, the assessment order and the remand report. On the first issue of allowability of additional

SANJAY YADAV,JAHANABAD vs. NFAC, DELHI, DELHI

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

ITA 217/PAT/2025[2016-17]Status: DisposedITAT Patna11 Sept 2025AY 2016-17

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 147Section 234BSection 250Section 271(1)(b)Section 271(1)(c)

53,228/- which is wrong, illegal and unjustified on the facts and circumstances of the appellant's case. 5. For that the Ld. CIT (A) NFAC has affirmed the order of Ld. AO and not allowing payment of rent of Rs. 6,60,000/- in respect of TDS on rent is wrong, illegal and unjustified on the facts and circumstances

SANJAY YADAV,JAHANABAD vs. NFAC, DELHI, DELHI

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

ITA 218/PAT/2025[2016-17]Status: DisposedITAT Patna11 Sept 2025AY 2016-17

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 147Section 234BSection 250Section 271(1)(b)Section 271(1)(c)

53,228/- which is wrong, illegal and unjustified on the facts and circumstances of the appellant's case. 5. For that the Ld. CIT (A) NFAC has affirmed the order of Ld. AO and not allowing payment of rent of Rs. 6,60,000/- in respect of TDS on rent is wrong, illegal and unjustified on the facts and circumstances

SANJAY YADAV,JAHANABAD vs. NFAC, DELHI, DELHI

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

ITA 216/PAT/2025[2016-17]Status: DisposedITAT Patna11 Sept 2025AY 2016-17

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 147Section 234BSection 250Section 271(1)(b)Section 271(1)(c)

53,228/- which is wrong, illegal and unjustified on the facts and circumstances of the appellant's case. 5. For that the Ld. CIT (A) NFAC has affirmed the order of Ld. AO and not allowing payment of rent of Rs. 6,60,000/- in respect of TDS on rent is wrong, illegal and unjustified on the facts and circumstances

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

ITO, WARD-2(1), BEGUSARAI, BEGUSARAI vs. MANISH KUMAR MOTANI, KHAGARIA, BIHAR

In the result, the appeal of the Revenue and CO of the Assessee are dismissed

ITA 442/PAT/2024[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Ito, Ward 2(1), Begusarai Manish Kumar Motani, 3Rd Floor, G.S. Motors Building, Manish Kumar Motani, Hanuman Har Har Mahadev Chauk, Traders, Mill Road, Khagaria, Vs. Begusarai-851101, Begusarai, Khagaria, Bihari-851204 Bihar-851101 (Appellant) (Respondent) Pan No. Ajjpm4263D Co No. 02/Pat/2025 (Arising In Ita No. 442/Pat/2024 For A.Y. 2017-18) Ito, Ward 2(1), Begusarai Manish Kumar Motani, 3Rd Floor, G.S. Motors Building, Manish Kumar Motani, Hanuman Har Har Mahadev Chauk, Traders, Mill Road, Khagaria, Vs. Begusarai-851101, Begusarai, Khagaria, Bihari-851204 Bihar-851101 (Applicant) (Respondent) Assessee By : S/Shri A.K. Rastogi, S.K. Duta, Ars Revenue By : Shri A.H. Chowdhary, Dr Date Of Hearing: 24.11.2025 Date Of Pronouncement: 26.02.2026

For Appellant: S/Shri A.K. RastogiFor Respondent: Shri A.H. Chowdhary, DR
Section 133ASection 40A(3)

53,95,910/- as against the return income of ₹34,62,020/- by making the two additions (i) ₹8,02,45,293/ - in respect of undisclosed sales and (ii) 16,88,598/-, in respect of disallowance computed at the rate of 10% on Freight & wages expenses, Miscellaneous expenses, travelling and conveyance expenses etc. 6. In the appellate proceedings, the learned

M/S KUMAR PIYUSH CONSTRUCTION PRIVATE LTD,NALANDA vs. PR. CIT-1, PATNA

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

ITA 156/PAT/2019[2014-15]Status: DisposedITAT Patna08 Jan 2025AY 2014-15

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 263Section 43B

disallowance also.” 2.0. Aggrieved with the action of Ld. PCIT, the assessee is in appeal before us with the following grounds of appeal: 3 M/s Kumar Piyush Construction Private Limited “Ground number 1 Was not justified in initiating proceedings under Section 263 of the Act since the order under Section 143(3) of the Act dated 20 December

DCIT, CIRCLE-1, PATNA vs. M/S ALKEM LABORATORIES LTD, PATNA

In the result, the appeal of the revenue is dismissed

ITA 219/PAT/2018[2010-11]Status: DisposedITAT Patna29 Sept 2022AY 2010-11
Section 115Section 115JSection 143(3)Section 147Section 148Section 14ASection 154Section 250(6)Section 35

1. On the facts and in the circumstances of the case, the Ld. CIT(A) erred in granting relief to the assessee on account of adjustment made to book profit on account of Provisions for Doubtful debts/advance for A.V. 2010-11, 2011-12 & 2012-13 under the provision of section 115JB of the Income

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

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

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

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

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

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

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

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

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

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

JOINT COMMISSIONER INCOME-TAX(IN-SITU), CIRCLE-1, PATNA, PATNA vs. NORTH BIHAR POWER DISTRIBUTION COMPANY LIMITED, PATNA

In the result, the appeals of the Revenue and COs of the assessee are dismissed

ITA 99/PAT/2025[2013-14]Status: DisposedITAT Patna23 Feb 2026AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am**

For Appellant: Sh. Ankit Kumar, CA**For Respondent: Md. A. H. Chowdhary, CIT (DR).**

53,29,48,286/- to the total income of the assessee during the year under consideration. - 3.2. Aggrieved assessee preferred an appeal before the learned CIT (A), who deleted the addition after examining the order issued by CERC relating to these expenses submitted by the ld. Counsel of the assessee by recording a clearcut finding that the expenses were

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-1, PATNA, PATNA vs. NORTH BIHAR POWER DISTRIBUTION COMPANY LIMITED, PATNA

In the result, the appeals of the Revenue and COs of the assessee are dismissed

ITA 234/PAT/2025[2017-18]Status: DisposedITAT Patna23 Feb 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Sh. Ankit Kumar, CAFor Respondent: Md. A. H. Chowdhary, CIT (DR)

53,29,48,286/- to the total income of the assessee during the year under consideration. 3.2. Aggrieved assessee preferred an appeal before the learned CIT (A), who deleted the addition after examining the order issued by CERC relating to these expenses submitted by the ld. Counsel of the assessee by recording a clearcut finding that the expenses were

SHASHI KRISHNA EDUCATIONAL AVAM WELFARE SOCIETY,PATNA vs. AO, PATNA

ITA 428/PAT/2025[2018-19]Status: DisposedITAT Patna29 Jan 2026AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 11Section 12ASection 12A(1)(b)Section 143(1)Section 154Section 250

section 11 were duly complied with. 6. That the demand of Rs. 53,13,260/- is unjustified, arbitrary, and deserves to be quashed. 7. That the appellant craves leave to add, alter or withdraw any ground of appeal at the time of hearing.” 3. Brief facts of the case are that the assessee is an AOP and had filed