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11,279 results for “disallowance”+ Section 132(4)clear

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Key Topics

Section 153A95Addition to Income73Section 153C65Section 13260Section 80I45Disallowance44Section 143(3)43Search & Seizure33Section 14323Deduction

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

disallowance is primarily based on:  A statement recorded under Section 132(4) during search; and  An inference that payments made

Showing 1–20 of 11,279 · Page 1 of 564

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18
Section 14713
Natural Justice13

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

disallowance is primarily based on:  A statement recorded under Section 132(4) during search; and  An inference that payments made

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE -05 , DELHI

ITA 5521/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

disallowance is primarily based on:  A statement recorded under Section 132(4) during search; and  An inference that payments made

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , MANGALORE

ITA 433/BANG/2024[2015-16]Status: DisposedITAT Bangalore03 Jul 2024AY 2015-16
Section 132Section 132(4)Section 153ASection 153DSection 234A

disallowed.\n8. The learned CIT[A] further ought to have appreciated that sanction\nu/s.153D was accorded is without application of mind and such a\nmechanically granted approval vitiates the assessment order\nrendering it to be held illegal and void-ab-initio under the facts and in\nthe circumstances of the appellant's case.\n9. Without prejudice to the right

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , MANGALORE

ITA 432/BANG/2024[2014-15]Status: DisposedITAT Bangalore03 Jul 2024AY 2014-15
Section 132Section 132(4)Section 153ASection 153DSection 234A

disallowed.\n8. The learned CIT[A] further ought to have appreciated that sanction\nu/s.153D was accorded is without application of mind and such a\nmechanically granted approval vitiates the assessment order\nrendering it to be held illegal and void-ab-initio under the facts and in\nthe circumstances of the appellant's case.\n9. Without prejudice to the right

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALURU

In the result, appeals of the assessee in ITA Nos

ITA 431/BANG/2024[2013-14]Status: DisposedITAT Bangalore03 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Sri Narendra Sharma, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 132Section 132(4)Section 153ASection 153DSection 234A

132(4) of the Act. However, this statement cannot, on a standalone basis, without reference to any other material discovered during search and seizure operations, empower the AO to frame the block assessment.” [Emphasis in bold and underline supplied] (vii) Honourable Mumbai Bench of ITAT in Arihant Universal Realty (P.) Ltd. v. DCIT( ITA NO. 4342/2017 dated 05.04.2022 ) held

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

ITA 835/BANG/2024[2014-15]Status: DisposedITAT Bangalore12 Jun 2024AY 2014-15
For Appellant: Shri V. Srinivasan, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132Section 132(4)Section 234ASection 69A

Section 132(4) of the Act cannot be the sole basis for making additions unless corroborated by other independent evidence. The addition for AY 2014-15 on account of salary income was deleted. For AY 2018-19, the Tribunal found no corroborative material to support the disallowance

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

ITA 836/BANG/2024[2018-19]Status: DisposedITAT Bangalore12 Jun 2024AY 2018-19
Section 115BSection 132Section 132(4)Section 234A

section 132(4) of the Act. The Tribunal has\ncommitted an error in ignoring the retraction made by the assessee.\"\n\"16.4 We have duly considered the contention of the assessee and also\nperused the documentary evidences produced by the assessee. On\nperusing the facts, it is apparent that the addition is made based on the\ngeneral practice of cash

ASSISTANT COMMISSIONER OF INCOME-TAX,CENTRAL CIRCLE - 2(2),, PUNE vs. M/S SINHGAD TECHNICAL EDUCATION SOCIETY (TRUST), PUNE

In the result, the appeal of the Revenue in ITA

ITA 1654/PUN/2017[2014-15]Status: DisposedITAT Pune01 Apr 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl. It(Ss)A No./ Name Of Appellant Name Of Respondent Asst. No.

For Appellant: Shri Chetan A. KariaFor Respondent: Shri Abhinay Kumbhar
Section 11Section 12ASection 132Section 153A

132(4) are to be believed, it would only mean that they collected the capitation fees for their personal enrichment. It is further fortified by fact that even the Central Government had been stepped into control the corruption in the private sector and the Lokpal and Lokayukta Act passed in the year 2013. In the said Act, the office bearers

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 725/PUN/2022[2018-19]Status: DisposedITAT Pune28 Jun 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

For Appellant: Shri Ratan SamalFor Respondent: Shri Keyur Patel
Section 132(4)Section 139(1)

disallowances, the assessee had filed an appeal before the ld. CIT(A) contenting inter alia that the Assessing Officer ought not to have treated the unsecured loans of Rs.13,27,54,925/- as bogus loans, are merely accommodation entries since the interest was paid on such loans after deducting the TDS and the loans were accepted through the mode

ACIT, CENTRAL CIRCLE-15, NEW DELHI vs. LUXMAN BUILDERS PVT. LTD., NEW DELHI

In the result, the CO filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

ITA 817/DEL/2018[2010-11]Status: DisposedITAT Delhi14 Dec 2021AY 2010-11

Bench: Shri R.K. Panda & Shri Kul Bharatassessment Year: 2010-11 Acit, Vs Lumax Builders Pvt. Ltd., Central Circle-15, 25, Bazar Lane, New Delhi. Bengali Market, New Delhi. Pan: Aaacl2184R Co No.93/Del/2018 (Ita No.817/Del/2018) Assessment Year: 2010-11 Lumax Builders Pvt. Ltd., Vs. Acit, 25, Bazar Lane, Central Circle-15, Bengali Market, New Delhi New Delhi. Pan: Aaacl2184R (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate & Shri Lalit Mohan, Advocate Revenue By : Ms Paramita M. Biswas, Cit, Dr Date Of Hearing : 16.09.2021 Date Of Pronouncement : 14.12.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Revenue Is Directed Against The Order Dated 3Rd November, 2017 Of The Cit(A)-26, New Delhi, Relating To Assessment Year 2010- 11. Co No.93/Del/2018 2. The Assessee Has Filed The Co Against The Appeal Filed By The Revenue. For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Shri Gautam Jain, Advocate &For Respondent: Ms Paramita M. Biswas, CIT, DR
Section 132Section 132(4)Section 153A

section 132(4) of Sh. Sampat Sharma cannot be treated as incriminating material found during the course of search. In the result, we hold that addition of share capital in the year under consideration has been made without relying on any incriminating material found during the course of search.” 44. In the light of the above decisions, statements recorded

M/S. NIRALA HOUSING PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

ITA 3135/DEL/2015[2011-12]Status: DisposedITAT Delhi16 Nov 2018AY 2011-12

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

For Appellant: Sh. Rahul Khare, Adv. &For Respondent: Sh. Manoj Kumar Chopra, Sr. DR
Section 132Section 271Section 271(1)(c)Section 271A

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

M/S. NIRALA HOUSING PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

ITA 3137/DEL/2015[2012-13]Status: DisposedITAT Delhi16 Nov 2018AY 2012-13

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

For Appellant: Sh. Rahul Khare, Adv. &For Respondent: Sh. Manoj Kumar Chopra, Sr. DR
Section 132Section 271Section 271(1)(c)Section 271A

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

M/S. NIRALA HOUSING PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

ITA 3136/DEL/2015[2012-13]Status: DisposedITAT Delhi16 Nov 2018AY 2012-13

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

For Appellant: Sh. Rahul Khare, Adv. &For Respondent: Sh. Manoj Kumar Chopra, Sr. DR
Section 132Section 271Section 271(1)(c)Section 271A

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

NIRALA DEVELOPERS PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

ITA 3155/DEL/2015[2012-13]Status: DisposedITAT Delhi16 Nov 2018AY 2012-13

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

For Appellant: Sh. Rahul Khare, Adv. &For Respondent: Sh. Manoj Kumar Chopra, Sr. DR
Section 132Section 271Section 271(1)(c)Section 271A

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

DCIT, NEW DELHI vs. M/S NIRALA HOUSING PVT. LTD.,, NEW DELHI

In the result, all the five appeals are dismissed

ITA 3531/DEL/2015[2011-12]Status: DisposedITAT Delhi16 Nov 2018AY 2011-12

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

For Appellant: Sh. Rahul Khare, Adv. &For Respondent: Sh. Manoj Kumar Chopra, Sr. DR
Section 132Section 271Section 271(1)(c)Section 271A

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

ITA 939/BANG/2025[2020-21]Status: DisposedITAT Bangalore13 Nov 2025AY 2020-21
For Appellant: \nShri M.V Prasad, CA & Shri KS Rajendra KumarFor Respondent: \nShri Muthu Shankar, CIT &
Section 12ASection 143(3)Section 153ASection 153BSection 25Section 250Section 8

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

ITA 503/BANG/2020[2013-14]Status: DisposedITAT Bangalore16 Aug 2021AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramaniam, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 11Section 11(1)(a)Section 12ASection 132Section 143(1)Section 153ASection 37

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

ITA 500/BANG/2020[2010-11]Status: DisposedITAT Bangalore16 Aug 2021AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramaniam, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 11Section 11(1)(a)Section 12ASection 132Section 143(1)Section 153ASection 37

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

ITA 501/BANG/2020[2011-12]Status: DisposedITAT Bangalore16 Aug 2021AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramaniam, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 11Section 11(1)(a)Section 12ASection 132Section 143(1)Section 153ASection 37

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31