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1,123 results for “disallowance”+ Section 153Dclear

Sorted by relevance

Delhi470 Mumbai136 Bangalore84 Chennai72 Chandigarh66 Cochin62 Amritsar46 Allahabad37 Jaipur33 Agra24 Nagpur17 Lucknow17 Raipur15 Hyderabad11 Ahmedabad9 Indore8 Patna5 Jodhpur4 Visakhapatnam3 Kolkata2 Pune2

Key Topics

Section 153A136 Section 153D82 Section 153C81 Addition to Income64 Section 6837 Section 13237 Section 25037 Section 143(3)32 Search & Seizure30 Disallowance

LENIENT CONSULTANTS PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-2, NOIDA

In the result, the appeal of the Assessee is partly allowed\nas indicated above

ITA 2331/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Sept 2025AY 2016-17

Section 153ASection 153DSection 250

Section 153D of the Act, the Additional CIT\ndoes not act as a reviewing/appellate authority to allow or disallow\nthe

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Appeals of the assessee are allowed

ITA 6159/DEL/2018[2010-11]Status: DisposedITAT Delhi12 Sept 2025AY 2010-11

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

Showing 1–20 of 1,123 · Page 1 of 57

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19

Natural Justice9

For Appellant: Sh. Ruchesh Sinha, Adv

For Respondent: Sh. T. James Singson, CIT, DR

Section 11Section 127Section 132Section 139(1)Section 153ASection 153DSection 274

section 153D of the Act by the Addl. CIT is merely administrative in nature to safeguard internal checks & balances without affecting the quasi-judicial powers of the AO or creating any prejudice to assessee. In fact, while granting approval under section153D of the Act, the Addl. CIT does not act as a Reviewing/Appellate Authority to allow or disallow

VANSHIKA MOTORS (P) LTD.,MEERUT vs. ACIT, CIRCLE- 2, MEERUT

Appeals of the assessee are allowed

ITA 6214/DEL/2017[2010-11]Status: DisposedITAT Delhi20 Mar 2025AY 2010-11

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

For Appellant: Sh. Ruchesh Sinha, AdvFor Respondent: Sh. T. James Singson, CIT, DR

Section 11Section 127Section 132Section 139(1)Section 153ASection 153DSection 274

section 153D of the Act by the Addl. CIT is merely administrative in nature to safeguard internal checks & balances without affecting the quasi-judicial powers of the AO or creating any prejudice to assessee. In fact, while granting approval under section153D of the Act, the Addl. CIT does not act as a Reviewing/Appellate Authority to allow or disallow

DCIT, NEW DELHI vs. M/S KHEMKA STUART LEISURE LTD.,, NEW DELHI

Appeals of the assessee are allowed

ITA 6215/DEL/2015[2008-09]Status: DisposedITAT Delhi25 Feb 2025AY 2008-09

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

For Appellant: Sh. Ruchesh Sinha, AdvFor Respondent: Sh. T. James Singson, CIT, DR

Section 11Section 127Section 132Section 139(1)Section 153ASection 153DSection 274

section 153D of the Act by the Addl. CIT is merely administrative in nature to safeguard internal checks & balances without affecting the quasi-judicial powers of the AO or creating any prejudice to assessee. In fact, while granting approval under section153D of the Act, the Addl. CIT does not act as a Reviewing/Appellate Authority to allow or disallow

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Appeals of the assessee are allowed

ITA 6158/DEL/2018[2009-10]Status: DisposedITAT Delhi12 Sept 2025AY 2009-10

For Appellant: \nSh. Ruchesh Sinha, AdvFor Respondent: \nSh. T. James Singson, CIT, DR

Section 11Section 127Section 132Section 139(1)Section 153ASection 153DSection 274

153D has been\ngranted in a mechanical manner and without application of mind\nand thus it is invalid and bad in law and consequently vitiated the\nassessment order for want of valid approval u/s 153D of the Act.\nIn view of the above discussion, we hold that the order passed u/s\n153A r.w.s.43(3) has to be quashed, thus ordered

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Appeals of the assessee are allowed

ITA 6216/DEL/2018[2014-15]Status: DisposedITAT Delhi12 Sept 2025AY 2014-15

For Appellant: \nSh. Ruchesh Sinha, AdvFor Respondent: \nSh. T. James Singson, CIT, DR

Section 11Section 127Section 132Section 139(1)Section 153ASection 153DSection 274

Section 147\nread with Section 148 of the Act. Hon'ble Delhi High Court observed as\nunder:-\n\n“11. The purpose of section 151 of the Act is to introduce a\nsupervisory check over the work of the AO, particularly, in the\ncontext of reopening of assessment. The law expects the AO to\nexercise the power under section

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Appeals of the assessee are allowed

ITA 6160/DEL/2018[2011-12]Status: DisposedITAT Delhi12 Sept 2025AY 2011-12

For Appellant: \nSh. Ruchesh Sinha, AdvFor Respondent: \nSh. T. James Singson, CIT, DR

Section 11Section 127Section 132Section 139(1)Section 153ASection 153DSection 274

Section is\nnot turned into an empty ritual. Needless to emphasize that before\ngranting approval, the Chief Commissioner or the Commissioner, as\nthe case may be, must have before him the material on the basis\nwhereof an opinion in this behalf has been formed by the Assessing\nOfficer. The approval must reflect the application of mind to the\nfacts

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Appeals of the assessee are allowed

ITA 6214/DEL/2018[2012-13]Status: DisposedITAT Delhi12 Sept 2025AY 2012-13

For Appellant: \nSh. Ruchesh Sinha, AdvFor Respondent: \nSh. T. James Singson, CIT, DR

Section 11Section 127Section 132Section 139(1)Section 153ASection 153DSection 274

section 142(2A) does entail civil consequences, the\nrule audialterampartem is required to be observed.”\n\n16.\nFurther, Hon'ble Orissa High Court in the case of Serajuddin& Co.\n(supra), has considered the case of Hon'ble Delhi High Court in the case\nof Yum! Restaurants Asia Pte.Ltd. Vs. DCIT – [2017] 397 ITR 665 (Delhi),\nwhich has dealt with

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Appeals of the assessee are allowed

ITA 6215/DEL/2018[2013-14]Status: DisposedITAT Delhi12 Sept 2025AY 2013-14

For Appellant: \nSh. Ruchesh Sinha, AdvFor Respondent: \nSh. T. James Singson, CIT, DR

Section 11Section 127Section 132Section 139(1)Section 153ASection 153DSection 274

section 136 of the Act, proceedings before an Assessing\nOfficer are deemed to be judicial proceedings. Section 136 of the\nAct, stipulates that any proceeding before an Income-tax Authority\nshall be deemed to be judicial proceedings within the meaning of\nsections 193 and 228 of Indian Penal Code, 1860 and also for the\npurpose of section 196 of I.P.C

ASSISTANT COMMISSIONER OF INCOME TAX, ALLAHABAD vs. JYOTI MEDISERVICES LTD., ALLAHABAD

ITA 129/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

section 153D of the Act were inserted by Finance Act, 2007 with effect from 01/06/2007. In our humble understanding of the said provisions, we are of the opinion that the Legislature wanted the assessment/reassessment of the search cases should be made and order should be passed with the prior approval of superior authority. The word approval has not been defined

JYOTI MEDISERVICES PRIVATE LIMITED, ,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, , ALLAHABAD

ITA 115/ALLD/2025[2013-14]Status: DisposedITAT Allahabad21 Nov 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

section 153D of the Act were inserted by Finance Act, 2007 with effect from 01/06/2007. In our humble understanding of the said provisions, we are of the opinion that the Legislature wanted the assessment/reassessment of the search cases should be made and order should be passed with the prior approval of superior authority. The word approval has not been defined

JYOTI MEDISERVICES PRIVATE LIMITED,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, ALLAHABAD, ALLAHABAD

ITA 113/ALLD/2025[2011-12]Status: DisposedITAT Allahabad21 Nov 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

section 153D of the Act were inserted by Finance Act, 2007 with effect from 01/06/2007. In our humble understanding of the said provisions, we are of the opinion that the Legislature wanted the assessment/reassessment of the search cases should be made and order should be passed with the prior approval of superior authority. The word approval has not been defined

JYOTI MEDISERVICES PRIVATE LIMITED,,ALLAHABAD vs. DCIT, CENTRAL CIRCLE,, ALLAHABAD

ITA 114/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

section 153D of the Act were inserted by Finance Act, 2007 with effect from 01/06/2007. In our humble understanding of the said provisions, we are of the opinion that the Legislature wanted the assessment/reassessment of the search cases should be made and order should be passed with the prior approval of superior authority. The word approval has not been defined

DCIT CENTRAL CIRCLE-8, NEW DELHI vs. AMOLAK SINGH BHATIA, BILASPUR

In the result, all the cross objections filed by the assessee are allowed as above and all the appeals of the Revenue are dismissed as infructuous

ITA 719/DEL/2021[2006-07]Status: DisposedITAT Delhi18 Apr 2023AY 2006-07

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri P. Praveen Sidharth, CIT DR

Section 153Section 153ASection 153B(1)(a)Section 153D

section 153D of the Act was inserted by the Finance Act, 2007 w.e.f. 1.6.2007. In our humble understanding of said provision, the legislative intent for insertion of said provision is clear inasmuch as prior to insertion of provision u/s.153D, there was no provision for taking approval in cases of assessment or reassessment where search 33 ITA Nos.717 to 721/Del./2021

DCIT CENTRAL CIRCLE-8, NEW DELHI vs. AMOLAK SINGH BHATIA, BILASPUR

In the result, all the cross objections filed by the assessee are allowed as above and all the appeals of the Revenue are dismissed as infructuous

ITA 720/DEL/2021[2007-08]Status: DisposedITAT Delhi18 Apr 2023AY 2007-08

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri P. Praveen Sidharth, CIT DR

Section 153Section 153ASection 153B(1)(a)Section 153D

section 153D of the Act was inserted by the Finance Act, 2007 w.e.f. 1.6.2007. In our humble understanding of said provision, the legislative intent for insertion of said provision is clear inasmuch as prior to insertion of provision u/s.153D, there was no provision for taking approval in cases of assessment or reassessment where search 33 ITA Nos.717 to 721/Del./2021

DCIT CENTRAL CIRCLE-8, NEW DELHI vs. AMOLAK SINGH BHATIA, BILASPUR

In the result, all the cross objections filed by the assessee are allowed as above and all the appeals of the Revenue are dismissed as infructuous

ITA 717/DEL/2021[2004-05]Status: DisposedITAT Delhi18 Apr 2023AY 2004-05

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri P. Praveen Sidharth, CIT DR

Section 153Section 153ASection 153B(1)(a)Section 153D

section 153D of the Act was inserted by the Finance Act, 2007 w.e.f. 1.6.2007. In our humble understanding of said provision, the legislative intent for insertion of said provision is clear inasmuch as prior to insertion of provision u/s.153D, there was no provision for taking approval in cases of assessment or reassessment where search 33 ITA Nos.717 to 721/Del./2021

DCIT CENTRAL CIRCLE-8, NEW DELHI vs. AMOLAK SINGH BHATIA, BILASPUR

In the result, all the cross objections filed by the assessee are allowed as above and all the appeals of the Revenue are dismissed as infructuous

ITA 718/DEL/2021[2005-06]Status: DisposedITAT Delhi18 Apr 2023AY 2005-06

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri P. Praveen Sidharth, CIT DR

Section 153Section 153ASection 153B(1)(a)Section 153D

section 153D of the Act was inserted by the Finance Act, 2007 w.e.f. 1.6.2007. In our humble understanding of said provision, the legislative intent for insertion of said provision is clear inasmuch as prior to insertion of provision u/s.153D, there was no provision for taking approval in cases of assessment or reassessment where search 33 ITA Nos.717 to 721/Del./2021

DCIT CENTRAL CIRCLE-8, NEW DELHI vs. AMOLAK SINGH BHATIA, BILASPUR

In the result, all the cross objections filed by the assessee are allowed as above and all the appeals of the Revenue are dismissed as infructuous

ITA 721/DEL/2021[2003-04]Status: DisposedITAT Delhi18 Apr 2023AY 2003-04

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri P. Praveen Sidharth, CIT DR

Section 153Section 153ASection 153B(1)(a)Section 153D

section 153D of the Act was inserted by the Finance Act, 2007 w.e.f. 1.6.2007. In our humble understanding of said provision, the legislative intent for insertion of said provision is clear inasmuch as prior to insertion of provision u/s.153D, there was no provision for taking approval in cases of assessment or reassessment where search 33 ITA Nos.717 to 721/Del./2021

KAMAL KANT VERMA,HAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, KANPUR

In the result, all the appeals are allowed

ITA 53/LKW/2022[2018-2019]Status: HeardITAT Lucknow20 Nov 2024AY 2018-2019

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 153ASection 153D

section 153A of the Income Tax Act, 1961. 3. That the learned assessing officer has erred in making addition arbitrarily without any relevance or nexus to the seized material. 4. That the assessment order passed by Ld. AO is without jurisdiction and bad in law as without valid and lawful approval u/s. 153D of the Income

SACHIN VERMA,HAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - II, KANPUR

In the result, all the appeals are allowed

ITA 59/LKW/2022[2018-2019]Status: DisposedITAT Lucknow20 Nov 2024AY 2018-2019

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 153ASection 153D

section 153A of the Income Tax Act, 1961. 3. That the learned assessing officer has erred in making addition arbitrarily without any relevance or nexus to the seized material. 4. That the assessment order passed by Ld. AO is without jurisdiction and bad in law as without valid and lawful approval u/s. 153D of the Income