What is 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO authority for?

Reasons for reopening an assessment must be specific and not vague, scanty, or based on borrowed satisfaction. The Assessing Officer must quantify the escaped income.

How many judgments cite 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO?

295 judgments on BharatTax cite 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO (338 ITR 51), spanning 2012 to 2026.

Which sections of the Income Tax Act does 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 68, Section 133(6), Section 142(1).

394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO (338 ITR 51)

Income Tax Officer, Kolkata vs. Alcom Investment Pvt. Ltd., Kolkata

In the result, the appeal of the revenue is dismissed and the cross objection of the assessee is allowed

ITA 16/KOL/2024[2008-09]Status: DisposedITAT Kolkata17 Jan 2025AY 2008-09

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 132Section 133(6)Section 142(1)Section 143(2)Section 147Section 148Section 45

…nsel cited a decision passed by the Hon’ble Supreme Court in the case of Kelvinator (320 ITR 561), decision of Hon’ble Delhi High Court in the case of SFIL Stock Broking Ltd. (325 ITR 285), Sarthak Securities Ltd. (329 ITR 110) and Signature Hotels Pvt. Ltd. (338 ITR 51). 8. Upon hearing the submission of the Ld. Counsel for the respective parties, we have perused the order of Ld. CIT(A) and the facts of the case of the assessee. It is the case of the assessee that case of the assessee was reopened by issuing notice u/s 148 of the Act which were issued on 26.03.2015. There is no denying to this fact that the reo…

Begraj Agarwal & Ors HUF, Kolkata vs. I.T.O., Ward - 34(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1370/KOL/2024[2013-2014]Status: DisposedITAT Kolkata15 Jan 2025AY 2013-2014

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito, Ward 34(1), Kolkata Begraj Agarwal & Ors. Huf Aaykar Bhavan Poorva, 110, Diamond Heritage, Unit No.609, Strand Road, Kolkata-700001 Shantipally, Kolkata-700107, Vs. West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabhb8295F Assessee By : Shri S.M. Surana, Ar Revenue By : Shri Amuldeep Kaur, Dr Date Of Hearing: 19.12.2024 Date Of Pronouncement : 15.01.2025

For Appellant: Shri S.M. Surana, ARFor Respondent: Shri Amuldeep Kaur, DR

Section 139(1)Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 68

…vs. Smt Paramji Kaur (2009) 311 ITR 38 (Punjab and Haryana) ii. CIT vs. Sfil Stock Broking Ltd. (2010) 325 ITR 285 (Delhi) iii. ITO Vs. Sarthak Securities (P.) Ld. (2010) 329 ITR 110 (Delhi) iv. Signature Hotels P. Ld. Vs. ITO Another (2011) 338 IT 51 (supra) 338 ITR 51 v. Akshar Builders and Developers Vs. ACIT WP No. 14490 of 2018 (Bombay) vi. Ankita A. Choksey Vs. ITO (Bombay) WP No. 3344 of 2018 Begraj Agarwal & Ors Huf; A.Y. 2013-14 06. The ld. Authorized Representative therefore prayed that in view of the ratio laid down in the above decisions, wherein the ld. AO has reopened the assessment on the basis of…

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2024[2017-18]Status: DisposedITAT Delhi02 Jan 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.2442 to 2445/Del/2023 (ASSESSMENT YEARS 2013-14 to 2016-17) DCIT, Lotus Herbals Pvt. Ltd., CC-20, Delhi. Room No.269A, 2 nd Floor, ARA Vs. Centre, E-2, Jhandewalan, New Delhi-110055. PAN-AAACL0198F (Appellant) (Respondent) Assessee by Shri Rohit Jain, Adv. and Shri Shivam Gupta, CA Department by Sh. Mukesh Jha, CIT DR and Ms. Pooja Swroop, CIT-DR 29.09.2025 Date of Hearing Date of Pronouncement 23.12.2025 O R D E R PER MANISH AGARWAL, AM: These are five…

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2024[2013-14]Status: DisposedITAT Delhi02 Jan 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.2442 to 2445/Del/2023 (ASSESSMENT YEARS 2013-14 to 2016-17) DCIT, Lotus Herbals Pvt. Ltd., CC-20, Delhi. Room No.269A, 2 nd Floor, ARA Vs. Centre, E-2, Jhandewalan, New Delhi-110055. PAN-AAACL0198F (Appellant) (Respondent) Assessee by Shri Rohit Jain, Adv. and Shri Shivam Gupta, CA Department by Sh. Mukesh Jha, CIT DR and Ms. Pooja Swroop, CIT-DR 29.09.2025 Date of Hearing Date of Pronouncement 23.12.2025 O R D E R PER MANISH AGARWAL, AM: These are five…

Harpreet Kaur Kaushik Manek, Bhavnagar vs. The Dy.CIT., Circle-1, Bhavnagar

In the result, appeal filed by the assessee is partly allowed for statistical purpose

ITA 109/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2011-12

Section 133(6)Section 139Section 142(1)Section 147Section 148Section 234ASection 271(1)(c)Section 69

…e Hon’ble Gujarat High Court in the case of Paresh Babubhai Bhalani vs. ITO (supra), Harikishan S. Virmani vs. DCIT (2017) 394 ITR 146. The Ld. AR also relied upon the decision of Hon’ble Delhi High Court in case of Signature Hotels P. Limited vs. ITO (2012), 338 ITR 51. Thus, the CIT(A) was not right in upholding the order of the Assessing Officer passed under Section 147 read with Section 143(3) of the Act which is barred by limitation. 5.2 As regards to ground nos.2, 3, 4 & 5 relating to the merits regarding unexplained investment under Section 69 of the Act, the Ld. AR submitted that the Assessing Officer ma…

Rahul Premier India Agency Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 4(), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1414/KOL/2024[2013-2014]Status: DisposedITAT Kolkata09 Oct 2024AY 2013-2014

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 132(4)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

…d to first enquire into the issue after receiving information otherwise the re-opening can not be sustained. The case of the assessee is squarely covered by a series of decisions namely SFIL Stock Broking 325 ITR 285 ( Del), and Signature Hotel Pvt Ltd VS ITO 338 ITR 51 ( Del) . In both the above decisions , the Hon’ble court has held that the AO has to apply his mind to the information received and independently arrive at a belief that income has escaped. In the case of CIT Vs Insecticide India Ltd. 357 ITR 330(Del) the Hon’ble Court has held that the re-opening can not be made on the reasons which did not menti…