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“reassessment proceedings”

ReassessmentSections 147-151Sections 147-1518,150 judgments

The decision most relied on for reassessment proceedings is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on reassessment proceedings

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

ITO v. Lakhmani Mewal Das
103 ITR 437 · 1976 · Supreme Court
721
citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

PCIT v. Meenakshi Overseas Pvt. Ltd.
395 ITR 677 · 2017 · High Court
471
citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Ranbaxy Laboratories Ltd. v. CIT
336 ITR 136 · 2011 · High Court
398
citing judgments

In reassessment proceedings under Section 147/148, the Assessing Officer can assess other income not specified in the original notice if the initial ground for reopening assessment is found to be valid. However, if the income for which the assessment was initially reopened is found not to have escaped assessment, the Assessing Officer cannot proceed to assess any other income.

Judgments citing reassessment proceedings

Hcl Technologies Sweden Ab(Successor of Hcl Sweden Ab), New Delhi vs. ACIT, Circle- Int. Tax 2(1)(1), New Delhi

ITA 583/DEL/2021[2012-13]Status: DisposedITAT Delhi29 Mar 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

source. The cases of the appellants were reopened by issuance of notice u/s 148 of the Act. During the course of reassessment proceedings, the draft assessment order was passed wherein the amount received by the assessee was held to be taxable as ‘Fee for technical services

Hcl America Inc., New Delhi vs. ACIT, Circle-Int. Tax 2(1)(1), New Delhi

ITA 542/DEL/2021[2012-13]Status: DisposedITAT Delhi29 Mar 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

source. The cases of the appellants were reopened by issuance of notice u/s 148 of the Act. During the course of reassessment proceedings, the draft assessment order was passed wherein the amount received by the assessee was held to be taxable as ‘Fee for technical services

Hcl Great Britain Limited, New Delhi vs. ACIT, Circle-Int. Tax 2(1)(1), New Delhi

ITA 541/DEL/2021[2012-13]Status: DisposedITAT Delhi29 Mar 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

source. The cases of the appellants were reopened by issuance of notice u/s 148 of the Act. During the course of reassessment proceedings, the draft assessment order was passed wherein the amount received by the assessee was held to be taxable as ‘Fee for technical services

Thota Venkateswara Rao, Kakinada vs. Income Tax Officer, Ward-1, Kakinada

In the result, appeal of the assessee is allowed

ITA 221/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam28 Mar 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.221/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2017-18) Thota Venkateswara Rao Vs. Income Tax Officer D.No.67-21-12/4 Ward-1 Lb Nagar Ss Kakinada Kakinada [Pan : Abipt6770F] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Aparna Villuri, DR
Section 147Section 148Section 187(3)Section 69A

case. 2. The learned Commissioner of Income Tax (Appeals) ought to have quashed the notice issued u/s 148 as invalid and the consequent reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) is not justified in sustaining the addition

Saurabh Agrotech (P) Ltd, Alwar vs. DCIT, Central Circle, Alwar

In the result, the appeal filed by the assessee is partly allowed as per terms indicated above

ITA 154/JPR/2024[2011-12]Status: DisposedITAT Jaipur28 Mar 2024AY 2011-12

Bench: SHRI MANISH BORAD (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri. Ajay Malik (CIT) a
Section 132Section 143(3)Section 14ASection 153ASection 801B

search no incriminating material is found, in case of completed/unabated assessment, the only remedy available to the Revenue would be to initiate the reassessment proceedings under 7 Saurabh Agrotech (P) Ltd. Vs. DCIT sections 147/48 of the Act, subject to fulfilment of the conditions mentioned in sections 147/148

Deputy Commissioner of Income Tax -23(1), Mumbai vs. Kalpsaru Diamonds, Mumbai

In the result, the grounds raised by the assessee as well as In the result, the grounds raised by the assessee as well as Revenue are allowed for statistical purposes

ITA 3400/MUM/2023[2012-13]Status: DisposedITAT Mumbai28 Mar 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Years: 2012-13 Kalpsaru Diamonds, Acit 23(2), Jw 8040/250, Bharat Diamond Piramal Chambers, Vs. Bourse, Bkc, Bandra East, Mumbai-400013. Mumbai-400051. Pan No. Aaafk 6960 H Appellant Respondent Assessment Years: 2012-13 Dy. Cit-23(1), Kalpsaru Diamonds, Room No. 511, Fifth Floor, Jw 8040/250, Bharat Diamond Piramal Chambers, Parel, Vs. Bourse, Bkc, Bandra East, Lalbaugh-400012. Mumbai-400051. Pan No. Aaafk 6960 H Appellant Respondent

For Respondent: Mr. Ajay Singh
Section 143(3)Section 148Section 69C

reje the Ld. CIT(A) has rejected the contention of the assessee that cted the contention of the assessee that reassessment proceedings are invalid due to no failure on the part reassessment proceedings are invalid due to no failure on the part reassessment proceedings are invalid due to no failure ... reassessment The Ld. CIT(A) also rejected the challenge of the reassessment The Ld. CIT(A) also rejected the challenge of the reassessment proceedings on the ground that notice u/s 148 of the Act was proceedings on the ground that notice u/s 148 of the Act was proceedings

Kalpsaru Diamonds, Mumbai vs. ACIT 23(2), Mumbai

In the result, the grounds raised by the assessee as well as In the result, the grounds raised by the assessee as well as Revenue are allowed for statistical purposes

ITA 3223/MUM/2023[2012-13]Status: DisposedITAT Mumbai28 Mar 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Years: 2012-13 Kalpsaru Diamonds, Acit 23(2), Jw 8040/250, Bharat Diamond Piramal Chambers, Vs. Bourse, Bkc, Bandra East, Mumbai-400013. Mumbai-400051. Pan No. Aaafk 6960 H Appellant Respondent Assessment Years: 2012-13 Dy. Cit-23(1), Kalpsaru Diamonds, Room No. 511, Fifth Floor, Jw 8040/250, Bharat Diamond Piramal Chambers, Parel, Vs. Bourse, Bkc, Bandra East, Lalbaugh-400012. Mumbai-400051. Pan No. Aaafk 6960 H Appellant Respondent

For Respondent: Mr. Ajay Singh
Section 143(3)Section 148Section 69C

reje the Ld. CIT(A) has rejected the contention of the assessee that cted the contention of the assessee that reassessment proceedings are invalid due to no failure on the part reassessment proceedings are invalid due to no failure on the part reassessment proceedings are invalid due to no failure ... reassessment The Ld. CIT(A) also rejected the challenge of the reassessment The Ld. CIT(A) also rejected the challenge of the reassessment proceedings on the ground that notice u/s 148 of the Act was proceedings on the ground that notice u/s 148 of the Act was proceedings

Sagar Babanrao Awatade, Navi Mumbai vs. Income Tax Officer, Ward-1, Panvel

Appeal is allowed

ITA 79/PUN/2024[2014-15]Status: DisposedITAT Pune27 Mar 2024AY 2014-15

Bench: Shri Satbeer Singh Godaraआयकर अपील सं. /Ita No.79/Pun/2024 "नधा"रण वष" / Assessment Year : 2014-15

For Appellant: Shri Harsh Goyal &For Respondent: Smt. Neha Deshpande
Section 139Section 142Section 143Section 143(3)Section 144Section 147Section 148

under this section, record his reasons for doing so." 9. By going through the aforesaid definition it is abundantly clear that before opening any reassessment proceedings the Assessing Officer has to record reason to believe that any income chargeable to tax has escaped assessment for the relevant assessment year ... corresponding sale transaction required to be verified. Now the law is no more res integra, inasmuch as, the Assessing Officer cannot take recourse to reassessment proceeding just for the 6 ITA.No.79/PUN/2024 Sagar Babanrao Awatade purpose of verification. There is a difference between reason to believe and reason to suspect

Sreepada Venkatasubbamma, Achanta vs. Income Tax Officer, Ward-1, Palakol

In the result, appeal of the assessee is allowed for statistical purpose

ITA 29/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam26 Mar 2024AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.29/Viz/2024 (ननधधारण वर्ा / Assessment Year : 2013-14) Sreepada Venkatasubbamma Vs. Income Tax Officer D.No.4-166 Ward-1 Brahmana Veedhi Palakol Penumanchili, Achanta West Godavari Dist [Pan : Djzps9581M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Aparna Villuri, DR
Section 144Section 147Section 148Section 69A

Appeals) ought to have held that the notice issued u/s 148 of the Act as invalid and ought to have quashed the consequent reassessment proceedings as void-ab-initio. 4. Without prejudice to Ground No.2 and Ground No.3, the learned Commissioner of Income Tax (Appeals) ought to have directed

Kapil Infra Avenues Private Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle-1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated hereinabove

ITA 258/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam26 Mar 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.258/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2017-18) Kapil Infra Avenues Private Vs. Deputy Commissioner Of Limited, Income Tax, Vijayawada. Circle-1(1), Pan: Aadck 4944 P Vijayawada. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessee By : Sri Gvn Hari, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Aparna Villuri, Sr. Ar सुिवधईकीतधरीख/ Date Of Hearing : 21/03/2024 घोर्णधकीतधरीख/Date Of : 26/03/2024 Pronouncement O R D E R Per S. Balakrishnan:

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148

reopened after verification of financials of the company and after recording reason for reopening and with prior approval of the competent authority. During the reassessment proceedings, it was observed by the Ld. 3 AO that the assessee has paid interest on sale advances ranged from 10% to 14% and average

Google Ireland Limited, Ireland vs. DCIT (It), JCIT(OSD) (It) - Circle 1(1), Bengaluru

In the result, the appeals filed by the assessee are allowed

ITA 193/BANG/2024[2015-16]Status: DisposedITAT Bangalore26 Mar 2024AY 2015-16

Bench: Shri George George K.

Section 143(3)Section 148Section 195Section 201Section 9(1)(vi)

appeal in the said cases. It was held by the AO that in view of the departmental stand and the interest of the revenue, reassessment proceeding had to be completed. Accordingly, the AO IT(IT)A Nos.191 to 194/Bang/2024 Page 4 of 43 passed the draft assessment order making additions

ACIT Central-2, Bhopal vs. M/S Balaji Farms and Reality, Bhopal

Appeal is allowed and assessee’s cross-

ITA 166/IND/2022[2012-13]Status: DisposedITAT Indore22 Mar 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniacit (Central)-2, M/S.Balaji Farms & बनाम/ Bhopal Reality, Vs. 158,3Rd Floor, Zone-Ii, M.P.Nagar, Bhopal (Pan:Aalfb9630L) (Revenue/Appellant) (Assessee/Respondent)

Section 143(3)Section 147Section 148Section 271(1)(c)Section 274Section 50C

levied penalty of Rs. 59,00,000/- u/s 271(1)(c) of the Act, which is under consideration. As a matter of fact, the reassessment proceedings were initiated on the addition made during original assessment proceedings and the addition made during original assessment proceedings and the addition made during reassessment

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

ITA 1066/BANG/2023[2018-19]Status: DisposedITAT Bangalore22 Mar 2024AY 2018-19

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 234BSection 271ASection 69

ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE BEFORE SHRI

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

ITA 1065/BANG/2023[2017-18]Status: DisposedITAT Bangalore22 Mar 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 271ASection 69

ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE BEFORE SHRI

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

ITA 1064/BANG/2023[2016-17]Status: HeardITAT Bangalore22 Mar 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 271ASection 69

ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE BEFORE SHRI

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(3), Bengaluru

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

ITA 1062/BANG/2023[2015-16]Status: DisposedITAT Bangalore22 Mar 2024AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 271ASection 69

ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE BEFORE SHRI

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(3), Bengaluru

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

ITA 1061/BANG/2023[2014-15]Status: DisposedITAT Bangalore22 Mar 2024AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 271ASection 69

ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE BEFORE SHRI

Sureshchandra Seksaria HUF, Mumbai vs. ITO Ward 17(3)(4), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 531/MUM/2024[2012-13]Status: DisposedITAT Mumbai22 Mar 2024AY 2012-13

Bench: Shri Amit Shukla, Hon’Ble & Shri S Rifaur Rahman, Hon’Ble

Section 139(1)Section 143(3)Section 147Section 148Section 234ASection 250Section 69Section 69C

response thereto, the assessee filed return on 03.05.2019 for the subject assessment year declaring the same income i.e. = 1,35,800/-. During the reassessment proceedings, the assessee filed objection against the reasons for reopening which was rejected by the AO by passing an order of 17.10.2019. After hearing the assessee ... account of purchase from the said party and %68,678/- u/s 69C of the Act as notional commission. 4. In the reassessment proceedings, the assessee submitted that it is engaged in the business of bill discounting and profit from such businesses is duly disclosed in the return of income

The Agriculture Development Co.Op.Credit Society Ltd., Sidhpur vs. The ITO, Patan Ward-1, Unjha

In the result, Ground No. 3 of the assessee’s appeal is allowed for statistical purpose purposes

ITA 231/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad21 Mar 2024AY 2017-18

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri H.V. Doshi, A.RFor Respondent: Ms. Saumya Pandey Jain, Sr. D.R
Section 147Section 57Section 80PSection 80P(4)

gross interest income. 4. Ld. CIT(A) has erred in law and facts in not allowing the ground of the appellant against the reassessment proceedings initiated on the issue of claim u/s 80P allowed in respect of interest income received from co. op. banks. 5. Ld. CIT(A) has erred ... assessee against such interest income. 4. Subsequently, the case of the assessee was reopened under Section 147 of the Act. In the reassessment proceedings, the Assessing Officer denied the claim under Section 80P of the act and made addition of Rs.56,74,088/-. In the reassessment order, the Assessing Officer

The Agriculture Development Co.Op.Credit Society Ltd., Sidhpur vs. The ITO, Patan Ward-4, Unjha

In the result, Ground No. 3 of the assessee’s appeal is allowed for statistical purpose purposes

ITA 230/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad21 Mar 2024AY 2012-13

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri H.V. Doshi, A.RFor Respondent: Ms. Saumya Pandey Jain, Sr. D.R
Section 147Section 57Section 80PSection 80P(4)

gross interest income. 4. Ld. CIT(A) has erred in law and facts in not allowing the ground of the appellant against the reassessment proceedings initiated on the issue of claim u/s 80P allowed in respect of interest income received from co. op. banks. 5. Ld. CIT(A) has erred ... assessee against such interest income. 4. Subsequently, the case of the assessee was reopened under Section 147 of the Act. In the reassessment proceedings, the Assessing Officer denied the claim under Section 80P of the act and made addition of Rs.56,74,088/-. In the reassessment order, the Assessing Officer