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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

Assistant Commissioner of Income Tax (Central)-1, Indore vs. Shri Ritesh Jain, Indore

ITA 794/IND/2018[2010-11]Status: DisposedITAT Indore12 Jan 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani & It(Ss)Ano.14/Ind/2022 (Assesssment Year 2011-12

Section 139Section 143(2)Section 147Section 148

dealings, he cannot obdurately adhere to his suspicions and treat the subscribed capital as the undisclosed income of the Company. 22. Further, being the reassessment proceedings, where the AO is ceased of certain information and documents, it is incumbent upon him to confront the same to the assessee and allow

The Tata Power Co. Ltd, Mumbai vs. Addl CIT RG 2(3), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 753/MUM/2013[2008-09]Status: DisposedITAT Mumbai12 Jan 2024AY 2008-09

Bench: Shri Vikas Awasthy& Ms. Padmavathy.Sआअसं.753/मुं/2013 (िन.व. 2008-09) The Tata Power Co. Ltd. Corporate Center, Block ‘B’, 5Th Floor, 34, Sant Thukaram Road, Carnak Bunder, Mumbai 400 009. Pan: Aaact-0054-A ...... अपीलाथ"/Appellant बनाम Vs. Additional Commissioner Of Income Tax, Range 2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent

For Appellant: Shri Nitesh Joshi with Shri Ninad PatadeFor Respondent: Shri Manoj Kumar&
Section 143(3)Section 14ASection 14A(2)

calculating deduction u/s. 80IA of the Act in respect of any of the units. Similar issue was raised by the Assessing Officer in reassessment proceedings initiated for Assessment Year 2006-07. However, considering the submissions of the assessee, reassessment proceedings were dropped by the Assessing Officer. 23. The ld. Departmental

Anuj Chaudhary, Ghaziabad vs. ITO, Ward- 1(1), Ghaziabad

ITA 3453/DEL/2018[2009-10]Status: DisposedITAT Delhi12 Jan 2024AY 2009-10

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Date of Hearing
Section 139Section 144Section 147Section 148Section 69

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER and SHRI ANUBHAV SHARMA, JUDICIAL

Xebec Hospitality P.Ltd, New Delhi vs. ITO, Ward-27(4), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 877/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Jan 2024AY 2010-11

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Ms. Chinu Bhasin , CAFor Respondent: Shri P.N. Barnwal, CIT-DR
Section 133(6)Section 147Section 153ASection 271(1)

That on the facts & in the circumstances of the case and in law, the Ld. CIT(A)/AO erred in initiating reassessment proceedings under section 147 of the Act 3. 2.1. without providing an opportunity of being heard, thereby violating the principles of natural justice. 4. 2.2. without any tangible

Akik Marketing India Pvt Ltd, New Delhi vs. ITO Ward - 2(1), New Delhi

ITA 4559/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Jan 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year : 2010-11 Akik Marketing India Pvt. Ltd. Vs. Ito, N-39, Ground Floor, Ward 2(1), Greater Kailash-I, New Delhi New Delhi-110048 Pan : Aaaca6579K (Appellant) (Respondent) Assessee By : Shri Gurjeet Singh, Ca & Shri Shantanu Jain, Adv. Revenue By : Shri Kanav Bali, Sr. Dr

For Appellant: Shri Gurjeet Singh, CA &For Respondent: Shri Kanav Bali, Sr. DR
Section 147Section 68

ruled against the appellant.” 4559/Del/2019 4. Assessee is in appeal raising following grounds: “1. Because the action for initiation, continuation and conclusion of reassessment proceedings is being challenged on facts and law. 2. Because the action for the assumption of jurisdiction of reassessment proceedings and the misapplication of the jurisdiction

Shri Rohit Sethi, Indore vs. The DCIT 2(1), Indore

In the result, the appeal is allowed

ITA 118/IND/2023[2008-09]Status: DisposedITAT Indore10 Jan 2024AY 2008-09

Bench: Shri Vijay Pal Rao & Shri Manish Boradassessment Year:2008-09 Shri Rohit Sethi, Dcit, 62, Shiv Vilas Palace, 2(1), बनाम/ Rajwada, Indore. Vs. Indore. (Assessee / Appellant) (Revenue / Respondent) Pan: Appps9427R Assessee By Shri S.S.Solanki, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 02.01.2024 Date Of Pronouncement 10.01.2024

Section 143(3)Section 148

assessment u/s 143(3)/147/254 of the Income-tax Act, 1961, was framed assessing the income at Rs. 35,07,800/-. In the said reassessment proceedings, addition of Rs. 30 lakhs was made towards unexplained investment allegedly made by the assessee by way of giving cash to Mr. Nilesh Ajmera ... R.Sethi in Dubai Flat. Based on these details appearing in the seized documents, case of the assessee was reopened and during the course of reassessment proceedings, the assessee admitted to have given Rs. 50 lakhs only to Nilesh Ajmera, but denied to have paid cash amount of Rs. 30 lakhs

Monika Chakarvarty, Kota vs. DCIT, Circle-2, Circle

In the result, both appeals of the assessee are allowed

ITA 413/JPR/2023[2017-2018]Status: DisposedITAT Jaipur10 Jan 2024AY 2017-2018

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 412 & 413/JPR/2023 fu/kZkj.k o"kZ@Assessment Years : 2012-13 & 2017-18 Monika Chakarvarty Prop. M/s Vipin Medicals, Nayapura, Kota. cuke Vs. DCIT Circle, Kota LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AELPC 3801 J vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Sidharth Ranka (Adv.), Shri Sorabh Harsh (Adv.) jktLo dh vksj ls@ Revenue by : Shri Anup Singh (Ad

For Appellant: Shri Sidharth Ranka (Adv.) &For Respondent: Shri Anup Singh (Addl. CIT) a
Section 142(1)Section 143(1)Section 147Section 148Section 69A

Appeals) has grossly erred in not dealing with the additional ground raised by assessee appellant wherein legality of the reassessment proceedings was challenged by the assessee appellant. 1.1 That on the facts and circumstances of the case and in law, the Id. Assessing Officer has grossly erred in not providing ... filed at Rs. 236430. It is to be noted that the original return was field on 19.09.2012. Further in its submission in reassessment proceeding the assessee has submitted that the cash deposit of Rs. 8687000/-. It is important to see the facts of the case as existing in the original

Monika Chakarvarty, Kota vs. DCIT, Circle-2, Kota

In the result, both appeals of the assessee are allowed

ITA 412/JPR/2023[2012-2013]Status: DisposedITAT Jaipur10 Jan 2024AY 2012-2013

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Sidharth Ranka (Adv.) &For Respondent: Shri Anup Singh (Addl. CIT) a
Section 142(1)Section 143(1)Section 147Section 148Section 69A

Appeals) has grossly erred in not dealing with the additional ground raised by assessee appellant wherein legality of the reassessment proceedings was challenged by the assessee appellant. 1.1 That on the facts and circumstances of the case and in law, the Id. Assessing Officer has grossly erred in not providing ... filed at Rs. 236430. It is to be noted that the original return was field on 19.09.2012. Further in its submission in reassessment proceeding the assessee has submitted that the cash deposit of Rs. 8687000/-. It is important to see the facts of the case as existing in the original

Coral Venture Private Limited, Mumbai vs. Assistant Commissioner of Income Tax 12(1)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2483/MUM/2023[2010-2011]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-2011

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2010-11

For Appellant: Mr. Subhash Chhajed and Mr. Hitesh RathodFor Respondent: Mr. H.M. Bhatt, Sr. DR
Section 143(3)Section 147Section 148Section 151

facts and circumstances of the case and in law, the Ld. CIT(A), National Faceless Appeal Centre ("NFAC"), Delhi has erred in upholding the reassessment proceedings initiated u/s 147 of the IT Act without serving the notice u/s 148 of the Act within the period of six years from ... Delhi has erred in upholding the reassessment (A) NFAC, Delhi has erred in upholding the reassessment (A) NFAC, Delhi has erred in upholding the reassessment proceedings initiated u/s 147 of the IT Act ignoring the contention proceedings initiated u/s 147 of the IT Act ignoring the contention proceedings initiated

Royal Fortune Business Consultants India Pvt. Ltd., Kolkata vs. ITO, Kolkata

In the result, the appeal of the assessee stands dismissed

ITA 959/KOL/2023[2012-13]Status: DisposedITAT Kolkata09 Jan 2024AY 2012-13

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A No.959/Kol/2023 Assessment Year: 2012-13 Royal Fortune Business Consultants India Pvt. Ltd. ........................……Appellant Flat No.2C, S.P. Block, 1St Floor, Raja Subodh Chandra Mullick Road, Kolkata- 700092. [Pan: Aadcr9408F] Vs. Ito, Ward-10(4), Kolkata......................…................…........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri B. K. Singh, Jcit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 04, 2024 Date Of Pronouncing The Order : January 09, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 27.07.2023 Of The National Faceless Appeal Centre (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. No One Has Put In Appearance On The Behalf Of The Assessee Despite Notice. However, On Earlier Date Also I.E. 08.11.2023, The Notice Was Issued To The Assessee But No One Has Put In Appearance & The Case Was Adjourned For Today. It Seems That The Assessee Is Not Interested In Pursuing Its Appeal, Therefore, We Proceed To Adjudicate This Appeal After Hearing The Ld. Dr & After Going Through The Records.

Section 147Section 151Section 250

assessment order passed by the Ld. A.O. u/s. 147 r.w.144 is bad in law and is liable to be quashed. 2. For that the reassessment proceedings initiated after 4 years from the end of the assessment year without there being any failure on the part of the assessee to disclose ... suffers from borrowed satisfaction, therefore the entire proceedings are bad in law and ab initio void. Moreover it appears that before initiation of reassessment proceedings either no approval was obtained as mandated u/s 151 or the approval, if any, was granted mechanically. 4. For that the Ld. AO erred

Vg Rajamani Agencies Pvt. Ltd., Coimbatore vs. PCIT-1, Coimbatore

In the result, the appeal filed by the assessee is allowed and the order passed by the Commissioner dated 14

ITA 812/CHNY/2023[2017-18]Status: DisposedITAT Chennai09 Jan 2024AY 2017-18

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.812/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) M/S. V.G. Rajamani Agencies Pvt. Ltd. Pcit-1 बनाम/ Vs. 66, Subbiah Mudaliar Street, Coimbatore. Thomas Street, Coimbatore-641 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcv-1589-R (अपीलाथ"/Appellant) : (!"थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri S. Sridhar (Advocate) Erode - Ld.Ar !"थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 09-01-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri S. Sridhar (Advocate) Erode - Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 133(6)Section 144Section 147Section 148Section 263

substitute the judgment of Ld. AO and impose another view on him. 6. The second pertinent fact is that the assessee has assailed the reassessment proceedings before first appellate authority which was pending for adjudication at the time of revision of the order. In such a case, the ratio

Golden Vats Private Limited, Chennai vs. ACIT, Central Circle 3(2), Chennai

In the result, the appeal filed by the assessee is allowed and the order passed by the Commissioner dated 14

ITA 416/CHNY/2023[2017-18]Status: DisposedITAT Chennai09 Jan 2024AY 2017-18

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.416/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) M/S. Golden Vats Private Limited Acit बनाम New No.272, 3Rd Floor, Central Circle-3(2), Avvai Shanmugam Salai, Chennai. / Vs. Gopalapuram , Chennai-600 086. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccg-9782-G (अपीलाथ"/Appellant) : (!"थ" / Respondent)

For Appellant: Shri T.S. Lakshmi Venkatraman (FCA)- Ld.ARFor Respondent: Shri V. Nandakumar (CIT)- Ld. DR
Section 143(3)Section 147Section 148Section 151Section 153CSection 263Section 263(1)Section 3Section 40

basis of which impugned assessment was framed. 3.2 It also transpired that on the date of issue of notice u/s 153C, reassessment proceedings u/s 147 was pending against the assessee for this year. The assessment framed u/s 143(3) was already reopened and notice u/s 148 was issued ... components were taxable and the assessee had not disclosed the true and full material facts in the return of income. Therefore, the reassessment proceedings were valid one and within the framework of law. Further, the reassessment proceedings got abated consequent to search assessment proceedings. The other arguments made

Gurbans Kaur Virk, Karnal vs. The Income Tax Officer, Ward 5, Karnal, Income Tax Office

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

ITA 3433/DEL/2023[2012-13]Status: DisposedITAT Delhi09 Jan 2024AY 2012-13

Bench: Shri M. Balaganeshgurbans Kaur Virk, Vs. Ito, H. No. 9, Street No. 7, Ward-5, Near Vijeta Public Karnal School, Karan Vihar, Karnal Pan: Albpv0645G Assessee By : Shri Amit Kaushik, Adv Revenue By: Ms. Kirti Sankratyayan, Sr. Dr Date Of Hearing 04/01/2024 Date Of Pronouncement 09/01/2024

For Appellant: Shri Amit Kaushik, AdvFor Respondent: Ms. Kirti Sankratyayan, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 234BSection 69A

deposit of Rs. 27,45,000/- as income from undisclosed source of assessee and made an addition u/s 69A of the Act and the reassessment proceedings were completed u/s 144 read with Section 147 of the Act on 05.12.2019. Even before the ld CIT(A), no compliance was made

M/S. Delighted Holdings (P) Ltd., Kolkata vs. Dcir, Cir-8(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 624/KOL/2023[2011-12]Status: DisposedITAT Kolkata08 Jan 2024AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 147Section 148

material facts at the time of making assessment, 7 I.T.A. No. 624/Kol/2023 Assessment Year: 2011-12 M/s Delighted Holdings Pvt. Ltd. initiation of reassessment proceedings after expiry of four years from the end of relevant assessment year on the basis of report of investigation cannot be sustained ... decision as discussed above, we are, therefore, inclined to hold that AO has no jurisdiction to re-open the assessment and accordingly quash reassessment proceedings as well as consequent order. Ground no. 1 raised by the assessee is allowed on legal issue. 9. Even on merit the appeal

Karamshi Jethabhai Somaiya Trust, Mumbai vs. Income Tax Officer(Exemption), Mumbai

The appeal of the assessee is allowed

ITA 2608/MUM/2023[2009-10]Status: DisposedITAT Mumbai08 Jan 2024AY 2009-10

Bench: Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri. K. Gopal a/w Ms. NehaFor Respondent: Shri P.D. Chougule , Sr. DR
Section 12ASection 139Section 142Section 143Section 143(3)Section 147Section 148

Paper Book). The Ld. AR accordingly argued that the information basis which the assessing officer has initiated the reassessment proceedings is from the records which was already available with the assessing officer and therefore it cannot be said that the assessee has not disclosed the information fully and truly. Therefore

Suksham Finlease & Investment P.Ltd, New Delhi vs. ITO, Ward-24(3), New Delhi

In the result, appeal of the assessee is allowed

ITA 8321/DEL/2018[2009-10]Status: DisposedITAT Delhi08 Jan 2024AY 2009-10
Section 147Section 151Section 234BSection 69C

said reasons recorded and the ld. AO disposed of those objections by way of a speaking order dated 23.11.2016 and thereafter proceeded with the reassessment proceedings. In the reassessment proceedings, the ld AO made disallowance of Rs. 46,07,275/- representing losses claimed by the assessee due to client code ... portion of the said tribunal order is reproduced hereunder:- "4. The ground No. 1 to 1.4 of the appeal relates to validity of the reassessment proceeding. In the ground No. 1.1, the assessee has challenged "reason to believe" on the ground that same are not specific and lacking reliable

DCIT, Cir-3(3)(1), Mumbai vs. East West Pipeline Pvt Ltd., Mumbai

Accordingly, without any adjudication upon the merits, Ground No. 5 to 8 to raised by the Revenue are dismissed as being infructuous

ITA 1999/MUM/2023[2014-15]Status: DisposedITAT Mumbai05 Jan 2024AY 2014-15

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Biswanath Das
Section 143(3)Section 144BSection 147Section 73(1)

appeal: 2. "1. Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified in law in quashing the reassessment proceedings u/s 147 of the Income Tax Act, 1961 holding reopening of assessment as change of opinion when on the issue of a loss of Rs.6 ... Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified in law in quashing the reassessment proceedings u/s 147 of the Income Tax Act, 1961 on the above ground without appreciating the ratio of Supreme Court in the case of M/s. Phool Chand Bajrang

Mavenir Uk Holdings, United Kingdom vs. ACIT, Circle Int. Taxation 2(2)(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 185/DEL/2023[2013-14]Status: DisposedITAT Delhi05 Jan 2024AY 2013-14

Bench: Sh. Challa Nagendra Prasaddr. B. R. R. Kumar

For Appellant: Sh. Manuj Sabharwal, Adv. &For Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 144Section 144CSection 144C(4)Section 147Section 148Section 151Section 234A

limitation, bad in law and beyond jurisdiction for want of a proper and valid service to the Appellant, thereby vitiating the subsequent assessment/ reassessment proceedings. 5. On the facts and circumstances of the case & in law, the Appellant ought to be provided with the copy of sanction obtained under section ... prior to initiating the reassessment proceedings and other documents relied upon by the Ld. AO in the draft assessment thereby providing an opportunity to the Appellant to rebut the same before confirming the proposed addition under consideration. 6. On the facts and circumstances of the case & in law, the addition

Shri Mohan Lal Gupta, Shimla vs. Pr.CIT-1, Chandigarh

In the result, appeal of the Assessee is partly allowed

ITA 119/CHANDI/2021[2011-12]Status: DisposedITAT Chandigarh04 Jan 2024AY 2011-12

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Aditya Sood, AdvocateFor Respondent: Smt. Kusum, CIT DR
Section 143(3)Section 147Section 148Section 263Section 54F

were initiated and notice under section 148 was issued. In response to the notice, the assessee filed his return of income and thereafter, the reassessment proceedings were completed vide order dt. 21/12/2017 passed under section 143(3) r.w.s 147 of the Act. 4. In the reassessment order so passed under ... Jagjit Nagar(Solan) which was sold for a consideration of Rs. 23,99,000/-. 8. Firstly, it was submitted that the subject matter of reassessment proceedings and in particular, the reasons for initiating the reassessment proceedings was excess claim of deduction u/s 54F of the Act. Therefore, except

Creative Realmart Pvt. Ltd., Jaipur vs. ITO, Ward-3(5), Jaipur

ITA 599/JPR/2023[2013-14]Status: DisposedITAT Jaipur04 Jan 2024AY 2013-14
For Appellant: Sh. P.C. Parwal (CA)For Respondent: Sh. A.S. Nehra (Addl.CIT)
Section 133ASection 143(1)Section 144Section 147Section 148Section 68

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “A” JAIPUR श्री संदीप गोसाई, न्यायिक