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171 results for “reassessment”+ Section 6clear

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Key Topics

Section 148217 Section 147133 Addition to Income89 Section 143(3)59 Reassessment53 Section 15149 Section 6835 Section 26329 Reopening of Assessment25 Section 153A

MR. TASAVVER HUSAIN,FARRUKHABAD vs. ACIT , FARRUKHABAD

In the result, appeal filed by the assessee is allowed

ITA 96/AGR/2023[2017-18]Status: DisposedITAT Agra19 May 2025AY 2017-18

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singh

section (1) has been initiated; 6 | P a g e ITA No.95& 96/Agr/2023 (b) in a case where an assessment or reassessment

MR. TASAVVER HUSAIN,FARRUKHABAD vs. ACIT, FARRUKHABAD

In the result, appeal filed by the assessee is allowed

ITA 95/AGR/2023[2017-18]Status: DisposedITAT Agra19 May 2025AY 2017-18

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singh

section (1) has been initiated; 6 | P a g e ITA No.95& 96/Agr/2023 (b) in a case where an assessment or reassessment

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Section 143(2)23

HARICHARAN RATHORE,ASHOK NAGAR vs. INCOME TAX OFFICER,ASHOK NAGAR, ASHOK NAGAR

In the result, appeal filed by the assessee is allowed

ITA 472/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshharicharan Rathore, Vs. Ito, 125, Path Kheda, Ashok Ashok Nagar, Nagar, Mp Mp (Appellant) (Respondent) Pan: Csqpr0999M Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 144BSection 147Section 148Section 148ASection 151Section 151A

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

BADARIPRASAD,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, appeal filed by the assessee is allowed

ITA 473/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshbadriprasad, Vs. Income Tax Officer, Heerabagh Colony, Guna, Guna, Gwalior Gwalior (Appellant) (Respondent) Pan: Arapr6314B

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 144BSection 147Section 148Section 148ASection 151Section 151A

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

NARAYANI RATHORE,SHIVPURI vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

ITA 444/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshnarayani Rathore, Vs. Assessment Unit, Peeroth Shivpuri, Income Tax Shivpuri, Mp Department, National Faceless Appeal Centre, Delhi (Appellant) (Respondent) Pan: Dhgpr1886H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 144BSection 147Section 148Section 148ASection 151Section 151A

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

SMT. BINA WADHWA,AGRA vs. ITO WARD 1(1)(1), AGRA

In the result, the appeal is allowed for statistical purposes

ITA 147/AGR/2018[2010-11]Status: DisposedITAT Agra18 Sept 2019AY 2010-11

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaassessment Year: 2010-11

Section 133(6)Section 143(3)Section 147Section 148Section 151Section 16ASection 23ASection 24Section 34ASection 35

reassessment proceedings under section 147/148 of the Income Tax Act as valid, which is highly perverse, wrong, illegal and bad in law. 1.3Because under the facts and circumstances, the reasons recorded by the Ld AO are based on mere suspicion and vague, hence not valid. 2 1.4Because under the facts and circumstances, the assessment order passed under section

SUNITA,SAHU vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

ITA 432/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 144BSection 147Section 148Section 148ASection 151Section 151A

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

ASHOK SAHU,JHANSI vs. INCOME TAX OFFICER, WARD 2(3)(1), JHANSI, JHANSI

In the result, appeal filed by the assessee is allowed

ITA 452/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 144BSection 147Section 148Section 148ASection 151Section 151A

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

RAJ SINGH,MATHURA vs. ITO-3(3), MATHURA

In the result appeal is allowed

ITA 408/AGR/2018[2008-09]Status: DisposedITAT Agra22 Mar 2019AY 2008-09

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenashri. Raj Singh, Vs.. Income Tax Officer- 3(3), Village- Kharaut Chhata, Mathura Mathura. Pan: Akvpr1777Q (Appellant) (Respondent)

Section 144Section 148Section 151

6 proceedings omitted to consider that Letter dated 21.11.2014 was a mere non statutory letter and as such the learned Assessing officer has illegally and without authority of law has issued it and based on this unauthorized enquiry letter, proceedings under section 148 cannot be authorized under the law. He further submitted that even if the proceedings of enquiry

PUSHPA,MATHURA vs. ITO-1(2)(3), MATHURA

In the result,both appeals are allowed

ITA 332/AGR/2018[2009-10]Status: DisposedITAT Agra22 Mar 2019AY 2009-10

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenashri. Pushpendra Singh. Vs.. Income Tax Officer- 1(2)(3), M-22, Phase-I, Mahavidhya Colony. Agra. Mathura. Pan: Dldps6755P (Appellant) (Respondent) Smt. Pushpa Vs.. Income Tax Officer- 1(2)(3), M-22, Phase-I, Mahavidhya Colony. Agra. Mathura. Pan: Bcopd0484L (Appellant) (Respondent)

Section 147Section 148

6), the assessee filed reply and stated that 'my father own 52 Bighas of agricultural land and sold agricultural products. The amount so "received from sales consideration is being deposited in bank account. The assessee also stated that there is no source of income except agriculture." Whereas, on perusal of reply filed by the assessee, it is found that

HARDAYAL MILK PRODUCTS PRIVATE LIMITED,SHIKOHABAD vs. DCIT, CIRCLE-2(2)(1), FIROZABAD, FIROZABAD

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

ITA 343/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68

Sections 147/143(3) of the Act. 5. Aggrievedby the above said order, the assessee preferred appeal before the learned CIT(A), where the assessee filed detailed submissions both on validity of reassessment proceedings and merits of the case. Learned CIT(A) was not convinced with the detailed submissions of the assessee and holding the reassessment proceedings as legally valid, sustained

HARDAYAL MILK PRODUCTS PRIVATE LIMITED,SHIKOHABAD vs. DCIT, CIRCLE-2(2)(1), FIROZABAD, FIROZABAD

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

ITA 344/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68

Sections 147/143(3) of the Act. 5. Aggrievedby the above said order, the assessee preferred appeal before the learned CIT(A), where the assessee filed detailed submissions both on validity of reassessment proceedings and merits of the case. Learned CIT(A) was not convinced with the detailed submissions of the assessee and holding the reassessment proceedings as legally valid, sustained

SH ABHISHEK GUPTA ,AGRA vs. ITO W2(2)(1),, FIROZABAD

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

ITA 172/AGR/2022[2012-13]Status: DisposedITAT Agra14 Feb 2025AY 2012-13

Bench: Shri Ramit Kochar & Shri Sudhir Kumarshri Abhishek Gupta The Income Tax Officer 405, Anupam Omerean Ward 2(2)(1), Firozabad, Heights, Mughal Road, V. U.P. Kamla Nagar, Agra-282005 Uttar Pradesh "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aefpg0755D Appellant .. Respondent

For Appellant: Written adj. application rejectedFor Respondent: Sh. Shailendra Srivastava, Sr

Section 143(3)Section 147Section 253(3)

6,39,510/- and to pay tax and interest thereon. 02. Because the Ld. Commissioner of Income Tax- Appeals, National Faceless Appeal Centre has erred in law and on facts in confirming addition of Rs.1,50,000/- on account of gift received from the assessee's sister without considering the material evidences placed on record by the assessee. 03. Because

DIXIT RICE MILL ,AURAIYA vs. DCIT, BENGALURU

In the result, the appeal of assessee is treated as allowed for statistical

ITA 373/AGR/2018[2016-17]Status: DisposedITAT Agra10 Jan 2020AY 2016-17

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 143(1)Section 246Section 246ASection 36

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

CHANDRA PRAKASH GOPLANI,BENGALURU vs. ITO 2(1)(1), AGRA

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

ITA 166/AGR/2023[2012-13]Status: DisposedITAT Agra29 Jan 2025AY 2012-13

Bench: : Shri Ramit Kocharassessment Year: 2012-13

Section 143(2)Section 144Section 147Section 148Section 253(3)

Section 147 of the 1961 Act. Thus , it was an ex-parte reassessment order passed by the AO. 6. Assessee

SMT. VIDHYA AGARWAL,AGRA vs. I.T.O., WARD-4(4), AGRA

The appeal is allowed

ITA 335/AGR/2014[2000-01]Status: DisposedITAT Agra22 Mar 2019AY 2000-01

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meena

6 I.T.A No. 216 /Agra/2012 & Others reasons recorded alleging gift received from one Chartered Accountant Mr. D.K. Agarwal to be bogus , being based on report dated 22.03.2006 of ITO 4(1), Agra, held the re-opening to be bad in law by holding that the reasons were recorded without application of mind. Our attention was drawn to copy this order

ANURAG MITTAL ,FIROZABAD vs. DCIT CENTRAL CIRCLE, AGRA

In the result, both the appeals of the assessee are allowed

ITA 136/AGR/2018[2013-14]Status: DisposedITAT Agra06 Nov 2019AY 2013-14

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 153ASection 153DSection 234A

reassessment under section 153A of the Act. The Ld. D.R’s have also relied upon the definition of Approval and 5.1 sanction given in Black’s law dictionary. It was further submitted by the Ld. DR’s that approval of Additional CIT is totally distinct from the Assessment order and it is not required to be communicated. Hence

RAJESH LADHANI,FAIZABAD vs. DCIT CC , AGRA

In the result, all three appeals of the assessee are allowed

ITA 106/AGR/2019[2009-10]Status: DisposedITAT Agra06 Nov 2019AY 2009-10

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meenaita No. 106,107 & 108/Agra/2019 Assessment Year: 2008-09 & 2011-12 Vs. Dy. C.I.T. –Central Circle, Rajesh Ladhani, 259, Savera Bhawan, Ram Nagar Colony, Agra. Faizabad. Pan: Abapl5646C (Appellant) (Respondent)

Section 132(4)Section 153ASection 153D

6. On the other hand, the Department represented by Ld. CIT D.R Shri Sunil Bajpayee and Sr. D.R Shri. Waseem Arshad who both have argued the matter from the side of Department submitted that the order passed under section 153D of the Act by the Additional CIT was merely an Administrative order and no civil or penalty consequences would flow

RADHIKA GARG,HATHRAS vs. INCOME TAX OFFICER, WARD-2(1)(3), AGRA

In the result, the appeal of the assessee is allowed

ITA 433/AGR/2024[2012-13]Status: DisposedITAT Agra19 Nov 2025AY 2012-13

Bench: Shri M. Balaganesh(Through Virtual Hearing) Radhika Garg, Vs. Income Tax Officer, 14/100, Kambhu Tola Ward-2(1)(3), Hospital Road, Hathras, Up Agra (Appellant) (Respondent) Pan:Afepg2999H Assessee By : Shri Anurag Sinha, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Shri Anurag Sinha, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 142(1)Section 143(2)Section 144Section 147Section 148Section 292B

section 143(2) of the Act and then proceeded to frame the re-assessment. Hence in the light of the aforesaid decisions, the entire Radhika Garg reassessment proceedings deserve to be quashed as void abinitio. Accordingly, the Ground No. 5 raised by the assessee is allowed. 6

LAKSHYA ICE & COLD STORAGE P LTD,ALIGARH vs. ITO WARD 1(5), ALIGARH

In the result, by the assessee is allowed

ITA 124/AGR/2018[2010-11]Status: DisposedITAT Agra16 May 2019AY 2010-11

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenam/S Lakshya Ice & Cold Storage Pvt. Ltd. Vs.. Income Tax Officer, Goyal Bhawan, Opp. Maheshwari Inter Ward 1(5), Aligarh College, Sasni Gate, Bye Pass Road, Aligarh (Pan: Aabcl5656R) (Respondent) (Appellant)

For Appellant: Sh. Pradeep K. Sahgal, Adv. & Sh. Utsav Sahgal, C.AFor Respondent: Shri Waseem Arshad, Sr.DR

Section 147Section 148Section 234BSection 271(1)(c)Section 68

section 148 of the Act has been initiated in the case of the assessee company, therefore the reassessment order passed U/S 143(3)/147 of the Act is illegal, bad in law and abintito void and deserves to be quashed/cancelled. b) Because the reassessment made is bad in law because prior to the completion of reassessment the reasons recorded were