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18 results for “reassessment u/s 147”+ Deductionclear

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Key Topics

Section 14736Section 26328Section 14822Section 143(3)20Reassessment16Addition to Income14Section 14410Deduction9Disallowance7

SH. YUGAL KISHOR AGARWAL,AGRA vs. DCIT, CIRCLE 4(3)(1), ETAH

In the result, appeal filed by the assessee is allowed

ITA 3/AGR/2023[2012-13]Status: DisposedITAT Agra15 Jan 2025AY 2012-13

Bench: : Shri Ramit Kocharassessment Year: 2012-13

Section 143(2)Section 143(3)Section 147Section 148Section 57

reassessment order u/s 147 read with Section 143(3) dated 24.10.2019, the Assessing Officer made two additions – firstly, disallowance of Rs.12,15,413/- claimed by the assessee as expenditure against income from other sources by invoking provision of Section 57(iii) of the Act as the assessee could not furnish any evidences in respect of these expenses , and secondly disallowance

SURESH CHAND GUPTA,JHANSI vs. DCIT-6, JHANSI

Section 271(1)(b)6
Section 115
Section 69A4

In the result, the assessee’s appeal is dismissed

ITA 284/AGR/2017[2010-11]Status: DisposedITAT Agra03 Sept 2019AY 2010-11

Bench: Shri Laliet Kumar,And Dr. Mitha Lal Meena

Section 143(3)Section 147Section 148

reassessment proceedings under section 147 was initiated within the four year period from the end of the relevant assessment year and therefore, the first proviso to section 147 has no application and the Tribunal's finding to the contrary is factually incorrect. Amended provisions of section 147 effective from 1-4-1989 authorize income escaping assessment If the Assessing Officer

SHRI ATUL SRIVASTAVA,AGRA vs. PCIT-1, AGRA, AGRA

The appeals of the assessees are allowed in above terms

ITA 57/AGR/2022[2012-13]Status: DisposedITAT Agra30 Apr 2025AY 2012-13

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

Section 143(3)Section 147Section 148Section 263

reassessment proceedings. Thus the Pr. CIT has erred in imitating proceedings U/S 263. 2 | P a g e ITA No.56 & 57/Agr/2022 5. That the Asstt. Order dated 31-10-2019 is not prejudicial to the interests of the revenue.” 5. The order of the ld. PCIT in the case of Sarika Srivastava reveals that the assessee is a Doctor

SMT. SARIKA SRIVASTAVA,AGRA vs. PCIT-1, AGRA, AGRA

The appeals of the assessees are allowed in above terms

ITA 56/AGR/2022[2012-13]Status: DisposedITAT Agra30 Apr 2025AY 2012-13

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

Section 143(3)Section 147Section 148Section 263

reassessment proceedings. Thus the Pr. CIT has erred in imitating proceedings U/S 263. 2 | P a g e ITA No.56 & 57/Agr/2022 5. That the Asstt. Order dated 31-10-2019 is not prejudicial to the interests of the revenue.” 5. The order of the ld. PCIT in the case of Sarika Srivastava reveals that the assessee is a Doctor

M/S UMA GLASS WORKS,AGRA vs. PR.CIT.-1, AGRA

In the result, both the appeals of the assessee for AYs 2014-15 and

ITA 18/AGR/2021[2015-16]Status: DisposedITAT Agra02 Nov 2022AY 2015-16

Bench: Shri Anil Chaturvedi & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.17 & 18/Agra/2021 िनधा"रणवष"/Assessment Years:2014-15 & 2015-16 बनाम M/S Uma Glass Works Pcit, 22, Near Industrial Estate, Vs. Agra-1, Firozabad - 283203 Uttar Pradesh.

Section 143(3)Section 147Section 148Section 263

reassessment was completed u/s 143(3) of the Act read with Section 147 of the Act determining the income of the assessee by making an addition of Rs.19,90,13,470/-. The said Rs.19,90,13,469/- represents the difference in opening stock, purchases, sales, closing stock and the net profit as shown by the assessee in its return

M/S UMA GLASS WORKS ,FIROZABAD vs. PR.CIT.-1, AGRA

In the result, both the appeals of the assessee for AYs 2014-15 and

ITA 17/AGR/2021[2014-15]Status: DisposedITAT Agra02 Nov 2022AY 2014-15

Bench: Shri Anil Chaturvedi & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.17 & 18/Agra/2021 िनधा"रणवष"/Assessment Years:2014-15 & 2015-16 बनाम M/S Uma Glass Works Pcit, 22, Near Industrial Estate, Vs. Agra-1, Firozabad - 283203 Uttar Pradesh.

Section 143(3)Section 147Section 148Section 263

reassessment was completed u/s 143(3) of the Act read with Section 147 of the Act determining the income of the assessee by making an addition of Rs.19,90,13,470/-. The said Rs.19,90,13,469/- represents the difference in opening stock, purchases, sales, closing stock and the net profit as shown by the assessee in its return

PARMANAND,AGRA vs. ITO, WARD, 2(1)(2), AGRA

In the result, assessee’s appeal is allowed

ITA 447/AGR/2025[2015-16]Status: DisposedITAT Agra17 Apr 2026AY 2015-16
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 250Section 69C

147 of the Act, notice u/s. 148 dated 30.03.2021 was issued seeking assessee to file return within 30 days. The assessee filed return of income belatedly on 25.12.2021 which was e-verified on 17.03.2022 in accordance with the clarification provided in CBDT Notification No. 5/2022 dated 29.07.2022 as per the answer given by the deptt. FAQ No. 6 which

PEHAL,CHHATARPUR vs. ITO (EXEMPTION), GWALIOR

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

ITA 46/AGR/2024[2010-11]Status: DisposedITAT Agra09 Jan 2025AY 2010-11

Bench: SHRI RAMIT KOCHAR (Accountant Member)

For Appellant: Sh. Sanjay Parekh, CAFor Respondent: Sh. Shailendra Srivastava, Sr. DR
Section 11Section 11(1)(a)Section 12ASection 12A(2)Section 143(3)Section 144Section 147Section 148Section 250

147 of the Act on the ground that registration u/s. 12AA was granted effective from 01.04.2011, i.e., assessment year 2012-13, but the assessee has claimed exemption u/s. 11 of the Act for the impugned assessment year, i.e., 2010-11. There was no compliance by the assessee during the assessment proceedings as well as in the first appellate proceedings. Both

JAWAHAR LAL AGARWAL,AGRA vs. I.T.O., WARD-4(2), AGRA

In the result, the appeal is allowed

ITA 336/AGR/2014[2005-06]Status: DisposedITAT Agra24 Nov 2017AY 2005-06

Bench: Shri A. D. Jain

Section 129Section 143Section 147Section 148Section 234ASection 50CSection 54BSection 54F

deduction u/s 54F and 54B taking the provisions of section 50C of the I.T. Act not applying on it. 5. Because in any view, the ld. CIT (A) has erred in confirming the interest charged u/s 234A, 234B & 234C, which is wrong and illegal.” 2. The following additional ground has also been raised: “7. Because in any view, the Assessment

SINGH CARRIERS,JHANSI vs. WARD 2(3)(1), JHANSI

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

ITA 140/AGR/2025[2019-20]Status: DisposedITAT Agra24 Jun 2025AY 2019-20

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Singh Carriers, Ward-2(3)(1), 2716, Swamipuram Vs. Jhansi. Colony, Gwalior Road, Jhansi, Uttar Pradesh-284003. Pan-Aacfs9607B (Appellant) (Respondent)

Section 144Section 147Section 250Section 251(1)Section 37(1)Section 69

u/s 144 to the file of the AO by Finance Act, 2024, w.e.f. 01.10.2024 however, when the assessee raised the jurisdictional issue, it is the duty of the Ld. CIT(A) to decide the legal issues first then to proceed to decide the grounds taken on the merits of the additions even in case of ex-parte order. Since

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

ITA 368/AGR/2025[2015-16]Status: DisposedITAT Agra26 Nov 2025AY 2015-16

Bench: Shri M. Balaganesh(Through Virtual Hearing)

For Appellant: Shri Anurag Sinha, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 151Section 271(1)(b)Section 69A

reassessment was completed u/s 147 read with Section 144B of the Act on 26.03.2022 wherein, loss from house property of Rs. 52,567/- was disallowed apart from making addition on account of unexplained money u/s 69A in respect of credits in the bank account in the sum of Rs. 28,20,500 and denying deduction

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

ITA 388/AGR/2025[2014-15]Status: DisposedITAT Agra26 Nov 2025AY 2014-15

Bench: Shri M. Balaganesh(Through Virtual Hearing)

For Appellant: Shri Anurag Sinha, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 151Section 271(1)(b)Section 69A

reassessment was completed u/s 147 read with Section 144B of the Act on 26.03.2022 wherein, loss from house property of Rs. 52,567/- was disallowed apart from making addition on account of unexplained money u/s 69A in respect of credits in the bank account in the sum of Rs. 28,20,500 and denying deduction

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

ITA 367/AGR/2025[2014-15]Status: DisposedITAT Agra26 Nov 2025AY 2014-15

Bench: Shri M. Balaganesh(Through Virtual Hearing)

For Appellant: Shri Anurag Sinha, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 151Section 271(1)(b)Section 69A

reassessment was completed u/s 147 read with Section 144B of the Act on 26.03.2022 wherein, loss from house property of Rs. 52,567/- was disallowed apart from making addition on account of unexplained money u/s 69A in respect of credits in the bank account in the sum of Rs. 28,20,500 and denying deduction

GUMAN SINGH KUSHWAH,SHIVPURI vs. INCOME TAX OFFICER, ASHOKNAGAR

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

ITA 544/AGR/2025[2014-15]Status: DisposedITAT Agra22 Jan 2026AY 2014-15

Bench: Shri M. Balaganeshgumnam Singh Kushwah, Vs. Income Tax Officer, Infront Of Collector Kothi, Ashok Nagar, Shiv Colony, Shivpuri, Mp Mp (Appellant) (Respondent) Pan: Bcjpk2729Q Assessee By : Shri Ashish Goyal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 22/01/2026

For Appellant: Shri Ashish Goyal, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 142(1)Section 143(3)Section 144Section 147Section 148Section 194Section 194ISection 201Section 206ASection 50C

u/s 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 16.03.2022 by the Assessing Officer, National Faceless Assessment Centre, Delhi (hereinafter referred to as ‘ld. AO’). 2. One of the ground raised before me is that the learned NFAC had mechanically confirmed the order of the ld AO without giving his independent findings

M/S TOMAR & BROTHERS,ETAWAH vs. A.C.I.T., CIRCLE-5, FIROZABAD

The appeal stands allowed

ITA 348/AGR/2014[2007-08]Status: DisposedITAT Agra22 Apr 2025AY 2007-08

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 348/Agr/2014 (िनधा"रणवष" / Assessment Year:2007-08) M/S. Tomar & Brothers Acit, Circle 5, बनाम/ 843-A, Moti Jheel Colony, Firozabad. Vs. Etawah (Up). "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaft-7229-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Anurag Sinha, Adv. – Ld. Ar " थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2007-08 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)- Ii, Agra [Cit(A)] Dated 31-03-2014 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S. 147 Of The Act On 29-12-2011. Both Sides Made Vehement Arguments. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed- Off As Under. The Ld. Ar Has Assailed The Validity Of Reassessment Proceedings. 2. Upon Perusal Of Assessment Order, It Could Be Seen That Assessee’S Return Of Income Was Scrutinized U/S. 143(3) On 18-11-2009. However, The Case Was Reopened Vide Notice U/S 07-01-2011 On The Allegation That The Assessee Did Not Deduct Tax At Source On Machinery Rental Payments.

For Appellant: Sh. Anurag Sinha, Adv. – Ld. ARFor Respondent: Sh. Shailender Shrivastava – Ld. Sr. DR
Section 07Section 143(3)Section 194I

147 of the Act on 29-12-2011. Both sides made vehement arguments. Having heard rival submissions and upon perusal of case records, the appeal is disposed- off as under. The Ld. AR has assailed the validity of reassessment proceedings. 2. Upon perusal of assessment order, it could be seen that assessee’s return of income was scrutinized u/s

PRAMOD KUMAR GUPTA,TIKAMGARH vs. ITO , TIKAMGARH

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

ITA 446/AGR/2025[2012-13]Status: DisposedITAT Agra26 Nov 2025AY 2012-13

Bench: Shri M. Balaganesh(Through Virtual Hearing) Pramod Kumar Gupta, Vs. Ito, House No. 393, Tikamgarh Bhelasee Baldev Gargh, Mp (Appellant) (Respondent) Pan: Auupg5954D Assessee By : None Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/11/2025 Date Of Pronouncement 26/11/2025

For Appellant: NoneFor Respondent: Shri Anil Kumar, Sr. DR
Section 144Section 147Section 194Section 69A

u/s 147 of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 21.12.2018 by the Assessing Officer, ITO, Ward- Takamgarh (hereinafter referred to as „ld. AO‟). 2. At the outset, I find that there is a delay in filing of appeal by the Assessee before this Tribunal by 846 days. Considering the reasons adduced in the condonation

SHRI SWAMI RAM SWAROOP SHARMA,MATHURA vs. ITO WARD-3(4), MATHURA

In the result, both the appeals are treated as allowed, for statistical purposes

ITA 146/AGR/2017[2008-09]Status: DisposedITAT Agra09 Jul 2018AY 2008-09

Bench: Shri A. D. Jain & Dr. Mitha Lal Meenakapil Sharma, Executor Of The Vs..Ito,3(4), Estate Of Late (Shri) Ram Swaroop Mathura. Sharma, Gandhi Marg, Vrindavan, Mathura. C/O R.M. Mehta S-125, Panchsheel Park (First Floor), New Delhi Pan:Anhps1936P (Revenue) (Assessee) Kapil Sharma, Executor Of The Vs..Ito,3(4), Estate Of Late (Shri) Ram Swaroop Mathura. Sharma, Gandhi Marg, Vrindavan, Mathura. C/O R.M. Mehta S-125, Panchsheel Park (First Floor), New Delhi Pan:Anhps1936P (Assessee) (Revenue)

deduction on account of expenditure to the extent of 50% of the gross receipts whereas the claim as made was allowable in full. In any case only as an alternative submission the disallowance sustained was on the higher side”. 5. The facts are that the AO, in the assessment order, added certain credit entries appearing in the assessee’s bank

SHRI SWAMI RAM SWAROOP SHARMA,MATHURA vs. ITO WARD 3(4), MATHURA

In the result, both the appeals are treated as allowed, for statistical purposes

ITA 16/AGR/2016[2008-09]Status: DisposedITAT Agra09 Jul 2018AY 2008-09

Bench: Shri A. D. Jain & Dr. Mitha Lal Meenakapil Sharma, Executor Of The Vs..Ito,3(4), Estate Of Late (Shri) Ram Swaroop Mathura. Sharma, Gandhi Marg, Vrindavan, Mathura. C/O R.M. Mehta S-125, Panchsheel Park (First Floor), New Delhi Pan:Anhps1936P (Revenue) (Assessee) Kapil Sharma, Executor Of The Vs..Ito,3(4), Estate Of Late (Shri) Ram Swaroop Mathura. Sharma, Gandhi Marg, Vrindavan, Mathura. C/O R.M. Mehta S-125, Panchsheel Park (First Floor), New Delhi Pan:Anhps1936P (Assessee) (Revenue)

deduction on account of expenditure to the extent of 50% of the gross receipts whereas the claim as made was allowable in full. In any case only as an alternative submission the disallowance sustained was on the higher side”. 5. The facts are that the AO, in the assessment order, added certain credit entries appearing in the assessee’s bank