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43 results for “reassessment u/s 147”+ Section 142(3)clear

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Key Topics

Section 14858Section 14756Addition to Income40Section 143(3)38Section 26333Reassessment25Section 142(1)23Section 14422Section 68

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

reassessment proceedings are ex facie bad in law, being initiated without satisfying the conditions stipulated in first proviso to Section 147, and are thus liable to be quashed as void ab initio. The statutory conditions under the first proviso to Section 147 are that no action for reopening can be taken beyond four years unless there is a failure

Showing 1–20 of 43 · Page 1 of 3

20
Section 153D17
Cash Deposit15
Disallowance11

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

reassessment proceedings are ex facie bad in law, being initiated without satisfying the conditions stipulated in first proviso to Section 147, and are thus liable to be quashed as void ab initio. The statutory conditions under the first proviso to Section 147 are that no action for reopening can be taken beyond four years unless there is a failure

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

3. Brief facts of the case are that the assessee filed return of income on 11.07.2012, declaring total income of Rs.8,16,230/-. Case of the assessee was reopened by the Revenue for framing reassessment by invoking provisions of section 147 of the 1961 Act. Notice u/s. 148 dated 26.03.2019 was issued by the Assessing Officer to the assessee

RATNESH KUMAR JAIN,SHIVPURI vs. INCOME TAX OFFICER ASHOK NAGAR, GWALIOR

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

ITA 278/AGR/2024[2014-15]Status: DisposedITAT Agra14 Feb 2025AY 2014-15
Section 143(3)Section 144BSection 144rSection 147Section 148Section 250

142(1) was issued by\nthe Assessing Officer. Later on, the assessee came forward and\nsubmitted that the original return of income filed u/s. 139 be treated as\nthe return of income filed in compliance to notice u/s. 148 of the Act. The\nassessee submitted replies before the Assessing Officer at the fag end\nwhen the re-assessment was getting

SARVESH KUMAR,FARRUKHABAD vs. INCOME TAX OFFICER WARD 4(2)(2) FARRUKHABAD, FARRUKHABAD

In the result, the appeal of the assessee is allowed

ITA 452/AGR/2024[2017-18]Status: DisposedITAT Agra13 Nov 2025AY 2017-18

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sarvesh Kumar, Vs. Ito, Okharu Khanpur, Ward-4(2)(2), Farrukhabad, Fatehgarh, Farrukhabad Ho 209601 (Appellant) (Respondent) Pan: Dsqpk3348G Assessee By : Shri Swaran Singh, Ca Shri Shailesh Gupta, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 18/11/2025

For Appellant: Shri Swaran Singh, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 115BSection 139Section 139(1)Section 139(4)Section 142(1)Section 143(3)Section 144Section 147Section 148Section 44A

reassessment u/s 143(3)/ 144 r.w.s. Section 147 of the Act. I find this issue was subject matter of adjudication by the coordinate bench of Hyderabad Tribunal in the case of Dr Vijay Kumar Sarvesh Kumar Datla Vs. ACIT reported in 1996 (3) TMI 176 dated 28.03.1996. The relevant operative portion of the said order is as under

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, appeal filed by the assessee for AY 2019-20 is\nallowed and appeals filed by the Revenue in AYs 2021-22, 2022-23 and\n2023-24 are dismissed

ITA 302/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

reassessment proceedings, the AO made an\nenquiry from the Md. Irfan vide summons issued dated 26.03.2023\nforming part of Supplementary paper Book at page 1,and the statement\nof Md. Irfan recorded on oath, wherein he had admitted that, he is\nengaged in trading of Alive animals and also confirmed that, he had made\nsales to assessee and also

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

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)

reassessment order dated29.11.2019passed by Assessing Officer u/s.144 r.w.s. 147 of the Income-tax Act, 1961. 2. Grounds of appeal raised by the assessee in the memo of appeal filed with the Income Tax Appellate Tribunal, Agra Bench, Agra reads as under : “1- BECAUSE the proceedings initiated u/s 147 and the notice issued u/s 148 is invalid, wrong, illegal, arbitrary, against

SAGAR DWELLINGS P LTD,NEAR SUN TEMPLE GWALIOR vs. ACIT, FACELESS

In the result, assessee’s appeal is dismissed

ITA 373/AGR/2025[2014-15]Status: DisposedITAT Agra16 Feb 2026AY 2014-15

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

142(1) of the Act were issued and served upon the assessee. The assessee raised objections against the reasons for reopening, which were disposed of on 18.02.2022. Further, assessee submitted his reply dated 04.02.2022. During the reassessment proceedings, the assessee contended that it had purchased steel and building material of Rs.1,46,66,985/- from M/s. Jai Baba Gurudev Traders

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED, AGRA

In the result, appeal filed by the assessee for AY 2019-20 is\nallowed and appeals filed by the Revenue in AYs 2021-22, 2022-23 and\n2023-24 are dismissed

ITA 300/AGR/2025[2019-20]Status: DisposedITAT Agra04 Dec 2025AY 2019-20
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

reassessment proceedings, the AO made an\nenquiry from the Md. Irfan vide summons issued dated 26.03.2023\nforming part of Supplementary paper Book at page 1,and the statement\nof Md. Irfan recorded on oath, wherein he had admitted that, he is\nengaged in trading of Alive animals and also confirmed that, he had made\nsales to assessee and also

MANOJ KUMAR AGARWAL,FARRUKHABAD vs. DCIT CIRCLE-4(2)(1) FARRUKHABAD, FARRUKHABAD

In the result, appeal of the assessee is allowed for AY 2017-18 and appeal of the assessee for AY 2015-16 is partly allowed

ITA 54/AGR/2025[2015-2016]Status: DisposedITAT Agra12 Dec 2025AY 2015-2016

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing)

For Appellant: Shri Swaran Singh, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 143(3)Section 147

reassessment was completed u/s 147 r.w.s. 144 r.w.s. 144B of the Act on 30.03.2022 wherein an addition of Rs. 1,23,46,358/- being the amount of unsecured loan added u/s 68 of the Act. 12. At the outset, we find that the reasons recorded by the ld AO for reopening the assessment are very very vague and does

MANOJ KUMAR AGARWAL,FARUKHABAD vs. ASSESSING OFFICER, FARRUKHABAD

In the result, appeal of the assessee is allowed for AY 2017-18 and appeal of the assessee for AY 2015-16 is partly allowed

ITA 76/AGR/2025[2017-18]Status: DisposedITAT Agra12 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing)

For Appellant: Shri Swaran Singh, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 143(3)Section 147

reassessment was completed u/s 147 r.w.s. 144 r.w.s. 144B of the Act on 30.03.2022 wherein an addition of Rs. 1,23,46,358/- being the amount of unsecured loan added u/s 68 of the Act. 12. At the outset, we find that the reasons recorded by the ld AO for reopening the assessment are very very vague and does

HMA AGRO INDUSTRIES LIMITED,AGRA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE, AGRA, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 251/AGR/2025[2018-2019]Status: DisposedITAT Agra04 Dec 2025AY 2018-2019

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

reassessment proceedings, the AO made an enquiry from the Md. Irfan vide summons issued dated 26.03.2023 forming part of Supplementary paper Book at page 1,and the statement of Md. Irfan recorded on oath, wherein he had admitted that, he is engaged in trading of Alive animals and also confirmed that, he had made sales to assessee and also

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 301/AGR/2025[2021-22]Status: DisposedITAT Agra04 Dec 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

reassessment proceedings, the AO made an enquiry from the Md. Irfan vide summons issued dated 26.03.2023 forming part of Supplementary paper Book at page 1,and the statement of Md. Irfan recorded on oath, wherein he had admitted that, he is engaged in trading of Alive animals and also confirmed that, he had made sales to assessee and also

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 303/AGR/2025[2023-24]Status: DisposedITAT Agra04 Dec 2025AY 2023-24

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

reassessment proceedings, the AO made an enquiry from the Md. Irfan vide summons issued dated 26.03.2023 forming part of Supplementary paper Book at page 1,and the statement of Md. Irfan recorded on oath, wherein he had admitted that, he is engaged in trading of Alive animals and also confirmed that, he had made sales to assessee and also

TEJ SINGH,MATHURA vs. ITO 1(3)(4), MATHURA

In the result, the Appeal of the assessee is partly allowed

ITA 8/AGR/2019[2009-10]Status: DisposedITAT Agra26 Sept 2023AY 2009-10
Section 142(1)Section 147Section 148

142(1) and section 274 r.w.s. 271(1)(b) were not answered by the appellant. Thereafter, a show- cause notice under section 144 was issued by the AO. on 16.11.2016 and on its non-service through the speed post, ITI was deputed to serve it personally on the appellant. Vide his report dated 06.12.2016, the ITI has reported that Shri

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

142(1) as well as show cause notice u/s. 144 of the Act, show causing to the assessee that why deduction u/s. 11 may not be denied to the assessee as registration u/s. 12AA was granted vide order dated 14.09.2011 w.e.f. 01.04.2011, i.e., for the assessment year 2012-13, but the assessee has claimed exemption u/s. 11 for the impugned

SONU JAIN THROUGH LEGAL HEIR AND FATHER OF LATE SONU JAIN SHRI RAJENDRA JAIN ,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, the appeal is partly allowed

ITA 158/AGR/2025[2016-17]Status: DisposedITAT Agra24 Jun 2025AY 2016-17

Bench: SHRI SUNIL KUMAR SINGH (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 142(1)Section 147Section 148Section 148ASection 149(1)(b)Section 250Section 69A

u/s 142(1) were issued from time to time which were partly replied by the legal heir of the assessee and finally the reassessment proceedings were completed vide order dt.09.03.2024 by making additions of Rs.78,88,849/- on account of bank deposits and interest from bank. The re-assessment order was passed in the name of father of assessee

INCOME TAX OFFICER, ASHOKNAGAR vs. AJIT SINGH , SHIVPURI

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

ITA 89/AGR/2025[2013]Status: DisposedITAT Agra04 Dec 2025

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Income Tax Officer, Vs. Ajit Singh, Ashoknagar, Village-Haatodh, Madhya Pradesh Post-Kota, Shivpuri (Appellant) (Respondent) Pan: Ccnps7470K Assessee By : Shri Vipin Upadhyay, Adv Revenue By: Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 17/11/2025 Date Of Pronouncement 04/11/2025

For Appellant: Shri Vipin Upadhyay, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT(DR)
Section 133(6)Section 139Section 142(1)Section 143(2)Section 143(3)Section 144Section 144BSection 147Section 148Section 148(1)

3,81,69,080/- and completed the assessment under section 144 read with section 147 of the Act on 30-3- 2022. This assessment was framed by the Learned JAO, Income Tax Officer, Ajit Singh Ashok Nagar. It is pertinent to note that both the notice under section 148 of the Act was issued by the Learned JAO and reassessment