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12 results for “reassessment u/s 147”+ Section 263clear

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Key Topics

Section 26333Section 14718Section 14818Section 143(3)13Section 15113Reassessment10Addition to Income10Bogus Purchases7Section 40A5

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 notice based on alleged bogus purchases from Md. Irfan. The Assessing Officer (AO) initially accepted the purchases as genuine after investigations, but the Principal Commissioner (PCIT) initiated revision proceedings u/s 263, viewing the AO's assessment as erroneous and prejudicial.", "held": "The Tribunal held that the PCIT had erred in invoking Section 263 as the AO had conducted adequate

Section 685
Section 1393
Natural Justice2

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

147 and the same enquiry have been referred in the case of the Md. Irfan. Though, it is very established that, this is not a case of lack of enquiry, therefore it is mere a change of opinion of the Ld. PCIT in invoking the provisions of section 263 read with Explanation 2 clause (a) and since adequate

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

147 and the same enquiry have been referred in the case of the Md. Irfan. Though, it is very established that, this is not a case of lack of enquiry, therefore it is mere a change of opinion of the Ld. PCIT in invoking the provisions of section 263 read with Explanation 2 clause (a) and since adequate

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

147 and the same enquiry have been referred in the case of the Md. Irfan. Though, it is very established that, this is not a case of lack of enquiry, therefore it is mere a change of opinion of the Ld. PCIT in invoking the provisions of section 263 read with Explanation 2 clause (a) and since adequate

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, after recording Md. Irfan's statement. However, the Principal Commissioner of Income Tax (PCIT) initiated revision proceedings u/s 263, believing the AO had not conducted proper inquiries. The PCIT set aside the assessment order, directing fresh inquiries.", "held": "The Tribunal held that the PCIT erred in invoking Section 263 by merely substituting his own opinion for that

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

Section 263 of the Act and passing the Impugned Order has failed to appreciate that the Ld. AO in the case of the Appellant passed the Assessment Order dated 31.10.2019 after duly considering all submissions of the Appellant. 4. That the Ld. Pr. CIT while making the order U/S 263 had ignored that the Asstt Order

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

Section 263 of the Act and passing the Impugned Order has failed to appreciate that the Ld. AO in the case of the Appellant passed the Assessment Order dated 31.10.2019 after duly considering all submissions of the Appellant. 4. That the Ld. Pr. CIT while making the order U/S 263 had ignored that the Asstt Order

VEERENDRA SINGH ,JALAUN vs. ITO,W 2(1)(5),ORAI, JALAUN

The appeal of the assessee is allowed in the manner as indicated above

ITA 169/AGR/2022[2011-12]Status: DisposedITAT Agra19 Feb 2025AY 2011-12

Bench: Shri Ramit Kocharveerendra Singh, Income-Tax Officer, Vill. Dakor Mohana, Orai, Ward 2(1)(5), Orai, Distt. Jalaun (Up)-285001. V. Distt. Jalaun (Up) "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bbjps 3108 J Appellant .. Respondent

Section 139Section 143(2)Section 147Section 148Section 250Section 44A

section 147 of the Act, and proceedings u/s 147 were initiated against the assessee. The Assessing Officer issued questionnaire to the assessee. The AO has recorded in the assessment order that the assessee filed his return of income on 16.7.2018 in response to notice u/s 148 of the Act as is emerging from the reassessment order passed by the Assessing

PAWAN AGRAWAL,MATHURA vs. INCOME TAX OFFICER 1(3)(1), MATHURA

In the result, the appeal of the Assessee is allowed

ITA 386/AGR/2025[2020-21]Status: DisposedITAT Agra26 Nov 2025AY 2020-21
For Appellant: \nShri M. M. Agarwal, CAFor Respondent: \nShri Anil Kumar, Sr. DR
Section 132Section 147Section 148Section 151

147 and 151 were\nlightly treated by the Income-tax Officer as well as by the\nCommissioner. Both of them appear to have taken the duty imposed on\nthem under those provisions as of little importance. They have\nsubstituted the form for the substance.\"\n20. This Court, while following Chhugamal Rajpal in the case of Ess Adv.\n(Mauritius

VIKAS CHANDRA HUF,ALIGARH vs. ITO WARD-4(1)(1), ALIGARH

In the result, the appeal of the assessee is allowed

ITA 450/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshvikas Chandra Huf, Vs. Cit(Appeals), D-117, Ramesh Vihar, Nfac, Delhi Ramghar Road, Aligarh Up (Appellant) (Respondent) Pan: Aakjv9476N Assessee By : Shri Pankaj Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Pankaj Garg, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 139(1)Section 147Section 148Section 148ASection 151

u/s 148A(d) as a fit 148A(d) AND/OR issuance of case. notice under section 148 of the Name: RAJAT Income-tax Act, 1961? BANSAL Designation: PCCIT, DELHI Date: 20/03/2023 15. It is evident that the approval order is bereft of any reasons. It does not even refer to any material that may have weighed in the grant of approval

MAHESH EDIBLE OIL INDUSTRIES LIMITED,DELHI vs. ASSTT. COMMISSIONER OF INCOME TAX, AGRA

ITA 117/AGR/2023[2017-18]Status: DisposedITAT Agra25 Apr 2025AY 2017-18
Section 142ASection 143(3)Section 145Section 153ASection 37(1)

reassess taking into consideration the other material in respect of completed\nassessments/unabated assessments. Meaning thereby, in respect of completed/unabated\nassessments, no addition can be made by the AO in absence of any incriminating material\nfound during the course of search under Section 132 or requisition under Section 132A of\nthe Act, 1961. However, the completed/unabated assessments can be re-opened

DEPUTY COMMISSIONER OF INCOME TAX, AGRA vs. MAHESH EDIBLE OIL INDUSTRIES LTD, DELHI

ITA 157/AGR/2023[2013-14]Status: DisposedITAT Agra25 Apr 2025AY 2013-14
Section 142ASection 143(3)Section 145Section 153ASection 37(1)

reassess taking into consideration the other material in respect of completed\nassessments/unabated assessments. Meaning thereby, in respect of completed/unabated\nassessments, no addition can be made by the AO in absence of any incriminating material\nfound during the course of search under Section 132 or requisition under Section 132A of\nthe Act, 1961. However, the completed/unabated assessments can be re-opened