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18 results for “reassessment u/s 147”+ Section 35clear

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Key Topics

Section 14856Section 14729Section 148A21Reassessment16Section 26315Section 15111Addition to Income11Section 688Section 143(3)

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

35 Further, in our view, there is no question of concurrent jurisdiction of the JAO and the FAO for issuance of notice under Section 148 of the Act or even for passing assessment or reassessment order. When specific jurisdiction has been assigned to either the JAO or the FAO in the Scheme dated 29th March, 2022, then

7
Section 1447
Reopening of Assessment7
Bogus Purchases5

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

35 Further, in our view, there is no question of concurrent jurisdiction of the JAO and the FAO for issuance of notice under Section 148 of the Act or even for passing assessment or reassessment order. When specific jurisdiction has been assigned to either the JAO or the FAO in the Scheme dated 29th March, 2022, then

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

35 Further, in our view, there is no question of concurrent jurisdiction of the JAO and the FAO for issuance of notice under Section 148 of the Act or even for passing assessment or reassessment order. When specific jurisdiction has been assigned to either the JAO or the FAO in the Scheme dated 29th March, 2022, then

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

35 Further, in our view, there is no question of concurrent jurisdiction of the JAO and the FAO for issuance of notice under Section 148 of the Act or even for passing assessment or reassessment order. When specific jurisdiction has been assigned to either the JAO or the FAO in the Scheme dated 29th March, 2022, then

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

35 Further, in our view, there is no question of concurrent jurisdiction of the JAO and the FAO for issuance of notice under Section 148 of the Act or even for passing assessment or reassessment order. When specific jurisdiction has been assigned to either the JAO or the FAO in the Scheme dated 29th March, 2022, then

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

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

35,180/- as originally determined by the Assessing\nOfficer in the assessment order dated 09.04.2021. Notice of\ndemand and challan is issued accordingly.\"\nH.\nFrom the above sequence of events and documentary evidences, it is\nvery much clear that the AO was well aware about the reasons for\nreopening of the assessment u/s 148 and he took all the step

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

35,180/- as originally determined by the Assessing Officer in the assessment order dated 09.04.2021. Notice of demand and challan is issued accordingly.” H. From the above sequence of events and documentary evidences, it is very much clear that the AO was well aware about the reasons for reopening of the assessment u/s 148 and he took all the step

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

35,180/- as originally determined by the Assessing Officer in the assessment order dated 09.04.2021. Notice of demand and challan is issued accordingly.” H. From the above sequence of events and documentary evidences, it is very much clear that the AO was well aware about the reasons for reopening of the assessment u/s 148 and he took all the step

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

35,180/- as originally determined by the Assessing Officer in the assessment order dated 09.04.2021. Notice of demand and challan is issued accordingly.” H. From the above sequence of events and documentary evidences, it is very much clear that the AO was well aware about the reasons for reopening of the assessment u/s 148 and he took all the step

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

35,180/- as originally determined by the Assessing\nOfficer in the assessment order dated 09.04.2021. Notice of\ndemand and challan is issued accordingly.\"\nH. From the above sequence of events and documentary evidences, it is\nvery much clear that the AO was well aware about the reasons for\nreopening of the assessment u/s 148 and he took all the step

ANJU AGARWAL,AGRA vs. INCOME TAX OFFICER, WARD 2(1)(1), AGRA

In the result, the appeal of the Assessee is allowed

ITA 320/AGR/2025[2019-20]Status: DisposedITAT Agra04 Dec 2025AY 2019-20

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Anju Agarwal, Vs. Income Tax Officer, D-26, Kamla Nagar, Ward-2(1)(1), Agra Agra (Appellant) (Respondent) Pan: Awtpa4297L Assessee By : Shri K. K. Jain, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

For Appellant: Shri K. K. Jain, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 133ASection 147Section 148Section 148ASection 151Section 68

reassessment stood completed under Section 147 r.w.s. 144B of the Act on 23-3- 2024 determining total income of the Assessee at Rs. 56,35,106/- after making an addition of Rs. 49,98,136/-, which stood upheld by the Learned NFAC. Anju Agarwal 4. At the outset, we find that the identical issue had been adjudicated by this Tribunal

SARVESH DEVI (LEGAL HEIR OF LATE MADAN LAL TOMAR),AGRA vs. ITO, WARD 2(1)(1), AGRA, AGRA

In the result, the appeal of the assessee is allowed

ITA 311/AGR/2025[2007-08]Status: DisposedITAT Agra13 Nov 2025AY 2007-08

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sarvesh Devi (Legal Heir Vs. Income Tax Officer, Of Late Madan Lal Tomar), Ward-4(3)(1), 51, Keshavkunj Pratap Hathras Nagar, Agra (Appellant) (Respondent) Pan: Eshpd4540M Assessee By : Shri Rajesh Malhotra, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 13/11/2025

For Appellant: Shri Rajesh Malhotra, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 144Section 147Section 148Section 292B

reassessment framed u/s 144/ 147 of the Act on 30.01.2015. 4. The ld AR before us challenged the validity of framing of assessment in the name of deceased by placing reliance on the decision of the Hon'ble Supreme Court in the case of PCIT Vs. Maruti Suzuki India Ltd reported in 416 ITR 613 wherein it was observed

NISHESH JAIN,AGRA vs. UMESH CHAND KASHYAP, AGRA

In the result, appeal of the assessee in ITA no

ITA 165/AGR/2023[2012-2013]Status: HeardITAT Agra30 Jan 2025AY 2012-2013

Bench: : Shri Ramit Kocharassessment Year: 2012-13

Section 144Section 147

reassessment order dated 13.11.2019passed by Assessing Officer u/s. 147 read Section 144 of the Income-tax Act, 1961(Letter No. ITBA/COM/F/17/2019- 20/1020330167(1))). 2. The learned counsel for the assessee CA Shri R.K.Singhal has filed an application(inward DAK No. 1035 dated 27.11.2024)which is placed before the Bench that the assessee wants to withdraw its appeal

SAROJ,MAINPURI vs. I.T.O WARD 2(5), MAINPURI

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

ITA 218/AGR/2024[2012-13]Status: DisposedITAT Agra14 Feb 2025AY 2012-13

Bench: : Shri Ramit Kochar & Shri Sudhir Kumarassessment Year: 2012-13

Section 139Section 142(1)Section 143(3)Section 144Section 147Section 148

reassessment proceedings. The assessee in response thereof submitted bank statement, but failed to furnish any evidence regarding source of cash deposits made by her in her saving bank account. The Assessing Officer issued show cause notice dated 02.09.2019 u/s. 144 to the assessee,but the assessee did not comply. Assessee thereafter submitted reply before the Assessing Officer and submitted that

BHAGWAN SWAROOP,ALIGARH vs. THE I.T.O. WARD 4(1)(1), ALIGARH , ALIGARH

In the result, the appeal is allowed for statistical purposes

ITA 276/AGR/2025[2018-19]Status: DisposedITAT Agra30 Jul 2025AY 2018-19

Bench: : Shri Sunil Kumar Singh & Shri Brajesh Kumar Singhassessment Year: 2018-19

Section 144Section 147Section 250

u/s. 147 r.w.s. sections 144 and 144B of the Income Tax Act, 1961, vide order dated 10.03.2023, making an addition of Rs.1,06,45,000/- on account of unexplained cash deposits in the bank account of the assessee. The assessee filed first appeal on 18.08.2023 against this assessment order dated 10.03.2023. As per assessee, the first appeal was filed within

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)

147 of the Act, after obtaining necessary approval from the competent authority.Notice under Section 148 of the Act was issued by the AO to the assessee on 31.03.2019 . Copy of reasons recorded by the AO were also provided to the assessee. Statutory notices u/s 142(1) , 143(2) and 144 were issued by the AO from time to time during

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