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10 results for “reassessment u/s 147”+ Section 43(1)clear

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Key Topics

Section 14714Section 14811Addition to Income10Section 143(3)9Section 689Section 2639Reassessment8Natural Justice5Bogus Purchases

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

5
Disallowance4
Section 2503
Section 40A3

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

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)

43,77,066\n54,58,13,054\n36,17,16,578\n108,13,44,591\nPurchases\nIt was observed by Ld. AO that the bogus purchases in respect to first\ntwo parties was compiled from the bank statements of the two concerns\nas the assessee did not produce the ledger of these two parties. There\nwas possibility that the quantum

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)

43,77,066\n54,58,13,054\n36,17,16,578\n108,13,44,591\nIt was observed by Ld. AO that the bogus purchases in respect to first\ntwo parties was compiled from the bank statements of the two concerns\nas the assessee did not produce the ledger of these two parties. There\nwas possibility that the quantum

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 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, 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

SHYAMA SHYAM INFRADEVELOPERS PRIVATE LIMITED,AGRA vs. ITO 2(1)(2), AGRA

In the result, the appeal of the assessee is allowed

ITA 503/AGR/2025[2016-17]Status: DisposedITAT Agra23 Jan 2026AY 2016-17

Bench: Shri M. Balaganeshshyama Shyam Vs. Ito, Infradevelopers Pvt Ltd, Ward-2(1)(2), Khasra No. 961, Bhahistabad, Agra Sikandra, Agra (Appellant) (Respondent) Pan: Aatcs9899R Assessee By : Shri Gaurav Agarwal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 21/01/2026 O R D E R

For Appellant: Shri Gaurav Agarwal, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 147Section 148

43,000/- during the year, out of which, the assessee had shown only ₹3,86,89,960/- as gross receipts. Accordingly, notice u/s 148 of the Act is issued to the assessee on 30.07.2022. In response to the said notice, the assessee filed its return of income on 23.08.2022 disclosing the same total income of ₹3,48,150/-. During

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

1), Aligarh. Mandi, Herduaganj, Aligarh- 202125 (UP). PAN : FHOPS3817K (Appellant) (Respondent) Assessee by Sh. Naveen Gargh, Advocate Department by Sh. Anil Kumar, Sr. DR Date of hearing 16.07.2025 Date of pronouncement 30.07.2025 ORDER PER : SUNIL KUMAR SINGH, JUDICIAL MEMBER: This appeal has been preferred by assessee against the impugned order dated 20.03.2025 passed in Appeal No. NFAC/2017-18/10268901

PAWAN KUMAR CHAUHAN,MAINPURI vs. ITO- WARD 2 (5) , AGRA, AGRA

ITA 162/AGR/2022[2012-13]Status: DisposedITAT Agra16 Apr 2025AY 2012-13
Section 147Section 250(6)Section 80

1. Because the Ld. CIT(A) has wrongly and arbitrarily confirmed all the\nadditions made by the Assessing Officer without considering the\nAudited Balance Sheet, purchase deed of properties, proof of life\ninsurance premium and tution fees paid.\n2. Because the total addition in the fixed assets is of Rs. 15,45,867/-\nduly appearing in the audited balance sheet