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28 results for “reassessment u/s 147”+ Section 68clear

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Key Topics

Section 143(3)29Section 14827Addition to Income26Section 6825Section 26325Section 14724Section 153D16Reassessment13Section 153A10

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

u/s. 147 of the Act. 14. Accordingly, we hold that the assumption of jurisdiction under section 147 of the Act is invalid. The reassessment proceedings are vitiated in law and consequential reassessment order, being not sustainable is liable to be quashed. The grounds raised by the assessee on this issue are allowed. 15. Since we have quashed the very reopening

Showing 1–20 of 28 · Page 1 of 2

Section 145(3)10
Disallowance10
Penalty9

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

u/s. 147 of the Act. 14. Accordingly, we hold that the assumption of jurisdiction under section 147 of the Act is invalid. The reassessment proceedings are vitiated in law and consequential reassessment order, being not sustainable is liable to be quashed. The grounds raised by the assessee on this issue are allowed. 15. Since we have quashed the very reopening

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

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

68,53,128/-, out of which cash deposits were to the tune\nof Rs.1,28,13,500/-. The assessee was asked by the Assessing Officer to\nexplain the source of the cash deposits, but no reply was furnished by\nthe assessee. Assessing Officer issued fresh show cause notice dated\n15.03.2022 along with draft assessment order proposing to make\naddition

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

147 of the Act in not making addition U/s 68 resulted in erroneous and prejudicial to the interests of revenue except stating that the Assessing Officer should have been made addition U/s 68 I.T.A.Nos.17 & 18/Agra/2021/A.Ys.2014-15 & 2015-16 instead of treating the net profit as assessed income of the Assessee on account of alleged difference in closing stock

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

147 of the Act in not making addition U/s 68 resulted in erroneous and prejudicial to the interests of revenue except stating that the Assessing Officer should have been made addition U/s 68 I.T.A.Nos.17 & 18/Agra/2021/A.Ys.2014-15 & 2015-16 instead of treating the net profit as assessed income of the Assessee on account of alleged difference in closing stock

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

68 of the Act. Further, we find that in the proforma reproduced above for seeking approval u/s 151 of the Act, in response to Question No. 7, the ld AO had mentioned that the provision of Explanation 2(b) of Section 147 of the Act would be applicable. On perusal of the Explanation 2(b) of Section 147

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

68 of the Act. Further, we find that in the proforma reproduced above for seeking approval u/s 151 of the Act, in response to Question No. 7, the ld AO had mentioned that the provision of Explanation 2(b) of Section 147 of the Act would be applicable. On perusal of the Explanation 2(b) of Section 147

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

SOURABH JAIN,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, the appeal of the assessee is dismissed

ITA 160/AGR/2025[2019-20]Status: DisposedITAT Agra24 Jun 2025AY 2019-20

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Saurabh Jain, Guna. 1, Near Sanjeevani Vs. Hospital Garha Colony, Guna, Madhaya Pradesh-473001 Pan-Bgjpj7915F (Appellant) (Respondent)

Section 147Section 148Section 250Section 251(1)(a)Section 271ASection 69A

u/s 250 of the Income Tax Act, 1961 (‘the Act’ for short). Saurabh Jain vs. ITO 2. The assessee has taken the following grounds of appeal: 1. On the facts and circumstances of the case, the Commissioner of Income Tax (Appeals) has erred in setting aside assessment without dealt to filed ground of appeal hence whole order

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

147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 23.03.2024 by the Assessing Officer, NFAC, Delhi (hereinafter referred to as „ld. AO‟). 2. The Assessee has raised the following grounds of appeal before us:- “1. Because the proceedings u/s 148A(b) as well as order passed u/s 148A(d) and consequential notice issued

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

68 read with section 263, of the Income-tax Act, 1961 - Cash credit (Gift) Assessment years 2007-08 and 2008-09 - Assessee received certain amount as gifts from his father and sister who were non-residents in India - Assessing Officer after making detailed enquiries, took a view that assessee had duly proved identity, source and creditworthiness of donors - Commissioner, however

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

68 read with section 263, of the Income-tax Act, 1961 - Cash credit (Gift) Assessment years 2007-08 and 2008-09 - Assessee received certain amount as gifts from his father and sister who were non-residents in India - Assessing Officer after making detailed enquiries, took a view that assessee had duly proved identity, source and creditworthiness of donors - Commissioner, however

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

68 read with section 263, of the Income-tax Act, 1961 - Cash credit (Gift) Assessment years 2007-08 and 2008-09 - Assessee received certain amount as gifts from his father and sister who were non-residents in India - Assessing Officer after making detailed enquiries, took a view that assessee had duly proved identity, source and creditworthiness of donors - Commissioner, however

RAJESH TYAGI,AMBAH vs. ITO WARD 1, MORENA, MORENA

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 618/AGR/2025[2020-21]Status: DisposedITAT Agra17 Feb 2026AY 2020-21

Bench: : Shri S. Rifaur Rahmanassessment Year: 2020-21 Rajesh Tyagi Vs. Assessment Unit, S/O Laxmi Narayan Tyagi Gavri National Faceless Assessment Service, Gulab Ka Pura Ambah Centre, Income Tax Officer, Distt. Morena Ward-1, Morena Pan : Bmmpt3132K (Appellant) (Respondent) Assessee By Sh. Sandeep, Ca Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 17.02.2026 Date Of Pronouncement 17.02.2026 Order

Section 142(1)Section 144Section 147Section 148Section 69A

reassessment order passed under section 147 r.w.s. 144 & 144B of the Act is bad in law, invalid and void-ab-initio. 7. BECAUSE under the facts and circumstance and in law the Assessing Officer has erred in making addition of Rs. 5,60,000/-on account of unexplained money for cash deposit in bank under section 69A r.w.s. 115BBE

ANIL KUMAR AGARWAL,AGRA vs. DCIT 2(1)(1), AGRA, AGRA

In the result, the appeal of the assessee is allowed

ITA 101/AGR/2025[2011-12]Status: DisposedITAT Agra19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Anil Kumar Agarwal, Vs. Dy. Cit, 44, R. S. Residency, Circle-2(1)(1), Dayal Bagh, Agra, Up Agra (Appellant) (Respondent) Pan: Aampa3335J Assessee By : Shri Rajni Kant Verma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Shri Rajni Kant Verma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 133(6)Section 143(3)Section 148Section 68

u/s 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated by the Assessing Officer, DCIT, Circle-2(1)(1), Agra (hereinafter referred to as ‘ld. AO’). 2. The only issue to be decided on merits in this appeal is as to whether the Learned JCIT(Appeals) was justified in confirming the addition

RADHIKA GARG,HATHRAS vs. INCOME TAX OFFICER, WARD-2(1)(3), AGRA

In the result, the appeal of the assessee is allowed

ITA 433/AGR/2024[2012-13]Status: DisposedITAT Agra19 Nov 2025AY 2012-13

Bench: Shri M. Balaganesh(Through Virtual Hearing) Radhika Garg, Vs. Income Tax Officer, 14/100, Kambhu Tola Ward-2(1)(3), Hospital Road, Hathras, Up Agra (Appellant) (Respondent) Pan:Afepg2999H Assessee By : Shri Anurag Sinha, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Shri Anurag Sinha, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 292B

u/s 144/147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 29.11.2019 by the Assessing Officer, ITO, Ward-2(1)(3), Agra (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 68 days. Considering the reasons adduced

RAVENDRA SINGH,AGRA vs. ACIT, CIRCLE 1(2)(1), AGRA

In the result, appeal filed by the assessee is allowed for statistical purposes and direct the ld

ITA 499/AGR/2025[2012-2013]Status: DisposedITAT Agra16 Feb 2026AY 2012-2013

Bench: : Shri S. Rifaur Rahmanassessment Year: 2012-13 Ravendra Singh Vs. Acit, 28, Tota Ka Taal Circle 1(2)(1), Loha Mandi, Uttar Pradesh Agra Pan : Abyps5329K (Appellant) (Respondent) Assessee By Shri Shashank Agarwal, Adv. Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 16.02.2026 Order

Section 143(2)Section 143(3)Section 148Section 151Section 250(6)Section 68

u/s 143(2) and 142(1) of the Act were issued and served on the assessee. In response, the assessee filed his written submissions through online portal. The assessee is a medical professional having specialization in the field of psychology & showed his income from the head profession and income from other sources. In response, the assessee has submitted a detailed

S G COMMERCIAL,JHANSI vs. ASSISTANT COMMISSIONER OF INCOME TAX, AGRA

Appeals stand allowed

ITA 368/AGR/2024[2017-18]Status: DisposedITAT Agra22 Apr 2025AY 2017-18

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.364/Agr/2024 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.365/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 3. आयकरअपीलसं./ Ita No.368/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & 4. आयकरअपीलसं./ Ita No.370/Agr/2024 (िनधा"रणवष" / Assessment Year: 2018-19; Smc Bench) & 5. आयकरअपीलसं./ Ita No.366/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 6. आयकरअपीलसं./ Ita No.367/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 7. आयकरअपीलसं./ Ita No.369/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & 8. आयकरअपीलसं./ Ita No.371/Agr/2024 (िनधा"रणवष" / Assessment Year: 2018-19) Acit (Central Circle) M/Ss G Commercial बनाम/ Vs. 452/2A, Cp Mission Compound Agra Jhansi Up 284003

For Appellant: Shri Suresh Gupta (CA) – Ld. ARFor Respondent: Shri Sukesh Kumar Jain – Ld. CIT DR
Section 132Section 142Section 143(1)Section 143(3)Section 145(3)Section 153ASection 153DSection 271DSection 40A(3)Section 68

68. The assessment order was passed after obtaining prior approval of Addl. Commissioner of Income Tax, Central Range, Kanpur as per the provisions of Sec.153DVide F. No. Addl CIT (CR) KNP/Approval u/s 153D/2020-21/53 dated 09-04-2021.Aggrieved, the assessee assailed the assessment so framed before Ld. CIT(A). Appellate Proceedings 3.1 The assessee made elaborate written submissions on legal grounds as well

S G COMMERCIAL,JHANSI vs. JOINT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KANPUR

Appeals stand allowed

ITA 369/AGR/2024[2017-18]Status: DisposedITAT Agra22 Apr 2025AY 2017-18

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.364/Agr/2024 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.365/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 3. आयकरअपीलसं./ Ita No.368/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & 4. आयकरअपीलसं./ Ita No.370/Agr/2024 (िनधा"रणवष" / Assessment Year: 2018-19; Smc Bench) & 5. आयकरअपीलसं./ Ita No.366/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 6. आयकरअपीलसं./ Ita No.367/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 7. आयकरअपीलसं./ Ita No.369/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & 8. आयकरअपीलसं./ Ita No.371/Agr/2024 (िनधा"रणवष" / Assessment Year: 2018-19) Acit (Central Circle) M/Ss G Commercial बनाम/ Vs. 452/2A, Cp Mission Compound Agra Jhansi Up 284003

For Appellant: Shri Suresh Gupta (CA) – Ld. ARFor Respondent: Shri Sukesh Kumar Jain – Ld. CIT DR
Section 132Section 142Section 143(1)Section 143(3)Section 145(3)Section 153ASection 153DSection 271DSection 40A(3)Section 68

68. The assessment order was passed after obtaining prior approval of Addl. Commissioner of Income Tax, Central Range, Kanpur as per the provisions of Sec.153DVide F. No. Addl CIT (CR) KNP/Approval u/s 153D/2020-21/53 dated 09-04-2021.Aggrieved, the assessee assailed the assessment so framed before Ld. CIT(A). Appellate Proceedings 3.1 The assessee made elaborate written submissions on legal grounds as well