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16 results for “reassessment u/s 147”+ Section 69clear

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Key Topics

Section 14724Section 14824Addition to Income16Section 153D12Section 153A12Section 2509Section 142(1)9Section 1449Limitation/Time-bar

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 after expiry of four years. Therefore, the jurisdictional requirement under the first proviso to Section 147, having been not satisfied, renders the entire reopening proceedings jurisdictionally invalid, as the same are based on mere change of opinion not permissible under section 147 of the Act. Accordingly, the entire reassessment proceedings are void ab initio and liable

8
Unexplained Investment7
Section 696
Reassessment6

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 after expiry of four years. Therefore, the jurisdictional requirement under the first proviso to Section 147, having been not satisfied, renders the entire reopening proceedings jurisdictionally invalid, as the same are based on mere change of opinion not permissible under section 147 of the Act. Accordingly, the entire reassessment proceedings are void ab initio and liable

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

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

ITA 278/AGR/2024[2014-15]Status: DisposedITAT Agra14 Feb 2025AY 2014-15

Bench: : Shri Ramit Kochar & Shri Sudhir Kumar

Section 143(3)Section 144BSection 144rSection 147Section 148Section 250

Section 147 of the Income Tax Act. 4 That without prejudice to the relief allowed as per grounds, as above, the authorities below have not considered the replies of the appellant filed before them, after taking into consideration the replies and the submissions made before them, no addition is liable to be made, addition made by the AO, sustained

SINGH CARRIERS,JHANSI vs. WARD 2(3)(1), JHANSI

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

ITA 140/AGR/2025[2019-20]Status: DisposedITAT Agra24 Jun 2025AY 2019-20

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Singh Carriers, Ward-2(3)(1), 2716, Swamipuram Vs. Jhansi. Colony, Gwalior Road, Jhansi, Uttar Pradesh-284003. Pan-Aacfs9607B (Appellant) (Respondent)

Section 144Section 147Section 250Section 251(1)Section 37(1)Section 69

147 r.w.s 144 of the Act as the assessee failed to comply any notice issued by the Assessing Officer and, thus, the AO made addition of Rs.21,14,22,258/- u/s 69 of the Act by holding the credits in the bank account as unexplained money. In first appeal, the Ld. CIT(A) while dealing with ground of appeal No.1

SAPNA CHAUHAN,ETAWAH vs. ITO, ETAWAH

In the result,both the appeals in ITA No

ITA 137/AGR/2018[2009-10]Status: DisposedITAT Agra22 Mar 2019AY 2009-10

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meena

Section 143(2)Section 143(3)Section 147Section 148Section 148(2)Section 234B

69 of the Act, and such fact alone cannot be a reason for ‘escapement of income’ and to clothe the learned Assessing officer with jurisdiction to issue notice under section 148 of the Act. ITAT, Delhi in the case of BirBahadur Singh Sijwali vs. ITO(2015) 68 SOT 197 (Delhi –Trib.) wherein it was held that (page

CHAND KHAN,SADA SHIV NAGAR vs. ITO WARD 1(2) , CITY CENTER

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

ITA 109/AGR/2024[2012-2013]Status: DisposedITAT Agra28 Jan 2025AY 2012-2013

Bench: : Shri Ramit Kocharassessment Year: 2012-13

Section 144Section 147

147 read with section 148 of the Act, and notice u/s. 148 dated 29.03.2019 was issued by the AO to the assessee seeking to reopen the concluded assessment. There was no response from the assessee to the notice u/s. 148. Further, statutory notice u/s. 143(2) and 142(1) were also issued to the assessee in the reassessment proceedings

PREMWATI SUMAN,AGRA vs. ITO-1(3), AGRA

In the result both appeals are allowed

ITA 393/AGR/2018[2008-09]Status: DisposedITAT Agra22 Mar 2019AY 2008-09

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenasmt. Premwati Suman, Vs.. Income Tax Officer- 1(3), 1/1, Hig Flats, Sanjay Place, Agra. Agra. Pan: Bnvps9819N (Appellant) (Respondent) Shri. Ranjeet Suman, Vs.. Income Tax Officer- 1(3), 1/1, Hig Flats, Sanjay Place, Agra. Agra. Pan: Bnlps9622P (Appellant) (Respondent)

Section 144Section 147Section 148Section 151

u/s 148 without complying the provision of Section 148 (2)” The Hon’ble High Court held that “Further, it has been held that the plea with regard to the jurisdiction of the Officer goes into the root of the matter, therefore, even if not raised at the first instance before the Assessing Authority, it can be raised before the Appellate

VISHNU SONI,SHIVPURI vs. ITO, ASHOKNAGAR

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

ITA 38/AGR/2025[2014-15]Status: DisposedITAT Agra24 Jun 2025AY 2014-15

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Mr. Vishnu Soni Ito, Ashok Nagar, Sadar Bazar, Vs. Aayakar Bawan, Shivpuri, Citiy Centre, Madhya Pradesh-473551 Gwalior, Madhya Pan-Awlps6188C Pradesh-474001 (Appellant) (Respondent)

Section 144BSection 147Section 148Section 250Section 56(2)(vii)Section 69

reassessment order by making addition of Rs.58,98,125/- being 50% in amount of investment made in acquisition of the immovable property (including the stamp charges) and further made addition of Rs.1,87,500/- u/s 56(2)(vii)(b) of the Act being the difference between the sale consideration and the circle rate. Against such order, an appeal was filed

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)

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 was framed

LT. SHRI MRADUL GARG,MATHURA vs. DCIT CENTRAL CIRCLE, AGRA

In the result, the appeals of the assessee are allowed and those of Revenue are

ITA 260/AGR/2017[2007-08]Status: DisposedITAT Agra18 Sept 2019AY 2007-08

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 142(1)Section 153ASection 153D

69 cases, solely relying on your undertaking to the effect that while completing the assessment as per draft assessment order, all the observations made in the appraisal report relating to examination / investigation as also the issues identified in the course of examination of seized material have carefully considered / kept in view. The approval, based on your undertaking as discussed herein

D.S. INDIA JEWELMART P LTD,MATHURA vs. ACIT CENTRAL CIRCLE, AGRA

In the result, the appeals of the assessee are allowed and those of Revenue are

ITA 268/AGR/2017[2012-13]Status: DisposedITAT Agra18 Sept 2019AY 2012-13

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 142(1)Section 153ASection 153D

69 cases, solely relying on your undertaking to the effect that while completing the assessment as per draft assessment order, all the observations made in the appraisal report relating to examination / investigation as also the issues identified in the course of examination of seized material have carefully considered / kept in view. The approval, based on your undertaking as discussed herein

ACIT CENTRAL CIRCLE, AGRA vs. D.S. INDIA JEWELMART P LTD, MATHURA

In the result, the appeals of the assessee are allowed and those of Revenue are

ITA 276/AGR/2017[2012-13]Status: DisposedITAT Agra18 Sept 2019AY 2012-13

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 142(1)Section 153ASection 153D

69 cases, solely relying on your undertaking to the effect that while completing the assessment as per draft assessment order, all the observations made in the appraisal report relating to examination / investigation as also the issues identified in the course of examination of seized material have carefully considered / kept in view. The approval, based on your undertaking as discussed herein

SAURABH AGARWAL,MATHURA vs. DCIT CENTRAL CIRCLE, AGRA

In the result, the appeals of the assessee are allowed and those of Revenue are

ITA 263/AGR/2017[2008-09]Status: DisposedITAT Agra18 Sept 2019AY 2008-09

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 142(1)Section 153ASection 153D

69 cases, solely relying on your undertaking to the effect that while completing the assessment as per draft assessment order, all the observations made in the appraisal report relating to examination / investigation as also the issues identified in the course of examination of seized material have carefully considered / kept in view. The approval, based on your undertaking as discussed herein

ASHOK KUMAR AGARWAL,MATHURA vs. DCIT CENTRAL CIRCLE, AGRA

In the result, the appeals of the assessee are allowed and those of Revenue are

ITA 269/AGR/2017[2012-13]Status: DisposedITAT Agra18 Sept 2019AY 2012-13

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 142(1)Section 153ASection 153D

69 cases, solely relying on your undertaking to the effect that while completing the assessment as per draft assessment order, all the observations made in the appraisal report relating to examination / investigation as also the issues identified in the course of examination of seized material have carefully considered / kept in view. The approval, based on your undertaking as discussed herein

DCIT CENTRAL CIRCLE, AGRA vs. LT. SHRI MRADUL GARG, MATHURA

In the result, the appeals of the assessee are allowed and those of Revenue are

ITA 272/AGR/2017[2010-11]Status: DisposedITAT Agra18 Sept 2019AY 2010-11

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 142(1)Section 153ASection 153D

69 cases, solely relying on your undertaking to the effect that while completing the assessment as per draft assessment order, all the observations made in the appraisal report relating to examination / investigation as also the issues identified in the course of examination of seized material have carefully considered / kept in view. The approval, based on your undertaking as discussed herein

BIKESH KUMAR,FIROZABAD vs. INCOME TAX OFFICER 2(2)(1) , FIROZABAD

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

ITA 490/AGR/2025[2013-14]Status: DisposedITAT Agra03 Feb 2026AY 2013-14

Bench: Shri M. Balaganeshbikesh Kumar, Vs. Income Tax Officer, Nagla Bhoop Nasirpur, Ward-2(2)(1), Shikhabad Firozabad, Firozabad Firozabad (Appellant) (Respondent) Pan: Bglpk0327A Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 23/01/2026 Date Of Pronouncement 03/02/2026

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 133(6)Section 142(1)Section 147Section 148Section 250Section 250(6)Section 69Section 69A

u/s 250 is bad in law, liable to be set aside.” 3. I have heard the rival submissions and perused the materials available on record. The assessee is engaged in the business of selling potatoes to persons outside Agra for which the buyers were sending the sales consideration by depositing the money in the bank account of the assessee