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11 results for “reassessment u/s 147”+ Section 70clear

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Key Topics

Section 14844Section 26327Section 14717Addition to Income9Section 143(3)7Section 687Reassessment7Section 40A3Section 149

M/S DEEPRAJ HOSPITAL P LTD,HATHRAS vs. ITO 3(5), HATHRAS

In the result, both the appeals are allowed

ITA 41/AGR/2017[2010-11]Status: DisposedITAT Agra01 Jun 2018AY 2010-11

Bench: Shri A. D. Jain

Section 147Section 148Section 68

reassessment has been assessed". 9. That reason recorded and consequent issue of notice u/s 148 of the Income Tax Act is also wrong and bad in law as it is not the own belief of the Assessing Officer but it is based on the information received from Commissioner of Income Tax, Aligarh. Under these facts as mentioned above the assessee

M/S CHARAN SINGH ICE & STORAGE P LTD,HATHRAS vs. ITO 3(5), HATHRAS

In the result, both the appeals are allowed

ITA 40/AGR/2017[2009-10]Status: DisposedITAT Agra
3
Bogus Purchases3
Section 32
Revision u/s 2632
01 Jun 2018
AY 2009-10

Bench: Shri A. D. Jain

Section 147Section 148Section 68

reassessment has been assessed". 9. That reason recorded and consequent issue of notice u/s 148 of the Income Tax Act is also wrong and bad in law as it is not the own belief of the Assessing Officer but it is based on the information received from Commissioner of Income Tax, Aligarh. Under these facts as mentioned above the assessee

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

reassessment proceedings. Thus the Pr. CIT has erred in imitating proceedings U/S 263. 2 | P a g e ITA No.56 & 57/Agr/2022 5. That the Asstt. Order dated 31-10-2019 is not prejudicial to the interests of the revenue.” 5. The order of the ld. PCIT in the case of Sarika Srivastava reveals that the assessee is a Doctor

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

reassessment proceedings. Thus the Pr. CIT has erred in imitating proceedings U/S 263. 2 | P a g e ITA No.56 & 57/Agr/2022 5. That the Asstt. Order dated 31-10-2019 is not prejudicial to the interests of the revenue.” 5. The order of the ld. PCIT in the case of Sarika Srivastava reveals that the assessee is a Doctor

PUSHPA,MATHURA vs. ITO-1(2)(3), MATHURA

In the result,both appeals are allowed

ITA 332/AGR/2018[2009-10]Status: DisposedITAT Agra22 Mar 2019AY 2009-10

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenashri. Pushpendra Singh. Vs.. Income Tax Officer- 1(2)(3), M-22, Phase-I, Mahavidhya Colony. Agra. Mathura. Pan: Dldps6755P (Appellant) (Respondent) Smt. Pushpa Vs.. Income Tax Officer- 1(2)(3), M-22, Phase-I, Mahavidhya Colony. Agra. Mathura. Pan: Bcopd0484L (Appellant) (Respondent)

Section 147Section 148

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

RAJ SINGH,MATHURA vs. ITO-3(3), MATHURA

In the result appeal is allowed

ITA 408/AGR/2018[2008-09]Status: DisposedITAT Agra22 Mar 2019AY 2008-09

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenashri. Raj Singh, Vs.. Income Tax Officer- 3(3), Village- Kharaut Chhata, Mathura Mathura. Pan: Akvpr1777Q (Appellant) (Respondent)

Section 144Section 148Section 151

u/s 148 without complying the provision of Section 148 (2)” The Hon’ble High Court held that “the plea with regard to the 11. 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 Authority at a later stage

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

PRAMOD KUMAR GARG,AGRA vs. DCIT,CIRCLE 2(1)(1), AGRA

In the result, assessee’s appeal is allowed

ITA 427/AGR/2025[2015-16]Status: DisposedITAT Agra15 Jan 2026AY 2015-16

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2015-16

Section 147Section 148Section 149Section 149(1)(b)Section 250Section 3

70 (SC). 7. The instant case relates to A.Y. 2015-16. Assessing Officer initially issued notice dated 28.06.2021 u/s. 148 of the Act. The Finance Act, 2021 substituted section 147 to 151 of the Act w.e.f. 01.04.2021 and sections 147 to 151 of the old law ceased to operate from 01.04.2021. The Apex Court in Rajeev Bansal (supra) specifically observed

RAJANI SAHU,GWALIOR vs. INCOME-TAX OFFICER, ASHOK NAGAR, GWALIOR

The appeal stand allowed in terms of our above order

ITA 420/AGR/2024[2015-2016]Status: DisposedITAT Agra22 Apr 2025AY 2015-2016

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 420/Agr/2024 (िनधा"रणवष" / Assessment Year:2015-16) Smt. Rajani Sahu Income-Tax Officer, बनाम/ Karera, Near Kali Mai Mandir, Ashok Nagar, Gwalior. Shivpuri Road Vs. Karera, Shivpuri (Mp). "थायीलेखासं./जीआइआरसं./Pan/Gir No. Ehpps-3090-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Deependra Mohan, Ca - Ld. Ar " थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 21-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2015-16 Arises Out Of An Order Passed By Learned Commissioner Of Income Tax (Appeals), Nfac, Delhi [Cit(A)] On 21-05-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 147 R.W.S. 144 Of The Act On 27-04-2023. In The Assessment Order, Ld. Ao Made Addition Of Deemed Income U/S 56(2)(Vii)(B) For Rs.48.90 Lacs. The Ld. Cit(A) Confirmed The Same Against Which The Assessee Is In Further Appeal Before Us. 2. The Ld. Ar, At The Outset, Raised A Pertinent Legal Issue Assailing Legality Of Reassessment Proceedings. It Has Been Stated That This Year Is Covered By The Decision Of Hon’Ble Delhi High Court In The Case Of Ibibo

For Appellant: Sh. Deependra Mohan, CA - Ld. ARFor Respondent: Sh. Shailender Shrivastava – Ld. Sr. DR
Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 3Section 56(2)(vii)

147 r.w.s. 144 of the Act on 27-04-2023. In the assessment order, Ld. AO made addition of deemed income u/s 56(2)(vii)(b) for Rs.48.90 Lacs. The Ld. CIT(A) confirmed the same against which the assessee is in further appeal before us. 2. The Ld. AR, at the outset, raised a pertinent legal issue assailing legality