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26 results for “reassessment u/s 147”+ Section 9(1)(vi)clear

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Key Topics

Section 14882Section 14734Section 26319Addition to Income19Section 15117Section 148A15Reassessment14Section 153A13Section 143(3)

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

vi) Copies of share application forms submitted by the investing company. (vii) Reply of share applicant filed in pursuance to notices u/s. 133(6) (viii) Copy of assessment order passed u/s. 143(3) in the case of share applicant, M/s. Silver Heritage Nivas (P) Ltd. for A.Y. 2012-13, wherein, the 17 | P a g e ITA No.344 & 343/Agr/2025 identical

Showing 1–20 of 26 · Page 1 of 2

12
Section 153D12
Limitation/Time-bar8
Reopening of Assessment7

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

vi) Copies of share application forms submitted by the investing company. (vii) Reply of share applicant filed in pursuance to notices u/s. 133(6) (viii) Copy of assessment order passed u/s. 143(3) in the case of share applicant, M/s. Silver Heritage Nivas (P) Ltd. for A.Y. 2012-13, wherein, the 17 | P a g e ITA No.344 & 343/Agr/2025 identical

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

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

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

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

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

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

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

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

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

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

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

vi. Smt Indra Bansal vs ACIT 192 TTJ (JD) 968 vii. Geeta Rani Panda vs ACIT 194 TTJ (CTK) 915 viii. AkilGulamali vs ITO 20 Taxman.com 380 ( para12) ix. Sun engineering (P) Ltd 198 ITR 297( para37) 3. On the other hand, the ld. DR had submitted that the legal grounds raised by the assessee is not born

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

vi. Smt Indra Bansal vs ACIT 192 TTJ (JD) 968 vii. Geeta Rani Panda vs ACIT 194 TTJ (CTK) 915 viii. AkilGulamali vs ITO 20 Taxman.com 380 ( para12) ix. Sun engineering (P) Ltd 198 ITR 297( para37) 3. On the other hand, the ld. DR had submitted that the legal grounds raised by the assessee is not born

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

vi. Smt Indra Bansal vs ACIT 192 TTJ (JD) 968 vii. Geeta Rani Panda vs ACIT 194 TTJ (CTK) 915 viii. AkilGulamali vs ITO 20 Taxman.com 380 ( para12) ix. Sun engineering (P) Ltd 198 ITR 297( para37) 3. On the other hand, the ld. DR had submitted that the legal grounds raised by the assessee is not born

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

vi. Smt Indra Bansal vs ACIT 192 TTJ (JD) 968 vii. Geeta Rani Panda vs ACIT 194 TTJ (CTK) 915 viii. AkilGulamali vs ITO 20 Taxman.com 380 ( para12) ix. Sun engineering (P) Ltd 198 ITR 297( para37) 3. On the other hand, the ld. DR had submitted that the legal grounds raised by the assessee is not born

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

vi. Smt Indra Bansal vs ACIT 192 TTJ (JD) 968 vii. Geeta Rani Panda vs ACIT 194 TTJ (CTK) 915 viii. AkilGulamali vs ITO 20 Taxman.com 380 ( para12) ix. Sun engineering (P) Ltd 198 ITR 297( para37) 3. On the other hand, the ld. DR had submitted that the legal grounds raised by the assessee is not born

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

vi. Smt Indra Bansal vs ACIT 192 TTJ (JD) 968 vii. Geeta Rani Panda vs ACIT 194 TTJ (CTK) 915 viii. AkilGulamali vs ITO 20 Taxman.com 380 ( para12) ix. Sun engineering (P) Ltd 198 ITR 297( para37) 3. On the other hand, the ld. DR had submitted that the legal grounds raised by the assessee is not born

SHRI SIYARAM YADAV,MAINPURI vs. ITO 2(5), MAINPURI

In the result, the appeal is allowed

ITA 117/AGR/2017[2011-12]Status: DisposedITAT Agra25 Jan 2018AY 2011-12

Bench: Shri A. D. Jain

Section 142(1)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 292BSection 50CSection 68

147 of the Act read with sec. 143(3) of the Act, notice u/s 143(2) is mandatory. In the absence of notice u/s 143(2), it is obvious that no further proceedings can be continued for assessment u/s 143 and without such a notice, the Assessing Officer cannot assume jurisdiction and this I.T.A No. 117/Agra/2017 4 defect cannot

DY.C.I.T., CENTRAL CIRCLE, AGRA vs. M/S VACMET PACKAGINGS (INDIA) PVT. LTD., AGRA

ITA 45/AGR/2015[2005-06]Status: DisposedITAT Agra08 Jun 2018AY 2005-06

Bench: Shri A. D. Jain & Dr. Mitha Lal Meena

Section 143(3)Section 147Section 148Section 153ASection 68

1. That Ld CIT (A) has erred in law and on facts by holding that the recording of reasons in this case is based on scanty and vague information and hence does not satisfy the requirements of section 147 without appreciating the fact that the Assessing officer, recorded the reasons on the basis of intimation received from

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)

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 by the Learned JAO. 6. The Assessee filed detailed submissions before

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

reassessment was completed on 30.12.2017 u/s 143(3) r.w.s 147 of the Act by treating the net profit of Rs.19,90,13,470/- as per the stock summary taken from the hard disk impounded during the survey as income of the assessee and brought to tax accordingly. The assessee preferred appeal before the Ld. CIT(A) against the action

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

reassessment was completed on 30.12.2017 u/s 143(3) r.w.s 147 of the Act by treating the net profit of Rs.19,90,13,470/- as per the stock summary taken from the hard disk impounded during the survey as income of the assessee and brought to tax accordingly. The assessee preferred appeal before the Ld. CIT(A) against the action

GHANSHYAM ,MATHURA vs. ITO 3(2), MATHURA

In the result, both the appeals are allowed

ITA 129/AGR/2018[2008-09]Status: DisposedITAT Agra19 Jun 2018AY 2008-09

Bench: Shri A. D. Jain

Section 147Section 148Section 151

1. ‘Virat Credit & Holdings (P) Ltd. Vs. ITO’, in CO No. 57/Del/2012 in 2. ITA No.89/Del/2012. ‘Hari Ram Gupta vs. ITO’, ITA No.5111/Del/2013. 3. ‘Tara Alloys Ltd. Vs. ITO’, in ITA No.2421/Del/2017. 4. 6. On the other hand, the ld. DR has placed strong reliance on the approval granted by the Additional CIT. The following decisions have been relied

GHANSHYAM ,MATHURA vs. ITO 3(2), MATHURA

In the result, both the appeals are allowed

ITA 238/AGR/2018[2008-09]Status: DisposedITAT Agra19 Jun 2018AY 2008-09

Bench: Shri A. D. Jain

Section 147Section 148Section 151

1. ‘Virat Credit & Holdings (P) Ltd. Vs. ITO’, in CO No. 57/Del/2012 in 2. ITA No.89/Del/2012. ‘Hari Ram Gupta vs. ITO’, ITA No.5111/Del/2013. 3. ‘Tara Alloys Ltd. Vs. ITO’, in ITA No.2421/Del/2017. 4. 6. On the other hand, the ld. DR has placed strong reliance on the approval granted by the Additional CIT. The following decisions have been relied