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35 results for “reassessment u/s 147”+ Unexplained Investmentclear

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Key Topics

Section 14867Section 14758Section 26337Addition to Income25Section 50C23Reassessment23Section 6818Section 56(2)(vii)16Section 143(3)

LAKSHYA ICE & COLD STORAGE P LTD,ALIGARH vs. ITO WARD 1(5), ALIGARH

In the result, by the assessee is allowed

ITA 124/AGR/2018[2010-11]Status: DisposedITAT Agra16 May 2019AY 2010-11

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenam/S Lakshya Ice & Cold Storage Pvt. Ltd. Vs.. Income Tax Officer, Goyal Bhawan, Opp. Maheshwari Inter Ward 1(5), Aligarh College, Sasni Gate, Bye Pass Road, Aligarh (Pan: Aabcl5656R) (Respondent) (Appellant)

For Appellant: Sh. Pradeep K. Sahgal, Adv. & Sh. Utsav Sahgal, C.AFor Respondent: Shri Waseem Arshad, Sr.DR
Section 147Section 148Section 234BSection 271(1)(c)Section 68

investment made by the shareholders in the share capital of the appellant as alleged accommodation entry, deserves to be deleted. 6. That the authorities below have erred in law and on facts in not providing the appellant the informations and documents/material for which specific request(s) was made. It is settled law that the AO is free to make enquiries

Showing 1–20 of 35 · Page 1 of 2

16
Section 153D12
Reopening of Assessment10
Limitation/Time-bar8

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

unexplained. 8. That as no investment as per reason recorded has been made by the assessee company it can very fairly be said that reason recorded does not exist in the Assessment Order and hence the assessment framed u/s 147 read with section 143(3) of the Income Tax Act deserves to be quashed. Hon'ble Bombay High Court

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 Agra01 Jun 2018AY 2009-10

Bench: Shri A. D. Jain

Section 147Section 148Section 68

unexplained. 8. That as no investment as per reason recorded has been made by the assessee company it can very fairly be said that reason recorded does not exist in the Assessment Order and hence the assessment framed u/s 147 read with section 143(3) of the Income Tax Act deserves to be quashed. Hon'ble Bombay High Court

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

unexplained income. Thus, a total addition of ₹18,32,11,500/- was made under Section 68 of the Act, vide assessment order dated 23.12.2019, passed under Sections 147/143(3) of the Act. 5. Aggrievedby the above said order, the assessee preferred appeal before the learned CIT(A), where the assessee filed detailed submissions both on validity of reassessment proceedings

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

unexplained income. Thus, a total addition of ₹18,32,11,500/- was made under Section 68 of the Act, vide assessment order dated 23.12.2019, passed under Sections 147/143(3) of the Act. 5. Aggrievedby the above said order, the assessee preferred appeal before the learned CIT(A), where the assessee filed detailed submissions both on validity of reassessment proceedings

VEERENDRA SINGH ,JALAUN vs. ITO,W 2(1)(5),ORAI, JALAUN

The appeal of the assessee is allowed in the manner as indicated above

ITA 169/AGR/2022[2011-12]Status: DisposedITAT Agra19 Feb 2025AY 2011-12

Bench: Shri Ramit Kocharveerendra Singh, Income-Tax Officer, Vill. Dakor Mohana, Orai, Ward 2(1)(5), Orai, Distt. Jalaun (Up)-285001. V. Distt. Jalaun (Up) "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bbjps 3108 J Appellant .. Respondent

Section 139Section 143(2)Section 147Section 148Section 250Section 44A

147 were initiated against the assessee. The Assessing Officer issued questionnaire to the assessee. The AO has recorded in the assessment order that the assessee filed his return of income on 16.7.2018 in response to notice u/s 148 of the Act as is emerging from the reassessment order passed by the Assessing Officer. So far as merits of the additions

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

unexplained, for which reason the case of the assessee was reopened. It was pointed out to the Ld.PCIT that the assessee had explained to the AO 10 | P a g e ITA No.56 & 57/Agr/2022 that the said investments were duly reflected in her Balance Sheet and the source of investment therein therefore duly disclosed. That therefore there was no question

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

unexplained, for which reason the case of the assessee was reopened. It was pointed out to the Ld.PCIT that the assessee had explained to the AO 10 | P a g e ITA No.56 & 57/Agr/2022 that the said investments were duly reflected in her Balance Sheet and the source of investment therein therefore duly disclosed. That therefore there was no question

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

unexplained investment. Therefore, the Ld. DR submits that the contention of the assessee that the order passed by the AO is subject matter of appeal before the Ld. Commissioner(Appeals) and no proceedings u/s 263 of the Act can be initiated is not acceptable. The Ld. DR submits that the PCIT has rightly assumed jurisdiction u/s 263 on issues which

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

unexplained investment. Therefore, the Ld. DR submits that the contention of the assessee that the order passed by the AO is subject matter of appeal before the Ld. Commissioner(Appeals) and no proceedings u/s 263 of the Act can be initiated is not acceptable. The Ld. DR submits that the PCIT has rightly assumed jurisdiction u/s 263 on issues which

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

unexplained which again is based on mere opinion and assumptions.” And: “Thus, as is evident from the above, the very initiation of proceedings u/s 147 in the assessee’s case is bad in law as there is inherent lack of jurisdiction at the end of the Assessing Officer.” 15. On receipt of the aforesaid reply of the assessee

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

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

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

KRIPA RAM VYAS,GWALIOR vs. ITO, GWALIOR

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

ITA 216/AGR/2025[2011-12]Status: DisposedITAT Agra12 Sept 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Kripa Ram Vyas, Vs. Ito, Pgv College, Jiwaji Gwalior Ganj, Lashkar Ho, Gird, Gwalior -474001 Pan: Abupv2129C Assessee By : None Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/08/2025 Date Of Pronouncement 12/09/2025

For Appellant: NoneFor Respondent: Shri Anil Kumar, Sr. DR
Section 144Section 147

u/s 144 read with Section 147 of the Act after making addition of Rs. 5 lakhs on account of unexplained investment in mutual funds. Even before the NFAC, no representation was made by the assessee as he is not conversant with the electronic notices sent to him due to lack of computer knowledge, which eventually lead to ex parte order

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

unexplained investment in the construction of Hotel Haveli.” 2. The ld. AR has submitted that he has moved an application for additional ground vide letter dated 08.07.2019 and the same may kindly be admitted. Additional ground raised by the assessee provides as under : Because the so-called approval as granted by the Learned Additional Commissioner of Income Tax, Central Range

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

unexplained investment in the construction of Hotel Haveli.” 2. The ld. AR has submitted that he has moved an application for additional ground vide letter dated 08.07.2019 and the same may kindly be admitted. Additional ground raised by the assessee provides as under : Because the so-called approval as granted by the Learned Additional Commissioner of Income Tax, Central Range

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

unexplained investment in the construction of Hotel Haveli.” 2. The ld. AR has submitted that he has moved an application for additional ground vide letter dated 08.07.2019 and the same may kindly be admitted. Additional ground raised by the assessee provides as under : Because the so-called approval as granted by the Learned Additional Commissioner of Income Tax, Central Range

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

unexplained investment in the construction of Hotel Haveli.” 2. The ld. AR has submitted that he has moved an application for additional ground vide letter dated 08.07.2019 and the same may kindly be admitted. Additional ground raised by the assessee provides as under : Because the so-called approval as granted by the Learned Additional Commissioner of Income Tax, Central Range