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23 results for “reassessment u/s 147”+ Section 36(1)(viii)clear

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Key Topics

Section 14769Section 14830Addition to Income23Section 143(3)18Section 26316Reopening of Assessment12Section 689Disallowance8Reassessment

THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

ITA 145/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad15 Feb 2024AY 2017-18

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Sanjay Jain, Sr.DR
Section 143(3)Section 147Section 148Section 250(6)

u/s 36(1)(viia) was to be calculated, which as per the AO the assessee had not done. He pointed out that clearly it was not the case of the AO that any fact vis-à-vis claim of provision of bad and doubtful debts or for that matter, the quantum of reserve under section 36(1)(viii

Showing 1–20 of 23 · Page 1 of 2

7
Survey u/s 133A6
Section 234B5
Section 271(1)5

THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

ITA 146/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad15 Feb 2024AY 2018-19

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Sanjay Jain, Sr.DR
Section 143(3)Section 147Section 148Section 250(6)

u/s 36(1)(viia) was to be calculated, which as per the AO the assessee had not done. He pointed out that clearly it was not the case of the AO that any fact vis-à-vis claim of provision of bad and doubtful debts or for that matter, the quantum of reserve under section 36(1)(viii

THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

ITA 144/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad15 Feb 2024AY 2012-13

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Sanjay Jain, Sr.DR
Section 143(3)Section 147Section 148Section 250(6)

u/s 36(1)(viia) was to be calculated, which as per the AO the assessee had not done. He pointed out that clearly it was not the case of the AO that any fact vis-à-vis claim of provision of bad and doubtful debts or for that matter, the quantum of reserve under section 36(1)(viii

MR. ARPANBHAI VIRAMBHAI DESAI,GANDHINAGAR vs. THE ITO, WARD-1, INT.TAX., AHMEDABAD

In the result, all four appeals filed by the assessee are allowed in above terms

ITA 338/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2017-18

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

viii) If the original assessment is processed under Section 143(1) of the Act and not Section 143(3) of the Act, the proviso to Section 147 will not apply. In other words, although the reopening may be after the expiry of four years from the end of the relevant assessment year, yet it would not be necessary

MR. ARPANBHAI VIRAMBHAI DESAI,GANDHINAGAR vs. THE ITO, WARD-1, INT.TAX.,, AHMEDABAD

In the result, all four appeals filed by the assessee are allowed in above terms

ITA 339/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

viii) If the original assessment is processed under Section 143(1) of the Act and not Section 143(3) of the Act, the proviso to Section 147 will not apply. In other words, although the reopening may be after the expiry of four years from the end of the relevant assessment year, yet it would not be necessary

MR. ARPANBHAI VIRAMBHAI DESAI,GANDHINAGAR vs. PR.CIT, AHMEDABAD-3, AHMEDABAD

In the result, all four appeals filed by the assessee are allowed in above terms

ITA 758/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2014-15

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

viii) If the original assessment is processed under Section 143(1) of the Act and not Section 143(3) of the Act, the proviso to Section 147 will not apply. In other words, although the reopening may be after the expiry of four years from the end of the relevant assessment year, yet it would not be necessary

MR. ARPANBHAI VIRAMBHAI DESAI,GANDHINAGAR vs. THE PR. CIT, AHMEDABAD-3, AHMEDABAD

In the result, all four appeals filed by the assessee are\nallowed in above terms

ITA 759/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2015-16
For Appellant: \nShri D K Parikh, ARFor Respondent: \nShri Sher Singh, CIT.DR
Section 12Section 147Section 263

viii) If the original assessment is processed under Section 143(1) of the Act and\nnot Section 143(3) of the Act, the proviso to Section 147 will not apply. In other words,\nalthough the reopening may be after the expiry of four years from the end of the\nrelevant assessment year, yet it would not be necessary

GOLD FINCH JEWELLERY LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

ITA 273/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad23 Aug 2022AY 2010-11

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Shri Aseem Thakkar, A.RFor Respondent: 01/08/2022
Section 131Section 133Section 143(2)Section 143(3)Section 148

1)(c) of the I.T. Act is initiated for concealing the particulars of income. 7.3 In response to summons issued in respect of M/s. Dhanvidhya Impex Pvt. Ltd., Shri Rupang R. Shah, Director attended on 9.12.2011. Shri Rupang Shah had stated that the statement given before Investigation Wing in the case of M/s. Goldfinch Jewellery Ltd. is correct

GOLD FINCH JEWELLERY LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

ITA 1074/AHD/2016[2006-07]Status: DisposedITAT Ahmedabad23 Aug 2022AY 2006-07

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Shri Aseem Thakkar, A.RFor Respondent: 01/08/2022
Section 131Section 133Section 143(2)Section 143(3)Section 148

1)(c) of the I.T. Act is initiated for concealing the particulars of income. 7.3 In response to summons issued in respect of M/s. Dhanvidhya Impex Pvt. Ltd., Shri Rupang R. Shah, Director attended on 9.12.2011. Shri Rupang Shah had stated that the statement given before Investigation Wing in the case of M/s. Goldfinch Jewellery Ltd. is correct

ARVINDKUMAR AMULKH TANNA,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2 (3), AHMEADABAD

ITA 577/AHD/2020[2015-16]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

Section 132Section 143(1)Section 143(3)Section 153A

viii) The appellant humbly submits that in the search proceedings in the case of appellant, no incriminating material for payments of cash in lieu of cheque payments were found and seized. 2. The Ld. CIT(A) has erred in law and on facts in giving the direction to the AO to verify the facts and satisfy himself as to whether

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

ITA 702/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad08 Apr 2021AY 2011-12
For Appellant: Shri S.N. Soparkar, Sr. A.RFor Respondent: Shri Mohd Usman, CIT-D.R
Section 115JSection 143(2)Section 143(3)Section 144CSection 144C(5)Section 37(1)Section 92C

u/s 80 IB. I.T.A No. 702 & 729/Ahd/2016 A.Y. 2011-12 Page No 30 Sun Pharmaceutical Industries Ltd. Vs. ACIT/Dy. CIT vs. Sun Pharmaceutical Industries Ltd xvi. Why, while claiming allocable office expenses the expense under the head legal, secretarial, corporate affairs etc are excluded. These are common expenses and should also be pro rata allocated to the units claiming deduction

JET AIR AGENCIES PVT LTD,WEST BENGAL vs. CENTRAL CIRCLE 2(3)AHMEDABAD, AHMEDABAD

In the result, Ground Nos

ITA 685/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad31 May 2024AY 2012-13

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities on the NMCE

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1595/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 May 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities on the NMCE

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1596/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 May 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities on the NMCE

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1597/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad31 May 2024AY 2012-13

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities on the NMCE

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1594/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad31 May 2024AY 2010-11

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities on the NMCE

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE)-1(4), AHMEDABAD, AHMEDABAD vs. HINDVA BUILDERS, AHMEDABAD

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1563/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR
Section 147Section 148Section 148ASection 149Section 250Section 3(1)

reassessment proceedings, the assessee had claimed that the total receipt of on-money cannot be considered as income and the income has to be considered at 15% of on-money receipt and it had declared more cash than such computed income in the IDS 2016 scheme and requested for telescoping of unaccounted cash expenses incurred by the assessee. However

DCIT, CENTRAL CIRCLE-1(4), AHMEDABAD, AHMEDABAD vs. HINDVA BUILDERS, AHMEDABAD

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1451/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR
Section 147Section 148Section 148ASection 149Section 250Section 3(1)

reassessment proceedings, the assessee had claimed that the total receipt of on-money cannot be considered as income and the income has to be considered at 15% of on-money receipt and it had declared more cash than such computed income in the IDS 2016 scheme and requested for telescoping of unaccounted cash expenses incurred by the assessee. However

DCIT, CENTRAL CIRCLE-1(4), AHMEDABAD, AHMEDABAD vs. HINDVA BUILDERS, AHMEDABAD

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1450/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR
Section 147Section 148Section 148ASection 149Section 250Section 3(1)

reassessment proceedings, the assessee had claimed that the total receipt of on-money cannot be considered as income and the income has to be considered at 15% of on-money receipt and it had declared more cash than such computed income in the IDS 2016 scheme and requested for telescoping of unaccounted cash expenses incurred by the assessee. However

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), AHMEDABAD, AHMEDABAD vs. HINDVA BUILDERS, AHMEDABAD

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1562/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR
Section 147Section 148Section 148ASection 149Section 250Section 3(1)

reassessment proceedings, the assessee had claimed that the total receipt of on-money cannot be considered as income and the income has to be considered at 15% of on-money receipt and it had declared more cash than such computed income in the IDS 2016 scheme and requested for telescoping of unaccounted cash expenses incurred by the assessee. However