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53 results for “reassessment u/s 147”

Sorted by relevance

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Key Topics

Section 14871Section 14751Section 143(3)31Section 153A30Addition to Income26Section 143(2)21Charitable Trust16Reassessment15Section 154

SANJAY MAJUMDAR,ALLAHABAD vs. PR. CIT, ALLAHABAD

ITA 68/ALLD/2018[2012-13]Status: DisposedITAT Allahabad28 Jan 2021AY 2012-13

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2012-13 Mr. Sanjay Majumdar, V. The Principal Commissioner Type Ii – 112, Devprayagam Of Income Tax, Sangam Vatika – Jhalwa, Aayakar Bhawan, Allahabad 211012 38, M.G. Marg, Civil Lines, Allahabad 211001 Pan: Adopm 2688P (Appellant) (Respondent)

For Appellant: Shri Basudev Banerjee, CAFor Respondent: Shri Debashish Chanda, CIT-DR
Section 147Section 154Section 263

u/s. 147 r.w.s. 143(3) of the 1961 Act, vide reassessment order dated 24.06.2016 , as in the opinion of Revenue

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3, MIRZAPUR vs. M/S. J.P.YADAV , SONEBHADRA

In the result, appeal filed by the Revenue in ITA no

Showing 1–20 of 53 · Page 1 of 3

11
Limitation/Time-bar10
Reopening of Assessment10
Section 688
ITA 319/ALLD/2018[2011-12]Status: DisposedITAT Allahabad11 May 2022AY 2011-12

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

For Appellant: Shri O.P. Shukla,C.AFor Respondent: Shri A.K. Singh, Sr.D.R
Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 144Section 147Section 194C

147 of the 1961 Act. During the course of appellate proceedings before ld. CIT(A), the assessee submitted that since the reassessment order was passed by the AO based on the details furnished by the assessee during the course of reassessment proceedings , the AO was not justified in framing assessment u/s

DR. AROTI GHOSH,ALLAHABAD vs. ITO, WARD-1(1), ALLAHABAD

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

ITA 37/ALLD/2022[2008-09]Status: DisposedITAT Allahabad15 Sept 2023AY 2008-09

Bench: Shri Aby T. Varkey & Shri Ramit Kocharassessment Year: 2008-09

For Appellant: Sh. S.K. Jaiswal, C.AFor Respondent: Sh. A.K. Singh, Sr. DR
Section 143(3)Section 147Section 148Section 154

147, and notice u/s 148 was issued. Statutory notices were also issued. During reassessment proceedings u/s 147, it was observed

SHYAM BABU KESARWANI,KAUSHAMBI vs. ITO WARD- 2 (5), KAUSHAMBI

In the result, the appeal is allowed for statistical purposes

ITA 110/ALLD/2024[2012-13]Status: DisposedITAT Allahabad27 Dec 2024AY 2012-13

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2012-13 Shyam Babu Kesarwani, Vs. Income Tax Officer, Tilhapur Mor, Kaushambi Ward-2(5), Kaushambi Pan:Bgepk4506N (Appellant) (Respondent) Assessee By: Sh. Praveen Godbole, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 22.10.2024 Date Of Pronouncement: 27.12.2024 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Against The Order Of The Ld. Cit(A), Nfac Under Section 250 Of The Act Passed On 22.12.2023. The Grounds Of Appeal Preferred Are As Under:- “1. That In Any View Of The Matter Assessment Made U/S 143(3) R.W.S. 147 Of The Act By Order Dated 31.10.2019 On Income Of Rs.28,27,870/- Is Bad Both On The Fact & In Law. 2. That In Any View Of The Matter Proceeding As Initiated U/S 147 Is Not Valid Proceeding In The Eyes Of Law Since No Material Was Brought On Record That Assessee Has Concealed Any Income & The Issue Again Taken Up In The Reassessment Proceeding Which Was Already Before The Assessing Officer At The Time Of Original Assessment & After Due Application Of Mind The Then Assessing Officer Passed Speaking Order U/S 143(3) Of The Act Hence Simply On Change Of Opinion The Reassessment Proceeding U/S 147 Of The Act As Initiated Are Bad In Law. 3. That In Any View Of The Matter The Addition Of Rs.25,25,415/- As Made By The Assessing Officer By Passing Ex-Parte Order On Account Of Excess Deposit In Bank Considered As Unexplained Money U/S 69A Of The Act Is Highly Unjustified & His Action As Confirmed By Cit(A) Is Highly Unjustified.

For Appellant: Sh. Praveen Godbole, C.AFor Respondent: Sh. A.K. Singh, Sr. DR
Section 143(3)Section 147Section 250Section 271(1)(c)Section 69A

u/s 147 is not valid proceeding in the eyes of law since no material was brought on record that assessee has concealed any income and the issue again taken up in the reassessment

M/S DIVYA CONSTRUCTION CO,BHADOHI vs. DCIT CIRCLE-3, MIRZAPUR

In the result, the appeal of the assessee is partly allowed

ITA 37/ALLD/2020[2013-14]Status: DisposedITAT Allahabad24 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(3)Section 148Section 68

reassessment proceedings u/s 147 of the I.T. Act. (E.2.1) We have heard both sides. We have perused materials on record

SMT. NEETA NATH L/H OF LATE DR. JITENDRA NATH,ALLAHABAD vs. ACIT, CENTRAL CIRCLE, ALLAHABAD

In the result, both the appeals in ITA No

ITA 15/ALLD/2018[2013-14]Status: DisposedITAT Allahabad16 Feb 2023AY 2013-14

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2013-14 Vs. The Asstt. Commissioner Of Smt. Neeta Nath, L/H Of Lt. Dr. Jitendra Nath Income Tax, Central Circle, Civil Lines, Allahabad B/401, Mayan Enclave, 49/13, Clive Road, Allahabad Pan-Abepn1795Q (Appellant) (Respondent) Assessment Year: 2013-14 Madhurendra Nath, Vs. The Asstt. Commissioner Of B-502, Vinayak Le Grande, Income Tax, Central Circle, 16/12, Lal Bahadur Shastri Civil Lines, Allahabad Road, Allahabad-211001 Pan-Aaipn8161D (Appellant) (Respondent) Appellant By: Sh. Siddharth Pathak, Adv Respondent By: Sh. Rabin Chaudhari, Cit Dr Date Of Hearing: 18.01.2023 Date Of Pronouncement: 16.02.2023 O R D E R Shri Vijay Pal Rao, J.M.: These Two Appeals By The Two Related Assessees Are Directed Against Two Separate Orders Of The Cit(A), Both Dated 28.04.2016 For The Assessment Year 2013-14. 2. These Appeals Are Arising From The Assessment Orders Passed Under Section 153C In Pursuant To The Search & Seizure Action Under Section 132(1) Of The Income Tax Act, Dated 05.12.2013 In The Case Of Shri. Hemant Kumar Sindhi. Therefore, The Facts & Circumstances As Well As The Grounds Of Appeal

For Appellant: Sh. Siddharth Pathak, AdvFor Respondent: Sh. Rabin Chaudhari, CIT DR
Section 132(1)Section 143(2)Section 153C

147 also requires issuance of a notice u/s 143(2) as a pre-condition for making assessment or reassessment. However

MADHURENDRA NATH,ALLAHABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

In the result, both the appeals in ITA No

ITA 16/ALLD/2018[2013-14]Status: DisposedITAT Allahabad16 Feb 2023AY 2013-14

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2013-14 Vs. The Asstt. Commissioner Of Smt. Neeta Nath, L/H Of Lt. Dr. Jitendra Nath Income Tax, Central Circle, Civil Lines, Allahabad B/401, Mayan Enclave, 49/13, Clive Road, Allahabad Pan-Abepn1795Q (Appellant) (Respondent) Assessment Year: 2013-14 Madhurendra Nath, Vs. The Asstt. Commissioner Of B-502, Vinayak Le Grande, Income Tax, Central Circle, 16/12, Lal Bahadur Shastri Civil Lines, Allahabad Road, Allahabad-211001 Pan-Aaipn8161D (Appellant) (Respondent) Appellant By: Sh. Siddharth Pathak, Adv Respondent By: Sh. Rabin Chaudhari, Cit Dr Date Of Hearing: 18.01.2023 Date Of Pronouncement: 16.02.2023 O R D E R Shri Vijay Pal Rao, J.M.: These Two Appeals By The Two Related Assessees Are Directed Against Two Separate Orders Of The Cit(A), Both Dated 28.04.2016 For The Assessment Year 2013-14. 2. These Appeals Are Arising From The Assessment Orders Passed Under Section 153C In Pursuant To The Search & Seizure Action Under Section 132(1) Of The Income Tax Act, Dated 05.12.2013 In The Case Of Shri. Hemant Kumar Sindhi. Therefore, The Facts & Circumstances As Well As The Grounds Of Appeal

For Appellant: Sh. Siddharth Pathak, AdvFor Respondent: Sh. Rabin Chaudhari, CIT DR
Section 132(1)Section 143(2)Section 153C

147 also requires issuance of a notice u/s 143(2) as a pre-condition for making assessment or reassessment. However

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

ITA 5/ALLD/2023[2012-13]Status: DisposedITAT Allahabad31 Oct 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1(5), ALLAHABAD

The appeals are partly allowed

ITA 8/ALLD/2023[2015-16]Status: DisposedITAT Allahabad31 Oct 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

SANJANA,ALLAHABAD vs. ITO, WARD-1(5), ALLAHABAD

The appeals are partly allowed

ITA 54/ALLD/2023[2016-17]Status: DisposedITAT Allahabad31 Oct 2025AY 2016-17

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

ITA 6/ALLD/2023[2013-14]Status: DisposedITAT Allahabad31 Oct 2025AY 2013-14

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

YOGI SATYAM,ALLAHABAD vs. ITO, WARD-1(5), ALLAHABAD

The appeals are partly allowed

ITA 9/ALLD/2023[2016-17]Status: DisposedITAT Allahabad31 Oct 2025AY 2016-17

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

SANJANA,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

ITA 53/ALLD/2023[2015-16]Status: DisposedITAT Allahabad31 Oct 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

SANJANA,ALLAHABAD vs. ITO, WARD- 1(5), ALLAHABAD

The appeals are partly allowed

ITA 51/ALLD/2023[2013-14]Status: DisposedITAT Allahabad31 Oct 2025AY 2013-14

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

SANJANA,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

ITA 52/ALLD/2023[2014-15]Status: DisposedITAT Allahabad31 Oct 2025AY 2014-15

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1(5), ALLAHABAD

The appeals are partly allowed

ITA 7/ALLD/2023[2014-15]Status: DisposedITAT Allahabad31 Oct 2025AY 2014-15

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

SANJANA,ALLAHABAD vs. ITO, WARD-1(5), ALLAHABAD

The appeals are partly allowed

ITA 50/ALLD/2023[2012-13]Status: DisposedITAT Allahabad31 Oct 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

147 of the Act against the appellant by observing "Since the appeal is decided on merits, hence these grounds are not adjudicated." 2. BECAUSE the CIT(A) has completely erred in giving partial relief of Rs.37.500/- only (i.e. restricting addition of 50% which has been calculated @ 7.5% of Rs.5,00,000/-), even after having accepting the fact that the amount

ARIES MARKETERS PRIVATE LIMITED,ALLAHABAD vs. COMMISSIONER OF INCOME TAX (APPEALS), ALLAHABAD

In the result, appeal filed by the assessee is allowed

ITA 141/ALLD/2019[2007-08]Status: DisposedITAT Allahabad11 Feb 2021AY 2007-08

Bench: Shri Vijay Pal Raoassessment Year: 2007-08

For Appellant: Shri S.K. Khanduja, AdvocateFor Respondent: Shri A.K. Singh, CIT (DR)
Section 143(3)Section 147Section 148Section 151Section 151(1)

reassessment u/s. 147 r.w.s. 143(3) of the Act on 31.03.2015 whereby the total income of the assessee was assessed

HARAKH CHAND GLASS PVT. LTD.,ALLAHABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, ALLAHABAD

In the result, the appeal is allowed

ITA 60/ALLD/2019[2008-09]Status: DisposedITAT Allahabad14 Feb 2020AY 2008-09

Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2008-09 Harakh Chand Glass Pvt. Ltd. V. Dy. Cit 77, Subhash Marg Circle 2 Johnstonganj, Allahabad Allahabad Tan/Pan:Aacch0049M (Appellant) (Respondent) S.A. No.01/Alld/2019 [In Ita No.60/Alld/2019] Assessment Year: 2008-09 Harakh Chand Glass Pvt. Ltd. V. Dy. Cit 77, Subhash Marg Circle 2 Johnstonganj, Allahabad Allahabad Tan/Pan:Aacch0049M (Applicant) (Respondent) Assessee By: Shri Abhinav Mehrotra, Advocate Department By: Shri S. K. Madhuk, Cit (Dr) Date Of Hearing: 13 02 2020 Date Of Pronouncement: 14 02 2020 O R D E R

For Appellant: Shri Abhinav Mehrotra, AdvocateFor Respondent: Shri S. K. Madhuk, CIT (DR)
Section 148Section 151Section 68

reassessment order is less than one month which is impermissible in law as held by various courts. 3. BECAUSE, on the facts and in the circumstances of the case, re-opening of Assessment is bad in law since the alleged notice U/s 148 was not issued with limitation and it is submitted with deep anguish and regret that Revenue

SYED SHOEB ASHRAF,AMBEDKAR NAGAR vs. CIT(APPEALS), DELHI

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

ITA 20/ALLD/2023[2011-12]Status: DisposedITAT Allahabad15 Sept 2023AY 2011-12

Bench: Shri Aby T. Varkey & Shri Ramit Kocharassessment Year: 2011-12 Mr. Syed Shoeb Ashraf, The Ito, 516, Vill & Post Baskhari, V. Ambedkar Nagar, U.P. Ambedkar Nagar-224129, U.P. Pan:Akrpa1580C (Appellant) (Respondent) Assessee By: None (Application) Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.09.2023 Date Of Pronouncement: 15.09.2023 O R D E R

For Appellant: None (Application)For Respondent: Sh. A.K. Singh, Sr. DR
Section 142(1)Section 144Section 144ASection 145(3)Section 147Section 148

147 were initiated by AO. Notice under section 148 was issued by the AO, but the same remained un-complied with. No return of income was filed pursuant to notice issued u/s 148. Other statutory notices were issued and served by the AO to the assessee. The assessee participated in re- assessment proceedings. The assessee could not explain nature