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42 results for “reassessment u/s 147”

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Key Topics

Section 14843 Section 14736 Section 153A24 Section 143(3)22 Addition to Income16 Charitable Trust16 Section 143(2)12 Section 15410 Reassessment

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

Showing 1–20 of 42 · Page 1 of 3

9

Limitation/Time-bar8

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 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 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

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

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 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

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

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 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

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

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

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

M/S DEORA ELECTRIC WORKS,ALLAHABAD vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE -1, ALLAHABAD

In the result, both appeals i

ITA 99/ALLD/2020[2009-10]Status: DisposedITAT Allahabad27 Dec 2024AY 2009-10

For Appellant: Sh. Praveen Godbole, C.AFor Respondent: Sh. A.K. Singh, Sr. DR

Section 1Section 143(3)Section 148Section 250

reassessment proceeding imperssible and liable to be withdrawn. 4. That in any view of the matter declared receipt were received were from government department through cheque supported by form no. 16A and accepted by AO in original assessment hence action of the assessing officer under the proceeding u/s 148 of the IT Act. is not correct. 5. That

DY. COMMISSIONER OF INCOME TAX, CIRCLE -1, ALLAHABAD vs. M/S DEORA ELECTRIC WORKS, ALLAHABAD

In the result, both appeals i

ITA 101/ALLD/2020[2009-10]Status: DisposedITAT Allahabad27 Dec 2024AY 2009-10

For Appellant: Sh. Praveen Godbole, C.AFor Respondent: Sh. A.K. Singh, Sr. DR

Section 1Section 143(3)Section 148Section 250

reassessment proceeding imperssible and liable to be withdrawn. 4. That in any view of the matter declared receipt were received were from government department through cheque supported by form no. 16A and accepted by AO in original assessment hence action of the assessing officer under the proceeding u/s 148 of the IT Act. is not correct. 5. That

DEEPAK AUTO SALES KUNDA PRATAPGARH,PRATAPGARH vs. INCOME TAX OFFICER PRATAPGARH, PRATAPGARH

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

ITA 69/ALLD/2025[2019-20]Status: DisposedITAT Allahabad24 Jul 2025AY 2019-20

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 142(1)Section 144Section 147Section 148Section 69A

u/s 147 of the Act was initiated by issue of notice 148 of the Act dated 20.03.2023 on the allegation that the assessee has I.T.A. No.69/Alld/2025 Assessment Year:2019-20 3 deposited cash in current account with PNB A/C No 6743002100000915 to the tune of Rs.2,34,98,000/-which remains unexplained. The said information as gathered by the department

SWATANTRA MISHRA,GEORGE TOWN, ALLAHABAD vs. ITO, WARD 1(5), ALLAHABAD

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

ITA 97/ALLD/2023[2011-12]Status: DisposedITAT Allahabad15 Sept 2023AY 2011-12

Bench: Shri Aby T. Varkey & Shri Ramit Kocharassessment Year: 2011-12 Smt. Swatantra Mishra, Income Tax Officer, F-6 Tulsiani Enclave, Lowther Road, V. Ward-1(5), Allahabad George Town, Allahabad, U.P. Pan:Axvpm0471B (Appellant) (Respondent) Assesseeby: 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 144Section 144BSection 147Section 148

147 read with Section 148 were initiated by AO on the basis of AIR information received that the assessee has made cash deposit of Rs. 46,18,300/- in 2 A.Y. 2011-12 Swatantra Mishra four bank accounts , and also there was purchase of Mutual Funds amounting to Rs. 10,00,000/-. After recording of reasons and obtaining prior approval