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19 results for “reassessment u/s 147”+ Set Off of Lossesclear

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Key Topics

Section 14850Section 14737Section 143(3)19Section 143(2)9Addition to Income9Reassessment8Section 139(1)6Reopening of Assessment6Section 143(1)

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

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

u/s 144 read with Section 147 of the 1961 Act, which is a best judgment reassessment order passed by the AO. Our attention was drawn by ld. Sr. DR to page number 46, 59 , 63 and 68 of the paper book filed by the assessee . The ld. Sr. DR would submit that ld. CIT(A) erred in deleting the additions

5
Section 36(1)(va)4
TDS4
Limitation/Time-bar3

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

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 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 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 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 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

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

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 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

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

SHERVANI SUGAR SYNDICATE LIMITED,C/O B. K. KAPUR CO. vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

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

ITA 137/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriaassessment Year: 2012-13 Shervani Sugar Syndicate V. National Faceless Limited Assessment Centre 17, Navyug Market, Ghaziabad- Delhi. 201001. Pan:Aadcs3658L (Appellant) (Respondent) Assessment Year: 2012-13 Shervani Sugar Syndicate V. Dc/Acit-2, Allahabad Limited Office Of The Assistant C/O 17, Navyug Market, Commissioner Of Income Ghaziabad-201001. Tax, Allahabad, Allahabad-211001. Pan:Aadcs3658L (Appellant) (Respondent) Appellant By: Shri Madhav Kapur Respondent By: Shri A. K. Singh, Sr. Dr Date Of Hearing: 23 09 2025 Date Of Pronouncement: 30 09 2025 O R D E R

For Appellant: Shri Madhav KapurFor Respondent: Shri A. K. Singh, Sr. DR
Section 147Section 253(3)

reassessment proceedings void ab inito. 4. That the Ld. CIT(A) has erred in law and on facts of the case in confirming the action of the Ld. AO in making the addition to the tune of Rs. 60,90,164/- other sources vide his order passed u/s 147 r.w.s. 144 dated 16.12.2019 which is in violation to provisions

SHERVANI SUGAR SYNDICATE LIMITED,GHAZIABAD vs. DC/ACIT-2, ALLAHABAD, ALLAHABAD

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

ITA 138/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriaassessment Year: 2012-13 Shervani Sugar Syndicate V. National Faceless Limited Assessment Centre 17, Navyug Market, Ghaziabad- Delhi. 201001. Pan:Aadcs3658L (Appellant) (Respondent) Assessment Year: 2012-13 Shervani Sugar Syndicate V. Dc/Acit-2, Allahabad Limited Office Of The Assistant C/O 17, Navyug Market, Commissioner Of Income Ghaziabad-201001. Tax, Allahabad, Allahabad-211001. Pan:Aadcs3658L (Appellant) (Respondent) Appellant By: Shri Madhav Kapur Respondent By: Shri A. K. Singh, Sr. Dr Date Of Hearing: 23 09 2025 Date Of Pronouncement: 30 09 2025 O R D E R

For Appellant: Shri Madhav KapurFor Respondent: Shri A. K. Singh, Sr. DR
Section 147Section 253(3)

reassessment proceedings void ab inito. 4. That the Ld. CIT(A) has erred in law and on facts of the case in confirming the action of the Ld. AO in making the addition to the tune of Rs. 60,90,164/- other sources vide his order passed u/s 147 r.w.s. 144 dated 16.12.2019 which is in violation to provisions

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

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

SHOBHA RASTOGI,ALLAHABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, ALLAHABAD

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

ITA 47/ALLD/2020[2008-09]Status: DisposedITAT Allahabad13 Aug 2021AY 2008-09

Bench: Shri.Vijay Pal Raoassessment Year: 2008-09 Smt. Shobha Rastogi, V. Deputy Commissioner Of Income 30-A, M.G. Marg, Civil Lines, Tax, Circle-1, Allahabad, U.P. Allahabad, U.P. Pan-Afqpr4774R (Appellant) (Respondent) Appellant By: Mr. Praveen Godbole, C.A. Respondent By: Mr. A.K. Singh, Sr. Dr Date Of Hearing: 12.08.2021 Date Of Pronouncement: 13.08.2021

For Appellant: Mr. Praveen Godbole, C.AFor Respondent: Mr. A.K. Singh, Sr. DR
Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 50C

reassessment framed by the Assessing Officer under section 143(3) read with section 147 of the Income Tax Act. The learned AR of the assessee has submitted that the Assessing Officer has issued notice under section 143(2) on 29.06.2010 which is beyond the limitation and therefore the re-assessment framed by the Assessing Officer is invalid and liable

DCIT, CIRCLE-II , ALLAHABAD vs. BHARAT PUMPS & COMPRESSORS LTD, ALLAHABAD

In the result, appeal filed by Revenue for ay: 2007-08 is allowed for statistical purposes

ITA 147/ALLD/2016[2005-06]Status: DisposedITAT Allahabad12 Aug 2021AY 2005-06

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

For Appellant: Ms. Tanu Singhal, C.AFor Respondent: Shri Shantanu Dhamija, CIT (DR)
Section 139(1)Section 143(1)Section 147Section 148Section 36(1)(va)

147 r.w. Section 148 of the Act and statutory notices were issued by Revenue from Bharat Pumps & Compressors Ltd. Assessment Years: 2005-06 & 2007-08 time to time during the course of reassessment proceedings . The Revenue also furnished to the assessee reasons recorded for reopening of the concluded assessment . The assessee was asked to furnish return of income in response

DCIT, CIRCLE-II , ALLAHABAD vs. BHARAT PUMPS & COMPRESSORS LTD, ALLAHABAD

In the result, appeal filed by Revenue for ay: 2007-08 is allowed for statistical purposes

ITA 148/ALLD/2016[2007-08]Status: DisposedITAT Allahabad12 Aug 2021AY 2007-08

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

For Appellant: Ms. Tanu Singhal, C.AFor Respondent: Shri Shantanu Dhamija, CIT (DR)
Section 139(1)Section 143(1)Section 147Section 148Section 36(1)(va)

147 r.w. Section 148 of the Act and statutory notices were issued by Revenue from Bharat Pumps & Compressors Ltd. Assessment Years: 2005-06 & 2007-08 time to time during the course of reassessment proceedings . The Revenue also furnished to the assessee reasons recorded for reopening of the concluded assessment . The assessee was asked to furnish return of income in response