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19 results for “reassessment”+ Revision u/s 263clear

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Key Topics

Section 263107Section 153A35Section 143(3)22Addition to Income15Section 14713Revision u/s 26313Section 14812Reassessment8Cash Deposit5Reopening of Assessment

SHRIMATI. LATA NARANG,JALANDHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessee is allowed

ITA 35/ASR/2021[2011-12]Status: DisposedITAT Amritsar02 Mar 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Ashray Sarna, CAFor Respondent: Smt. Rajinder Kaur, CIT- DR
Section 143(3)Section 147Section 263Section 5(2)Section 6

reassessment is not permissible .Accordingly after issue of certificate in respect of tax in dispute revision u/s 263 is not permissible

3
Section 263(1)2
Section 2502

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

In the result, the appeal filed by assessee is allowed

ITA 306/ASR/2024[2019-20]Status: DisposedITAT Amritsar09 Jan 2025AY 2019-20
Section 115BSection 143(3)Section 263Section 263(1)Section 69

reassessment, Assessing\nOfficer did not invoke section 68,\nhowever, Commissioner exercising his\nrevisionary power under section 263\nset aside assessment orders directing\nAssessing Officer to make fresh\nassessment after conducting detailed\nenquiry and upon satisfying on\ngenuneness of transaction - Whether\norder of Commissioner was not based\non irrelevant considerations and\nfurther in present circumstances, he\nwas not obliged to positively

SMT. SATVIR KAUR W/O SH. SHINDER SINGH,FEROZEPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, AMRITSAR

In the result, the appeal of the assessee is allowed

ITA 102/ASR/2022[2011-12]Status: DisposedITAT Amritsar29 May 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 139(1)Section 143(3)Section 148Section 263

revision proceedings u/s 263 of the Act are bad in law and deserves to be quashed. Reliance in this regard has been placed on the following judgments: • CIT vs. Anil Kumar Sharma as reported in 335 ITR 83 (Del, HC) “In view of the above discussion, it is apparent that the Tribunal arrived at a conclusive finding that, though

SHRI SUKHJINDER SINGH,JALANDHAR vs. PRINICPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessee is allowed

ITA 71/ASR/2022[2017-18]Status: DisposedITAT Amritsar20 Mar 2023AY 2017-18

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. P. N. Arora, AdvFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 263

reassessment is not permissible. Accordingly, after issue of certificate in respect of tax in dispute revision u/s 263 is not permissible

THE DY. COMMISSIONER OF INCOME TAX, AMRITSAR. vs. SH. JAIMAL SINGH, L/H. SH. PREM CHAND,, TARN TARAN

In the result, the appeal bearing ITA No

ITA 82/ASR/2016[2008-09]Status: DisposedITAT Amritsar09 Nov 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 139(9)Section 147Section 250Section 250(6)Section 263

revision u/s 263. 5. The Learned CIT A has erred in law and facts and circumstances of the case by not declaring reassessment

JALALABAD SOLVEX PRIVATE LTD,JALALABAD vs. PR COMMISSIONER OF INCOME TAX , AMRITSAR-1, PR COMMISSIONER OF INCOME TAX

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

ITA 117/ASR/2024[2014-2015]Status: DisposedITAT Amritsar29 Jan 2025AY 2014-2015

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: Sh. Ashwani Kalia, C.A
Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 263Section 263(1)

263 of the Act’61 , on the ground that the proper investigation and enquiry has not been made 5 I.T.A. No. 117/Asr/2024 Jalalabad Solvex Pvt. Ltd. v. Pr. CIT by the Assessing Officer, which has resulted in the order passed being erroneous and prejudicial to the interest of Revenue. The relevant portion of the shows cause notice is reproduced

M/S HEALTHAID FOODS SPECIALIST PVT. LTD ,AMRITSAR vs. PR. COMM. OF INCOME TAX ( CENTRAL), LUDHIANA

In the result, the appeal of the assessee ITA Nos

ITA 280/ASR/2017[2012-13]Status: DisposedITAT Amritsar15 Feb 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Sh. Rohit Mehra, CIT- DR
Section 153ASection 263

revision proceedings u/s. 263 the ld. PCIT found that there was no investigation in assessment related to issues involved in case of assessee which are as follows:- i. Stock declared in bank amount of Rs. 29.9 crores and value of stock as per books of accounts at Rs. 22.7 crores. There was no investigation by the ld. AO about

M/S HEALTHAID FOODS SPECIALIST PVT. LTD ,AMRITSAR vs. PR. COMM. OF INCOME TAX ( CENTRAL), LUDHIANA

In the result, the appeal of the assessee ITA Nos

ITA 281/ASR/2017[2013-14]Status: DisposedITAT Amritsar15 Feb 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Sh. Rohit Mehra, CIT- DR
Section 153ASection 263

revision proceedings u/s. 263 the ld. PCIT found that there was no investigation in assessment related to issues involved in case of assessee which are as follows:- i. Stock declared in bank amount of Rs. 29.9 crores and value of stock as per books of accounts at Rs. 22.7 crores. There was no investigation by the ld. AO about

M/S HEALTHAID FOODS SPECIALIST PVT. LTD ,AMRITSAR vs. PR. COMM. OF INCOME TAX(CENTRAL), LUDHIANA

In the result, the appeal of the assessee ITA Nos

ITA 277/ASR/2017[2009-10]Status: DisposedITAT Amritsar15 Feb 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Sh. Rohit Mehra, CIT- DR
Section 153ASection 263

revision proceedings u/s. 263 the ld. PCIT found that there was no investigation in assessment related to issues involved in case of assessee which are as follows:- i. Stock declared in bank amount of Rs. 29.9 crores and value of stock as per books of accounts at Rs. 22.7 crores. There was no investigation by the ld. AO about

M/S HEALTHAID FOODS SPECIALIST PVT. LTD ,AMRITSAR vs. PR. COMM. OF INCOME TAX(CENTRAL), LUDHIANA

In the result, the appeal of the assessee ITA Nos

ITA 278/ASR/2017[2010-11]Status: DisposedITAT Amritsar15 Feb 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Sh. Rohit Mehra, CIT- DR
Section 153ASection 263

revision proceedings u/s. 263 the ld. PCIT found that there was no investigation in assessment related to issues involved in case of assessee which are as follows:- i. Stock declared in bank amount of Rs. 29.9 crores and value of stock as per books of accounts at Rs. 22.7 crores. There was no investigation by the ld. AO about

M/S HEALTHAID FOODS SPECIALIST PVT. LTD ,AMRITSAR vs. PR. COMM. OF INCOME TAX ( CENTRAL), LUDHIANA

In the result, the appeal of the assessee ITA Nos

ITA 279/ASR/2017[2011-12]Status: DisposedITAT Amritsar15 Feb 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Sh. Rohit Mehra, CIT- DR
Section 153ASection 263

revision proceedings u/s. 263 the ld. PCIT found that there was no investigation in assessment related to issues involved in case of assessee which are as follows:- i. Stock declared in bank amount of Rs. 29.9 crores and value of stock as per books of accounts at Rs. 22.7 crores. There was no investigation by the ld. AO about

M/S HEALTHAID FOODS SPECIALIST PVT. LTD ,AMRITSAR vs. PR. COMM. OF INCOME TAX(CENTRAL), LUDHIANA

In the result, the appeal of the assessee ITA Nos

ITA 276/ASR/2017[2008-09]Status: DisposedITAT Amritsar15 Feb 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Sh. Rohit Mehra, CIT- DR
Section 153ASection 263

revision proceedings u/s. 263 the ld. PCIT found that there was no investigation in assessment related to issues involved in case of assessee which are as follows:- i. Stock declared in bank amount of Rs. 29.9 crores and value of stock as per books of accounts at Rs. 22.7 crores. There was no investigation by the ld. AO about

M/S HEALTHAID FOODS SPECIALIST PVT. LTD ,AMRITSAR vs. PR. COMM. OF INCOME TAX(CENTRAL), LUDHIANA

In the result, the appeal of the assessee ITA Nos

ITA 275/ASR/2017[2007-08]Status: DisposedITAT Amritsar15 Feb 2023AY 2007-08

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Sh. Rohit Mehra, CIT- DR
Section 153ASection 263

revision proceedings u/s. 263 the ld. PCIT found that there was no investigation in assessment related to issues involved in case of assessee which are as follows:- i. Stock declared in bank amount of Rs. 29.9 crores and value of stock as per books of accounts at Rs. 22.7 crores. There was no investigation by the ld. AO about

GURMAIL DASS SIDDHAR (DECEASED) THRU LH NIRANJAN KAUR(WIDOW),HOSHIARPUR vs. ITO W-1 , HOSHIARPUR

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

ITA 352/ASR/2024[2009-10]Status: DisposedITAT Amritsar27 Nov 2025AY 2009-10

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 352/Asr/2024 Assessment Year: 2009-10 Shri Gurmail Dass Siddhar Vs. Ito, Ward- 1, (Deceased) Through L/H Smt. Hoshiarpur. Niranjan Kaur, Widow Garshankar, Ward No. 2 Near Banga Road Octroi, Garshankar, Hoshiarpur. [Pan:-Bwzps4561C] (Appellant) (Respondent) Appellant By None (Adjournment Application) Sh. Charan Dass, Sr. Dr Respondent By Date Of Hearing 13.11.2025 27.11.2025 Date Of Pronouncement

Section 143(3)Section 250Section 263

revision before the jurisdictional PCIT, Jalandhar and vide 263 order dated 23.01.2019 assessment was set aside back to the files of the AO for fresh adjudication in compliance to the 263 order. 4.2 However, said order u/s 263 dated 23.01.2019 was appealed against before the Hon’ble ITAT, Amritsar Bench, and the tribunal vide order dated 13.05.2022 in I.T.A

M/S TORRENT ROOFING SYSTEM,HOSHIARPUR vs. INCOME TAX OFFICER WARD-4, HOSHIARPUR

In the result, the appeal of the assesse is allowed for statistical

ITA 84/ASR/2023[2014-15]Status: DisposedITAT Amritsar12 May 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143Section 263Section 40(1)(ia)

Reassessment made by the Assessing officer U/s 143 (3) read with section 263 of Income Tax Act and confirmed by CIT (A) is bad in law, especially when there is no new material available with the Assessing officer and all the facts were duly verified by the Assessing officer while framing the assessment and same was brought to the knowledge

SHRI SUCHHA SINGH THROUGH L/R RANJIT SINGH,KAPUTHALLA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

ITA 36/ASR/2021[2011-12]Status: HeardITAT Amritsar11 Feb 2026AY 2011-12

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm

For Appellant: Sh. Sandeep Vijh (CA) – Ld. ARFor Respondent: Sh. Farhat Khan (Ld. CIT) - DR
Section 133(6)Section 142(1)Section 143(3)Section 148Section 263

revision u/s 263 wherein it was alleged that no plausible explanation was furnished by the assessee on the investment so made in the immovable property. The assessment was framed out without carrying out necessary verification and accordingly, the assessee was show- caused. The assessee opposed the same, inter-alia, on the ground that the reassessment

SHRI KULDIP SINGH,KAPURTHALA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessee is dismissed

ITA 38/ASR/2021[2012-13]Status: DisposedITAT Amritsar17 Feb 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(2)Section 143(3)Section 147Section 148Section 263

reassessment order dated 20.12.2018, being invalid for wrongful assumption of jurisdiction u/s 147/148, was not capable of revision u/s 263

SHRI SHAM SUNDER AGGARWAL,KAPURTHALA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, the appeal of the assessee bearing ITA No

ITA 17/ASR/2021[2011-12]Status: DisposedITAT Amritsar27 Apr 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 147Section 148Section 151Section 263Section 263o

u/s 151 of the Act. During hearing before he ld. PCIT, the ld. AR submitted the following details which are enclosed in APB page 1 to 16. The relevant paragraph of assessee’s submission is extracted as below: 13. Now coming to the issues raised in the SCN as regards the alleged bogus purchases of Rs.1,97,93,175/- from

M/S JAMMU COOPERATIVE WHOLE SALE LIMITED,JAMMU vs. INCOME TAX OFFICER WARD-2 (1), JAMMU

ITA 150/ASR/2020[2005-06]Status: DisposedITAT Amritsar13 Jun 2023AY 2005-06

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 150/Asr/2020 Assessment Year: 2005-06 M/S Jammu Cooperative Whole Sale The Ito Limited (Super Bazar) Old Hospital Ward-2(1) Road, City Chowk, Jammu- Jammu 180001(J&K)-180001

For Appellant: None
Section 147Section 148Section 152Section 40A(3)

revision, in disguise and seek relief or claim relief in respect of items not claimed in the original assessment proceedings, unless relatable to "escaped income" and re-agitate the concluded matters. Even in cases where the claims of the assessee during the course of re-assessment proceedings relating to the escaped assessment are accepted, still the allowance of such claims