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35 results for “reassessment”+ Section 151(1)clear

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Key Topics

Section 148111Section 14792Addition to Income31Section 153D25Section 69A22Section 35A20Section 15115Section 25015Section 143(3)15Survey u/s 133A

IMRAN MAJEED,SRINAGAR vs. ITO WARD 1, SRINAGAR, SRINAGAR

In the result, the appeal for the Asstt

ITA 585/ASR/2024[2018-19]Status: DisposedITAT Amritsar25 Nov 2025AY 2018-19

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 147Section 148Section 148ASection 151Section 151ASection 250

reassessment in case of assessee was initiated after expiry of three years from end of relevant assessment year, sanction for issue of notice under section 148 ought to have been granted by authorities of rank referred to in section 151 (ii) and not by authorities of relatively lower rank under section 151 (i) Whether there was a gross delay

Showing 1–20 of 35 · Page 1 of 2

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Cash Deposit6
Reassessment6

IMRAN MAJEED,SRINAGAR vs. ITO, WARD 1, SRINAGAR, SRINAGAR

In the result, the appeal for the Asstt

ITA 586/ASR/2024[2019-20]Status: DisposedITAT Amritsar25 Nov 2025AY 2019-20

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 147Section 148Section 148ASection 151Section 151ASection 250

reassessment in case of assessee was initiated after expiry of three years from end of relevant assessment year, sanction for issue of notice under section 148 ought to have been granted by authorities of rank referred to in section 151 (ii) and not by authorities of relatively lower rank under section 151 (i) Whether there was a gross delay

SHRI RAVINDER SINGH ,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

ITA 9/ASR/2020[2017-18]Status: DisposedITAT Amritsar26 Jul 2023AY 2017-18

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

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Hitendra Bhauraoji Ninawe, CIT DR
Section 143(2)Section 153ASection 153D

151 can also be subject of jurisdictional challenge to reopening notice—It is an elementary law that whenever any statutory obligation is casted upon any statutory authority such authority is required to discharge its obligation not mechanically, not even formally but after due application of mind — Thus, obligation of granting Approval acts as an inbuilt protection to taxpayer against arbitrary

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

ITA 5/ASR/2020[2012-13]Status: DisposedITAT Amritsar26 Jul 2023AY 2012-13

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

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Hitendra Bhauraoji Ninawe, CIT DR
Section 143(2)Section 153ASection 153D

151 can also be subject of jurisdictional challenge to reopening notice—It is an elementary law that whenever any statutory obligation is casted upon any statutory authority such authority is required to discharge its obligation not mechanically, not even formally but after due application of mind — Thus, obligation of granting Approval acts as an inbuilt protection to taxpayer against arbitrary

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

ITA 8/ASR/2020[2016-17]Status: DisposedITAT Amritsar26 Jul 2023AY 2016-17

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

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Hitendra Bhauraoji Ninawe, CIT DR
Section 143(2)Section 153ASection 153D

151 can also be subject of jurisdictional challenge to reopening notice—It is an elementary law that whenever any statutory obligation is casted upon any statutory authority such authority is required to discharge its obligation not mechanically, not even formally but after due application of mind — Thus, obligation of granting Approval acts as an inbuilt protection to taxpayer against arbitrary

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

ITA 7/ASR/2020[2015-16]Status: DisposedITAT Amritsar26 Jul 2023AY 2015-16

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

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Hitendra Bhauraoji Ninawe, CIT DR
Section 143(2)Section 153ASection 153D

151 can also be subject of jurisdictional challenge to reopening notice—It is an elementary law that whenever any statutory obligation is casted upon any statutory authority such authority is required to discharge its obligation not mechanically, not even formally but after due application of mind — Thus, obligation of granting Approval acts as an inbuilt protection to taxpayer against arbitrary

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

ITA 6/ASR/2020[2013-14]Status: DisposedITAT Amritsar26 Jul 2023AY 2013-14

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

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Hitendra Bhauraoji Ninawe, CIT DR
Section 143(2)Section 153ASection 153D

151 can also be subject of jurisdictional challenge to reopening notice—It is an elementary law that whenever any statutory obligation is casted upon any statutory authority such authority is required to discharge its obligation not mechanically, not even formally but after due application of mind — Thus, obligation of granting Approval acts as an inbuilt protection to taxpayer against arbitrary

NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 236/ASR/2023[2011-12]Status: DisposedITAT Amritsar26 Sept 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Y. K. Sud & Sh. P. K. Anand, CAs
Section 132Section 142(1)Section 143(3)Section 148Section 153cSection 250

1) [Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, "belongs to; or 7 I.T.A. No. 236/Asr/2023 Assessment Year: 2011-12 (b) any books of account or documents, seized or requisitioned

KHURSHID AHMAD DAR,JAMMU AND KASHMIR, INDIA vs. ITO WARD, UDHAMPUR, UDHAMPUR

In the result, the appeal of the assessee is allowed

ITA 236/ASR/2025[2017-18]Status: DisposedITAT Amritsar10 Nov 2025AY 2017-18

Bench: Dr. Mitha Lalmeena, Hon'Ble & Shri Udayan Das Gupta, Hon'Blekhurshid Ahmad Dar Vs. Ito, Ward, Nully Poshwari Turkawangam, Udhampur Shopia, 192305, Jammu & Kashmir, India.Pin 192305. Pan No. Awmpd5664K Assessee By Shri Rohit Kapoor, Adv. & Shri V.S. Aggarwal, Itp. Revenue By Mrs. Roshanta Kumari Meena, Cit Dr. Date Of Hearing 23.09.2025. Date Of Pronouncement To. [1 .2025. Order Dr. Mitha Lal Meena, A.M.:

Section 144Section 147Section 148Section 148ASection 151Section 151(1)Section 250Section 250(6)Section 282Section 69A

151 were amended vide Finance Act of 2021, with effect from 1-4-2021 - Since there was a regime change with respect to law of limitation coming into effect from 1-4-2021, which curtailed time limit for reopening of assessment from 6 years to 3 years, revenue, with a view to avail limitation prescribed under unamended section 149, generated

LATE. SH. GURMAIL SINGH.S/O. LATE SH. LAL SINGH,SRI MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 57/ASR/2019[2012-13]Status: DisposedITAT Amritsar25 May 2023AY 2012-13

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

LATE. SH. GUMAIL SINGH . S/O. SH. LAL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 55/ASR/2019[2010-11]Status: DisposedITAT Amritsar25 May 2023AY 2010-11

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

LATE. SH. GURMAIL. SINGH S/O. SH. LAL SINGH,SHRI MUKAT SAR vs. DY. COMMISSIONER OF 9INCOME TAX. CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 56/ASR/2019[2011-12]Status: DisposedITAT Amritsar25 May 2023AY 2011-12

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

LATE. SH. GURMAIL. SINGH. S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 58/ASR/2019[2013-14]Status: DisposedITAT Amritsar25 May 2023AY 2013-14

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

LATE. SH. GURMAIL SINGH S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 59/ASR/2019[2014-15]Status: DisposedITAT Amritsar25 May 2023AY 2014-15

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SH. ARASHPREET SINGH S/O LATE SH. GURMAIL SINGH,SHRI MUKATSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 60/ASR/2019[2010-11]Status: DisposedITAT Amritsar25 May 2023AY 2010-11

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SH. ARSPREET SINGH . S/O. LATE. SH. GURMAIL SINGH ,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE .II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 61/ASR/2019[2011-12]Status: DisposedITAT Amritsar25 May 2023AY 2011-12

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CERCLE- II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 62/ASR/2019[2012-13]Status: DisposedITAT Amritsar25 May 2023AY 2012-13

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 63/ASR/2019[2013-14]Status: DisposedITAT Amritsar25 May 2023AY 2013-14

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SH. ARASHPREET SINGH. S/O.LATE.SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX .CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 64/ASR/2019[2014-15]Status: DisposedITAT Amritsar25 May 2023AY 2014-15

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

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

INCOME TAX OFFICER, WARD-3(1),FEROZEPUR, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

ITA 103/ASR/2024[2014-15]Status: DisposedITAT Amritsar15 Jan 2026AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

Section 143(3)Section 148Section 250Section 35A

reassessment complete is valid and the Appellants ground is dismissed. Issue on merits: I have gone through the submission made by the Appellant, the Appellant is an Association of Person which has been formed with the object of setting up and I.T.A. No. 103 & 104/Asr/202 1 Assessment Years: 2014-15 and 2017-18 1 operating warehousing facility for storage