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198 results for “reassessment u/s 147”+ Section 11(2)clear

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Key Topics

Section 148152Section 147135Addition to Income93Section 14477Section 250(6)48Section 25045Section 153D41Disallowance36Natural Justice

SH. VISHWA MITTER SEKHRI CHARITABLE SOCIETY,BATALA vs. THE INCOME TAX OFFICER, (EXEMPTION), AMRITSAR.

In the result the 2nd ground raised by the assessee is liable to be allowed

ITA 75/ASR/2016[2007-08]Status: DisposedITAT Amritsar13 Jul 2021AY 2007-08

Bench: Sh. Laliet Kumar & Dr. M. L. Meenai.T.A. No. 75/Asr/2016 Assessment Year: 2007-08

Section 10Section 10(23)Section 11Section 12Section 12ASection 143(1)Section 147Section 148Section 271

reassessment to be framed consequent to notice u/s 148. This makes it very clear that no assessment u/s 147 could be made even though the notice u/s 148 was already issued. Finally, it was submitted that liberal view of the 2nd proviso to section 12A(2) needs to be taken. He relied upon the following decisions :- Shyam Mandir Committee, Khatushyamji

Showing 1–20 of 198 · Page 1 of 10

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35
Section 69A30
Section 143(3)27
Reassessment27

MAJOR SINGH,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

In the result, the assessee’s appeal is partly allowed on the afore-said terms

ITA 426/ASR/2015[2005-06]Status: DisposedITAT Amritsar01 Jul 2019AY 2005-06

Bench: Sh. Sanjay Arorai.T.A. No. 426/Asr/2015 Assessment Year: 2005-06

For Appellant: Sh. Ashwani Kalia (Adv.)For Respondent: Sh. Charan Dass (D.R.)
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(1)

Section 143(2), in such a case, thus, is only toward provision of providing reasonable opportunity to the assessee to states it’s case where a return is filed by the assessee, i..e, in response to notice u/s.148(1), which is the ratio of the decision in Ram Narain Bansal (supra); Madhya Bharat Energy Corporation Ltd. (supra

SHRI HARSH VARDHAN ,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JALANDHAR

ITA 308/ASR/2018[2008-09]Status: DisposedITAT Amritsar21 Feb 2022AY 2008-09

Bench: Sh. Ravish Sood & Dr. M. L. Meena

For Appellant: Sh. Nirmal Mahajan, CAFor Respondent: Sh. Trilochan Singh PS Khalsa, DR
Section 143(2)Section 147Section 148

147 of the Act, i.e, without effecting a valid service of Notice u/s 148; as well as that as regards the validity of the assessment that was framed by him without issuing a Notice u/s 143(2) of the Act, nor with those that were advanced by him as regards the merits of the addition made

SHRI KASHMIR SINGH S/O SHRI SHINGARA SINGH,AMRITSAR vs. INCOME TAX OFFICER, WARD-5(3), AMRITSAR

ITA 23/ASR/2018[2009-10]Status: DisposedITAT Amritsar21 Feb 2022AY 2009-10

Bench: Sh. Ravish Sood & Dr. M. L. Meena

For Appellant: Sh. P. N. Arora, AdvFor Respondent: Sh. Trilochan Singh P S Khalsa, DR
Section 142(1)Section 143(3)Section 144Section 147Section 148Section 250(6)

2), Amritsar had on the same day, i.e, 28.03.2016 approached hi for his sanction/approval for taking recourse to parallel reassessment proceedings against the assessee, i.e, for the same year and, he had in a most mechanical manner, on the same day, i.e, on 28.03.2016 granted his sanction/approval as contemplated in sub-section (1) of section

LORD MAHAVIRA HOMOEOPHATIC MEDICAL COLLEGE AND HOSPITAL ,LUDHIANA vs. INCOME TAX OFFICER (EXEMPTIONS), JALANDHAR

In the result the 2nd ground raised by the assessee is liable to be allowed

ITA 383/ASR/2018[2014-15]Status: DisposedITAT Amritsar21 Sept 2021AY 2014-15

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 12Section 12ASection 143(3)

147 of the Act for the assessment years 2008-09 and 2009-10, 2004-05 to 2007-08 and 2010-11 to 2013-14. During the reassessment proceedings, the assessee has again filed the third application for registration under section 12A on 5-11-2014 along with the resolution passed by the Execute Council of the University approving certain amendments

M/S LORD MAHAVIR HOMEOPATHIC MEDICAL COLLAGE & HOSPITAL,LUDHIANA vs. INCOME TAX OFFICER WARD- ( EXEMPTIONS), JALANDHAR

In the result the 2nd ground raised by the assessee is liable to be allowed

ITA 125/ASR/2020[2016-17]Status: DisposedITAT Amritsar21 Sept 2021AY 2016-17

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 12Section 12ASection 143(3)

147 of the Act for the assessment years 2008-09 and 2009-10, 2004-05 to 2007-08 and 2010-11 to 2013-14. During the reassessment proceedings, the assessee has again filed the third application for registration under section 12A on 5-11-2014 along with the resolution passed by the Execute Council of the University approving certain amendments

M/S LORD MAHAVIRA HOMEOP[ATHIC MEDICAL COLLEGE & HOSPITAL ,LUDHIANA vs. INCOME TAX OFFICER WARD- ( EXEMPTIONS), JALANDHAR

In the result the 2nd ground raised by the assessee is liable to be allowed

ITA 139/ASR/2020[2015-16]Status: DisposedITAT Amritsar21 Sept 2021AY 2015-16

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 12Section 12ASection 143(3)

147 of the Act for the assessment years 2008-09 and 2009-10, 2004-05 to 2007-08 and 2010-11 to 2013-14. During the reassessment proceedings, the assessee has again filed the third application for registration under section 12A on 5-11-2014 along with the resolution passed by the Execute Council of the University approving certain amendments

M/S. SHYAM LAL THAPAR FOUNDATION,MOGA vs. THE INCOME TAX OFFICER_II,, MOGA

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 644/ASR/2013[2010-11]Status: DisposedITAT Amritsar27 Mar 2018AY 2010-11

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 644/(Asr)/2013 Assessment Year: 2010-11 I.T.A. No. 592/(Asr)/2015 Assessment Year: 2009-10

For Appellant: Sh. Jaswinder Singh (Adv.)For Respondent: Sh. Sandeep Chauhan (D.R.)
Section 11Section 12Section 12ASection 12A(1)Section 12A(2)Section 147

147, so that the tribunal; an assessment including, by definition, reassessment, held the same to be covered within the purview of the first proviso to section 12A(2). Coming back to our discussion as to the purpose/reason/s for the stipulation of the condition of the pendency of the assessment proceedings before the AO, i.e., which inform the same

INCOME TAX OFFICER (EXEMPTIONS), JALANDHAR vs. DR SHYAM LAL THAPAR NURSING HOME, MOGA

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 586/ASR/2016[2010-11]Status: DisposedITAT Amritsar27 Mar 2018AY 2010-11

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 644/(Asr)/2013 Assessment Year: 2010-11 I.T.A. No. 592/(Asr)/2015 Assessment Year: 2009-10

For Appellant: Sh. Jaswinder Singh (Adv.)For Respondent: Sh. Sandeep Chauhan (D.R.)
Section 11Section 12Section 12ASection 12A(1)Section 12A(2)Section 147

147, so that the tribunal; an assessment including, by definition, reassessment, held the same to be covered within the purview of the first proviso to section 12A(2). Coming back to our discussion as to the purpose/reason/s for the stipulation of the condition of the pendency of the assessment proceedings before the AO, i.e., which inform the same

M/S SHYMA LAL THAPAR FOUNDATION,MOGA vs. THE INCOME TAX OFFICERII, MOGA

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 592/ASR/2015[2009-10]Status: DisposedITAT Amritsar27 Mar 2018AY 2009-10

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 644/(Asr)/2013 Assessment Year: 2010-11 I.T.A. No. 592/(Asr)/2015 Assessment Year: 2009-10

For Appellant: Sh. Jaswinder Singh (Adv.)For Respondent: Sh. Sandeep Chauhan (D.R.)
Section 11Section 12Section 12ASection 12A(1)Section 12A(2)Section 147

147, so that the tribunal; an assessment including, by definition, reassessment, held the same to be covered within the purview of the first proviso to section 12A(2). Coming back to our discussion as to the purpose/reason/s for the stipulation of the condition of the pendency of the assessment proceedings before the AO, i.e., which inform the same

THE ASSTT. COMMISSIONER OF INCOME TAX, AMRITSAR. vs. M/S KHOSLA INTERNATIONAL, BATALA

ITA 307/ASR/2016[2008-09]Status: DisposedITAT Amritsar27 Mar 2019AY 2008-09

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 307/Asr/2016 Assessment Year: 2008-09

For Appellant: Sh. Avish Mahajan (C.A.)For Respondent: Sh. Charan Dass (D.R.)
Section 143(2)Section 143(3)Section 147Section 148(1)Section 14A

147. The jurisdiction to reassess being assumed on the issue of a valid notice u/s. 148, the notice u/s. 143(2) does not, it 10 Asst. CIT v. Khosla International may be appreciated, assume the status of a jurisdictional notice. The failure to issue a notice u/s. 143(2) in such a case would not invalidate an assessment, as explained

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSHAHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

ITA 514/ASR/2024[2017-18]Status: DisposedITAT Amritsar30 Jun 2025AY 2017-18

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

Section 147Section 148Section 250Section 80Section 80PSection 80P(2)(a)

147 r.w.s. 144B of the Act, dated 30/03/2022. 2. All the above appeals relating to four assessment years are almost on identical facts and common issues are involved and as such, for the sake of convenience, are taken up together and we take up assessment year 2013-14 as the lead case I.T.A. No. 513/Asr/2024. I.T.A. Nos. 513 to 516/Asr/2024

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSHAHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

ITA 515/ASR/2024[2018-19]Status: DisposedITAT Amritsar30 Jun 2025AY 2018-19

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

Section 147Section 148Section 250Section 80Section 80PSection 80P(2)(a)

147 r.w.s. 144B of the Act, dated 30/03/2022. 2. All the above appeals relating to four assessment years are almost on identical facts and common issues are involved and as such, for the sake of convenience, are taken up together and we take up assessment year 2013-14 as the lead case I.T.A. No. 513/Asr/2024. I.T.A. Nos. 513 to 516/Asr/2024

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSHAHR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

ITA 513/ASR/2024[2013-14]Status: DisposedITAT Amritsar30 Jun 2025AY 2013-14

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

Section 147Section 148Section 250Section 80Section 80PSection 80P(2)(a)

147 r.w.s. 144B of the Act, dated 30/03/2022. 2. All the above appeals relating to four assessment years are almost on identical facts and common issues are involved and as such, for the sake of convenience, are taken up together and we take up assessment year 2013-14 as the lead case I.T.A. No. 513/Asr/2024. I.T.A. Nos. 513 to 516/Asr/2024

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSAHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

ITA 516/ASR/2024[2020-21]Status: DisposedITAT Amritsar30 Jun 2025AY 2020-21

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

Section 147Section 148Section 250Section 80Section 80PSection 80P(2)(a)

147 r.w.s. 144B of the Act, dated 30/03/2022. 2. All the above appeals relating to four assessment years are almost on identical facts and common issues are involved and as such, for the sake of convenience, are taken up together and we take up assessment year 2013-14 as the lead case I.T.A. No. 513/Asr/2024. I.T.A. Nos. 513 to 516/Asr/2024

SHRIMATI MANJIT KAUR,BATHINDA vs. INCOME TAX OFFICER, WARD 2 (1), BATHINDA

In the result, both the appeals are disposed off in the terms indicated as above

ITA 147/ASR/2018[2009-10]Status: DisposedITAT Amritsar24 Aug 2022AY 2009-10

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

For Appellant: Sh. J. K. Gupta, AdvFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 148Section 69A

2 nor can it interfere with the notice simply because on an overall reappraisal of material, a different opinion may be formed. e) Jawand Sons Vs. CIT 326 ITR 39 P&H Manjit Kaur & Baljinder Singh v. ITO Under section 147 of the Act, after its amendment with effect from April 1, 1989, wide power has been given

SHRI BALJINDER SINGH ,BATHINDA vs. INCOME TAX OFFICER, WARD 2(1), BATHINDA

In the result, both the appeals are disposed off in the terms indicated as above

ITA 148/ASR/2018[2009-10]Status: DisposedITAT Amritsar24 Aug 2022AY 2009-10

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

For Appellant: Sh. J. K. Gupta, AdvFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 148Section 69A

2 nor can it interfere with the notice simply because on an overall reappraisal of material, a different opinion may be formed. e) Jawand Sons Vs. CIT 326 ITR 39 P&H Manjit Kaur & Baljinder Singh v. ITO Under section 147 of the Act, after its amendment with effect from April 1, 1989, wide power has been given

SHRIMATI AMARJIT KAUR W/O BUGAR SINGH,MANSA vs. INCOME TAX OFFICER WARD 1(4), MANSA

In the result, the appeal of the assessee is dismissed

ITA 1/ASR/2018[2009-10]Status: DisposedITAT Amritsar26 Jul 2023AY 2009-10

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

For Appellant: NoneFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 147Section 148Section 251(2)Section 49

2) are not taken, reassessment proceedings can be taken. h) Aditya and Co. Vs CIT 279 ITR 47 P&H In the case of an intimation under section 143(l)(a) of the Act the question of examination of the material by the Assessing Officer did not arise at that stage. Therefore, in case of intimation u/s

SHRI RAMESH KUMAR ,BATHINDA vs. INCOME TAX OFFICER WARD-1(3), BATHINDA

ITA 342/ASR/2019[2010-11]Status: DisposedITAT Amritsar21 Feb 2022AY 2010-11

Bench: Sh. Ravish Sood & Dr. M. L. Meena

For Appellant: Sh. Tarun Bansal, AdvocateFor Respondent: Sh. Trilochan Singh PS Khalsa, DR
Section 147Section 148Section 55(2)(b)

section 55(2)(b) and 55A of Income Tax Act, respectively before calculating the Capital Gain and order of A.O require to be set-a-side. 10. That the Id.CIT(A) has erred in law, as well as ,on facts by holding the land in question as individual land by ignoring land revenue record and further ignored that neither such

M/S BLUE CITY TOWNSHIP & COLONIZERS,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

ITA 90/ASR/2017[2009-10]Status: DisposedITAT Amritsar14 Jul 2023AY 2009-10

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

Section 147Section 148Section 151Section 234ASection 69

2. That on the facts and in the circumstances of the case, reassessment proceeding cannot be initiated under section 147 for the purpose of enquiry and verification. 3. That on the facts and in the circumstances of-the case, CIT did not recorded satisfaction under Section 151 for issuing notice under Section 147. 4. Without prejudice, no approval has been