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20 results for “reassessment u/s 147”+ Section 131(3)clear

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Key Topics

Section 14839Section 14734Addition to Income20Section 143(3)10Reopening of Assessment10Section 1318Reassessment8Cash Deposit7Section 153C

MESERS SUPERTECH FORGINGS(INDIA) PVT.LTD.,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE IV, JALANDHAR

In the result, the appeal of the Assessee is allowed

ITA 563/ASR/2018[2010-11]Status: DisposedITAT Amritsar02 Aug 2021AY 2010-11
Section 143(3)Section 147

147 are hereby rejected as not sustainable and you are requested to cooperate in the early finalization of the assessment proceedings. Further it is also hereby intimated that the enquiry letters u/s 133(6) issued by this office to all the 3 parties viz. M/s Lovy Steel and Allied Industries, M/s ShreenathIspat Udyog, M/s Shiv BholeKirpa Traders have been received

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

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

6
Section 2505
Natural Justice5
Section 684
Bench:
For Appellant: NoneFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 147Section 148Section 251(2)Section 49

3 are inter linked to each other wherein the appellant challenged validity of reopening of assessment u/s 147 of the Act. 4. The facts of the case as per record are that in the reassessment proceedings, the statutory notice under section 148 of the Income Tax Act was issued on 22 March 2016 which was received back with postal comments

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

reassessment are held to be devoid of any merits and substance and therefore, same are as such rejected. 12. In ground no. 3 & 4, the assessee has challenged approval granted by the CIT u/s 151 for issuing notice u/s 147 as bad in law. This issue of approval granted u/s 151 of the Income

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

ITA 141/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. Rohit Mehra, CIT DR
Section 131(1)Section 147Section 148Section 151(1)

131(1) of the Act, and directed him to produce a copy of the sale/purchase deeds a/w copy of his bank accounts for the period 01.04.2008 to 31.03.2009. In compliance, Sh. Baljinder Singh (supra) though appeared before the A.O, however, in his statement recorded on oath he did not even recognize the assessee, and categorically stated that he had neither

SOM RAJ,PATHANKOT vs. THE INCOME TAX OFFICER, PATHANKOT

ITA 628/ASR/2016[2010-11]Status: DisposedITAT Amritsar21 Feb 2022AY 2010-11

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

For Appellant: Shri. P. N. Arora, AdvFor Respondent: Shri. Rohit Mehra, CIT DR
Section 147Section 148

131 or u/s 133(6) of the Act; (ii). that the reasons on the basis of which the case of ITA No. 628/Asr/2016 – A.Y 2010-11 4 Som Raj. Vs. ITO, Ward 6(3), Pathankot the assessee was reopened does not bear any nexus with the material available on record; (iii). that the AO prior to reopening of the case

SHRI SHISH PAL SINGH,JALANHDHAR vs. INCOME TAX OFFICER, WARD 1(4) JALANDHAR

ITA 309/ASR/2017[2008-09]Status: DisposedITAT Amritsar28 Feb 2022AY 2008-09

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

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: Sh. Trilochan Singh PS Khalsa, Sr DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 153CSection 250(6)

3, point no-5 (mentioned above) the reason to belief of the ld ITO was formed from a receipt. In the course of argument the counsel had pointed out that in the receipt there is no amount is mentioned. The ld. Sr. DR relied on the ‘recorded statement’ of different parties which were summoned u/s 131

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED, TARN TARAN

In the result, both the appeals of the revenue are dismissed and

ITA 45/ASR/2021[2014-15]Status: DisposedITAT Amritsar15 Nov 2022AY 2014-15

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

For Appellant: Sh. Jatinder Nagpal, Adv. & Sh. Nimish Nagpal, CAFor Respondent: Sh. Rohit Mehra, CIT DR
Section 132(4)

131 of the IT Act, 1961 wherein he deposed that he has operated various bank accounts in the name of various bogus/ defunct firms to facilitate the modus operandi of bogus purchases. M/s Punjab Rice Land Pvt. Ltd. is one of the concern which has booked bogus purchases from the aforesaid two bogus firms amounting

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED , TARN TARAN

In the result, both the appeals of the revenue are dismissed and

ITA 44/ASR/2021[2012-13]Status: DisposedITAT Amritsar15 Nov 2022AY 2012-13

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

For Appellant: Sh. Jatinder Nagpal, Adv. & Sh. Nimish Nagpal, CAFor Respondent: Sh. Rohit Mehra, CIT DR
Section 132(4)

131 of the IT Act, 1961 wherein he deposed that he has operated various bank accounts in the name of various bogus/ defunct firms to facilitate the modus operandi of bogus purchases. M/s Punjab Rice Land Pvt. Ltd. is one of the concern which has booked bogus purchases from the aforesaid two bogus firms amounting

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

ITA 627/ASR/2017[2008-09]Status: DisposedITAT Amritsar21 Feb 2022AY 2008-09

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

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Sunil Gautam, CIT-DR
Section 143(3)Section 147Section 69Section 91

147 r.w.s 143(3), dated 30.03.2016, as well as on merits challenged the addition of Rs. 1.50 crore (supra) that was made by him, viz. (i). the A.O had though reopened the assessment on the ground that an amount of Rs. 1.50 crore (supra) received by the assessee from Sh. Surjit Singh (supra) without any consideration was liable

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

ITA 628/ASR/2017[2009-10]Status: DisposedITAT Amritsar21 Feb 2022AY 2009-10

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

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Sunil Gautam, CIT-DR
Section 143(3)Section 147Section 69Section 91

147 r.w.s 143(3), dated 30.03.2016, as well as on merits challenged the addition of Rs. 1.50 crore (supra) that was made by him, viz. (i). the A.O had though reopened the assessment on the ground that an amount of Rs. 1.50 crore (supra) received by the assessee from Sh. Surjit Singh (supra) without any consideration was liable

M/S HOLY FAITH INTERNATIONAL PVT. LTD,JALANDHAR vs. THE DY COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal of the assessee is allowed

ITA 181/ASR/2017[2008-09]Status: DisposedITAT Amritsar15 Jan 2019AY 2008-09

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.181/Asr./2017 : Asstt. Year : 2008-09 M/S Holy Faith International Vs Deputy Commissioner Of Income Tax, Pvt. Ltd., Mbd House, Central Circle-Ii, Railway Road, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Aaach6111J Assessee By : Sh. Sudhir Sehgal, Adv. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 07.01.2019 Date Of Pronouncement : 15.01.2019 Order Per N. K. Saini: This Is An Appeal By The Assessee Against The Order Dated 20.03.2017 Of Ld. Cit(A)-I, Jalandhar. 2. Following Grounds Have Been Raised In This Appeal: “1. That The Worthy Commissioner Of Income Tax (A)-1, Jalandhar Has Erred In Dismissing The Appeal Filed By The Assessee. 2. That The Ld. Cit(A) Has Erred In Confirming The Contention Of The Assessing Officer In Reopening The Case U/S 148 Of The Income Tax Act And, Thus, Framing Of Assessment U/S 147 R.W.S.143(3)/153C At An Income Of Rs. 4,95,13,441/- Against The Returned Income Of Rs. 4,63,33,441/-. 3. That The Ld. Cit(A) Has Erred In Not Considering That There Was No Reason To Believe That The Income Of The

For Appellant: Sh. Sudhir Sehgal, AdvFor Respondent: Sh. Bhawani Shankar, DR
Section 131Section 132Section 147Section 148Section 153C

131 and, as such, no addition could be made without acceding to the request of the assessee. 7. That the Worthy CIT (A) in para 16 having agreed that the Assessing Officer did not provide any opportunity to the assessee to cross-examine Sh. Sanjay Chaudhary and still confirmed the addition, which is against the principles of natural justice

SMT. ASHA CHHABRA,BATHINDA vs. INCOME TAX OFFICER, WARD - 1(1), BATHINDA

In the result, the ground no

ITA 695/ASR/2017[2013-14]Status: DisposedITAT Amritsar26 Sept 2022AY 2013-14

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

Section 131Section 133ASection 143(3)Section 147Section 148Section 250(6)

reassessment proceedings were initiated to verify the source of investment in the purchase of plot and construction of house. Hence, the reasons to believe as recorded by the AO were infact reasons to suspect. d) The finding of the CIT(A) in para-3.2 that "At the stage of notice, it is 'the believe' of the AO based on facts

YADAV RICE MILLS,MUKTSAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, BATHINDA, BATHINDA

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

ITA 415/ASR/2024[2012-13]Status: DisposedITAT Amritsar17 Sept 2025AY 2012-13

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

For Appellant: Sh. Ashwani Kumar, Ms. Deepali Aggarwal
Section 131Section 143(1)Section 143(3)Section 147Section 148Section 151Section 250Section 68Section 69C

reassessment proceedings has been initiated by the AO ( after necessary approval from higher authorities ) vide notice u/s 148 dated 23/03/2019. 5. Objections to notice u/s 148 has been raised and disposed off and submissions made by the assessee during assessment proceedings , consisting of books of accounts, copies of sale bills, transport documents evidencing movement of goods, bank statements, has been

MEASAGE BHAI INDUSTRIES PRIVATE LIMITED,MOGA vs. INCOME TAX OFFICER WARD-1, MOGA

Appeal of the assessee is allowed

ITA 358/ASR/2019[2011-12]Status: DisposedITAT Amritsar11 Aug 2022AY 2011-12

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

For Appellant: Sh. Sudhir SehgalFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 143(1)Section 147Section 148Section 44A

3. Further, you have stated that you had made a payments of Rs. 73,90,000/- for total purchase of Rs. 73,90,374/- during the F.Y 2010-11 instead of Rs. 58,74,080/-. During the course of proceedings u/s 131(1A) of the Income Tax Act, 1961, Sh. Rajesh Mittal, Prop M/s Kamna Overseas had admitted

SHRI GURCHARAN SINGH ,GARSHANKAR vs. INCOME TAX OFFICER, WARD-1, HOSHIARPUR

In the result, the appeal of the assessee is allowed

ITA 318/ASR/2018[2006-07]Status: DisposedITAT Amritsar28 Feb 2022AY 2006-07

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

For Appellant: Sh. S. K. Chopra, AdvFor Respondent: Sh. Trilochan Singh PS Khalsa, Sr DR
Section 131Section 143(2)Section 144Section 144(1)Section 147Section 148Section 250(6)

131 vide order sheet entry dt. 05-02-2014. The 3 Gurcharan Singh v. ITO copies available in the assessment records were also filed before the CIT(A). Therefore the addition of Rs. 3,95,000/- deserves to be deleted. 5. That the order of the CIT(A) confirming the addition of Rs. 3,95,000/-without going into

SHRIMATI. SAVITRI DEVI,BATHINDA vs. INCOME TAX OFFICER WARD-2(1), BATHINDA

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

ITA 340/ASR/2019[2010-11]Status: DisposedITAT Amritsar11 Nov 2022AY 2010-11

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

Section 143Section 147Section 148Section 250Section 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.” 3. Brief fact of the case is that the assessee’s case was reopened u/s 147 on basis of information related to sale of land amount to Rs.40,89,010/-. The assessment was completed

MANDEEP SINGH S/O SH. NARINDER SINGH VILLAGE AND POST OFFICE TARMALA MALOUT DISTRICT MUKTSAR,MUKTSAR vs. THE INCOME TAX OFFICER WARD 2(5) MUKTSAR JAO INCOME TAX OFFICER WARD 2(2) MUKTSAR, MUKTSAR

In the result appeal of the assessee is allowed

ITA 645/ASR/2024[2012-2013]Status: DisposedITAT Amritsar30 Jun 2025AY 2012-2013

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

Section 131Section 133(6)Section 147Section 148Section 151Section 250Section 282Section 69A

3. The brief facts emerging from records are that the assessee is engaged in the business of retail trading of foreign liquor under license granted by the State Excise authorities. On the basis information gathered by the AO that the assessee has made cash deposit amounting to Rs. 15 crore ( fifteen crores ) in the current account maintained with Oriental Bank

M/S. RAJ DEV ,KOTKAPURA vs. INCOME TAX OFFICER WARD-1, FARIDKOT

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

ITA 93/ASR/2023[2012-13]Status: DisposedITAT Amritsar10 Jul 2023AY 2012-13

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

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Sh. Pardeep Kumar, Sr. DR
Section 131Section 139Section 142(1)Section 144Section 250Section 68

147, of the Income-tax Act, 1961 - Assessment - Addition of income [Opportunity of hearing] - Assessee Sales Tax authority held that there was sale of spare parts of cars to assessee by car manufacturer but same was not recorded in books - Said information was supplied to Assessing Officer – Assessing Officer initiated reassessment proceedings and made addition to assessee's income

SHRI SURINDER SINGH DECEASED,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 357/ASR/2016[2002-03]Status: DisposedITAT Amritsar30 Jul 2019AY 2002-03

Bench: Sh. Sanjay Arora

For Appellant: Sh. Jatinder Nagpal (Adv.)For Respondent: Sh. S. S. Negi (D.R.)
Section 131(1)Section 143(3)Section 148(1)

reassessment proceedings, initiated through issue of notice u/s. 148(1) on 26.3.2009, his wife Smt. Jatinder Kaur, filed a reply dated 08.12.2009 (through her counsel, Sh. Nagpal), reproduced at page 3 of the assessment order, stating to be not aware of any such bank account of her late husband and, in any case, of any such money belonging

SH. VIKRANT KANSHAL,BATHINDA vs. THE ICNOMET-AX OFFICER,, BATHINDA

In the result, the assessee’s appeal is partly allowed

ITA 367/ASR/2014[2008-09]Status: DisposedITAT Amritsar12 Jul 2018AY 2008-09

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 367/Asr/2014 Assessment Year: 2008-09

For Appellant: Sh. Ashwani Kalia (C.A.)For Respondent: Smt. Parwinder Kaur, CIT-DR
Section 143(3)Section 147Section 148Section 68

3. We have heard the parties, and perused the material on record. 3.1 Ground 1 of the appeal, challenging the validity of the reassessment proceedings, was not pressed during hearing, with the ld. AR making an endorsement to that effect on the appeal memo. 3.2 We, next, consider the merits of the impugned addition, since sustained. Even as observed