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

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

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 obtained from the component authority as required u/s 151. Hence the notice

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

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

1 to 6 are interlinked to each other pertaining to the issues of validity of reasons for reopening of the assessment u/s 148 of the Act; sanction by PCIT under section 151 and non service of notice and thus, validity of reassessment proceeding. 6.1 In appeal, the Ld. CIT(A) has confirmed the finding of the AO on the issue

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

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

1 to 6 are interlinked to each other pertaining to the issues of validity of reasons for reopening of the assessment u/s 148 of the Act; sanction by PCIT under section 151 and non service of notice and thus, validity of reassessment proceeding. 6.1 In appeal, the Ld. CIT(A) has confirmed the finding of the AO on the issue

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

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

reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. Copy of the form for recording the reasons for initiating the proceedings under section 148 of the Act and for obtaining the approval of the JCIT

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

In the result, the appeal for the Asstt

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

147 is bad in law as the jurisdictional notice issued u/s 148 and proceedings completed u/s 148A(d) were made by the jurisdictional AO which is in violation with the provisions of section 151A read with notification no S.O. 1466 (E) No 18/2022 dated 29.03.2022. 6. That the information uploaded on the insight portal is nowhere corroborated with any independent

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

In the result, the appeal for the Asstt

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

147 is bad in law as the jurisdictional notice issued u/s 148 and proceedings completed u/s 148A(d) were made by the jurisdictional AO which is in violation with the provisions of section 151A read with notification no S.O. 1466 (E) No 18/2022 dated 29.03.2022. 6. That the information uploaded on the insight portal is nowhere corroborated with any independent

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

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

147 of the Act only after due application of mind, and if for some reason an error creeps into the exercise of the said power by the A.O, then, the superior officer, i.e, the authority specified in Sec. 151 of the Act is able to correct the same. It is for the aforesaid reason, that Section 151 requires an officer

SHRIMATI NEETIMA GOYAL,FEROZPUR CANTT. vs. INCOME TAX OFFICER,3(2), FEROZPUR

In the result, appeal of the assessee is allowed on legal ground

Bench: Shri L.P. Sahu, Am & Shri Ravish Sood, Jm आयकर अऩीऱ सं./Ita No.184/Asr/2018 (ननधाारण वषा / Assessment Year :2011-2012) Neetima Goyal, Vs. Ito, Ward-3(2), Ferozepur Prop. Raghav Sales, G.T.Road, Ferozepur Cantt., Pin-152001 स्थायी ऱेखा सं./ Panno. : Aicpg 3586 H (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri I.P.Bansal, Advocate राजस्व की ओर से /Revenue By : Shri Charan Dass, Dr

1. That under the facts and circumstances of the case impugned assessment order dated 27-12-2016 is bad in law on account of invalid initiation of reassessment proceedings on following grounds: - a. That Ld. AO did not have 'reason to believe' as postulated in section 147 of the Act to draw an opinion that the income of the assessee

SHRI TARLOCHAN SINGH,MANSA vs. INCOME TAX OFFICER WARD-1(4), MANSA

In the result, both the appeals of the assessees are allowed

1. The Ld. CIT(A) erred on facts & law in confirming the action of the AO of assessing the income at Rs.3,87,73,310/- + Agriculture income at Rs. 11,56,169/- vide order u/s 143(3)1147 dated 20.12.2017. 2. The Ld. CIT(A) erred on facts & law in confirming the validity of the proceedings u/s 1471148 because

SHRI NAROTAM SINGH,MANSA vs. INCOME TAX OFFICER WARD -1(4), MANSA

In the result, both the appeals of the assessees are allowed

1. The Ld. CIT(A) erred on facts & law in confirming the action of the AO of assessing the income at Rs.3,87,73,310/- + Agriculture income at Rs. 11,56,169/- vide order u/s 143(3)1147 dated 20.12.2017. 2. The Ld. CIT(A) erred on facts & law in confirming the validity of the proceedings u/s 1471148 because

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

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

u/s 132(1)( c ) which has to have been discovered during search. “Assessment of Income of any other person. 153C. [(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

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

In the result, the appeal of the assessee is allowed

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.:

151(1). Therefore, the assessment proceedings initiated u/s 148 is without jurisdiction as notice u/s 148 was issued after the expiry of three years with the approval joint commissioner/ additional commissioner of Income Tax. 3 8. That the appellant craves leave to add, amend and alter the grounds of appeal. 3. The Ld. AR explained that there was bonafide reason

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

151(1) of the Income- tax Act, 1961. 4. The assessee after receipt of the reasons to believe, filed the objection vide letter dated 10th of July 2017 mentioning therein that, the assessment proceedings of the assessee were completed under section 143 (3) of the Act, and the entire transaction of the assessee was examined by the assessing officer, therefore

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

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the 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

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

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

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the 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

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the 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

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income