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30 results for “reassessment u/s 147”+ Section 2(47)(v)clear

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Key Topics

Section 153C40Section 14733Section 143(3)28Section 14827Section 12A22Section 35A20Addition to Income19Section 26317Section 12

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 30 · Page 1 of 2

10
Reopening of Assessment8
Exemption7
Reassessment6

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

v. ITO particulars of the return without any new material. Even if proceedings under s. 143(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

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) on 12.11.2014 served upon the assessee on 5 I.T.A. No. 90/Asr/2017 Blue City Township & Colonizers v. ITO 13.11.2014 fixing the case for hearing on 20.11.2014. The case of the appellant company was adjourned on different dates at the request of the ld. counsel for the assessee company during the course of assessment proceedings by granting adjournment

M/S NICE TELECOM,MANSA vs. THE INCOME TAX OFFICER, WARD 1(4), MANSA

In the result, the assessee’s appeal is allowed

ITA 153/ASR/2014[2007-08]Status: DisposedITAT Amritsar07 Feb 2019AY 2007-08

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 153/Asr/2014 Assessment Year: 2007-08

For Appellant: Sh. I. S. Khurana (C.A.)For Respondent: Sh. Charan Dass (D.R.)
Section 142(1)Section 143(3)Section 144Section 147Section 148(1)Section 148(2)Section 2Section 271(1)(c)

2) for the purpose of issue of notice u/s. 148(1), stated two reasons to believe escapement of income chargeable to tax, as under: (PB pg. 9) (a) The assessee had claimed deduction on account of expenditure on ‘mobile repairs’ and on ‘recovery account’ at Rs.1,58,675 and Rs.1,96,636/- respectively. The repair expenses incurred during the warranty

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)

u/s 148 dated 31-03-2021 received Return of income section 148 filed in response to the notice under section [DIN: TBA/AST/S/148/2020- 21/1032083993(1)] 148 iii 28-06- Notice under section 143(2) issued on Notice under 2021 Objections the 28/06/2021 providing the details of section 143(2) reopening reassessment of proceedings read with section assessment filed by 147

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

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

ITA 184/ASR/2018[2011-12]Status: DisposedITAT Amritsar03 Feb 2020AY 2011-12

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

For Appellant: Shri I.P.Bansal, AdvocateFor Respondent: Shri Charan Dass, DR
Section 143(2)Section 143(3)Section 147Section 148Section 151Section 151(2)Section 44A

u/s 151(2) obtained by the AO from JCIT. The sanction has been granted by writing the words ‘ yes, satisfied’. Page 66 of the paper-book. 5. The assessee did not raise the ground before CIT(A) agitating the validity of reassessment proceedings. However, the assessee has filed an application for admission of additional grounds as well as admission

SH. VARINDER KUMAR SOUL,JALANDHAR vs. INCOME TAX OFFICER, WARD - 3(2), JALANDHAR

ITA 451/ASR/2017[2012-13]Status: DisposedITAT Amritsar16 Jan 2018AY 2012-13

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 451(Asr)/2017 Assessment Year: 2012-13 Pan: Cvips 5218R

For Appellant: Sh. Ashray Sarna (C.A.)For Respondent: Sh. Ghulam Mustafa (D. R.)
Section 139Section 143(3)Section 147Section 148Section 148(2)

Section 143(2), per which the law provides for the said verification, and sec. 147, operate in different fields, even as explained in Vipan Khanna v. CIT [2002] 255 ITR 220 (P&H). Be that as it may, there is equally no doubt that the AO had a valid reason to believe escapement from assessment qua rental income. The same

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)

47,44,901/-. 2. There is no other issue in the present case, because the receipts and expenses have been accepted by the department and regarding the genuineness of activity and aims and objects, there is no whisper in the order of Assessing Officer and meaning thereby, that if there would have been registration u/s 12A, then the surplus

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)

47,44,901/-. 2. There is no other issue in the present case, because the receipts and expenses have been accepted by the department and regarding the genuineness of activity and aims and objects, there is no whisper in the order of Assessing Officer and meaning thereby, that if there would have been registration u/s 12A, then the surplus

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)

47,44,901/-. 2. There is no other issue in the present case, because the receipts and expenses have been accepted by the department and regarding the genuineness of activity and aims and objects, there is no whisper in the order of Assessing Officer and meaning thereby, that if there would have been registration u/s 12A, then the surplus

KAISER INDUSTRIES LIMITED,SAMBA vs. PRINCIPAL.COMMISSIONER OF INCOME TAX-1, SRINAGAR

ITA 20/ASR/2021[2010-11]Status: DisposedITAT Amritsar16 Sept 2022AY 2010-11

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

For Appellant: Sh. R. K. Gupta, C.AFor Respondent: Sh. Rohit Mehra, CIT- DR
Section 143(3)Section 147Section 148Section 263

section 263 of the Act. 2. Ground of Appeal: The Worthy Pr. CIT is not justified on facts as well as on law in setting aside the assessment order passed u/s 143(3) of the Income Tax Act, 1961 on 20.12.2017. The assessment order has been passed by the ld. A.O. after conducting necessary enquiries and after application of mind

KAISER INDUSTRIES LIMITED ,SAMBA vs. PRINCIPAL COMMISSONER OF INCOME TAX-1, SRINAGAR

ITA 21/ASR/2021[2011-12]Status: DisposedITAT Amritsar16 Sept 2022AY 2011-12

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

For Appellant: Sh. R. K. Gupta, C.AFor Respondent: Sh. Rohit Mehra, CIT- DR
Section 143(3)Section 147Section 148Section 263

section 263 of the Act. 2. Ground of Appeal: The Worthy Pr. CIT is not justified on facts as well as on law in setting aside the assessment order passed u/s 143(3) of the Income Tax Act, 1961 on 20.12.2017. The assessment order has been passed by the ld. A.O. after conducting necessary enquiries and after application of mind

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

47 CCH 0197 (Ahd), is that as it has since been granted registration (i.e., on 20.01.2014 / copy on record), the assessment, setting aside the impugned order/s, be restored back to the file of the Assessing Officer (AO) to examine the application of sections 11 and 12 of the Act in view of section 12A(2), which reads as under: ‘Conditions

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

47 CCH 0197 (Ahd), is that as it has since been granted registration (i.e., on 20.01.2014 / copy on record), the assessment, setting aside the impugned order/s, be restored back to the file of the Assessing Officer (AO) to examine the application of sections 11 and 12 of the Act in view of section 12A(2), which reads as under: ‘Conditions

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

47 CCH 0197 (Ahd), is that as it has since been granted registration (i.e., on 20.01.2014 / copy on record), the assessment, setting aside the impugned order/s, be restored back to the file of the Assessing Officer (AO) to examine the application of sections 11 and 12 of the Act in view of section 12A(2), which reads as under: ‘Conditions

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

2. Succinctly stated, on the basis of the information in his possession that the assessee during the year under consideration had made cash ITA No. 628/Asr/2016 – A.Y 2010-11 3 Som Raj. Vs. ITO, Ward 6(3), Pathankot deposits of Rs. 47 lac in his Saving Bank Account No. 1110 with Punjab Gramin Bank, Taragarh, the A.O reopened the case

INCOME TAX OFFICER, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

ITA 104/ASR/2024[2017-18]Status: DisposedITAT Amritsar15 Jan 2026AY 2017-18

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

47,11,318/- as against claimed by the assessee in respect of expenditure of Rs 77,65,67,171/-. Hence, deduction u/s 35AD of the Act has been claimed by the assessee wrongly. 6. As per the provisions of section 147 of the Income Tax Act, 1961, if the Assessing Officer has reasons to believe that any income may, subject

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

47,11,318/- as against claimed by the assessee in respect of expenditure of Rs 77,65,67,171/-. Hence, deduction u/s 35AD of the Act has been claimed by the assessee wrongly. 6. As per the provisions of section 147 of the Income Tax Act, 1961, if the Assessing Officer has reasons to believe that any income may, subject