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18 results for “reassessment u/s 147”+ Section 263(1)clear

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Key Topics

Section 26352Section 143(3)31Section 14724Section 35A20Section 14815Addition to Income11Section 271D8Reassessment7Section 269S

SHRIMATI. LATA NARANG,JALANDHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessee is allowed

ITA 35/ASR/2021[2011-12]Status: DisposedITAT Amritsar02 Mar 2023AY 2011-12

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

For Appellant: Sh. Ashray Sarna, CAFor Respondent: Smt. Rajinder Kaur, CIT- DR
Section 143(3)Section 147Section 263Section 5(2)Section 6

147 of the Income Tax Act, 1961 for the Asstt.Year:2011-12 were initiated in your case as you did not file any information with respect to the source of cash deposited by you at Rs.35,50,000/- in your savings bank during the relevant period. In response to the notice u/s 148 of the Act, you filed the income

6
Cash Deposit6
Section 250(6)5
Revision u/s 2633

SH. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PR. COMMISSIONER OF INCME TAX , BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

ITA 39/ASR/2019[2008-09]Status: DisposedITAT Amritsar11 Aug 2022AY 2008-09

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

For Appellant: Sh. Anil Puri, AdvFor Respondent: Sh. Chandrajit Singh, CIT DR
Section 263Section 269SSection 271D

u/s 171D and 271E passed by the JCIT, Bathinda, wherein as per the section 271D and 271E, the JCIT is categorically empowered for the penalty performance, being the quasi judicial action; that the Ld. PCIT while cancelling the penalty order, passed Manjit Krishan Malhotra v. Pr.CIT under section 271D and 271E, dated 10.02.2014, by the Jt. Commissioner of Income

SHRI. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

ITA 40/ASR/2019[2008-09]Status: DisposedITAT Amritsar11 Aug 2022AY 2008-09

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

For Appellant: Sh. Anil Puri, AdvFor Respondent: Sh. Chandrajit Singh, CIT DR
Section 263Section 269SSection 271D

u/s 171D and 271E passed by the JCIT, Bathinda, wherein as per the section 271D and 271E, the JCIT is categorically empowered for the penalty performance, being the quasi judicial action; that the Ld. PCIT while cancelling the penalty order, passed Manjit Krishan Malhotra v. Pr.CIT under section 271D and 271E, dated 10.02.2014, by the Jt. Commissioner of Income

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)

reassessment of proceedings read with section assessment filed by 147 the assessee 8 I.T.A. No. 117/Asr/2024 Jalalabad Solvex Pvt. Ltd. v. Pr. CIT iv 08-12- Notice under The assessee has 2021 section 142(1) filed the required information in the Notice under section 142(1) issued on 08- 12- reply dated 2021 asking for the information:- 02/01/2022 and 28/02/2022

SMT. SATVIR KAUR W/O SH. SHINDER SINGH,FEROZEPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, AMRITSAR

In the result, the appeal of the assessee is allowed

ITA 102/ASR/2022[2011-12]Status: DisposedITAT Amritsar29 May 2023AY 2011-12

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

Section 139(1)Section 143(3)Section 148Section 263

section 263 of the l. T. Act, 1 9 6 1 after affording reasonable opportunity of being heard. 4. The case was reopened on the reasons that the assessee had deposited cash of Rs. 60,00,000 in her saving bank account maintained with the Oriental Bank of Commerce during the financial year 2010-11 and that no voluntary return

THE DY. COMMISSIONER OF INCOME TAX, AMRITSAR. vs. SH. JAIMAL SINGH, L/H. SH. PREM CHAND,, TARN TARAN

In the result, the appeal bearing ITA No

ITA 82/ASR/2016[2008-09]Status: DisposedITAT Amritsar09 Nov 2023AY 2008-09

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

Section 139(9)Section 147Section 250Section 250(6)Section 263

263. 5. The Learned CIT A has erred in law and facts and circumstances of the case by not declaring reassessment u/s 147 made on the basis of standalone AIR Information bad in law. 6. The Learned CIT A has erred in law and facts and circumstances of the case by upholding reassessment u/s 147 on the ground

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

1), New Delhi] [refer page no. 70-75 of case law paper book] Section 69A, read with section 147, of the Income-tax Act, 1961 - Unexplained money (Cash) - Assessment year 2012-13 - One of Directors of assessee company namely 'A' was carrying Rs. 5 lakhs from Delhi to Ghaziabad for payment of wages and other normal expenses - 'A' was stopped

SHRI KULDIP SINGH,KAPURTHALA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessee is dismissed

ITA 38/ASR/2021[2012-13]Status: DisposedITAT Amritsar17 Feb 2023AY 2012-13

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

Section 143(2)Section 143(3)Section 147Section 148Section 263

1. That the impugned order, mechanically passed to save limitation, by neither allowing sufficient opportunity, nor even by examining the reply 2 Kuldeep Singh v. Pr. CIT filed against shows cause notice, is wholly illegal and unsustainable in law. 2. That the reassessment order dated 20.12.2018, being invalid for wrongful assumption of jurisdiction u/s 147/148, was not capable of revision

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

reassessment proceeding and was satisfied that no income has escaped ITA Nos. 20&21/Asr/2021 7 Kaiser Industries Ltd. v. Pr.CIT assessment. The Ld. PCIT, Srinagar has set aside the order passed by Ld. A.O. u/s 143(3) read with section 147 of the I.T. Act, 1961 dated 20.12.2017 with the directions to the A.O to reframe the assessment de- novo

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

reassessment proceeding and was satisfied that no income has escaped ITA Nos. 20&21/Asr/2021 7 Kaiser Industries Ltd. v. Pr.CIT assessment. The Ld. PCIT, Srinagar has set aside the order passed by Ld. A.O. u/s 143(3) read with section 147 of the I.T. Act, 1961 dated 20.12.2017 with the directions to the A.O to reframe the assessment de- novo

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

u/s 147 / 148 , against the assessee, (for which the assessee is not in appeal ), but he has decided the issue in favour of the assessee, on merits of the case allowing the appeal by observing as follows: “Legal contention: I have perused the assessment order and the submission made by the Appellant. The AO has issued notice under section

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

u/s 147 / 148 , against the assessee, (for which the assessee is not in appeal ), but he has decided the issue in favour of the assessee, on merits of the case allowing the appeal by observing as follows: “Legal contention: I have perused the assessment order and the submission made by the Appellant. The AO has issued notice under section

SHRI SHAM SUNDER AGGARWAL,KAPURTHALA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

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

ITA 17/ASR/2021[2011-12]Status: DisposedITAT Amritsar27 Apr 2023AY 2011-12

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

Section 143(3)Section 147Section 148Section 151Section 263Section 263o

147 as also the additions made in order dt.27.12.2018, having close bearing on purchases doubted by PCIT, was pending, the jurisdiction u/s.263 could not be invoked in law. I.T.A. No.17/Asr/2021 3 Assessment Year: 2011-12 4. That when all the relevant details and documents were filed in reassessment, and examined by the ld. lTO qua the issues as per 'reasons

SH GAUTAM SETH,BATALA vs. THE INCOME TAX OFFICER, BATALA

In the result, the Ground Nos

ITA 108/ASR/2017[2008-09]Status: DisposedITAT Amritsar04 Jul 2022AY 2008-09

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

For Appellant: Sh. Mrs. Rano Jain, Adv. &For Respondent: Smt. Rajinder Kaur, CIT DR
Section 143(2)Section 143(3)Section 148Section 234BSection 250(6)Section 271Section 40A(3)Section 44A

reassessment order passed u/s 143(3) r.w.s. 147 and the additions made therein are illegal bad in law and without jurisdiction as no notice u/s 143(2) has not been served within the prescribed time as per the provisions of law” The relevant facts are already on record and no new fact is required to be investigated. The above noted

M/S. PUNJAB IRON & STEEL COMPANY LIMITED,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeal of the assesse is allowed

ITA 75/ASR/2023[2008-09]Status: DisposedITAT Amritsar03 Aug 2023AY 2008-09

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

For Appellant: NoneFor Respondent: Sh. S. R. Kaushik, CIT DR
Section 153ASection 68

263 of 2011 GA No. 2856 of 2011 High Court of Calcutta: "After getting the PAN number and getting the information that the creditor is assessed under the Act, the Assessing Officer should enquire from the Assessing Officer of the creditor as to the genuineness of the transaction and whether transaction has been accepted by the Assessing Officer

M/S JAMMU COOPERATIVE WHOLE SALE LIMITED,JAMMU vs. INCOME TAX OFFICER WARD-2 (1), JAMMU

ITA 150/ASR/2020[2005-06]Status: DisposedITAT Amritsar13 Jun 2023AY 2005-06

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 150/Asr/2020 Assessment Year: 2005-06 M/S Jammu Cooperative Whole Sale The Ito Limited (Super Bazar) Old Hospital Ward-2(1) Road, City Chowk, Jammu- Jammu 180001(J&K)-180001

For Appellant: None
Section 147Section 148Section 152Section 40A(3)

1) Road, City Chowk, Jammu- Jammu 180001(J&K)-180001 PAN: AAAJJ0397H (Appellant) (Respondent) Appellant by : None Shri Nakul Aggarwal, Sr. DR Respondent by Date of Hearing : 07/06/2023 Date of Pronouncement : 13/06/2023 ORDER Per Dr. M. L. Meena, AM: This is an appeal filed by the Assessee against the order of the Ld. CIT(A)/NFAC, Delhi dtd. 12/08/2020, wherein

GURPAL SINGH SIDHU,NEAR GOVT SCHOOL vs. ITO WARD 1(2), BATHINDA, BATHINDA

In the result, the appeal of the assessee is partly allowed for

ITA 9/ASR/2025[2017-18]Status: DisposedITAT Amritsar19 Aug 2025AY 2017-18

Bench: Udayan Das Gupta & Shri Brajesh Kumar Singh[Assessment Year: 2017-18]

Section 142(1)Section 144Section 69A

reassessment notice was unjustified The facts of this case were entirely different than that of present case of the appellant. In the present case, the appellant could not explain source and nature of cash deposits before the Assessing Officer. Therefore, the Assessing Officer correctly proceeded with re-assessment proceedings and completed the assessment accordingly. 5.5. The appellant argued that

SHRI GURBINDER SINGH MAHAL,AMRITSAR vs. INCOME TAX OFFICER WARD-IV ( 2), AMRITSAR

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

ITA 22/ASR/2023[2014-15]Status: DisposedITAT Amritsar24 Apr 2023AY 2014-15

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

Section 144Section 144oSection 250(4)Section 250(6)Section 250o

reassessment or recomputation under section 147) of the income of the deceased and for the purpose of levying any sum in the hands of the legal representative in accordance with the provisions of sub-section (1),— (a) any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative