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21 results for “reassessment u/s 147”+ Section 80clear

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Key Topics

Section 14847Section 14724Section 35A20Section 26316Addition to Income15Section 142(1)12Section 143(3)9Reopening of Assessment9Section 271D

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

u/s 147 of the Income Tax Act: 7. It is well settled in law that reasons, as recorded for reopening the reassessment, are to be examined on a standalone basis. Nothing can be added to the reasons so recorded, nor anything can be deleted from the reasons so recorded. Hon'ble Bombay High Court, in the case of Hindustan Lever

Showing 1–20 of 21 · Page 1 of 2

8
Section 2507
Cash Deposit6
Reassessment5

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

u/s 151 of the Act, by observing as under: “5.0 Non service of 148 notice: it has been contended that no notice under section 148 of the Income Tax Act was served upon the appellant, however in the remand report the Assessing Officer clearly mentioned that the notice was issued but it remained non-complied. There is difference between

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

u/s 151 of the Act, by observing as under: “5.0 Non service of 148 notice: it has been contended that no notice under section 148 of the Income Tax Act was served upon the appellant, however in the remand report the Assessing Officer clearly mentioned that the notice was issued but it remained non-complied. There is difference between

SH. FARUKH JEHAN ZEB ,SRINAGAR vs. INCOME TAX OFFICER, ANANT NAG

In the result, the appeal of the assessee is dismissed

ITA 444/ASR/2017[2008-09]Status: DisposedITAT Amritsar03 Aug 2023AY 2008-09

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

For Appellant: Sh. Touseef Ahmad Khanday &For Respondent: Sh. S. M. Surendranath, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 68

147 and failure to take steps under section 143(3) will not render the Assessing Officer powerless to initiate reassessment proceedings even when intimation under section 143(1) had been issued.” 10. In another case of “Raymond Woolen Mills Limited. Vs ITO”, 236 ITR 34 the Hon’ble Apex Court has observed as under: “In this case

SHRI BARJINDERPAL SINGH BHULLAR,MOHALI vs. INCOME TAX OFFICER WARD- 1 (3), BATHINDA

Accordingly, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 672/ASR/2019[2008-09]Status: DisposedITAT Amritsar21 Feb 2022AY 2008-09

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

For Appellant: Sh. P. N. Arora, AdvFor Respondent: Sh. Trilochan Singh PS Khalsa, DR
Section 142(1)Section 147Section 148Section 271(1)(c)

80 lac (supra) a/w consideration in kind, i.e, one furnished flat admeasuring 250 sq. ft worth Rs. 1,01,25,000/-, therefore, his income of Rs. 1,81,25,000/- on account of Long Term Capital Gain (“LTCG”, for short) had escaped assessment, reopened his case u/s 147 of the Act. Observing, that the Notice u/s

SHRI BRIJINDERPAL SINGH BHULLAR,MOHALI vs. INCOME TAX OFFICER WARD- 1 (3), BATHINDA

Accordingly, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 671/ASR/2019[2008-09]Status: DisposedITAT Amritsar21 Feb 2022AY 2008-09

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

For Appellant: Sh. P. N. Arora, AdvFor Respondent: Sh. Trilochan Singh PS Khalsa, DR
Section 142(1)Section 147Section 148Section 271(1)(c)

80 lac (supra) a/w consideration in kind, i.e, one furnished flat admeasuring 250 sq. ft worth Rs. 1,01,25,000/-, therefore, his income of Rs. 1,81,25,000/- on account of Long Term Capital Gain (“LTCG”, for short) had escaped assessment, reopened his case u/s 147 of the Act. Observing, that the Notice u/s

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 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 to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable

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 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 to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable

SHRIMATI. HARBHAJAN KAUR,JALANDHAR vs. INCOME TAX OFFICER WARD -1 (20, JALANDHAR

In the result, the appeal of the assessee is allowed

ITA 104/ASR/2021[2012-13]Status: DisposedITAT Amritsar20 Dec 2022AY 2012-13

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

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Mrs. Kanchan Garg, Sr. DR
Section 142(1)Section 143(2)Section 147Section 148Section 149Section 69

80,000/- of which purchase deed was executed on 06.02.2012 where stamp duty charged was Rs. 64,800/-. After verification of registration deed, Assessing Officer held that land purchased by the assessee was “capital asset” within the meaning of section 2(14) of the Income Tax Act, 1961 and unexplained investment in the said property was taxable which escaped income

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

In the result, the appeal for the Asstt

ITA 586/ASR/2024[2019-20]Status: DisposedITAT Amritsar25 Nov 2025AY 2019-20

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

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 147Section 148Section 148ASection 151Section 151ASection 250

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

ITA 585/ASR/2024[2018-19]Status: DisposedITAT Amritsar25 Nov 2025AY 2018-19

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

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 147Section 148Section 148ASection 151Section 151ASection 250

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

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)

147 for reopening of assessment is required to be issued in this case. In this case more than four years have lapsed from the end of assessment year under consideration. Hence, necessary sanction to issue notice u/s 148 has been obtained separately from Pr. CIT (Central) as per the provisions of section 151 of the Act." Notice u/s

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)

147 for reopening of assessment is required to be issued in this case. In this case more than four years have lapsed from the end of assessment year under consideration. Hence, necessary sanction to issue notice u/s 148 has been obtained separately from Pr. CIT (Central) as per the provisions of section 151 of the Act." Notice u/s

INCOME TAX OFFICER,WARD 1 (2), BATHINDA vs. MESERS SHREE BHAGWATI COTTON TRADERS ,, BATHINDA

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

ITA 479/ASR/2018[2009-10]Status: DisposedITAT Amritsar13 Oct 2022AY 2009-10

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

Section 143(3)Section 148Section 250(6)Section 68

section 147 of the Income Tax, 1961.” 6.1 As per the recorded reasons, the total amount of Rs.27,80,000/- was paid to M/s Pratap Enterprises Proprietor and Mr. Varinder Kumar in following sequenceson dated 06.10.2008, Rs.10 lac and Rs.17,80,000/- on dated 14.11.2008. But the assessee filed the objection before the ld. AO against the reopening

MESERS SHREE BHAGWATI COTTON TRADERS,BATHINDA vs. INCOME TAX OFFICER,WARD 1 (2), BATHINDA

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

ITA 480/ASR/2018[2009-10]Status: DisposedITAT Amritsar13 Oct 2022AY 2009-10

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

Section 143(3)Section 148Section 250(6)Section 68

section 147 of the Income Tax, 1961.” 6.1 As per the recorded reasons, the total amount of Rs.27,80,000/- was paid to M/s Pratap Enterprises Proprietor and Mr. Varinder Kumar in following sequenceson dated 06.10.2008, Rs.10 lac and Rs.17,80,000/- on dated 14.11.2008. But the assessee filed the objection before the ld. AO against the reopening

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

147 of the Act, the condition precedent is reason to believe that income had escaped assessment but not establishment of the fact of actual escapement of income. Accordingly, while issuing notice u/s 148 of the Act, there should be evidence on record or specific information received from outside agencies or gathered by the AO to demonstrate that there

LAKHVIR SINGH 810, VPO MALLAH TEHSIL JAGRAON DISTRICT LUDHIANA,PUNJAB vs. THE ASSESSMENT UNIT NFAC DELHI JAO INCOME TAX OFFICER WARD-1, MOGA, PUNJAB

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 541/ASR/2024[2015-2016]Status: DisposedITAT Amritsar29 May 2025AY 2015-2016

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

For Appellant: Sh. Sudhir Sehgal, AR
Section 142(1)Section 147Section 148Section 148ASection 250Section 69A

80,000/-) as stated by the AO) and the contention of the assessee was that the said deposit has come out of sale of agricultural produce. It was further submitted that 4 I.T.A. No. 541/Asr/2024 Assessment Year: 2015-16 investment in fixed deposits were made out of closure proceeds of earlier fixed deposits. 7. However, the AO accepted the documentary

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

reassessment under s. 147. We also do not find anything in the context of s. 273 which would require the words 'regular assessment' to be given a meaning different from the one given by the legislature when these words were defined." 25. I respectfully agree with the views expressed by Chandurkar J. Moreover, there is another aspect to this case

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

reassessment under s. 147. We also do not find anything in the context of s. 273 which would require the words 'regular assessment' to be given a meaning different from the one given by the legislature when these words were defined." 25. I respectfully agree with the views expressed by Chandurkar J. Moreover, there is another aspect to this case

SH. PRATAP SINGH SAMRA,,AMRITSAR. vs. THE INCOME TAX OFFICER, AMRITSAR.

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 189/ASR/2017[2008-09]Status: DisposedITAT Amritsar19 Apr 2022AY 2008-09

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

For Appellant: Sh. NoneFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 133(6)Section 147Section 148Section 250(6)

u/s 148 on the basis of the information from AIR. The Assessing Officer [in brevity the AO] took prior approval before issuance of notice. The addition was made on the basis of the depositing cash in different banks. The assessee filed an appeal before the ld. CIT(A). The ld. CIT(A) considered the issue and the peak credit