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122 results for “reassessment u/s 147”+ Set Off of Lossesclear

Sorted by relevance

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Key Topics

Section 153A86Section 26371Section 14855Addition to Income54Section 13252Section 14746Section 153D31Section 143(3)30Section 250(6)

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. WINSOME TEXTILE INDUSTRIES LTD, CHANDIGARH

ITA 556/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh27 Feb 2025AY 2011-12
For Respondent: \nThe DCIT
Section 115JSection 143(1)Section 143(3)Section 148

U/S 147 and 143(3) for A.Ys.\n2011-12, 2012-13, 2013-14 and 2014-15.\nThe assumption of jurisdiction and the extension of scope of inquiry beyond the\nreasons recorded deserves to be set aside on the following grounds:-\ni) The assessee company filed its return of income on 29th September, 2011 at nil\nincome after set- ting

INDO PACIFIC FINLEASE LTD,CHANDIGARH vs. PCIT- CHANDIGARH 1, CHANDIGARH

In the result, both the appeals are filed by the\nassessee are allowed

Showing 1–20 of 122 · Page 1 of 7

27
Reopening of Assessment23
Reassessment22
Natural Justice13
ITA 449/CHANDI/2024[2015-16]Status: Disposed
ITAT Chandigarh
16 Apr 2025
AY 2015-16
For Appellant: \nSh. Ashok Goel, C.AFor Respondent: \nSh.Rohit Sharma, CIT-D.R
Section 147Section 148Section 203(1)Section 263

reassessment order passed was illegal and invalid due to following:-\n\n1. Notice u/s 148 issued on 01.04.2021 is time barred for the above Assessment Year.\nRegarding the date of issue of notice, there is no date mentioned on ITBA portal when the notice was uploaded and column is left blank. The snapshot is as under:\n\nIncome Tax Portal

INDO PACIFIC FINLEASE LTD,CHANDIGARH vs. PCIT CHANDIGARH 1, CHANDIGARH

In the result, both the appeals are filed by the\nassessee are allowed

ITA 448/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh16 Apr 2025AY 2014-15
For Appellant: \nSh. Ashok Goel, C.AFor Respondent: \nSh.Rohit Sharma, CIT-D.R
Section 147Section 148Section 203(1)Section 263

reassessment order passed was illegal and invalid due to following:-\n1. Notice u/s 148 issued on 01.04.2021 is time barred for the above Assessment\nYear.\nRegarding the date of issue of notice, there is no date mentioned on ITBA\nportal when the notice was uploaded and column is left blank. The snapshot\nis as under:\nIncome Tax Portal, Government

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 528/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh27 Feb 2025AY 2011-12

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Ved Parkash Kalia Sr. DR
Section 115JSection 143(1)Section 143(3)Section 147Section 148

set- ting of brought forward losses to the tune of Rs.210509768/-. The said return was accepted and a notice was issued U/s. 147 on 26th March, 2017. The reasons recorded for initiation of proceedings U/s. 147 indicated that during the course of assessment proceedings for A.Y. 2013-14, the amount raised after the issue of GDRs during

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

ITA 644/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh18 Sept 2024AY 2015-16

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Rohit Jain, Advocate and Ms. Somya Jain, C.AFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 250Section 253Section 3

u/s 148 of the I.T. Act on 10.02.2020. Thus, the notice was issued by the AO within four years from the end of the relevant assessment year and, therefore, the first Proviso to section 147 of the I.T. Act is not attracted in this case. 5.8 Section 147 of the Income Tax Act is reproduced as under:- Income escaping assessment

SHRI HARI & CO OWNERS,KAITHAL vs. PR. CIT, CHANDIGARH -1, ROHTAK

In the result, both the above appeals of the Assessee are dismissed

ITA 403/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh31 Jul 2024AY 2013-14

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 263

loss of Revenue cannot be treated as Prejudicial to the interest of Revenue. Twin test is key. 10. In Form No. 36 the assessee has raised the following grounds of appeal: 1. That on the facts and circumstances of the case and in law, the order passed by the PCIT, Rohtak u/s 263 of the Income

SHRI HARI & CO OWNERS,KAITHAL vs. PR. CIT, CHANDIGARH -1, ROHTAK

In the result, both the above appeals of the Assessee are dismissed

ITA 402/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh31 Jul 2024AY 2012-13

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 263

loss of Revenue cannot be treated as Prejudicial to the interest of Revenue. Twin test is key. 10. In Form No. 36 the assessee has raised the following grounds of appeal: 1. That on the facts and circumstances of the case and in law, the order passed by the PCIT, Rohtak u/s 263 of the Income

EMSON TOOLS MFG CORP LTD,LUDHIANA vs. DCIT, LUDHIANA

In the result, the appeal of the assessee is allowed

ITA 845/CHANDI/2016[2009-10]Status: DisposedITAT Chandigarh27 Apr 2018AY 2009-10

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaemson Tools Mfg. Corpn. Ltd., Vs. The D.C.I.T.,(Cc-I), D-2, Focal Point, Ludhiana. Ludhiana. Pan: Aaace3698M (Appellant) (Respondent)

For Appellant: Shri Sarabjit GargFor Respondent: Smt.Chanderkanta, Addl.CIT
Section 132Section 142Section 143(3)Section 147Section 148Section 68

set aside the order of the CIT(A) and restore that of the AO. Som Nath Maini vs commissioner Of Income Tax. Taexpert Citation 1239 of 2006 ITR Citation 306 ITR 414(p&h) The assessee incurred capital loss on account of sale of gold jewellery and also- had short-term capital gain of almost equal amount. The Assessing Officer

M/S RPA DEVELOPERS,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, all the appeals filed by the assessee are hereby allowed

ITA 1026/CHANDI/2017[2013-14]Status: DisposedITAT Chandigarh16 Oct 2018AY 2013-14

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

For Appellant: Sh. Pankaj Bhalla, CAFor Respondent: Smt. Anita Sinha, CIT DR alongwith
Section 132(1)Section 139(1)Section 143(2)Section 153CSection 250(6)Section 3Section 36(1)(iii)Section 72

loss claimed and interest expenses claimed. 5. In appeal, the Ld. CIT(A) confirmed the addition made by the Assessing officer. 6. Being aggrieved of the order of the CIT(A) on this issue, the assessee, thus has come up on appeal before us. 7. At the outset, ld. counsel for the assessee has submitted that the impugned additions have

RAJESH KHANNA,NEELKANTH PLYWOOD, YAMUNANAGAR vs. INCOME TAX OFFICER, WARD-3, INCOME TAX OFFICER, YAMUNANAGAR

In the result, the assessee's appeal in ITA

ITA 62/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh19 Aug 2024AY 2018-19

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Goel, CAFor Respondent: Shri Dharam Vir, JCIT Sr.DR
Section 148Section 69A

147 of the Act. Order under sub-section (d) of section 148A of the Act has been passed in such case vide DIN ITBA/AST/F/148A/2021-22/1042149336(1) dated 30/03/2022 and annexed herewith for reference. 2. I, therefore, propose to assess or reassess such income or recompute the loss or the depreciation allowance or any other, allowance or deduction for the Assessment Year

INCOME TAX OFFICER, YAMUNA NAGAR vs. RAJESH KHANNA, YAMUNA NAGAR

In the result, the assessee's appeal in ITA

ITA 230/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh19 Aug 2024AY 2018-19

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Goel, CAFor Respondent: Shri Dharam Vir, JCIT Sr.DR
Section 148Section 69A

147 of the Act. Order under sub-section (d) of section 148A of the Act has been passed in such case vide DIN ITBA/AST/F/148A/2021-22/1042149336(1) dated 30/03/2022 and annexed herewith for reference. 2. I, therefore, propose to assess or reassess such income or recompute the loss or the depreciation allowance or any other, allowance or deduction for the Assessment Year

SH. BIKRAMJIT SINGH,CHANDIGARH vs. PR. CIT-2, CHANDIGARH

ITA 878/CHANDI/2019[2009-10]Status: DisposedITAT Chandigarh28 Oct 2020AY 2009-10

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No.878/Chd/2019 "नधा"रणवष" / Assessment Year :2009-10 Shri Bikramjeet Singh, The Pcit-2, बनाम Sco 33, Sector 20-D, Chandigarh Chandigarh "थायीलेखासं./Pan No: Aeeps9345E अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: ShriAjay Kumar Jain, CAFor Respondent: Smt. C Chandrakanta, CIT
Section 143(3)Section 147Section 263

reassessment proceedings u/s 147 of the Act were initiated by the Assessing Officer (AO) on the assessee on the basis of information in his possession ITA No.878-Chd-2019 ShriBikramjeet Singh, Chandigarh 2 from Asstt. DIT (Investigation) Unit 1(3). Ahmedabad, that the assessee had availed contrived losses in share trading by resorting to Client Code Modification, to the tune of Rs.2

LATE SH. RAJ KUMAR WADHWA THROUGH L/H SMT. USHA WADHWA,PATIALA vs. DCIT, CIRCLE, PATIALA

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

ITA 1335/CHANDI/2019[2008-09]Status: DisposedITAT Chandigarh14 Jun 2021AY 2008-09

Bench: The Appeal Is Finally Heard Or Disposed Off.” 3. Ground No 1 & 4 Being General In Nature Need No Adjudication.

For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Ashok Khanna, Addl.CIT
Section 143(1)Section 147Section 148Section 250(6)

loss account alongwith relevant Annexures submitted by Smt. 5) Usha Wadhwa legal heirs of Sh, Raj Kumar Wadhwa for AY 2008-2009 as per return already filed original. 6) Copy of the demand notice u/s 156 in the name of dead person vide notice dated 1 28.02.2014 and 1E| page of assessment order u/s 143(3) r.w.s 147 as passed

M/S GREATER MOHALI AREA DEVELOPMENT AUTHORITY,MOHALI vs. DCIT, C-6(1), MOHALI

In the result; the appeals filed by the assessee in ITA

ITA 1202/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh08 Nov 2021AY 2011-12
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Smt.C.Chandrakanta, CIT
Section 143Section 143(3)Section 147Section 250(6)Section 29(1)

reassessment is already complete and the assessing officer has passed the assessment order, we do not find any reason to interfere with the impugned order passed tni the High Court in exercise of our power under Article 136 of the Constitution of India. The special leave petitions are accordingly dismissed. However, we make it clear that it will be open

DCIT, C-6(1), MOHALI vs. M/S GREATER MOHALI AREA DEVELOPMENT AUTHORITY, MOHALI

In the result; the appeals filed by the assessee in ITA

ITA 1237/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh08 Nov 2021AY 2010-11
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Smt.C.Chandrakanta, CIT
Section 143Section 143(3)Section 147Section 250(6)Section 29(1)

reassessment is already complete and the assessing officer has passed the assessment order, we do not find any reason to interfere with the impugned order passed tni the High Court in exercise of our power under Article 136 of the Constitution of India. The special leave petitions are accordingly dismissed. However, we make it clear that it will be open

M/S GREATER MOHALI AREA DEVELOPMENT AUTHORITY,MOHALI vs. DCIT, C-6(1), MOHALI

In the result; the appeals filed by the assessee in ITA

ITA 1177/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh08 Nov 2021AY 2010-11
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Smt.C.Chandrakanta, CIT
Section 143Section 143(3)Section 147Section 250(6)Section 29(1)

reassessment is already complete and the assessing officer has passed the assessment order, we do not find any reason to interfere with the impugned order passed tni the High Court in exercise of our power under Article 136 of the Constitution of India. The special leave petitions are accordingly dismissed. However, we make it clear that it will be open

MASTER TRUST LIMITED,LUDHIANA vs. ASSISTANT COMMISSIONER OF INCOME TAX, LUDHIANA

In the result, ground no. 1 of the assessee’s appeal is allowed

ITA 334/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh29 Nov 2024AY 2015-16

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Ashwani Kumar, C.A and Shri Aditya Kumar, C.AFor Respondent: Smt. Kusum Bansal, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

loss so claimed by the assessee and the assessed income was determined at Rs. 4,33,75,115/-. 5. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A) who has since sustained the said disallowance and against the said findings and direction of the Ld. CIT(A), the assessee is in appeal before

M/S GREATER MOHALI AREA DEVELOPMENT AUTHORITY,MOHALI vs. DCIT, C-6(1), MOHALI

In the result, the appeal of the assessee is hereby dismissed

ITA 1560/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh22 May 2018AY 2009-10

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumarassessment Year : 2009-10

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Sh. Gulshan Raj, CIT DR
Section 139Section 142Section 143(3)Section 147Section 148

loss or the depreciation allowance or any other allowance, as the case may be for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year): Provided that where an assessment under sub section (3) of section 143 or this section has been made for the relevant assessment year

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

ITA 514/CHANDI/2023[2012-2013]Status: DisposedITAT Chandigarh02 Jan 2025AY 2012-2013

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Kusum Bansal, CIT-DR
Section 127Section 132Section 143(3)Section 147Section 148Section 148(2)Section 153Section 153A

set up. What a reasonable person can infer from the above is that as the transactions were sham, the assessee company opted not to comply the letter of this office. 5. M/s SP Singla Constructions Pvt. Ltd. has e-filed its original return of income for A.Y. 2012-13 vide acknowledgement no. 507755821300912 on 30.09.2012 declaring total income of Rs.32

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 288/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from