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39 results for “reassessment u/s 147”+ Deductionclear

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Key Topics

Section 143(3)52Section 153A38Section 14736Section 14829Addition to Income22Section 14A19Section 8019Deduction14Reassessment14

ACIT, ERNAKULAM vs. APPOLO TYRES LTD, COCHIN

In the result, the Revenue’s appeals as well as the Assessee’s COs, are allowed

ITA 140/COCH/2020[2011-12]Status: DisposedITAT Cochin30 Nov 2023AY 2011-12

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Joseph Markose, AdvocateFor Respondent: Sh. Sanjit K. Das, CIT-DR and Smt
Section 147

u/s. 147 was bad-in-law and reassessment so concluded not valid.” (emphasis, ours) 4. We may at the outset clarify two aspects. Firstly, the assessee’s COs, filed on 25/6/2020, though out of time by 3 days, were admitted as the delay is saved by the order of the Hon'ble Apex Court in Suo Motu Writ Petition 3/2020

ACIT, ERNAKULAM vs. APPOLO TYRES LTD, COCHIN

In the result, the Revenue’s appeals as well as the Assessee’s COs, are allowed

ITA 139/COCH/2020[2009-10]Status: Disposed

Showing 1–20 of 39 · Page 1 of 2

Disallowance13
Section 3612
Section 26311
ITAT Cochin
30 Nov 2023
AY 2009-10

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Joseph Markose, AdvocateFor Respondent: Sh. Sanjit K. Das, CIT-DR and Smt
Section 147

u/s. 147 was bad-in-law and reassessment so concluded not valid.” (emphasis, ours) 4. We may at the outset clarify two aspects. Firstly, the assessee’s COs, filed on 25/6/2020, though out of time by 3 days, were admitted as the delay is saved by the order of the Hon'ble Apex Court in Suo Motu Writ Petition 3/2020

M/S.COOL MINDS TECHNOLOGIES P. LTD,COCHIN vs. THE ACIT, COCHIN

The appeals are dismissed

ITA 375/COCH/2016[2007-08]Status: DisposedITAT Cochin22 Aug 2025AY 2007-08

Bench: CIT(A) the it was claimed by the Assessee that deduction under Section 10B of the Act was initially claimed by the Assessee under the bona fide belief that it is entitled to deduction under Section 10B of the Act. The CITT(A) dismissed the appeal of the Assessee agreeing with the Assessing Officer and holding that the Assessing Officer was justified in not considering the claim made by the Assessee under Section 10A of the Act. Now the Assessee is in

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Smt. Leena Lal, Sr. DR
Section 10ASection 10BSection 143(3)Section 147Section 148Section 250Section 263

147 of the Act for the Assessment Year 2007-2008. The present appeal has come up for hearing in view of the Order, dated 16/06/2025, passed by the Hon'ble Kerala High Court in the appeal (ITA No. 31/2025) preferred by the Assessee. Assessment Year 2007-2008 2. The Assessee has raised multiple grounds challenging the order passed

BHARATH RASIKLAL SHAH,COCHIN vs. PCIT KOCHI-1, KOCHI

In the result, the appeal filed by the assessee is allowed

ITA 744/COCH/2024[2017-18]Status: DisposedITAT Cochin10 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Advocate &
Section 143Section 143(3)Section 144Section 147Section 194ASection 263Section 263(1)

reassessment u/s 147 and the assessment by NFAC has also found the same to be in order. Therefore, when the online portal of the Income tax department is self-explanatory with regard to the deduction

MARIAMMA JOSEPH,KOTTAYAMN vs. THE ACIT, CENTRAL CIRCLE, KOTTAYAM,, KOTTAYAM

In the result, the assessee’s appeal is decided on the aforesaid terms

ITA 672/COCH/2022[2010-2011]Status: DisposedITAT Cochin28 Mar 2024AY 2010-2011

Bench: Shri Sanjay Arora & Shri Manomohan Dasmariamma Joseph Asst. Cit, Central Circle Hotel Floral Park Kottayam 686001 Gandhinagar Vs. Kottayam 686008 [Pan:Accpj9135F] (Appellant) (Respondent)

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143Section 143(1)Section 143(3)Section 153ASection 154Section 208Section 210Section 234Section 234BSection 234B(3)

147 or section 153A, on the amount by which the tax on the total income determined on the basis of the reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment as referred to in sub-section (1), as the case

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

ITA 270/COCH/2021[2016-2017]Status: DisposedITAT Cochin31 Jul 2025AY 2016-2017

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

ITA 271/COCH/2021[2014-2015]Status: DisposedITAT Cochin31 Jul 2025AY 2014-2015

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

ITA 268/COCH/2021[2013-2014]Status: DisposedITAT Cochin31 Jul 2025AY 2013-2014

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

ITA 269/COCH/2021[2015-2016]Status: DisposedITAT Cochin31 Jul 2025AY 2015-2016

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

ITA 464/COCH/2025[2006-2007]Status: DisposedITAT Cochin22 Aug 2025AY 2006-2007

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri R. Krishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 148Section 194CSection 40

reassessment was completed vide order dated 28.03.2013 passed u/s. 143(3) r.w.s. 147 of the Act after making addition of Rs. 7,33,77,497/- being the amount paid to Muthoot Pappachan Consultancy & Management (hereinafter called “MPCMS”) towards professional charges/consultancy u/s. 40(a)(ia) for non-deduction

MUTHOOT FINCORP LIMITED,TRIVANDRUM vs. ITO,CIRCLE CENTRAL, TRIVANDRUM

In the result, the appeals filed by the assessee stand dismissed

ITA 496/COCH/2025[2010-2011]Status: DisposedITAT Cochin22 Aug 2025AY 2010-2011

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri R. Krishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 148Section 194CSection 40

reassessment was completed vide order dated 28.03.2013 passed u/s. 143(3) r.w.s. 147 of the Act after making addition of Rs. 7,33,77,497/- being the amount paid to Muthoot Pappachan Consultancy & Management (hereinafter called “MPCMS”) towards professional charges/consultancy u/s. 40(a)(ia) for non-deduction

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

ITA 465/COCH/2025[2013-2014]Status: DisposedITAT Cochin22 Aug 2025AY 2013-2014

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri R. Krishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 148Section 194CSection 40

reassessment was completed vide order dated 28.03.2013 passed u/s. 143(3) r.w.s. 147 of the Act after making addition of Rs. 7,33,77,497/- being the amount paid to Muthoot Pappachan Consultancy & Management (hereinafter called “MPCMS”) towards professional charges/consultancy u/s. 40(a)(ia) for non-deduction

PARISONS ESTATES AND INDUSTRIES PRIVATE LIMITED,CALICUT vs. ACIT CIRCLE 1(1), KOZHIKODE

In the result, the appeal filed by the assessee is dismissed

ITA 171/COCH/2023[2009-10]Status: DisposedITAT Cochin10 Jun 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2009-10

For Appellant: Shri Surendranath Rao, CAFor Respondent: Smt. Leena Lal, Snr. AR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

deduction of the market value of Page 4 of 10 the agricultural produce under Rule 7 and further reducing the income to 40% under Rule 8 is not correct. 3. As against the said order, the assessee filed an appeal before the Ld.CIT(A) and raised the legal ground that the reopening of the assessment u/s. 147

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 918/COCH/2022[2008-09]Status: DisposedITAT Cochin02 May 2024AY 2008-09

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 153ASection 153CSection 234A

u/s. 153C r/w s. 144 on 28.12.2010. The Tribunal, in appeal, set aside the assessment for fresh consideration vide it’s order dated 10.07.2013 (in ITA Nos. 223 to 227/Coch/2013 / copy on record); the relevant part of which reads as: ‘4.1 In the case of V N Radhakrishnan, a similar contention was raised by the department that the assessee

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,ERNAKULAM vs. ACIT CENTRAL CIRCLE-2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 916/COCH/2022[2005-06]Status: DisposedITAT Cochin02 May 2024AY 2005-06

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 153ASection 153CSection 234A

u/s. 153C r/w s. 144 on 28.12.2010. The Tribunal, in appeal, set aside the assessment for fresh consideration vide it’s order dated 10.07.2013 (in ITA Nos. 223 to 227/Coch/2013 / copy on record); the relevant part of which reads as: ‘4.1 In the case of V N Radhakrishnan, a similar contention was raised by the department that the assessee

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 917/COCH/2022[2007-08]Status: DisposedITAT Cochin02 May 2024AY 2007-08

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 153ASection 153CSection 234A

u/s. 153C r/w s. 144 on 28.12.2010. The Tribunal, in appeal, set aside the assessment for fresh consideration vide it’s order dated 10.07.2013 (in ITA Nos. 223 to 227/Coch/2013 / copy on record); the relevant part of which reads as: ‘4.1 In the case of V N Radhakrishnan, a similar contention was raised by the department that the assessee

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 919/COCH/2022[2009-10]Status: DisposedITAT Cochin02 May 2024AY 2009-10

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 153ASection 153CSection 234A

u/s. 153C r/w s. 144 on 28.12.2010. The Tribunal, in appeal, set aside the assessment for fresh consideration vide it’s order dated 10.07.2013 (in ITA Nos. 223 to 227/Coch/2013 / copy on record); the relevant part of which reads as: ‘4.1 In the case of V N Radhakrishnan, a similar contention was raised by the department that the assessee

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

ITA 267/COCH/2021[2012-2013]Status: DisposedITAT Cochin31 Jul 2025AY 2012-2013
For Appellant: \nShri G. Surendranath Rao, CAFor Respondent: \nShri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

reassess such income for such\n assessment year. Further, section 147 makes it very clear that in order to invoke\nprovisions of section 147, there should be income which has escaped assessment,\nand such escapement should be based on fresh tangible material which comes to the\npossession of the Assessing Officer subsequent to the completion of the original\nassessment

A & B ASSOCIATES,THIRUVANANTHAPURAM vs. THE INCOME TAX OFFICER, THIRUVANANTHAPURAM

In the result, the appeal of the assesse is allowed for statistical purpose

ITA 643/COCH/2025[2018-19]Status: DisposedITAT Cochin05 Dec 2025AY 2018-19

Bench: the Ld. CIT(A). The Ld.CIT(A) partly allowed the appeal filed by the assessee by directing the AO to -

For Appellant: Shri Lokanathan, C.AFor Respondent: Shri Sanjit Kumar Das, Sr. D/R
Section 115BSection 142(1)Section 144Section 147Section 148Section 148ASection 250

deducted as TDS. As the business was not profitable, and for some other major reasons, the relationship between the partners was substantially damaged and the partners had lost confidence between them. After some preliminary legal steps, they have decided to dissolve the firm and 4 A&B Associates accordingly, the firm was dissolved w.e.f. 05/07/2018 on the condition that

JUBILEE MISSION HOSPITAL ,KAKKANAD vs. THE DCIT, KOCHI

In the result, the appeals filed by the assessee in ITA Nos

ITA 91/COCH/2022[2013-14]Status: DisposedITAT Cochin14 Sept 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Sri Surendranath Rao, A.RFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 147Section 148

147. Income escaping assessment – If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently