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20 results for “reassessment u/s 147”+ Revision u/s 263clear

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Mumbai368 Delhi334 Bangalore188 Chennai167 Kolkata151 Jaipur76 Ahmedabad75 Chandigarh59 Pune52 Raipur46 Hyderabad40 Indore33 Rajkot28 Cuttack24 Allahabad21 Cochin20 Nagpur18 Surat14 Amritsar13 Agra11 Jodhpur11 Lucknow10 Karnataka9 Dehradun7 Visakhapatnam6 Jabalpur6 Patna4 Calcutta3 Varanasi3 Ranchi3 Himachal Pradesh2 Guwahati2 SC2 Uttarakhand1 Kerala1

Key Topics

Section 14720 Section 26318 Section 143(3)17 Section 14815 Section 153A11 Section 2(22)(e)11 Addition to Income10 Section 153C8 Depreciation

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)

revision u/s 263 of the Act. It is pertinent to note that the same issue was raised at the reassessment u/s 147

6

Reopening of Assessment6

Section 234B(3)5

M/S SKYLINE E TECH,KOCHI vs. ACIT CIRCLE 2(2), KOCHI

In the result, both the appeals of the assessee are allowed

ITA 268/COCH/2023[2005-06]Status: DisposedITAT Cochin03 Jan 2025AY 2005-06

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Radhesh Bhatt, CAFor Respondent: Shri Sanjit Kumar Das, CIT(DR)

Section 143(2)Section 143(3)Section 250Section 263Section 32Section 32(1)Section 47

revised is order 26.12.2008 u/s. 143(3) r.w.s. 147 of the Act dated If reassessment is quashed, revisionary Yes. proceedings will also become infructuous 22. Hence, as reassessment order is quashed, subsequent order u/s. 143(3) r.w.s. 263

M/S SKYLINE E TECH,KOCHI vs. ACIT CIRCLE 2(2), KOCHI

In the result, both the appeals of the assessee are allowed

ITA 269/COCH/2023[2005-06]Status: DisposedITAT Cochin03 Jan 2025AY 2005-06

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Radhesh Bhatt, CAFor Respondent: Shri Sanjit Kumar Das, CIT(DR)

Section 143(2)Section 143(3)Section 250Section 263Section 32Section 32(1)Section 47

revised is order 26.12.2008 u/s. 143(3) r.w.s. 147 of the Act dated If reassessment is quashed, revisionary Yes. proceedings will also become infructuous 22. Hence, as reassessment order is quashed, subsequent order u/s. 143(3) r.w.s. 263

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)

263 or section 264, the amount on which interest was payable under sub-section (1) or sub-section (3) has been increased or reduced, as the case may be, the interest shall be increased or reduced accordingly, and— (i) in a case where the interest is increased, the Assessing Officer shall serve on the assessee a notice of demand

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

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 aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254, or section 260 or section 262 or section 263 or section

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

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 aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254, or section 260 or section 262 or section 263 or section

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

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 aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254, or section 260 or section 262 or section 263 or section

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

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 aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254, or section 260 or section 262 or section 263 or section

NELLIKKOTE KUNHIPARI MOHAMMEDALI,KOZHIKODE vs. ACIT CIRCLE-1(1), KOZHIKODE

In the result, appeal filed by the assessee stands allowed

ITA 881/COCH/2024[2007-08]Status: DisposedITAT Cochin15 Jul 2025AY 2007-08

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

For Appellant: Shri Surendranath Rao, CAFor Respondent: Sri Suresh Sivanandan, CIT-DR

Section 143(3)Section 148Section 2(22)(e)Section 263

revision order passed U/s. 263 was set-aside by the Tribunal vide order dated 30/01/2009 in ITA Nos. 957 to 951/Coch/2007. Subsequently, based on the information unearthed during the course of the search and seizure operation in the case of M/s Parisons Group of companies that the appellant received loans and advances from the companies namely (1) Parrisons Agrotech

NELLIKKOTE KUNHIPARI MOHAMMEDALI,KOZHIKODE vs. ACIT CIRCLE-1(1), KOZHIKODE

In the result, appeal filed by the assessee stands allowed

ITA 880/COCH/2024[2004-05]Status: DisposedITAT Cochin15 Jul 2025AY 2004-05

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

For Appellant: Shri Surendranath Rao, CAFor Respondent: Sri Suresh Sivanandan, CIT-DR

Section 143(3)Section 148Section 2(22)(e)Section 263

revision order passed U/s. 263 was set-aside by the Tribunal vide order dated 30/01/2009 in ITA Nos. 957 to 951/Coch/2007. Subsequently, based on the information unearthed during the course of the search and seizure operation in the case of M/s Parisons Group of companies that the appellant received loans and advances from the companies namely (1) Parrisons Agrotech

NELLIKKOTE KUNHIPARI MOHAMMEDALI,KOZHIKODE vs. ACIT CIRCLE-1(1), KOZHIKODE

In the result, appeal filed by the assessee stands allowed

ITA 888/COCH/2024[2006-07]Status: DisposedITAT Cochin15 Jul 2025AY 2006-07

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

For Appellant: Shri Surendranath Rao, CAFor Respondent: Sri Suresh Sivanandan, CIT-DR

Section 143(3)Section 148Section 2(22)(e)Section 263

revision order passed U/s. 263 was set-aside by the Tribunal vide order dated 30/01/2009 in ITA Nos. 957 to 951/Coch/2007. Subsequently, based on the information unearthed during the course of the search and seizure operation in the case of M/s Parisons Group of companies that the appellant received loans and advances from the companies namely (1) Parrisons Agrotech

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: DisposedITAT Cochin30 Nov 2023AY 2009-10

Bench: Shri Sanjay Arora & Shri Manomohan Das

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

147, even the availability of Form 3CL with the AO would not absolve the assessee from, in view of the variation in the deduction claimed per the return and that later approved by the prescribed authority, to state reasons in support of it’s claim as made, or otherwise, where in agreement with the revision, revise it’s return

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

147, even the availability of Form 3CL with the AO would not absolve the assessee from, in view of the variation in the deduction claimed per the return and that later approved by the prescribed authority, to state reasons in support of it’s claim as made, or otherwise, where in agreement with the revision, revise it’s return

JUBILEE MISSION HOSPITAL.,THRISSUR vs. THE DCIT, KOCHI

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

ITA 90/COCH/2022[2010-11]Status: DisposedITAT Cochin14 Sept 2022AY 2010-11

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

revised return was not in order for that year or subsequent assessment years including the instant year's computation, which was based on such wrong written down value of assets. Moreover, the assessing officer had observed that the closing balance of preceding year and opening balance of relevant year under general fund was different, hence, the assessee's books

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

revised return was not in order for that year or subsequent assessment years including the instant year's computation, which was based on such wrong written down value of assets. Moreover, the assessing officer had observed that the closing balance of preceding year and opening balance of relevant year under general fund was different, hence, the assessee's books

JUBILEE MISSION HOSPITAL,THRISSUR vs. THE DCIT, KOCHI

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

ITA 89/COCH/2022[2009-10]Status: DisposedITAT Cochin14 Sept 2022AY 2009-10

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

revised return was not in order for that year or subsequent assessment years including the instant year's computation, which was based on such wrong written down value of assets. Moreover, the assessing officer had observed that the closing balance of preceding year and opening balance of relevant year under general fund was different, hence, the assessee's books

JUBILEE MISSION HOSPITAL,THRISSUR vs. THE DCIT, THRISSUR

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

ITA 88/COCH/2022[2008-09]Status: DisposedITAT Cochin14 Sept 2022AY 2008-09

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

revised return was not in order for that year or subsequent assessment years including the instant year's computation, which was based on such wrong written down value of assets. Moreover, the assessing officer had observed that the closing balance of preceding year and opening balance of relevant year under general fund was different, hence, the assessee's books

SRI.PARAYARUKANDY VETTATH GANGADHARAN,CALICUT vs. THE DCIT CIRCLE-1(1), CALICUT

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

ITA 157/COCH/2023[2007-08]Status: DisposedITAT Cochin12 Apr 2024AY 2007-08

Bench: Shri Sanjay Arora & Shri Manomohan Dasparayarukandy Vettath Gangadharan Dy. Cit, Circle - 1(1) Kerala Transport Company (Decd., Calicut Vs. Represented By Lrs.) K.T.C. Building, Ymca Calicut 673001 [Pan: Adhpg8318B] (Appellant) (Respondent)

For Appellant: Shri Suresh Kumar C., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R

Section 147Section 148Section 149Section 150(1)Section 153Section 2(22)(e)Section 268A

revision, as the case may be, was made by reason of any other provision limiting the time within which any action for assessment, reassessment or recomputation may be taken. 2.3 In first appeal, the assessee’s principal grievance, which constituteshis sole grievance before us, i.e., of the reassessment proceedings being time barred, was discussed at length. In view

M/S SANTHIMADOM HERBAL CITY TRUST,ERNAKULAM vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are partly allowed

ITA 920/COCH/2022[2008-09]Status: DisposedITAT Cochin14 Nov 2023AY 2008-09

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

For Appellant: Sri.Mathew Joseph, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.DR

Section 132Section 144Section 153ASection 153C

147 or reassessment under section 153A, on the amount by which the tax on the total income determined on the basis of such reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the earlier assessment aforesaid. Explanation.—[* * *] (4) Where as a result of an order under

M/S SANTHIMADOM HERBAL CITY TRUST,ERNAKULAM vs. ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the assessee’s appeals are partly allowed

ITA 921/COCH/2022[2009-10]Status: DisposedITAT Cochin14 Nov 2023AY 2009-10

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

For Appellant: Sri.Mathew Joseph, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.DR

Section 132Section 144Section 153ASection 153C

147 or reassessment under section 153A, on the amount by which the tax on the total income determined on the basis of such reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the earlier assessment aforesaid. Explanation.—[* * *] (4) Where as a result of an order under