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124 results for “reassessment u/s 147”+ Section 13clear

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Key Topics

Section 143(3)131Section 26371Addition to Income68Reassessment59Section 14754Section 14852Section 244A45Section 153A40Section 40

THE DCIT, COCHIN vs. M/S APPOLLO TYRES LTD, COCHIN

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

ITA 53/COCH/2017[1993-94]Status: DisposedITAT Cochin01 Jan 2018AY 1993-94

Bench: Shri George George K, Jm & Shri Manjunatha G, Am

For Appellant: Sri. A.Santhom Bose [CIT-DR]For Respondent: Sri. V.Sathyanarayanan, CA
Section 143Section 143(3)Section 147Section 234BSection 234B(1)Section 234B(3)Section 234B(4)Section 263

section 234B(3) states about levy of ITA No.53/Coch/2017. 12 M/s.Appollo Tyres Limited. interest from the date of determination of total income u/s 143(1) of the Act up to the date of reassessment or re- computation u/s 147 of the Act. The learned AR relied on the order of the Tribunal in the case of MBG Commodities

Showing 1–20 of 124 · Page 1 of 7

39
Cash Deposit28
Section 10A25
Deduction25

M/S.US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE JCIT, TRIVANDRUM

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

ITA 247/COCH/2017[2009-10]Status: DisposedITAT Cochin23 Jul 2018AY 2009-10

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.M.Raghunathan SFor Respondent: Sri.Santam Bose
Section 10ASection 10BSection 143(1)Section 143(3)Section 144CSection 263

147 will not alter that position. Explanation 3 only enables the Assessing Officer, once an assessment is reopened, to assess or reassess the income in respect of any issue, even an issue in respect of which no reasons were indicated in the notice under section 148(2). This, however, will not obviate the bar of limitation under section

THE CHOICE FOUNDATION,COCHIN vs. THE ACIT, COCHIN

In the result, appeal filed by the assessee is allowed

ITA 20/COCH/2017[2010-11]Status: DisposedITAT Cochin29 Jan 2018AY 2010-11

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri. K.M.JoseFor Respondent: Sri. A.Dhanaraj, Sr.DR
Section 11Section 11(1)(d)Section 13(8)Section 143(1)Section 143(3)Section 147Section 148Section 2Section 2(15)Section 2(24)(ii)

reassessment u/s 143 r.w.s. 147 of the Income-tax Act, was completed vide order dated 10.03.2015 by assessing the total income at Rs.6,96,60,510. Subsequently order u/s 154 of the Income-tax Act was passed by order dated 06.08.2015 wherein the total income of the assessee was reduced to Rs.1,60,56,579. 3.2 Subsequently notice was issued

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

147 or s. 153A where made for the first time. This is of course subject to being modified consequentially on a change in the tax liability in revision or appeal. Credit, further, in computing this interest, is to be allowed for the tax deposited during the default period, i.e., for which interest is being charged. 4.4 The primary facts

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

147 or s. 153A where made for the first time. This is of course subject to being modified consequentially on a change in the tax liability in revision or appeal. Credit, further, in computing this interest, is to be allowed for the tax deposited during the default period, i.e., for which interest is being charged. 4.4 The primary facts

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

147 or s. 153A where made for the first time. This is of course subject to being modified consequentially on a change in the tax liability in revision or appeal. Credit, further, in computing this interest, is to be allowed for the tax deposited during the default period, i.e., for which interest is being charged. 4.4 The primary facts

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

147 or s. 153A where made for the first time. This is of course subject to being modified consequentially on a change in the tax liability in revision or appeal. Credit, further, in computing this interest, is to be allowed for the tax deposited during the default period, i.e., for which interest is being charged. 4.4 The primary facts

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

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

ITA 267/COCH/2021[2012-2013]Status: DisposedITAT Cochin31 Jul 2025AY 2012-2013

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 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 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

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

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

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

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

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

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

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

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

section 147 of the Act for barring initiation of assessment after 4 years. Now if the assessee, in view of the said difference, ought to have done so if Form 3CL was available at the time of filing the return of income, why shouldn’t it be so during the course of the assessment proceedings on receipt of the said

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
Section 147

section 147 of the Act for barring initiation of assessment after 4 years. Now if the assessee, in view of the said difference, ought to have done so if Form 3CL was available at the time of filing the return of income, why shouldn’t it be so during the course of the assessment proceedings on receipt of the said

ACIT, TRIVANDRUM vs. KERALA STATE ELECTRICITY BOARD, TRIVANDRUM

In the result, both the appeals of the Revenue are dismissed

ITA 53/COCH/2019[2006-07]Status: DisposedITAT Cochin08 Aug 2019AY 2006-07

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 115JSection 143(3)Section 147Section 148

reassess such income, other than the income involving matters which are the subject matters of any appeal, reference or revision, which is chargeable to tax and has escaped assessment." [Emphasis Supplied] 6.6 Further, the Jurisdictional High Court in assessee’s own case reported in (2010) 329 ITR 91 has deleted the addition made u/s. 43B with regard to supply surcharge

ACIT, TRIVANDRUM vs. KERALA STATE ELECTRICITY BOARD, TRIVANDRUM

In the result, both the appeals of the Revenue are dismissed

ITA 52/COCH/2019[2005-06]Status: DisposedITAT Cochin08 Aug 2019AY 2005-06

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 115JSection 143(3)Section 147Section 148

reassess such income, other than the income involving matters which are the subject matters of any appeal, reference or revision, which is chargeable to tax and has escaped assessment." [Emphasis Supplied] 6.6 Further, the Jurisdictional High Court in assessee’s own case reported in (2010) 329 ITR 91 has deleted the addition made u/s. 43B with regard to supply surcharge