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82 results for “reassessment u/s 147”+ Section 17(2)clear

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Key Topics

Section 143(3)101Section 14864Addition to Income59Reassessment52Section 14740Section 153A31Cash Deposit31Section 271(1)(c)30Section 139(1)

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

17 March 2015 Since the subject section 143(3) matter of revision read with section proceedings under 147 section 263 is not covered under the reassessment order, the reassessment order cannot be considered for time limit purposes under section 263(2) of the Act. Ground No.2 - Without prejudice, revision proceedings have been initiated on account of issues that are neither

Showing 1–20 of 82 · Page 1 of 5

28
Section 26324
Section 13222
Search & Seizure20

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 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,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

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

SRI. ELDHOSE K. VARGHESE,MUVATTUPUZHA vs. THEDCIT, ERNAKULAM

In the result, appeals for assessment year 2006-07 to 2008-09 and 2010-11 are allowed while the appeals of the assessee for assessment year 2009-10, 2011-12 and 2012-13 are partly allowed

ITA 261/COCH/2016[2006-07]Status: DisposedITAT Cochin03 Oct 2017AY 2006-07

Bench: Shri P. K. Bansal & Shri George George K.

Section 132Section 143(1)Section 143(2)Section 153ASection 153CSection 234A

u/s 153A shall be computed by considering the originally determined income. If some incriminating material is found in respect of such assessment years for which the assessment is not pending, then the total income would be determined by considering the originally determined income plus income emanating from the incriminating material found during the course of search. In respect of assessment

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

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 ,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

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 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 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 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

VRINDAVAN BUILDERS PVT LTD,NAGALAND vs. ACIT CENTRAL CIRCLE, KOLLAM

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 697/COCH/2024[2014-15]Status: DisposedITAT Cochin09 Jun 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

u/s 147 will be rendered invalid -reliance placed on Saraswati Garewal [2024] 158 taxmann.com 37 (Raipur ITAT), Tata Capital Financial Services Ltd. v. Asst. CIT [2022] 137 taxmann.com 315 (Bom) and Sabh Infrastructure Ltd. v. ACIT [2018] 89 taxmann.com 409 (Del). Finally it is contended that no reassessment proceedings can be initiated for the purpose of making protective addition placing

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM vs. VRINDAVAN BUILDERS PRIVATE LIMITED, PATHANAMTHITTA

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 736/COCH/2024[2017-18]Status: DisposedITAT Cochin09 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

u/s 147 will be rendered invalid -reliance placed on Saraswati Garewal [2024] 158 taxmann.com 37 (Raipur ITAT), Tata Capital Financial Services Ltd. v. Asst. CIT [2022] 137 taxmann.com 315 (Bom) and Sabh Infrastructure Ltd. v. ACIT [2018] 89 taxmann.com 409 (Del). Finally it is contended that no reassessment proceedings can be initiated for the purpose of making protective addition placing

VRINDAVAN BUILDERS PVT LTD,NAGALAND vs. ACIT CENTRAL CIRCLE, KOLLAM

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 700/COCH/2024[2017-18]Status: DisposedITAT Cochin09 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

u/s 147 will be rendered invalid -reliance placed on Saraswati Garewal [2024] 158 taxmann.com 37 (Raipur ITAT), Tata Capital Financial Services Ltd. v. Asst. CIT [2022] 137 taxmann.com 315 (Bom) and Sabh Infrastructure Ltd. v. ACIT [2018] 89 taxmann.com 409 (Del). Finally it is contended that no reassessment proceedings can be initiated for the purpose of making protective addition placing

VRINDAVAN BUILDERS PVT LTD,NAGALAND vs. ACIT, CENTRAL CIRCLE, KOLLAM

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 695/COCH/2024[2012-13]Status: DisposedITAT Cochin09 Jun 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

u/s 147 will be rendered invalid -reliance placed on Saraswati Garewal [2024] 158 taxmann.com 37 (Raipur ITAT), Tata Capital Financial Services Ltd. v. Asst. CIT [2022] 137 taxmann.com 315 (Bom) and Sabh Infrastructure Ltd. v. ACIT [2018] 89 taxmann.com 409 (Del). Finally it is contended that no reassessment proceedings can be initiated for the purpose of making protective addition placing

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM vs. VRINDAVAN BUILDERS PRIVATE LIMITED, PATHANAMTHITTA

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 734/COCH/2024[2015-16]Status: DisposedITAT Cochin09 Jun 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

u/s 147 will be rendered invalid -reliance placed on Saraswati Garewal [2024] 158 taxmann.com 37 (Raipur ITAT), Tata Capital Financial Services Ltd. v. Asst. CIT [2022] 137 taxmann.com 315 (Bom) and Sabh Infrastructure Ltd. v. ACIT [2018] 89 taxmann.com 409 (Del). Finally it is contended that no reassessment proceedings can be initiated for the purpose of making protective addition placing