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33 results for “reassessment u/s 147”+ Section 32clear

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Key Topics

Section 143(3)30Section 153A25Addition to Income24Section 26321Section 8021Exemption13Section 37(1)12Deduction12Section 139(1)

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

Showing 1–20 of 33 · Page 1 of 2

11
Reassessment11
Section 14710
Disallowance10

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

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

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

u/s. 147, which is to the AO, and, two, to meet the assessee’s reliance on the said procedure for drawing a contrary presumption. Page 16 ITANos. 139 & 140/Coch/ 2020 (AYs 2009-10 & 2011-12) CO Nos. 02 & 03/Coch/2020 Asst. CIT vs. Apollo Tyres Ltd. We may though, if only for the sake of clarity, state the background facts

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, which is to the AO, and, two, to meet the assessee’s reliance on the said procedure for drawing a contrary presumption. Page 16 ITANos. 139 & 140/Coch/ 2020 (AYs 2009-10 & 2011-12) CO Nos. 02 & 03/Coch/2020 Asst. CIT vs. Apollo Tyres Ltd. We may though, if only for the sake of clarity, state the background facts

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

147 dated 26.12.2008 for redoing the same. Subsequently notices were issued u/s. 143(2) on 27.11.2011. 4. During the assessment proceedings it was found that assessee firm over the years had developed a software called ‘Quadra software’ and for this AY this was valued at Rs.57 lakhs. Such valuation was divided by the partners, credited to their capital account

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

147 dated 26.12.2008 for redoing the same. Subsequently notices were issued u/s. 143(2) on 27.11.2011. 4. During the assessment proceedings it was found that assessee firm over the years had developed a software called ‘Quadra software’ and for this AY this was valued at Rs.57 lakhs. Such valuation was divided by the partners, credited to their capital account

M/S.POPULAR FINANCE,PATHANAMTHITTA vs. THE ACIT, CIRCLE-1, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

ITA 203/COCH/2019[2014-15]Status: DisposedITAT Cochin03 Dec 2019AY 2014-15

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

Section 143(2)Section 143(3)Section 263Section 37(1)

reassessment proceedings u/s. 263 pending till the decision of the Apex Court in the cases of Shri Arun Thomas & Shri Thomas Thomas for the Assessment Year 2008-09 as per law. 4. Against this the assessees are in appeal before us with the following grounds of appeals: 1. The order of the learned Pr. Commissioner of Income Tax, Kottayam

M/S POPULAR FINANCE COMPANY,PATHANAMTHITTA vs. THE ACIT,CIR-1,, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

ITA 204/COCH/2019[2014-15]Status: DisposedITAT Cochin03 Dec 2019AY 2014-15

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

Section 143(2)Section 143(3)Section 263Section 37(1)

reassessment proceedings u/s. 263 pending till the decision of the Apex Court in the cases of Shri Arun Thomas & Shri Thomas Thomas for the Assessment Year 2008-09 as per law. 4. Against this the assessees are in appeal before us with the following grounds of appeals: 1. The order of the learned Pr. Commissioner of Income Tax, Kottayam

M/S POPULAR FINANCE COMPANY,PATHANAMTHITTA vs. THE ACIT,CIR-1,, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

ITA 202/COCH/2019[2014-15]Status: DisposedITAT Cochin03 Dec 2019AY 2014-15

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

Section 143(2)Section 143(3)Section 263Section 37(1)

reassessment proceedings u/s. 263 pending till the decision of the Apex Court in the cases of Shri Arun Thomas & Shri Thomas Thomas for the Assessment Year 2008-09 as per law. 4. Against this the assessees are in appeal before us with the following grounds of appeals: 1. The order of the learned Pr. Commissioner of Income Tax, Kottayam

YENKEY ROLLER FLOUR MILLS,CALICUT vs. DCIT C-1(1), KOZHIKKODE

In the result, the appeal filed by the appellant stands allowed

ITA 522/COCH/2023[2006-2007]Status: DisposedITAT Cochin14 May 2025AY 2006-2007

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 147Section 148Section 149

32,87,670/-. While doing so, the AO made certain disallowances on account of disallowance of interest and disallowance on account of excess wastage and depreciation, etc. Subsequently, the AO sought to reopen the assessment by issuing notice u/s. 148 of the Act on 23.03.2013 after recording the following reasons u/s. 147 of the Act:- "Information has been received from

M/S.AKAY FLAVOURS & AROMATICS P. LTD,ERNAKULAM vs. THE ACIT, ERNAKULAM

In the result, the appeal filed by the assesseee is allowed as indicated

ITA 491/COCH/2016[2004-05]Status: DisposedITAT Cochin05 Feb 2018AY 2004-05

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year : 2004-05

Section 10ASection 10BSection 139(1)Section 143Section 32(2)Section 72

147 was completed vide order dated 27/12/2007. In the reassessment completed, deduction claimed by the assessee u/s. 10B of the Act was reduced to ‘Nil’ . The Assessing Officer recomputed the deduction u/s. 10B of the Act after setting off carry forward business loss u/s. 72 of the I.T. Act and unabsorbed depreciation u/s. 32

THE AD COMMISSIONER OF INCOME TAX, ALAPPUZHA vs. N S S KARAYOGAM, ALAPPUZHA

In the result, the appeals filed by the assessee are partly allowed, as indicated above

ITA 505/COCH/2018[2005-06]Status: DisposedITAT Cochin05 Mar 2019AY 2005-06

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

For Appellant: Smt.A.S.Bindhu, Sr.DRFor Respondent: Sri.T.M.Sreedharan, Advocate
Section 143Section 148Section 153Section 254

32 days in filing this appeal and proceed to dispose off the appeal on merits. ITA No.505/Coch/2018. 2 M/s.NSS Karayogam Br. No.1365. 3. The solitary issue that is raised by the Revenue is whether the assessment completed vide order dated 28.03.2014 pursuant to ITAT’s order dated 21.10.2011 was barred by limitation u/s 153(2A) of the I.T.Act

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 of TDS. On further appeal before the CIT(A), the CIT(A) confirmed

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 of TDS. On further appeal before the CIT(A), the CIT(A) confirmed

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 of TDS. On further appeal before the CIT(A), the CIT(A) confirmed

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 41/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

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

32,04,380 244.29 270.83 1,46,39,131 14,34,751 Company TOTAL 48,8037,490 14,34,751 3.6 For the assessment year 2011-12, in the case of R. Prakash, as per details filed by the assessee, the Assessing Officer noticed that the assessee had sold various I.T.A. Nos.37 to 49/Coch/2016 grades of cashew kernels to concerns

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 47/COCH/2016[2008-09]Status: DisposedITAT Cochin03 Feb 2020AY 2008-09

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

32,04,380 244.29 270.83 1,46,39,131 14,34,751 Company TOTAL 48,8037,490 14,34,751 3.6 For the assessment year 2011-12, in the case of R. Prakash, as per details filed by the assessee, the Assessing Officer noticed that the assessee had sold various I.T.A. Nos.37 to 49/Coch/2016 grades of cashew kernels to concerns