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19 results for “reassessment”+ Section 139(5)clear

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Key Topics

Section 14746Section 14836Section 153D20Addition to Income17Section 143(3)11Section 153A10Section 143(2)8Section 139(1)8Section 108Exemption

INCOME TAX OFFICER, WARD-1(1)(3), DEHRADUN, AAYKAR BHAWAN, SUBHASH ROAD, DEHRADUN vs. UTTARAKHAND PURV SAINIK KALYAN NIGAM LIMITED, STATION SUB AREA

In the result, appeal of the assessee is allowed

ITA 92/DDN/2024[2015-16]Status: DisposedITAT Dehradun23 Dec 2025AY 2015-16

Bench: Sh. Yogesh Kumar U.S. & Sh. Manish Agarwal

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. Amar Pal Singh, JCIT-DR
Section 10Section 139Section 139(1)Section 139(4)Section 143(3)Section 148Section 149Section 617

section 139(4) of the Act to the assessee, how there could be any satisfaction on the part of the learned AO to conclude that the income of the assessee has escaped assessment. Hence, the very basis of reopening deserves to be quashed for want of any satisfaction that could be legally recorded. The reopening made by learned AO deserves

5
Reopening of Assessment5
Natural Justice4

ARJUN SINGH SAHI,DEHRADUN vs. DCIT/ACIT CEN CIR DDN, DEHRADUN

Appeal is allowed

ITA 12/DDN/2025[2017-18]Status: DisposedITAT Dehradun06 Feb 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman(Through Video Conferencing) Assessment Year: 2017-18 Sh. Arjun Singh Sahi, Vs. Dcit/Acit, Aayakar Bhawan, Central Circle, 13A-Subhash Road, Dehradun Uttarakhand Pan :Axjps5225P (Appellant) (Respondent) Assessee By Sh. Mukesh Kudiyal, Adv. Department By Sh. A.S. Rana, Sr. Dr

Section 139(1)Section 139(5)Section 143(3)Section 148Section 153ASection 69A

139(5) of the Act on 08.09.2017. The Assessing Officer thereafter issued section 153A notice to him on 16.10.2018 which stood dropped on 05.07.2019. There is further no dispute that the Assessing Officer thereafter served him the impugned reopening notice under section 148 on 14.10.2019 which finally culminated in his reassessment

SHRI PRITPAL SINGH,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-2, DEHRADUN

In the result, the appeal of the Assessee is allowed

ITA 189/DDN/2019[2014-2015]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-2015

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) Shri Pritpal Singh, Vs. Acit, 71, Guru Road, Circle-2, Dehradun Dehradun (Appellant) (Respondent) Pan: Ahkps3632F Assessee By : Shri Savyasachi Kumar Sahai, Adv Revenue By: Shri Amar Singh Rana, Sr. Dr Date Of Hearing 22/08/2023 Date Of Pronouncement 15/09/2023

For Appellant: Shri Savyasachi Kumar Sahai, AdvFor Respondent: Shri Amar Singh Rana, Sr. DR
Section 271(1)(c)Section 50CSection 56(2)(vii)

139(5) of the Act expired on 31.03.2016, hence, the AO treated the manual revised return filed on 29.11.2016 as non est. Later in order to regularise the said revised return, a notice u/s 148 of the Act was issued by the ld AO on 02.12.2016. The Assessee submitted that the revised return filed on 29.11.2016 may be treated

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

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

ITA 168/DDN/2019[2009-10]Status: DisposedITAT Dehradun22 Dec 2023AY 2009-10
Section 10Section 127Section 132Section 143(3)Section 153ASection 153A(1)(a)Section 153CSection 153D

139. Section 153D of the Act relevant for our purposes is to be noted "Prior approval necessary for assessment in cases of search or requisition. 153D.-No order of assessment or reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [sub-section

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

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

ITA 169/DDN/2019[2010-11]Status: DisposedITAT Dehradun22 Dec 2023AY 2010-11
Section 10Section 127Section 132Section 143(3)Section 153ASection 153A(1)(a)Section 153CSection 153D

139. Section 153D of the Act relevant for our purposes is to be noted "Prior approval necessary for assessment in cases of search or requisition. 153D.-No order of assessment or reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [sub-section

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

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

ITA 170/DDN/2019[2011-12]Status: DisposedITAT Dehradun22 Dec 2023AY 2011-12
Section 10Section 127Section 132Section 143(3)Section 153ASection 153A(1)(a)Section 153CSection 153D

139. Section 153D of the Act relevant for our purposes is to be noted "Prior approval necessary for assessment in cases of search or requisition. 153D.-No order of assessment or reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [sub-section

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

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

ITA 167/DDN/2019[2008-09]Status: DisposedITAT Dehradun22 Dec 2023AY 2008-09
Section 10Section 127Section 132Section 143(3)Section 153ASection 153A(1)(a)Section 153CSection 153D

139. Section 153D of the Act relevant for our purposes is to be noted "Prior approval necessary for assessment in cases of search or requisition. 153D.-No order of assessment or reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [sub-section

M/S. SHARDA EXPORTS,MEERUT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the Assessee in ITA No

ITA 40/DDN/2022[2006-07]Status: DisposedITAT Dehradun26 Sept 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 7. The Co-ordinate Bench of the Tribunal in Assessee’s own case for Assessment Year 2005-06 (supra), having similar set of facts

M/S. SHARDA EXPORTS,MEERUT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE , DEHRADUN

In the result, appeal of the Assessee in ITA No

ITA 41/DDN/2022[2007-2008]Status: DisposedITAT Dehradun26 Sept 2025AY 2007-2008

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 7. The Co-ordinate Bench of the Tribunal in Assessee’s own case for Assessment Year 2005-06 (supra), having similar set of facts

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, appeal of the Assessee in ITA No

ITA 44/DDN/2022[2006-07]Status: DisposedITAT Dehradun26 Sept 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 7. The Co-ordinate Bench of the Tribunal in Assessee’s own case for Assessment Year 2005-06 (supra), having similar set of facts

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, appeal of the Assessee in ITA No

ITA 45/DDN/2022[2007-08]Status: DisposedITAT Dehradun26 Sept 2025AY 2007-08

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 7. The Co-ordinate Bench of the Tribunal in Assessee’s own case for Assessment Year 2005-06 (supra), having similar set of facts

AJAY GARG,DEHRADUN vs. ACIT CENTRAL CIRCLE DEHRADUN, DEHRADUN

In the result, appeal of the assessee is partly allowed

ITA 200/DDN/2024[2015-2016]Status: DisposedITAT Dehradun26 Sept 2025AY 2015-2016
Section 132(4)Section 139(1)Section 147Section 148Section 148(2)Section 151Section 250

reassessment proceedings is held as invalid and is hereby\nquashed. The cross objections of the assessee taken in ground of appeal\nno.1 to 5 of the assessee C.O. are allowed.”\n16. It is further seen that AO has re-opened the case of the\nassessee for the reason that assessee has received cash loan of INR\n50 Lakhs

SH.SANJAY RAWAT,,DEHRADUN vs. ACIT, CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 104/DDN/2024[2013-14]Status: DisposedITAT Dehradun11 Feb 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

139(1) of the Act, declaring total income of INR 2,96,090/- on 28.09.2015. A survey operation was conducted in the case of Shri Amit Sharma at 06, Shastri Nagar, Haridwar Road, Rishikesh and M/s. Shiva Electricals , Prop. Shri Amit Sharma, 3-New Friend Colony, Bye Pass Road, Dehradun and during the survey, certain loose papers were found

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 90/DDN/2024[2015-16]Status: DisposedITAT Dehradun11 Feb 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

139(1) of the Act, declaring total income of INR 2,96,090/- on 28.09.2015. A survey operation was conducted in the case of Shri Amit Sharma at 06, Shastri Nagar, Haridwar Road, Rishikesh and M/s. Shiva Electricals , Prop. Shri Amit Sharma, 3-New Friend Colony, Bye Pass Road, Dehradun and during the survey, certain loose papers were found

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CRICLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 95/DDN/2024[2013-14]Status: DisposedITAT Dehradun11 Feb 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

139(1) of the Act, declaring total income of INR 2,96,090/- on 28.09.2015. A survey operation was conducted in the case of Shri Amit Sharma at 06, Shastri Nagar, Haridwar Road, Rishikesh and M/s. Shiva Electricals , Prop. Shri Amit Sharma, 3-New Friend Colony, Bye Pass Road, Dehradun and during the survey, certain loose papers were found

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

ITA 64/DDN/2024[2014-15]Status: DisposedITAT Dehradun29 Oct 2025AY 2014-15
Section 147Section 148Section 234ASection 271(1)(b)Section 69A

5\nITO [2022] 143 taxmann.com 11 (Delhi) and of the Co-ordinate\nBench of Delhi Tribunal in the case of Nitin Jain vs ACIT in ITA\nNo.1775/Del/2024 order dated 07.03.2025.\n12. On the other hand, Ld. Sr.DR for the Revenue vehemently\nsupported the orders of the lower authorities and submits that\nnotice u/s 148 was sent on the e-mail

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

ITA 78/DDN/2024[2014-15]Status: DisposedITAT Dehradun29 Oct 2025AY 2014-15
Section 147Section 148Section 234ASection 271(1)(b)Section 69A

5\nITA Nos.64, 78 & 79/DDN/2024\nITO [2022] 143 taxmann.com 11 (Delhi) and of the Co-ordinate\n12. On the other hand, Ld. Sr.DR for the Revenue vehemently\nsupported the orders of the lower authorities and submits that\nnotice u/s 148 was sent on the e-mail ID of the assessee and\ntherefore the claim of the assessee that

ATUL KUMAR AGRAWAL,MANPUR ROAD, KASHIPUR vs. NATIONAL E-ASSESSMENT CENTRE, NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 19/DDN/2025[2018-19]Status: DisposedITAT Dehradun16 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year: 2018-19] Mr. Atul Kumar Agarwal Vs National Prop.M/S. R.K. Industries, E-Assessment Centre, Manpur Road, Kashipur, New Delhi U.S. Nagar, Uttarakhand- 244713 Pan-Aaopa9970H Appellant Respondent Assessee By Shri Deepak Joshi,Adv. & Shri Rudra Pratab, Adv. Revenue By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 13.11.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 04.12.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2017-18/10235798 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Filed His Return Of Income On 15.08.2018, Declaring Total Income At Inr 5,81,560/-. The Case Of The Assessee Was Re-Opened U/S 147 Of The Act. Accordingly, Notice U/S 148 Was Issued On 30.03.2022, In Response To Which The Assessee Filed Return Of Income On 03.05.2022, Declaring Same Income As Was Declared In The Return Filed U/S 139(1) Of The Act. Thereafter Notice U/S 143(2) Of The Act Was Issued Followed By Notices U/S 142(1) Alongwith Questionnaires. In Response Filed Replies From Time To Time. After Considering The Submissions Made By The Assessee, Ao Completed The Assessment Vide Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Wherein The Total Income Was Assessed At Inr 54,23,320/-.

Section 133ASection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69C

139(1) of the Act. Thereafter notice u/s 143(2) of the Act was issued followed by notices u/s 142(1) alongwith questionnaires. In response filed replies from time to time. After considering the submissions made by the assessee, AO completed the assessment vide order dated 15.03.2023 passed u/s 147 r.w.s. 144B of the Act wherein the total income

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

ITA 79/DDN/2024[2015-16]Status: DisposedITAT Dehradun29 Oct 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode]

Section 147Section 148Section 234ASection 250Section 271(1)(b)Section 69A

5. That in facts and circumstances of the case, the CIT(A) has not consider the submission and evidence filed before him is unfair and uncalled. 6. That in facts and circumstances of the case, the CIT(A) relied upon the earlier year receipt which was low stating AO has not substantiated with sufficient reason for huge increase in sale