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75 results for “reassessment”+ Section 147clear

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Key Topics

Section 147145Section 148140Section 143(3)67Addition to Income49Section 26346Reopening of Assessment31Section 15123Reassessment23Limitation/Time-bar21Section 153

SH. ASHOK KUMAR,HARIDWAR vs. ITO, HARIDWAR

In the result, the appeal of the assessee is allowed

ITA 107/DDN/2025[2015-16]Status: DisposedITAT Dehradun17 Sept 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalashok Kumar, Assessment Unit, 19, Sitapur Mazara, Jwalapur, Income Tax Haridwar, Uttarakhand-249407 Vs. Department. Pan-Btupk9604E (Appellant) (Respondent) Assessee By Shri Pankaj Goel, Adv. Department By Shri A. S. Rana, Sr. Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 17/09/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Ld. Cit(A)’ For Short) In Appeal No. Nfac/2014-15/10271519 Dated 10.04.2025 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is An Agriculturist Having No Any Other Source Of Income Than Agricultural Income. Since, The Income From Agricultural Operations Is Exempt From Tax, He Was Not Obliged To File The Return Of Income. The Assessing Officer Based On The Information That Assessee Has Deposited A Sum Of Rs.76,00,000/- In Zila Sahkari Bank Ltd., Initiated Reassessment Proceedings In The Case Of Assessee By Recording Reasons That Income To The Extent Of Rs.76,00,000/- Has Escaped Assessment In The Order Passed U/S 148A(D) Of The Act. Accordingly, Notices U/S 148 Was Issued On 26.03.2022. In Response To Which Assessee Filed Return Of Income On 12.04.2022 Ashok Kumar Vs. Ito Declaring Total Income Of Rs.10,00,000/- From Agriculture Activity & Claimed The Same As Exempt From Tax. The Assessing Officer Passed The Reassessment Order Wherein He Has Made The Additions On Account Of Agriculture Income Of Rs.10,00,000/- By Treating The Same As Income From Other Sources & Further Made Additions Of Rs.76,00,000/- Being Cash Deposited During Demonetization As Unexplained Money U/S 69A Of The Act. The Ao Further Made Additions Of Rs.2,67,195/- As Against Nil Income Declared Towards Bank Interest.

Section 147Section 148

Showing 1–20 of 75 · Page 1 of 4

19
Section 143(2)18
Section 54B16
Section 148A
Section 69A

147. Sub-section (2) of section 148 mandates reasons for issuance of notice by the Assessing Officer and sub-section (1) thereof mandates service of notice to the assessee before the Assessing Officer proceeds to assess, reassess

SHRI SALIM ALI,DEHRADUN vs. ITO, DEHRADUN

In the result, appeals are partly allowed as indicated above

ITA 1570/DEL/2015[2007-08]Status: DisposedITAT Dehradun23 Jun 2023AY 2007-08

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2007-08 Salim Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Bapba5312H (Appellant) (Respondent) Assessment Year: 2007-08 Azad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azvpa8477F (Respondent) (Appellant) Assessment Year: 2007-08 Shahzad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azopa9077A (Respondent) (Appellant) Assessees By : Sh. Saurabh Gupta, Ca & Sh. Rishabh Gupta, Ca Revenue By : Sh. A.S. Rana, Cit/Dr Date Of Hearing : 19.06.2023 Date Of Pronouncement: 23.06.2023

For Respondent: Sh. A.S. Rana, CIT/DR
Section 132Section 143(3)Section 147Section 153C

sections 147 and 148 of the Act. The ITAT held the notice issued under sec. 148 and proceedings under sec. 147 as illegal and void ab initio. It was held that Assessing Officer having not followed procedure under sec. 153C, reassessment

SHRI AZAD ALI,DEHRADUN vs. ITO, DEHRADUN

In the result, appeals are partly allowed as indicated above

ITA 1572/DEL/2015[2007-08]Status: DisposedITAT Dehradun23 Jun 2023AY 2007-08

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2007-08 Salim Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Bapba5312H (Appellant) (Respondent) Assessment Year: 2007-08 Azad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azvpa8477F (Respondent) (Appellant) Assessment Year: 2007-08 Shahzad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azopa9077A (Respondent) (Appellant) Assessees By : Sh. Saurabh Gupta, Ca & Sh. Rishabh Gupta, Ca Revenue By : Sh. A.S. Rana, Cit/Dr Date Of Hearing : 19.06.2023 Date Of Pronouncement: 23.06.2023

For Respondent: Sh. A.S. Rana, CIT/DR
Section 132Section 143(3)Section 147Section 153C

sections 147 and 148 of the Act. The ITAT held the notice issued under sec. 148 and proceedings under sec. 147 as illegal and void ab initio. It was held that Assessing Officer having not followed procedure under sec. 153C, reassessment

SHRI SHAHAZAD ALI,DEHRADUN vs. ITO, DEHRADUN

In the result, appeals are partly allowed as indicated above

ITA 1574/DEL/2015[2007-08]Status: DisposedITAT Dehradun23 Jun 2023AY 2007-08

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2007-08 Salim Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Bapba5312H (Appellant) (Respondent) Assessment Year: 2007-08 Azad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azvpa8477F (Respondent) (Appellant) Assessment Year: 2007-08 Shahzad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azopa9077A (Respondent) (Appellant) Assessees By : Sh. Saurabh Gupta, Ca & Sh. Rishabh Gupta, Ca Revenue By : Sh. A.S. Rana, Cit/Dr Date Of Hearing : 19.06.2023 Date Of Pronouncement: 23.06.2023

For Respondent: Sh. A.S. Rana, CIT/DR
Section 132Section 143(3)Section 147Section 153C

sections 147 and 148 of the Act. The ITAT held the notice issued under sec. 148 and proceedings under sec. 147 as illegal and void ab initio. It was held that Assessing Officer having not followed procedure under sec. 153C, reassessment

G & T RESOURCES (EUROPE) LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 5553/DEL/2012[2004-05]Status: DisposedITAT Dehradun29 Apr 2022AY 2004-05

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5553/Del/2012 : Asstt. Year: 2004-05 G&T Resources (Europe) Ltd., Vs Adit, C/O F-04 & 05, Triveni Commercial International Taxation, Complex, Sheikh Sarai, Phase-I, Dehradun New Delhi-110017 (Appellant) (Respondent) Pan No. Aabcg9877F Assessee By : None Revenue By : Sh. T. S. Mapwal, Sr. Dr Date Of Hearing: 25.04.2022 Date Of Pronouncement: 29.04.2022 Order Per Dr. B. R. R. Kumar: The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Ao U/S 143(3) Of The Income Tax Act, 1961 Dated 23.11.2006. 2. The Assessee Has Raised Revised Grounds Of Appeal: “1. That, On The Facts & In The Circumstances Of The Case & In Law, The Learned Ao Has Erred On Facts & In Law In Initiating Proceedings Under Section 148 Read Together With Section 147 Of The Income 1Ax Act, 1961. 2. That In The Absence Of Any New Facts, Other Than The Ones Already On Record Based On Which The Assessment Order Was Passed, Initiating Proceedings Under Section 148 After Expiry Of Four Years Are Bad In Law & Void Abinitio. 3. That, The Learned Ao Having Considered The Facts, Applied The Spirit Of The Boards Instructions As Contained In Notification 1767 In A Speaking Assessment Order Erred In Initiating Proceedings Under Section 148 After The Expiry Of Four Years Merely Because In A Subsequent

For Appellant: NoneFor Respondent: Sh. T. S. Mapwal, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 44B

Section 147, the reassessment proceedings initiated u/s 147 of the Income Tax Act 1961 beyond a period of four years

SHRI GANGA RAM ADWANI,RISHIKESH vs. DCIT, RISHIKESH

In the result the appeal filed by the assessee is allowed

ITA 1511/DEL/2017[2008-09]Status: DisposedITAT Dehradun11 Nov 2020AY 2008-09

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaasstt. Year 2008-09

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri S.K. Chatterjee, Sr. DR
Section 143(3)Section 147Section 148Section 234BSection 234C

section 147 of the IT Act, 1961. Necessary approval u/s 151(1) of the Act 1961 of the CIT, Dehradun for initiating proceedings u/s 147 has been received vide his office letter F. No. Pr.CIT/DDN/Sct.Appr./148/2014-15/2734 dated 26.03.2015.” 3.1. Thereafter notice u/s 148 was issued on 26th March 2015. The assessee in response to the said notice submitted that

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

section 147 of the Act, the reassessment deserves to be quashed. Reliance in this regard has been rightly placed by the ld AO on the decision

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

section 147 of the Act, the reassessment deserves to be quashed. Reliance in this regard has been rightly placed by the ld AO on the decision

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

section 147 of the Act, the reassessment deserves to be quashed. Reliance in this regard has been rightly placed by the ld AO on the decision

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

section 147 of the Act, the reassessment deserves to be quashed. Reliance in this regard has been rightly placed by the ld AO on the decision

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

147 of the act is in accordance with provisions of the Act and requested for the confirmation of the same. 14. Heard the contentions of both parties and perused the material available on record. The claim of the assessee is that the AO has proceeded to re-open the assessment solely on the basis of borrowed satisfaction and the information

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

147 of the act is in accordance with provisions of the Act and requested for the confirmation of the same. 14. Heard the contentions of both parties and perused the material available on record. The claim of the assessee is that the AO has proceeded to re-open the assessment solely on the basis of borrowed satisfaction and the information

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

147 of the act is in accordance with provisions of the Act and requested for the confirmation of the same. 14. Heard the contentions of both parties and perused the material available on record. The claim of the assessee is that the AO has proceeded to re-open the assessment solely on the basis of borrowed satisfaction and the information

MASCOT FASTNERS PRIVATE LIMITED,UTTARAKHAND vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI, -

In the result, the appeal of the assessee is hereby allowed

ITA 46/DDN/2024[2013-14]Status: DisposedITAT Dehradun02 Apr 2025AY 2013-14

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) M/S. Mascot Fastners Pvt. Vs. National Faceless Ltd, Assessment Centre, Plot No. B-155, Eldeco, Sidcul, Delhi Industrial Park, Sitarganj, Udham Singh Nagar, 262 403 (Appellant) (Respondent) Pan: Aabcm4504H Assessee By : Shri Atul Ninawat, Partner Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 18/03/2025 Date Of Pronouncement 02/04/2025

For Appellant: Shri Atul Ninawat, PartnerFor Respondent: Shri A. S. Rana, Sr. DR
Section 115JSection 143(3)Section 147Section 80Section 80I

section 147 of the Act does not get satisfied at all in the instant case. Further on perusal of the explanation given by the assessee, the Learned AO had indeed formed an opinion in the original scrutiny assessment proceedings. The Learned AO in the reassessment

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 2956/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5583/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3072/DEL/2012[2009-10]Status: DisposedITAT Dehradun08 Jun 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section

ADIT, DEHRADUN vs. M/S. M.I. OVERSEAS LTD., NOIDA

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3045/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5565/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5564/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section