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54 results for “reassessment”+ Section 147(6)clear

Sorted by relevance

Mumbai2,247Delhi2,180Chennai736Ahmedabad677Kolkata488Jaipur475Bangalore442Hyderabad435Pune318Chandigarh272Raipur238Indore218Rajkot216Surat208Visakhapatnam134Amritsar132Cochin115Patna111Nagpur97Agra85Guwahati83Lucknow65Cuttack61Jodhpur55Dehradun54Allahabad43Ranchi34Panaji21Jabalpur13Varanasi8

Key Topics

Section 147123Section 148104Section 143(3)58Section 26339Addition to Income36Section 15123Reopening of Assessment22Section 15319Reassessment18

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 54 · Page 1 of 3

Section 54B16
Section 143(2)14
Limitation/Time-bar13
Section 148A
Section 69A

6. The AO made further addition on account of agriculture income by holding the same as income from other sources being unexplained and also made additions towards the bank interest which was not part of the reasons recorded. It was thus claim of the assessee that once the very basis of initiation of proceedings u/s 147 of the Act does

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

147 are illegal and void ab initio – AO having not followed procedure under s. 153C, reassessment order was rightly quashed by the CIT (A).” 6 | P a g e ITA No. 1570, 1572 & 1574/Del/2015 21. Following the mandate of section

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

147 are illegal and void ab initio – AO having not followed procedure under s. 153C, reassessment order was rightly quashed by the CIT (A).” 6 | P a g e ITA No. 1570, 1572 & 1574/Del/2015 21. Following the mandate of section

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

147 are illegal and void ab initio – AO having not followed procedure under s. 153C, reassessment order was rightly quashed by the CIT (A).” 6 | P a g e ITA No. 1570, 1572 & 1574/Del/2015 21. Following the mandate of section

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

6 (for first notice u/s 148) and page 19 to 24 (for second 148 notice), nowhere the AO had even whispered about the failure on the part of the Assessee to disclose fully and truly all material facts that are relevant for the purpose of assessment. Hence, as per proviso to section 147 of the Act, the reassessment

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

6 (for first notice u/s 148) and page 19 to 24 (for second 148 notice), nowhere the AO had even whispered about the failure on the part of the Assessee to disclose fully and truly all material facts that are relevant for the purpose of assessment. Hence, as per proviso to section 147 of the Act, the reassessment

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

6 (for first notice u/s 148) and page 19 to 24 (for second 148 notice), nowhere the AO had even whispered about the failure on the part of the Assessee to disclose fully and truly all material facts that are relevant for the purpose of assessment. Hence, as per proviso to section 147 of the Act, the reassessment

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

6 (for first notice u/s 148) and page 19 to 24 (for second 148 notice), nowhere the AO had even whispered about the failure on the part of the Assessee to disclose fully and truly all material facts that are relevant for the purpose of assessment. Hence, as per proviso to section 147 of the Act, the reassessment

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

6. This assessment was sought to be reopened by the Learned AO vide issuance of notice under section 148 of the Act dated 28-3-2021. Further we find that the Learned AO had sought to reopen the assessment only on perusal of the assessment records. This itself goes to prove that there was absolutely no tangible material available with

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

6 raised by the 8. assessee wherein the assessee has challenged the re-opening of the assessment u/s 148 of the Act, it is stated that sole basis for initiating the proceedings is alleged entries found noted in some loose papers impounded during the course of survey in the case of Shri Amit Sharma. Ld. AR submits that

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

6 raised by the 8. assessee wherein the assessee has challenged the re-opening of the assessment u/s 148 of the Act, it is stated that sole basis for initiating the proceedings is alleged entries found noted in some loose papers impounded during the course of survey in the case of Shri Amit Sharma. Ld. AR submits that

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

6 raised by the 8. assessee wherein the assessee has challenged the re-opening of the assessment u/s 148 of the Act, it is stated that sole basis for initiating the proceedings is alleged entries found noted in some loose papers impounded during the course of survey in the case of Shri Amit Sharma. Ld. AR submits that

SMT. SAPNA GUPTA,HARIDWAR vs. THE PRINCIPAL COMMISSIONER OF INCOEM TAX, DEHRADUN

In the result, the appeal of the assessee is dismissed

ITA 16/DDN/2021[2009-2010]Status: DisposedITAT Dehradun08 Jun 2023AY 2009-2010

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2009-10 Smt. Sapna Gupta, Vs The Pr. Cit, 299, Awas Vikas Colony, Dehradun. Vivek Vihar, Haridwar – 249 407, Uttarakhand. Pan: Acspg4083D (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate & Ms Deepashri Rao, Ca Revenue By : Shri N.S. Jangpangi, Cit, Dr Date Of Hearing : 27.04.2023 Date Of Pronouncement : 08.06.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.16/Ddn/2021 For Ay 2009-10 Arises Out Of The Order Of The Pr. Commissioner Of Income Tax (Appeals), Dehradun, [Hereinafter Referred To As „Ld. Pcit‟, In Short] In Din & Order No. Itba/Rev/F/Rev5/2020- 21/1031815348(1) Dated 27.03.2021 Against The Order Of Assessment Passed U/S 148/147 R.W.S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As „The Act‟) Dated 26Th/28Th December, 2018 By The Ld. Assessing Officer, Ward 1(3)(3), Haridwar (Hereinafter Referred To As „Ld. Ao‟). 2. The Only Issue To Be Decided In This Appeal Is As To Whether The Ld. Pcit Was Justified In Invoking Revisionary Jurisdiction U/S 263 Of The Act In Respect Of Disallowance Of Purchases Of Rs 33,35,500/- In The Facts & Circumstances Of The Instant Case.

For Appellant: Shri Rohit Jain, Advocate &For Respondent: Shri N.S. Jangpangi, CIT, DR
Section 147Section 148Section 263Section 263(2)

section 147 of the Act dated 26.12.2018. 7. This reassessment dated 26.12.2018 was sought to be revised by the ld. PCIT by invoking revisionary jurisdiction u/s 263 of the Act on the ground that the ld. AO ought to have disallowed the entire purchases from M/s Meet Enterprises amounting to Rs 1,06,80,540/- and since only

SIME DARBY ENGINEERING SDN BHD,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

ITA 9/DDN/2021[2017-18]Status: DisposedITAT Dehradun27 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(4)

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality

SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, appeals of the Assessee in ITA No

ITA 7616/DEL/2018[2015-16]Status: DisposedITAT Dehradun27 Jan 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(4)

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality

SIME DARBY ENGINEERING SDNBHD,MALAYSIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

ITA 40/DDN/2021[2018-19]Status: DisposedITAT Dehradun27 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(4)

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

ITA 1557/DEL/2017[2013-14]Status: DisposedITAT Dehradun27 Jan 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality

NATIONAL OIL WELL VARCO PTE. LTD (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE. LTD),MAHARASHTRA vs. THE DEPUTY DIRECTOR OF INCOME TAX CIRCLE-1( INTERNATIONAL TAXATION ), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

ITA 5/DDN/2021[2017-18]Status: DisposedITAT Dehradun27 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality

NATIONAL OILWELL VARCO PTE. LTD. (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE LTD.),MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

ITA 419/DEL/2019[2015-16]Status: DisposedITAT Dehradun27 Jan 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CI9RCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

ITA 5898/DEL/2017[2014-15]Status: DisposedITAT Dehradun27 Jan 2026AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality