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16 results for “reassessment”+ Section 151(2)clear

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Key Topics

Section 14848Section 14740Section 15121Addition to Income14Section 26313Section 143(3)11Reopening of Assessment10Section 143(2)9Section 106

BABU LAL PATWARI ,UTTARAKHAND vs. DCIT CIRCLE-2(1)(), UTTARAKHAND

In the result, the appeal filed by the assessee is allowed

ITA 60/DDN/2024[2014-15]Status: DisposedITAT Dehradun23 Jan 2026AY 2014-15

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Somil Agarwal, AdvocateFor Respondent: Shri S.K. Chaterjee, CIT DR
Section 148Section 148ASection 151

2) of Before expiry of four Joint the old regime years from the end of the Commissioner relevant assessment year Section 151(1) of After expiry of four years from Principal Chief Commissioner or the old regime the end of the relevant Chief Commissioner or Principal assessment years Commissioner or Commissioner Section 151(i) of the Three years or less

NAMITA AGRAWAL,UTTRAKHAND vs. DCIT, CENTRAL CIRCLE, DEHRADUN, INCOME TAX OFFICE ,DEHRADUN

Section 2506
Reassessment5
Natural Justice5

In the result, appeal of the assessee is allowed

ITA 13/DDN/2025[2019-20]Status: DisposedITAT Dehradun09 Jul 2025AY 2019-20

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2019-20] Namita Agrawal, Vs Dcit, 36/1, E C Road, Dehradun, Central Circle, Uttarakhand-248001 Dehradun Pan-Afspa0668P Appellant Respondent Assessee By Shri Anil Jain, Adv. & Shri Naman Jain, Adv. Revenue By Shri S.K.Chaterjee, Cit. Dr Date Of Hearing 09.07.2025 Date Of Pronouncement 09.07.2025 Order

Section 127Section 147Section 148Section 151Section 250Section 69B

2), the Principal Chief Commissioner or the Chief Commissioner or the g Principal Commissioner or the Commissioner or the Joint Commissioner, as the case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice under section 148, need not issue such notice himself." 12. A plain reading

SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION WORD DEHRADUN, DEHRADUN

In the result, appeals of the assessee are allowed

ITA 218/DDN/2025[2009-10]Status: DisposedITAT Dehradun18 Feb 2026AY 2009-10

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

2), the Principal Chief Commissioner or the Chief Commissioner or the g Principal Commissioner or the Commissioner or the Joint Commissioner, as the case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice under section 148, need not issue such notice himself." 12. A plain reading

SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION DEHRADUN, DEHRADUN

In the result, appeals of the assessee are allowed

ITA 220/DDN/2025[2011-12]Status: DisposedITAT Dehradun18 Feb 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

2), the Principal Chief Commissioner or the Chief Commissioner or the g Principal Commissioner or the Commissioner or the Joint Commissioner, as the case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice under section 148, need not issue such notice himself." 12. A plain reading

SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION WORD DEHRADUN, DEHRADUN

In the result, appeals of the assessee are allowed

ITA 219/DDN/2025[2010-11]Status: DisposedITAT Dehradun18 Feb 2026AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

2), the Principal Chief Commissioner or the Chief Commissioner or the g Principal Commissioner or the Commissioner or the Joint Commissioner, as the case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice under section 148, need not issue such notice himself." 12. A plain reading

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

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

ITA 3071/DEL/2016[2011-12]Status: DisposedITAT Dehradun28 Nov 2023AY 2011-12
For Appellant: Shri Sanjay Malik, Adv. &For Respondent: Smt. Poonam Sharma, Addl. CIT
Section 10Section 10(2688)Section 143(2)Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)

section 143(2) was invalid, illegal and void-ab- inito. 14. That in any case and in any view of the matter action of Ld. CIT(A) is not quashing the impugned reassessment order passed by the ld. AO u/s 147/148 of the Act, is bad in law and against the facts and circumstances of the case. 15. That

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

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

ITA 3072/DEL/2016[2012-13]Status: DisposedITAT Dehradun28 Nov 2023AY 2012-13
For Appellant: Shri Sanjay Malik, Adv. &For Respondent: Smt. Poonam Sharma, Addl. CIT
Section 10Section 10(2688)Section 143(2)Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)

section 143(2) was invalid, illegal and void-ab- inito. 14. That in any case and in any view of the matter action of Ld. CIT(A) is not quashing the impugned reassessment order passed by the ld. AO u/s 147/148 of the Act, is bad in law and against the facts and circumstances of the case. 15. 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)

2 2.1. That the PCIT exceeded his jurisdiction in setting aside the reassessment order on the issue of alleged bogus „purchases‟ from M/s Meet Enterprises, despite the fact that the issue in reassessment proceedings was restricted only to alleged bogus „payments‟ made to the said party. 2.2. That the PCIT failed to appreciate that the issue of disallowance of alleged

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

2 [relate to, the\nassessee; or\n(d) the Assessing Officer has received any information under the scheme\nnotified under section 135A pertaining to income chargeable to tax\nescaping assessment for any assessment year in the case of the\nassessee.]\nExplanation.—For the purposes of this section, specified authority means\nthe specified authority referred to in section 151.]”\n12.\nFrom

OMWATI,DEHRADUN vs. PR.CIT, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 6853/DEL/2017[2010-11]Status: DisposedITAT Dehradun15 Sept 2023AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshsmt. Omwati Pr. Cit W/O Sh. Dariyav Singh Dehradun 171/1, Vasant Vihar, Vs. Dehradun Pan-Aanpw 6438K (Appellant) (Respondent)

Section 143(3)Section 147Section 148Section 263Section 54B

2 of 12 Omwati vs. Pr. CIT (a) That assumption of jurisdiction u/s 147 is itself is bad in law as the reason recorded would not have led to the formation of belief of escapement of income. (b) That impugned reassessment order was passed without complying with the mandatory conditions of section 147 to 151

ACHARYA BALKRISHNA,HARIDWAR vs. DCIT, DEHRADUN

In the result appeal of the assessee is allowed

ITA 112/DDN/2025[2015-16]Status: DisposedITAT Dehradun24 Sept 2025AY 2015-16

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 144Section 147Section 148Section 148ASection 149Section 151Section 250Section 68Section 69Section 69C

2. That the learned Commissioner of Income Tax (Appeals) has further erred both in law and on facts in upholding the initiation of proceedings under section 147 of the Act, in as much as, the instant reassessment proceedings were without satisfying the statutory pre-conditions as envisaged under the Act, being barred by limitation as per first proviso to section

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

2. On the facts and circumstances of the case, Ld. CIT (A) has erred both on facts as well as on the law in affirming the order of the AO which is null; and void for the reason of absence of DIN on the assessment order as mandated by the CBDT Circular No. 19/2019. 3 On the facts and circumstances

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

2. On the facts and circumstances of the case, Ld. CIT (A) has erred both on facts as well as on the law in affirming the order of the AO which is null; and void for the reason of absence of DIN on the assessment order as mandated by the CBDT Circular No. 19/2019. 3 On the facts and circumstances

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

2. On the facts and circumstances of the case, Ld. CIT (A) has erred both on facts as well as on the law in affirming the order of the AO which is null; and void for the reason of absence of DIN on the assessment order as mandated by the CBDT Circular No. 19/2019. 3 On the facts and circumstances

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

2\n2. That in facts and circumstances of the case, the higher authorities\nhas failed to record their independent satisfaction and approval has\nbeen granted without application of mind and without going through\nthe file and in hasty manner is unjustified and illegal.\n3. That in facts and circumstances of the case, the AO has taken the\ncredit side

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

2\nITA Nos.64, 78 & 79/DDN/2024\n2.\n3.\n4.\n5.\n6.\nThat in facts and circumstances of the case, the higher authorities\nhas failed to record their independent satisfaction and approval has\nbeen granted without application of mind and without going through\nthe file and in hasty manner is unjustified and illegal.\nThat in facts and circumstances of the case