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9 results for “reassessment u/s 147”+ Disallowanceclear

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Mumbai2,542Delhi1,399Chennai658Bangalore512Kolkata439Jaipur297Ahmedabad276Hyderabad200Pune147Chandigarh141Surat133Raipur128Indore103Rajkot69Amritsar65Lucknow56Nagpur52Guwahati47Visakhapatnam44Cochin38Agra36Cuttack35Jodhpur35Allahabad35Patna27Karnataka17Panaji16Dehradun9Jabalpur5Telangana5Calcutta5Kerala4Varanasi3SC2Gauhati2Orissa2Ranchi1Punjab & Haryana1

Key Topics

Section 14723Section 14820Section 2638Section 143(3)8Reassessment5Section 80I4Section 104Addition to Income4Reopening of Assessment

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 263
4
Bogus Purchases3
Disallowance3
Limitation/Time-bar3
Section 263(2)

disallowed in the reassessment proceedings completed u/s 143(3) read with section 147 of the Act dated 26.12.2018. 7. This

SHRI VIBHU GROVER,KOTDWARA vs. PCIT, DEHRADUN

In the result appeal of the assessee is allowed

ITA 110/DDN/2024[2015-16]Status: DisposedITAT Dehradun26 Sept 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalvibhu Grover, Pcit, M/S Grover Sales Corporation, Dehradun. Garage Road, Kotdwara, Vs. Pauri-246169 Pan:Agdpg5842R (Appellant) (Respondent) Assessee By Shri Anil Jain, Adv. Department By Shri S.K. Chaterjee, Cit-Dr

Section 142(1)Section 147Section 148Section 263

147 r.w.s 144B of the Act dated 25.03.2022 and direct the AO to pass fresh assessment order after due enquiries and verification. 5. Against the said order, the assessee is in appeal before the Tribunal. All the grounds of appeal taken by the assessee are challenging the revisionary order passed u/s 263 without appreciating the facts of the case, therefore

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

147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course

M/S. SHARDA EXPORTS,MEERUT vs. THE INCOME TAX OFFICER, WARD-1(3)(3), HARIDWAR

In the result, the appeal of the Assessee is allowed and the appeal of the revenue is dismissed

ITA 39/DDN/2022[2005-2006]Status: DisposedITAT Dehradun15 Sept 2023AY 2005-2006

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) M/S. Sharda Exports, Vs. Ito, C/O. Sh. Jitendra Kumar Gupta, Ward-1(3)(3), 219, Railway Road, Meerut Haridawar (Appellant) (Respondent) Pan: Aayfs1694N Dcit, Vs. M/S. Sharda Exports, Central Circle, C/O. Sh. Jitendra Kumar Gupta, Dehradun 219, Railway Road, Meerut (Appellant) (Respondent) Pan: Aayfs1694N

For Appellant: Shri Raj Kumar, CAFor Respondent: Shri Amar Singh Rana, Sr. DR
Section 147Section 148Section 151Section 80Section 80I

disallowance of Rs. 12,96,73,815/-made on account of deduction claimed u/s 80IC of the Act by the assessee for the period under consideration. 2. That the order of the Ld. CIT(A) being erroneous in law and on facts that, it has failed to fully appreciate the energy analysis done by the AO in order to examine

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

In the result, the appeal of the Assessee is allowed and the appeal of the revenue is dismissed

ITA 43/DDN/2022[2005-06]Status: DisposedITAT Dehradun15 Sept 2023AY 2005-06

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) M/S. Sharda Exports, Vs. Ito, C/O. Sh. Jitendra Kumar Gupta, Ward-1(3)(3), 219, Railway Road, Meerut Haridawar (Appellant) (Respondent) Pan: Aayfs1694N Dcit, Vs. M/S. Sharda Exports, Central Circle, C/O. Sh. Jitendra Kumar Gupta, Dehradun 219, Railway Road, Meerut (Appellant) (Respondent) Pan: Aayfs1694N

For Appellant: Shri Raj Kumar, CAFor Respondent: Shri Amar Singh Rana, Sr. DR
Section 147Section 148Section 151Section 80Section 80I

disallowance of Rs. 12,96,73,815/-made on account of deduction claimed u/s 80IC of the Act by the assessee for the period under consideration. 2. That the order of the Ld. CIT(A) being erroneous in law and on facts that, it has failed to fully appreciate the energy analysis done by the AO in order to examine

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

147 r.w.s. 144B of the Act wherein the total income was assessed at INR 54,23,320/-. 3. Against the said order, assessee filed an appeal before Ld. CIT(A) who vide order dated 04.12.2024, dismissed the appeal of the assessee. 4. Aggrieved by the order of Ld. CIT(A), assessee is in appeal before the Tribunal by taking following

METRO FROZEN FRUIT & VEGETABLES PVT. LTD.,ROORKEE vs. DCIT, CIRCLE, HARIDWAR

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

ITA 1555/DEL/2019[2009-10]Status: DisposedITAT Dehradun08 Mar 2022AY 2009-10

Bench: Shri R.K. Panda & Shri N. K. Choudhry[Assessment Year: 2009-10] Metro Frozen Fruits & Dcit, Vegetables Pvt. Ltd. Circle Haridwar, Plot No.22, Rajpur, Vs Uttarakhan Bhagwanpur, Roorkee, Uttrakhand Pan-Aaecm4521F Assessee Revenue Assessee By Sh. Piyush Kuchhal, Fca Revenue By Ms. Poonam Sharma Cit-Dr Date Of Hearing 23.02.2022 Date Of Pronouncement 08.03.2022 Order Per R.K. Panda, Am, This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.01.2019 Of The Learned Cit(A), Dehradun, Relating To Assessment Year 2009-10. 2. The Grounds Raised By The Assessee Are As Under:-

Section 143(3)Section 147Section 148

147 of the Act are illegal and liable to be quashed. 3 7. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law, in ignoring the fact that the initiation of reassessment proceedings are bad in law as the same amounts to change of opinion of AO only

RITU SINGHAL,DEHRADUN vs. DCIT/ACIT , CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 47/DDN/2025[2022-23]Status: DisposedITAT Dehradun29 Oct 2025AY 2022-23
Section 143(3)Section 147Section 250Section 69A

reassessment proceedings were\ninitiated in the case of assessee and re-assessment order was passed\nu/s 147 on 25.01.2024, making an addition of INR 40,91,770/- to the\nassessee's total return income.\n3. Against the said order, assessee filed an appeal before Ld. CIT(A)\nwho vide order dated 30.01.2025, partly allowed the appeal of the\nassessee

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

disallowed and added back to its total income.” 4. Aggrieved by the assessment order dated 30.03.2017, Assessee preferred an Appeal before the ld. CIT(A). The ld. CIT(A) vide order dated 27.01.2024,allowed the appeal of the assessee.As against the order of the ld. CIT(A), Assessee preferred the present appeal. 5. The ld. DR submitted that