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47 results for “reassessment u/s 147”+ Section 143(2)clear

Sorted by relevance

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Key Topics

Section 147107Section 14882Section 143(3)59Section 26339Addition to Income30Section 15319Reopening of Assessment18Section 54B16Section 143(2)

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

Showing 1–20 of 47 · Page 1 of 3

14
Section 15114
Reassessment12
Limitation/Time-bar11

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 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

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), DEHRADUN

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

ITA 1675/DEL/2016[2012-13]Status: DisposedITAT Dehradun27 Jan 2026AY 2012-13

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

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

2 | P a g e ITA No. 1570, 1572 & 1574/Del/2015 (iii) Sh. Salim Ali : 16.67% (iv) Sh. Shahzad Ali : 16.67% (v) Sh. Azad Ali : 16.66% 3. Based on such information, assessments in cases of the sellers of land, including the present assessees, were reopened under section 147 of the Act and ultimately, assessment orders were passed in respect

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

2 | P a g e ITA No. 1570, 1572 & 1574/Del/2015 (iii) Sh. Salim Ali : 16.67% (iv) Sh. Shahzad Ali : 16.67% (v) Sh. Azad Ali : 16.66% 3. Based on such information, assessments in cases of the sellers of land, including the present assessees, were reopened under section 147 of the Act and ultimately, assessment orders were passed in respect

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

2 | P a g e ITA No. 1570, 1572 & 1574/Del/2015 (iii) Sh. Salim Ali : 16.67% (iv) Sh. Shahzad Ali : 16.67% (v) Sh. Azad Ali : 16.66% 3. Based on such information, assessments in cases of the sellers of land, including the present assessees, were reopened under section 147 of the Act and ultimately, assessment orders were passed in respect

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

147 is reproduced as under:- “Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment

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

147 is reproduced as under:- “Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment

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

147 is reproduced as under:- “Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment

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

147 is reproduced as under:- “Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment

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

143(3) of the Act dated 17.02.2021 at a total income of INR 1,57,96,090/- by making addition of INR 1,55,00,000/- holding the same as unexplained receipts by the assessee. 5. Against the said order, assessee filed an appeal before Ld. CIT(A) who vide order dated 16.04.2024, dismissed the appeal of the assessee

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

143(3) of the Act dated 17.02.2021 at a total income of INR 1,57,96,090/- by making addition of INR 1,55,00,000/- holding the same as unexplained receipts by the assessee. 5. Against the said order, assessee filed an appeal before Ld. CIT(A) who vide order dated 16.04.2024, dismissed the appeal of the assessee

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

143(3) of the Act dated 17.02.2021 at a total income of INR 1,57,96,090/- by making addition of INR 1,55,00,000/- holding the same as unexplained receipts by the assessee. 5. Against the said order, assessee filed an appeal before Ld. CIT(A) who vide order dated 16.04.2024, dismissed the appeal of the assessee

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

reassessment order was passed without complying with the mandatory conditions of section 147 to 151 of Income Tax Act, 1961. 2. That in any case and in any view of the matter, Ld. Pr. CIT has erred in law in assuming jurisdiction and passing the impugned order u/s 263, is bad in law and against the facts and circumstances

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)

147 r.w.s 143(3) of the Act is erroneous and prejudicial to the interests of Revenue on the issue of alleged bogus „purchases‟ made from one M/s Meet Enterprises. 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