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28 results for “reassessment u/s 147”+ Section 27clear

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Key Topics

Section 14735Section 14835Addition to Income25Section 15319Section 143(3)17Section 26315Section 44B14Section 914Limitation/Time-bar

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

27, Ann A-11 page No. 143, Ann. PO-1 page No. 9 & 10 and statements on oath u/s 132(4) of Shri Deepak Mittal S/o Ashwani Kumar Mittal and Shri Ashwani Kumar Mittal were recorded on 23.09.2011. From these documents/evidences, it has been found that land measuring 0.5480 hect. situated at Jwalapur, Hardwar known as farm house land

Showing 1–20 of 28 · Page 1 of 2

12
Section 15110
Reopening of Assessment8
Natural Justice5

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

27. Ground number 8 of the appeal is against the chargeability of interest u/s 234B of the income tax act. The learned assessing officer is aggrieved that the learned CIT – A has held that the interest u/s 234B was not chargeable in this case by relying on the decision of the honourable jurisdictional High Court in case

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

ITA 5584/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

27. Ground number 8 of the appeal is against the chargeability of interest u/s 234B of the income tax act. The learned assessing officer is aggrieved that the learned CIT – A has held that the interest u/s 234B was not chargeable in this case by relying on the decision of the honourable jurisdictional High Court in case

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

27. Ground number 8 of the appeal is against the chargeability of interest u/s 234B of the income tax act. The learned assessing officer is aggrieved that the learned CIT – A has held that the interest u/s 234B was not chargeable in this case by relying on the decision of the honourable jurisdictional High Court in case

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

27. Ground number 8 of the appeal is against the chargeability of interest u/s 234B of the income tax act. The learned assessing officer is aggrieved that the learned CIT – A has held that the interest u/s 234B was not chargeable in this case by relying on the decision of the honourable jurisdictional High Court in case

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

27. Ground number 8 of the appeal is against the chargeability of interest u/s 234B of the income tax act. The learned assessing officer is aggrieved that the learned CIT – A has held that the interest u/s 234B was not chargeable in this case by relying on the decision of the honourable jurisdictional High Court in case

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

27. Ground number 8 of the appeal is against the chargeability of interest u/s 234B of the income tax act. The learned assessing officer is aggrieved that the learned CIT – A has held that the interest u/s 234B was not chargeable in this case by relying on the decision of the honourable jurisdictional High Court in case

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

27. Ground number 8 of the appeal is against the chargeability of interest u/s 234B of the income tax act. The learned assessing officer is aggrieved that the learned CIT – A has held that the interest u/s 234B was not chargeable in this case by relying on the decision of the honourable jurisdictional High Court in case

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

section 148 of the Act were invoked on the basis of borrowed satisfaction and no independent verification of fact was made. It is observed that AO has based his satisfaction on the entries found noted in loose papers No. LP 184 & 186 however, in the report filed before the Hon’ble Settlement Commission, the ld. PCOT stated that the entries

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

section 148 of the Act were invoked on the basis of borrowed satisfaction and no independent verification of fact was made. It is observed that AO has based his satisfaction on the entries found noted in loose papers No. LP 184 & 186 however, in the report filed before the Hon’ble Settlement Commission, the ld. PCOT stated that the entries

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

section 148 of the Act were invoked on the basis of borrowed satisfaction and no independent verification of fact was made. It is observed that AO has based his satisfaction on the entries found noted in loose papers No. LP 184 & 186 however, in the report filed before the Hon’ble Settlement Commission, the ld. PCOT stated that the entries

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

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

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

u/s 80 IC in respect of sale of scrap and job work. 6. The Ld. CIT(A) has erred on facts in stating that no disclosure of the process of generation of scrap was made so as to work out whether the scrap was generated from his eligible manufacturing business or not. 7. The above grounds are all independent

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

Section 143(3) of the Act. 6. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law rejecting the contention of the assessee that approval having been granted in a mechanical manner is bad in law, hence the consequential proceedings u/s 147 of the Act are illegal and liable

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), 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.,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