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15 results for “reassessment u/s 147”+ Section 40clear

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Key Topics

Section 14726Section 14823Section 44B14Section 914Addition to Income14Section 26313Section 143(3)8Section 143(1)4Section 143(2)

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

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

4
Reassessment3
Limitation/Time-bar2

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

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

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

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

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

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

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

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

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

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

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

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

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

40, 41, 44 & 45/DDN/2022 M/s Sharda Export Vs. the ACIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘DEHRADUN/’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER I.T.A. No. 40/DDN/2022 (A.Y 2006-07) I.T.A. No. 41/DDN/2022 (A.Y 2007-08) M/s Sharda Exports Vs ACIT C/o. Sh. Jitenera Kumar Gupta Central Circle, Income

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

40, 41, 44 & 45/DDN/2022 M/s Sharda Export Vs. the ACIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘DEHRADUN/’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER I.T.A. No. 40/DDN/2022 (A.Y 2006-07) I.T.A. No. 41/DDN/2022 (A.Y 2007-08) M/s Sharda Exports Vs ACIT C/o. Sh. Jitenera Kumar Gupta Central Circle, Income

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

40, 41, 44 & 45/DDN/2022 M/s Sharda Export Vs. the ACIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘DEHRADUN/’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER I.T.A. No. 40/DDN/2022 (A.Y 2006-07) I.T.A. No. 41/DDN/2022 (A.Y 2007-08) M/s Sharda Exports Vs ACIT C/o. Sh. Jitenera Kumar Gupta Central Circle, Income

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

40, 41, 44 & 45/DDN/2022 M/s Sharda Export Vs. the ACIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘DEHRADUN/’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER I.T.A. No. 40/DDN/2022 (A.Y 2006-07) I.T.A. No. 41/DDN/2022 (A.Y 2007-08) M/s Sharda Exports Vs ACIT C/o. Sh. Jitenera Kumar Gupta Central Circle, Income

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

40, 460/-. 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

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

DAVINDER KUMAR MAGO,PUNJABI BAGH vs. DCIT/ACIT CENTRAL CIRCLE, DDN, DEHRADUN

In the result appeal of the assessee is allowed

ITA 17/DDN/2026[2019-20]Status: DisposedITAT Dehradun12 Mar 2026AY 2019-20

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Davinder Kumar Mago Vs Dcit/Acit 12/1, Punjabi Bagh, Central Circle, External Punjabi Bagh, Dehradun New Delhi-110026 Uttarakhand Pan-Ajhpm9802A Appellant Respondent Appellant By Shri Ajay Wadhwa, Adv. (Vc) Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : This Appeal Filed By The Assessee Against The Order By Pr.Cit (Central), Kanpur At Meerut Passed U/S 263 Of The Income Tax Act, 1861 (“The Act”) Dated 08.01.2026 Arising Out Of The Order Passed U/S 143(3) R.W.S. 147 Of The Act.

Section 142(1)Section 143(3)Section 147Section 263

147 of the Act. The reassessment order was passed wherein income declared by the assessee is accepted by AO. Thereafter, based on the information provided by the AO himself, Ld. PCIT initiated revision proceedings u/s 263 of the Act and the ld. PCIT hold the assessment order as erroneous and pre-judicial to the interest of the Revenue

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

ITA 79/DDN/2024[2015-16]Status: DisposedITAT Dehradun29 Oct 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode]

Section 147Section 148Section 234ASection 250Section 271(1)(b)Section 69A

147 r.w.s. 144 r.w.s 144B of the Act and the remaining two appeals in ITA Nos. 78 & 79/DDN/2024 are filed by the assessee against penalty order, both dated 07.09.2022 passed u/s 271(1)(b) of the Act for Assessment Years 2014-15 & 2015-16 respectively. ITA Nos.64, 78 & 79/DDN/2024 2. As these three appeals are having the issues which