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12 results for “reassessment u/s 147”+ Section 47clear

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Delhi1,030Mumbai981Bangalore375Chennai317Jaipur311Ahmedabad303Hyderabad151Kolkata140Chandigarh132Pune113Raipur98Indore96Visakhapatnam62Surat54Rajkot49Amritsar43Guwahati41Lucknow40Cuttack38Nagpur30Patna29Telangana29Cochin25Jodhpur20Allahabad16Karnataka14Dehradun12Agra10Orissa4SC2Ranchi2Jabalpur2Varanasi2Rajasthan1Uttarakhand1

Key Topics

Section 26321Section 14716Section 44B14Section 914Section 143(3)10Addition to Income10Reassessment5Section 684Section 148

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

ADIT, DEHRADUN vs. M/S. M.I. OVERSEAS LTD., NOIDA

4
Section 54B4
Revision u/s 2632
Natural Justice2

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

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

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

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

147 of the Act on 21/03/2016. This assessment was sought to be revised by the Ld. PCIT by invoking revision jurisdiction u/s 263 of the Act on the ground that the Ld. A.O. had not examined the claim of deduction u/s 54B of the Act made by the Ld. AO, thereby making reassessment order erroneous and prejudicial to the interest

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

M/S PARASNATH FUELS (P) LTD.,DEHRADUN vs. DCIT, DEHRADUN

In the result, appeal of the assessee stands partly allowed for statistical purposes

ITA 213/DDN/2024[2017-18]Status: DisposedITAT Dehradun28 Nov 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalparasnath Fuels Pvt. Ltd., The Dcit, Circle 1(1), 28 Feet Road, Dehradun Vikas Nagar, Vs Dehradun - 248198 Pan-Aaicp2190D Assessee Revenue Assessee By Dr. Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. Revenue By Sh. Amar Pal Singh, Jcit Sr. Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 28.11.2025 Order Per Manish Agarwal, Am, This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appellate Centre [Cit(A), In Short], Dated 08.10.2024 In Appeal No. Nfac/2016-17/10104734 Arising Out Of The Order Passed U/S 147 Of The Income Tax Act, 1961 (‘The Act’) Dt. 08.10.2024 For Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: 1. That Having Regard To The Facts & Circumstances Of The Case, Assumption Of Jurisdiction In Initiating The Proceedings U/S 147 & Passing The Impugned Order U/S 147/144B & That Too Without Complying With Mandatory Conditions U/S 147 To 151A Parasnath Fuels Pvt.Ltd. Vs. Dcit

Section 115BSection 147Section 234ASection 68

147 and passing the impugned order u/s 147/144B, is illegal, bad in law and against the facts and circumstances of the case and the same is not sustainable on legal and factual grounds. 3. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action

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

ADIT, DEHRADUN vs. M/S. DAELIM INDUSTRIAL CO. LTD., DEHRADUN

In the result, appeal of the Revenue is allowed for statistical purpose

ITA 171/DEL/2013[2003-04]Status: DisposedITAT Dehradun31 Oct 2023AY 2003-04

Bench: Shri Challa Nagendra Prasada N D Shri M. Balaganesh

For Appellant: Shri Mayank Kumar
Section 143(3)Section 147

reassessment cannot be challenged on ground of change of opinion. iv. Whether on the facts and circumstances of the case the CIT (A) has erred in relying upon the order of the Hon'ble Court of Uttarakhand quashing the initiation of proceedings u/s 147 when it is distinguishable on facts. v. Whether on the facts and circumstances of the case