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23 results for “reassessment u/s 147”+ Section 50clear

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Key Topics

Section 26332Section 143(3)29Addition to Income21Section 14720Section 15319Section 54B16Section 44B14Section 914Section 148

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

section 147 of the IT Act, 1961. Necessary approval u/s 151(1) of the Act 1961 of the CIT, Dehradun for initiating proceedings u/s 147 has been received vide his office letter F. No. Pr.CIT/DDN/Sct.Appr./148/2014-15/2734 dated 26.03.2015.” 3.1. Thereafter notice u/s 148 was issued on 26th March 2015. The assessee in response to the said notice submitted that

Showing 1–20 of 23 · Page 1 of 2

12
Limitation/Time-bar10
Reassessment5
Natural Justice4

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

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

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

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

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 to section 149 of the Act. 2.1 That the learned Commissioner of Income Tax (Appeals) has further failed to appreciate the fact that the proceedings initiated under section

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

DARIYAV SINGH,DEHRADUN vs. PR. CIT, DEHRADUN

In the result, both the appeals of the assessee are allowed

ITA 2029/DEL/2018[2010-11]Status: DisposedITAT Dehradun28 Jun 2023AY 2010-11

Bench: Shri Saktijit Dey & Shri M. Balaganeshsh. Sanjay Kumar Pr. Cit 170, Vasant Vihar-1 Dehradun Dehradun Vs. Pan-Akkpk 1007F (Appellant) (Respondent) Sh. Dariyav Singh Pr. Cit 28-Chakrata Road, Dehradun Dehradun Vs. Pan-Awkps 6026L (Appellant) (Respondent) Appellant By Dr. Rakesh Gupta & Mr. Sherey Jain, Advocates Respondent By Mr. N.S.Jangpangi, Cit-Dr

Section 143(3)Section 147Section 263Section 54B

50% of share of 1,60,00,000/-) and claimed deduction u/s 54B of the Act. The Ld. A.O. issued notice u/s 148 of the Act on 08/04/2014 for verification of correctness of the capital gain. In response to such notice, the assessee filed his return of income on 09/05/2014 showing the capital gains on sale of agricultural land

SANJAY KUMAR,DEHRADUN vs. PRCIT, DEHRADUN

In the result, both the appeals of the assessee are allowed

ITA 2187/DEL/2018[2010-11]Status: DisposedITAT Dehradun23 Jun 2023AY 2010-11

Bench: Shri Saktijit Dey & Shri M. Balaganeshsh. Sanjay Kumar Pr. Cit 170, Vasant Vihar-1 Dehradun Dehradun Vs. Pan-Akkpk 1007F (Appellant) (Respondent) Sh. Dariyav Singh Pr. Cit 28-Chakrata Road, Dehradun Dehradun Vs. Pan-Awkps 6026L (Appellant) (Respondent) Appellant By Dr. Rakesh Gupta & Mr. Sherey Jain, Advocates Respondent By Mr. N.S.Jangpangi, Cit-Dr

Section 143(3)Section 147Section 263Section 54B

50% of share of 1,60,00,000/-) and claimed deduction u/s 54B of the Act. The Ld. A.O. issued notice u/s 148 of the Act on 08/04/2014 for verification of correctness of the capital gain. In response to such notice, the assessee filed his return of income on 09/05/2014 showing the capital gains on sale of agricultural land

SHRI ABHISHEK JOSHI,DEHRADUN vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX , DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 8/DDN/2021[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

Bench: Sh. Saktijit Dey & Shri M. Balaganeshshri Abhishek Joshi, Vs. The Pr. Cit, C/O. Parimal Patet, Gk Patet & Dehradun Co, 14 Abhishek Tower, Subhash Road, Dehradun (Appellant) (Respondent) Pan: Ajopj4300M Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Aggarwal, Adv Revenue By: Shri N. S. Jangpangi, Cit Dr Date Of Hearing 26/07/2023 Date Of Pronouncement 15/09/2023

For Appellant: Dr. Rakesh gupta, AdvFor Respondent: Shri N. S. jangpangi, CIT DR
Section 143(3)Section 147Section 148Section 263Section 54F

reassessment passed u/s 143(3) rws 147 of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 30.10.2018 by the Assessing Officer, ITO, Ward-1(1), Dehradun (hereinafter referred to as „ld. AO‟). 2. The assessee has raised the following grounds of appeal:- “1. That having regard to the facts and circumstances of the case, Ld. PCIT

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

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

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