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181 results for “reassessment u/s 147”+ Deemed Dividendclear

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Key Topics

Section 14798Section 153A73Addition to Income66Section 14856Section 2(22)(e)45Section 143(3)38Section 13225Section 14A25Section 263

SUDHIR DHINGRA,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

ITA 5721/DEL/2018[2014-15]Status: DisposedITAT Delhi13 Jan 2022AY 2014-15

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

ACIT, CENTRAL CIRCLE-II, GURGAON vs. ANOOP THATAI, NEW DELHI

Showing 1–20 of 181 · Page 1 of 10

...
25
Reassessment22
Disallowance20
Deemed Dividend19

In the result, appeal of the revenue is dismissed

ITA 6362/DEL/2018[2015-16]Status: DisposedITAT Delhi13 Jan 2022AY 2015-16

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

SUDHIR DHINGRA,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

ITA 5722/DEL/2018[2016-17]Status: DisposedITAT Delhi13 Jan 2022AY 2016-17

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

ITA 6361/DEL/2018[2016-17]Status: DisposedITAT Delhi13 Jan 2022AY 2016-17

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

ITA 6358/DEL/2018[2012-13]Status: DisposedITAT Delhi13 Jan 2022AY 2012-13

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

ANOOP THATAI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

ITA 5719/DEL/2018[2014-15]Status: DisposedITAT Delhi13 Jan 2022AY 2014-15

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

ITA 6359/DEL/2018[2013-14]Status: DisposedITAT Delhi13 Jan 2022AY 2013-14

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

ITA 6357/DEL/2018[2011-12]Status: DisposedITAT Delhi13 Jan 2022AY 2011-12

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

ITA 6360/DEL/2018[2015-16]Status: DisposedITAT Delhi13 Jan 2022AY 2015-16

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

ITA 6356/DEL/2018[2010-11]Status: DisposedITAT Delhi13 Jan 2022AY 2010-11

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

Section 132Section 139Section 147Section 153ASection 158BSection 2(22)(e)

deemed dividend u/s 2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A

CHETAN SETH,NEW DELHI vs. ITO,WARD-15(3), DELHI

ITA 1808/DEL/2023[2004-05]Status: DisposedITAT Delhi25 Jun 2025AY 2004-05

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

deemed dividend u/s 2(22)(e) in the hands of the appellant. The CIT(A) had acted in the interest of revenue and had he not come to this conclusion a substantial income would have remained untaxed. 6.7. The appellant has stated that the order u/s 148/143(3) is illegal and without jurisdiction. However, there were sufficient reasons

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

ITA 2983/DEL/2015[2005-06]Status: DisposedITAT Delhi25 Jun 2025AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

deemed dividend u/s 2(22)(e) in the hands of the appellant. The CIT(A) had acted in the interest of revenue and had he not come to this conclusion a substantial income would have remained untaxed. 6.7. The appellant has stated that the order u/s 148/143(3) is illegal and without jurisdiction. However, there were sufficient reasons

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

ITA 2985/DEL/2015[2007-08]Status: DisposedITAT Delhi25 Jun 2025AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

deemed dividend u/s 2(22)(e) in the hands of the appellant. The CIT(A) had acted in the interest of revenue and had he not come to this conclusion a substantial income would have remained untaxed. 6.7. The appellant has stated that the order u/s 148/143(3) is illegal and without jurisdiction. However, there were sufficient reasons

ISWAR CHAND DUBEY,DELHI vs. ITO,WARD-68 (1), DELHI

ITA 2985/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

deemed dividend u/s 2(22)(e) in the hands of the appellant. The CIT(A) had acted in the interest of revenue and had he not come to this conclusion a substantial income would have remained untaxed. 6.7. The appellant has stated that the order u/s 148/143(3) is illegal and without jurisdiction. However, there were sufficient reasons

PUNIT KUMAR AGGARWAL,DELHI vs. ITO,WARD-36(2), DELHI

ITA 2983/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

deemed dividend u/s 2(22)(e) in the hands of the appellant. The CIT(A) had acted in the interest of revenue and had he not come to this conclusion a substantial income would have remained untaxed. 6.7. The appellant has stated that the order u/s 148/143(3) is illegal and without jurisdiction. However, there were sufficient reasons

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

The appeals of the assessee are partly allowed

ITA 2984/DEL/2015[2006-07]Status: DisposedITAT Delhi25 Jun 2025AY 2006-07

Bench: Shri Satbeer Singh Godara\Nand\Nshri Brajesh Kumar Singh\Nita Nos.1808/Del/2023 & 2983, 2984 & 2985/Del/2015\N[Assessment Years: 2004-05, 2005-06, 2006-07 & 2007-08]\Nshri Chetan Seth,\Nplot No.14, Lcs, Sector-B-1,\Nvasant Kunj,\Nnew Delhi-110070\Npan-Aolps2992A\Nappellant\Nincome Tax Officer,\Nward-15(3),\Nvs New Delhi\Nrespondent\Nappellant By\Nrespondent By\Nshri Arun Kishore, Ca &\Nshri Alok Suri, Ca\Nshri Rajesh Kumar Dhanesta, Sr.\N(Dr)\Ndate Of Hearing\Ndate Of Pronouncement\N28.03.2025\N25.06.2025\Norder\Nper Brajesh Kumar Singh, Am,\Nthese Four Appeals Filed By The Assessee Are Directed Against The\Norder Of Ld. Commissioner Of Income Tax (Appeals)-7, Delhi, Dated\N24.02.2015 For Ay 2004-05, 27.02.2015 For Ay 2005-06, 2006-07 And\N2007-08 Respectively Arising Out Of Assessment Orders Passed U/S 147/144\Nof The Income Tax Act, 1961 (Hereinafter Referred To ‘The Act') Dated\N31.10.2011 For All The Above Assessment Years, Respectively. Since, The\Nissues Are Common & Connected, Hence, These Appeals Were Heard\Ntogether & Are Disposed Of By This Common Order.\N2. First, We Shall Take Up The Ita No.1808/Del/2023 Pertaining To Ay\N2004-05.\N2.

Section 147Section 148Section 2Section 2(22)Section 2(22)(e)

deemed dividend u/s 2(22)(e) of the Act but has directed to make\nthe addition in the hands of Shri Chetan Seth, being the common director of both these\ncompanies and having the majority of the shareholding therein i.e. 54.2% and 28% of shares of\nrelied upon the decision of the Hon'ble Delhi High Court in the case

LATE RAMESH CHAND GOYAL,NEW DELHI vs. ITO, NEW DELHI

In the result, the appeal is allowed in part for statistical purposes

ITA 1187/DEL/2014[2009-10]Status: DisposedITAT Delhi15 Feb 2017AY 2009-10

Bench: Sh. S.K. Yadav & Sh. O.P. Kantassessment Year: 2009-10 Vs. Income Tax Officer, Ward-24(4), Late Ramesh Chand Goyal Through L/H Smt. Manorma New Delhi Goyal, A-15/5, Vasant Vihar, New Delhi Pan : Aagpg7119L (Appellant) (Respondent) Appellant By Sh. M.L. Dua, Adv. Respondent By Sh. F.R. Meena, Sr.Dr Date Of Hearing 11.01.2017 Date Of Pronouncement 15.02.2017 Order Per O.P. Kant, A.M.:

Section 143(1)Section 143(2)Section 147Section 148Section 2(22)Section 2(22)(e)

reassessment under Section 147 and within jurisdiction of the ITO. 2. That learned CIT (A) erred in holding that the ITO was not bound to follow the instructions contained in CBDT's Circular No. 495 dated 22.9.1987 to the effect that deemed dividend in cases where loans/advances were made to other concerns/firms etc. would be taxed in the hands

ACIT, NEW DELHI vs. MRS. SEEMA DEVI BANSAL, NEW DELHI

In the result, the Revenue’s appeal stands dismissed

ITA 6462/DEL/2014[2010-11]Status: DisposedITAT Delhi18 Jul 2018AY 2010-11

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

For Appellant: Sh. Ved Jain, AdvFor Respondent: Sh. K. Tewari, Sr. DR
Section 142(1)Section 143(1)Section 143(3)Section 148Section 2Section 2(22)(e)

u/s 2(22)(e) of the Act. He has deleted the addition on the grounds that the said amount was advanced for the business purposes and hence a commercial transaction not covered within the meaning of deemed dividend under section 2(22)(e) of the Act. 5. It was explained to the AO that the companies have received the money

SHRI ANIL NANDA,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal filed by the assessee is dismissed

ITA 3318/DEL/2017[2007-08]Status: DisposedITAT Delhi18 Aug 2021AY 2007-08

Bench: Shri R.K. Panda & Shri Kuldip Singhassessment Year: 2007-08 Anil Nanda, Vs Dcit, 12-C, Friends Colony, Circle-68(1), New Delhi. New Delhi. Pan Aafpn4381A (Appellant) (Respondent) Assessee By : Shri Deepak Ostwal, Ca Revenue By : Shri Satpal Gulati, Cit, Dr Date Of Hearing : 02.06.2021 Date Of Pronouncement : 18.08.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31St March, 2017 Of The Cit(A)-32, New Delhi Relating To Assessment Year 2007-08. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & It Filed Its Return Of Income On 30Th July, 2007 Declaring Total Income At Rs.8,25,64,675/-. The Assessment Was Completed U/S 143(3) Of The Act On 30Th October, 2009 Accepting The Returned Income. Subsequently, The Ao Reopened The Assessment U/S 147 Of The It Act, 1961 After Recording The Following Reasons:-

For Appellant: Shri Deepak Ostwal, CAFor Respondent: Shri Satpal Gulati, CIT, DR
Section 143(3)Section 147Section 148Section 151Section 2(22)(e)Section 246

Deemed Dividend Dividend 29 G I Power Corporation Ltd,, ITAT ICD is different from loan and 419-435 New ... vs Assessee I.T.A No. Amritsar cannot be treated as a loan 305(Asr)/2014 Date of Order 23/03/2016 30 United Electrical Co. (P) Ltd. Delhi High Approval by Commissioner 436-444 vs Cit & Ors Equivalent Court u/s 151 must be with

HARMANDER SINGH SRAN,NEW DELHI vs. ACIT, CC- 29, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 4018/DEL/2017[2012-13]Status: DisposedITAT Delhi14 Aug 2025AY 2012-13
Section 10(34)Section 115Section 139(1)Section 147Section 148Section 2(22)(e)Section 250

u/s 147 r.w.s.143(3) of the Act\npertaining to assessment year 2012-13.\n\n2. Brief facts of the case are that assessee is an individual, filed\nhis return of income on 30.07.2012, declaring income of INR\n30,42,800/-. The assessee is Director of M/s HBN Dairies & Allied\nLtd. wherein he is having share holding