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402 results for “reassessment u/s 147”+ Section 145(2)clear

Sorted by relevance

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Key Topics

Section 147105Section 148104Section 6894Addition to Income74Section 143(3)70Section 153A59Section 153C50Section 143(2)32Reassessment

M/S. INDIA EXPOSITION MART LTD.,NEW DELHI vs. DCIT, NEW DELHI

ITA 1079/DEL/2016[2009-10]Status: DisposedITAT Delhi12 Aug 2025AY 2009-10
Section 139(1)Section 147Section 148

145.\nIn view of above submission & case laws favoring assessee. We pray\nyour honor to quash proceedings undersea 147/148 Income Tax Act\"\n4.\nThere is infact only one ground of appeal and that is against the\nreopening of assessment u/s 147. The main argument of the appellant\nrevolves around the fact that full details of the expenses of Phase

VINOD MONGIA,WAST AZAD NAGAR, DELHI vs. INCOME TAX OFFICER , VIKAS BHAWAN,DELHI

In the result, the appeal of the assessee is allowed

ITA 1844/DEL/2024[2012-2013]Status: DisposedITAT Delhi31 Jul 2025AY 2012-2013

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2012-13] Vinod Mongia, Vs Ito, C-40, Street No.1A, West Ward-58(7), Azad Nagar, Delhi-110005. Vikas Bhawan, Pan-Akhpm6218R Delhi Appellant Respondent Appellant By Shri Shivam Jain, Adv. & Shri Nitin Kanwar, Adv. Respondent By Shri Om Parkash, Sr. Dr Date Of Hearing 14.05.2025 Date Of Pronouncement 31.07.2025

Showing 1–20 of 402 · Page 1 of 21

...
31
Section 15129
Search & Seizure26
Reopening of Assessment21
Section 143Section 143(2)Section 147Section 148Section 250Section 68

145 shall, so far as may be, apply." An analysis of this sub section indicates that, after the return is filed, this clause enables the assessing officer to complete the assessment by following the procedure like issue of notice under Sections 143(2)/142 and complete the assessment under Section 143(3). This Section does not provide for accepting

CAIRN UK HOLDING LTD.,AHMEDABAD vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result ground No. 5 of the appeal of the assessee is allowed

ITA 1669/DEL/2016[2007-08]Status: DisposedITAT Delhi09 Mar 2017AY 2007-08

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

For Appellant: Shri Percy Pardiwala Sr. AdvFor Respondent: Shri Sanjay Puri CIT
Section 143(3)Section 144

2)/2Q13-14/453 dated ' 25.02.2014" (Emphasis added) 6.8 Further, in the said reasons, at various places reference was given of the February 2014. This goes to prove that the survey report was received by the AO in the month of February 2014 only. 6.9 In view of the above, the Appellant submits that since the survey report had been received

SUNRISE PROPBUILD PVT LTD.,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

ITA 1258/DEL/2025[2012-13]Status: DisposedITAT Delhi26 Nov 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1258/Del/2025 (A.Y. 2012-13) M/S Sunrise Propbuild Pvt. Ltd. V Assistant Commissioner Of House No. B-4, 1St Floor, Shop S Income Tax, Central Circle-Ii, No. 25, Ashirward Complex, Faridabad, Village Pitampura, New Delhi- Haryana-121001 110034 Pan: Aapcs2201K Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 26/11/2025

Section 143(2)Section 147Section 148Section 151Section 153C

reassessment Sunrise Propbuild Pvt. Ltd. Vs. ACIT proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances of the case, the Ld. CIT-(A) has erred in upholding the order of Ld. A.O without considering the fact that the reasons u/s 148 were recorded merely

SUNRISE PORPBUILD PVT LTD,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

ITA 1257/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1258/Del/2025 (A.Y. 2012-13) M/S Sunrise Propbuild Pvt. Ltd. V Assistant Commissioner Of House No. B-4, 1St Floor, Shop S Income Tax, Central Circle-Ii, No. 25, Ashirward Complex, Faridabad, Village Pitampura, New Delhi- Haryana-121001 110034 Pan: Aapcs2201K Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 26/11/2025

Section 143(2)Section 147Section 148Section 151Section 153C

reassessment Sunrise Propbuild Pvt. Ltd. Vs. ACIT proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances of the case, the Ld. CIT-(A) has erred in upholding the order of Ld. A.O without considering the fact that the reasons u/s 148 were recorded merely

ANIL KUMAR JAIN,NEW DELHI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-26, JHANDEWALAN, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 475/DEL/2025[2013-14]Status: DisposedITAT Delhi16 Jan 2026AY 2013-14

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(1)Section 143(3)Section 147Section 148Section 151

reassessment u/s 148 qua genuineness of unsecured loan as well as purchases disclosed, considered and accepted during the original assessment under Section 143(3) of the Income Tax Act, 1961 for AY 2013-14 2. On the facts and circumstances of the case, the impugned order dated 10th December 2024 passed by the CIT(A) as well as order dated

ADDL.CIT, SPECIAL RANGE-18, NEW DELHI vs. JAGANANTH HEMCHAND JAIN, NEW DELHI

In the result, the appeal of the Revenue as well as Cross Objection of the assessee is dismissed

ITA 7754/DEL/2018[2010-11]Status: DisposedITAT Delhi29 Feb 2024AY 2010-11

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

Section 143(3)Section 145(3)Section 147Section 148Section 148(2)Section 69C

2. We shall first refer to appeal of the Revenue in ITA No.7755/Del/2018 relevant to Assessment Year 2011-12 as adverted in the course of hearing. The Cross Objection thereon in CO No.16/Del/2023 filed by assessee seeking to raise jurisdictional infirmities in the action of Assessing Officer shall also be adverted simultaneously. 3. The grounds raised by the Revenue read

ADDL.CIT, SPECIAL RANGE-18, NEW DELHI vs. JAGANANTH HEMCHAND JAIN, NEW DELHI

In the result, the appeal of the Revenue as well as Cross Objection of the assessee is dismissed

ITA 7755/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Feb 2024AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

Section 143(3)Section 145(3)Section 147Section 148Section 148(2)Section 69C

2. We shall first refer to appeal of the Revenue in ITA No.7755/Del/2018 relevant to Assessment Year 2011-12 as adverted in the course of hearing. The Cross Objection thereon in CO No.16/Del/2023 filed by assessee seeking to raise jurisdictional infirmities in the action of Assessing Officer shall also be adverted simultaneously. 3. The grounds raised by the Revenue read

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1344/DEL/2024[2013-14]Status: DisposedITAT Delhi13 Sept 2024AY 2013-14

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

147 and 148 of the Act as existed earlier and which have been brought back into the statute w.e.f. 01/04/2021 were sufficient to take care of the assessments in consequence to an income-tax search. The Legislature in its wisdom carved out special provisions for such assessments w.e.f. 01/06/2003 till 20 ITAs No.1342, 1343, 1344, 1345, 1346, 1347 & 1348/DEL/2024 31/03/2021

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-I, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1348/DEL/2024[2018-19]Status: DisposedITAT Delhi13 Sept 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

147 and 148 of the Act as existed earlier and which have been brought back into the statute w.e.f. 01/04/2021 were sufficient to take care of the assessments in consequence to an income-tax search. The Legislature in its wisdom carved out special provisions for such assessments w.e.f. 01/06/2003 till 20 ITAs No.1342, 1343, 1344, 1345, 1346, 1347 & 1348/DEL/2024 31/03/2021

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1347/DEL/2024[2016-17]Status: DisposedITAT Delhi13 Sept 2024AY 2016-17

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

147 and 148 of the Act as existed earlier and which have been brought back into the statute w.e.f. 01/04/2021 were sufficient to take care of the assessments in consequence to an income-tax search. The Legislature in its wisdom carved out special provisions for such assessments w.e.f. 01/06/2003 till 20 ITAs No.1342, 1343, 1344, 1345, 1346, 1347 & 1348/DEL/2024 31/03/2021

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1343/DEL/2024[2012-13]Status: DisposedITAT Delhi13 Sept 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

147 and 148 of the Act as existed earlier and which have been brought back into the statute w.e.f. 01/04/2021 were sufficient to take care of the assessments in consequence to an income-tax search. The Legislature in its wisdom carved out special provisions for such assessments w.e.f. 01/06/2003 till 20 ITAs No.1342, 1343, 1344, 1345, 1346, 1347 & 1348/DEL/2024 31/03/2021

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1342/DEL/2024[2011-12]Status: DisposedITAT Delhi13 Sept 2024AY 2011-12

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

147 and 148 of the Act as existed earlier and which have been brought back into the statute w.e.f. 01/04/2021 were sufficient to take care of the assessments in consequence to an income-tax search. The Legislature in its wisdom carved out special provisions for such assessments w.e.f. 01/06/2003 till 20 ITAs No.1342, 1343, 1344, 1345, 1346, 1347 & 1348/DEL/2024 31/03/2021

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1345/DEL/2024[2014-15]Status: DisposedITAT Delhi13 Sept 2024AY 2014-15

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

147 and 148 of the Act as existed earlier and which have been brought back into the statute w.e.f. 01/04/2021 were sufficient to take care of the assessments in consequence to an income-tax search. The Legislature in its wisdom carved out special provisions for such assessments w.e.f. 01/06/2003 till 20 ITAs No.1342, 1343, 1344, 1345, 1346, 1347 & 1348/DEL/2024 31/03/2021

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1346/DEL/2024[2015-16]Status: DisposedITAT Delhi13 Sept 2024AY 2015-16

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

147 and 148 of the Act as existed earlier and which have been brought back into the statute w.e.f. 01/04/2021 were sufficient to take care of the assessments in consequence to an income-tax search. The Legislature in its wisdom carved out special provisions for such assessments w.e.f. 01/06/2003 till 20 ITAs No.1342, 1343, 1344, 1345, 1346, 1347 & 1348/DEL/2024 31/03/2021

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

ITA 4067/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

147 r.w.s. 143(3) of the Act by the Assessing Officer [“AO”] pertaining to AY 2019-20. ITA Nos.4115 & 4067/Del/2025 2. As the captioned cross-appeals filed by the Revenue and the assessee are having common issues of addition made u/s 68 of the Act, wherein in all the entries of loans received from one company M/s Hallow Securities

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

ITA 4115/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

147 r.w.s. 143(3) of the Act by the Assessing Officer [“AO”] pertaining to AY 2019-20. ITA Nos.4115 & 4067/Del/2025 2. As the captioned cross-appeals filed by the Revenue and the assessee are having common issues of addition made u/s 68 of the Act, wherein in all the entries of loans received from one company M/s Hallow Securities

M/S VEENA ENTERPRISES LTD.,,NEW DELHI vs. ACIT, NEW DELHI

In the result appeal of the assessee is allowed

ITA 2517/DEL/2013[2004-05]Status: DisposedITAT Delhi09 Oct 2015AY 2004-05

Bench: Sh. N. K. Saini, Am & Sh. H. S. Sidhu, Jm Ita No. 2517/Del/2013 : Asstt. Year : 2004-05 M/S Veena Enterprises Ltd., Vs Assistant Commissioner Of 81, Vigyan Vihar, Income Tax, Circle 17(1), New Delhi-110092 New Delhi (Appellant) (Respondent) Pan No. Aaacv3918K Assessee By : Sh. Ajay Vohra, Sr. Adv. Sh. Rohit Garg, Fca Sh. Deepesh Jain, Ca & Sh. Udit Naresh, Adv. Revenue By: Sh. J. P. Chandrakar, Sr. Dr Date Of Hearing : 15.07.2015 Date Of Pronouncement : 09.10.2015 Order Per N.K. Saini, A.M. This Is An Appeal By The Assessee Against The Order Dated 22.01.2013 Of The Ld. Cit(A)-19, New Delhi.

For Appellant: Sh. Ajay Vohra, Sr. Adv. Sh. Rohit Garg, FCAFor Respondent: Sh. J. P. Chandrakar, Sr. DR
Section 147Section 148

section 148 was served and therefore, reassessment deserves to be quashed, is not acceptable.” 11. The reliance was placed on the following case laws: " CIT Vs Jagat Novel Exhibitors (P.) Ltd. (2012) 18 Taxmann.com 138 (Del) " CIT Vs Three Dee Exim P. Ltd. (2012) 20 Taxmann.com 146 (Del) " CIT Vs Vision Inc. (2012) 21 Taxmann.com 515 (Del) " I. M. Constructions

CHARBUJA MARMO (INDIA) PVT. LTD.,DELHI vs. PR.CIT- 2 , NEW DELHI

In the result, appeal of Assessee allowed

ITA 4749/DEL/2019[2010-11]Status: DisposedITAT Delhi31 Dec 2019AY 2010-11

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Ms. Nidhi Srivastava, CIT-DR
Section 143(1)Section 147Section 148Section 151Section 263

u/s 147. The Pr. CIT had given his satisfaction u/s 151 separately as mentioned at page 5 of the paper book filed by the ld. counsel for the assessee. The Assessing Officer, in the instant case, has disposed of the objections by passing a speaking order, therefore, it is wrong to say that the assessment was reopened in a mechanical

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2937/DEL/2023[2016-17]Status: DisposedITAT Delhi30 Aug 2024AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets