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357 results for “reassessment u/s 147”+ Section 171clear

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Key Topics

Section 148150Section 153D92Section 14784Section 6873Section 153A67Addition to Income66Section 143(3)56Section 143(2)48Section 148A

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

reassessment stating that the notice u/s\n143(2) dated 18.05.2014 & 22.12.2014 have become time barred u/s\n153(2) of the I.T.Act. Further, assessee stating in its reply that the notice\nu/s 148 was issued on 10.03.2013 therefore the assessment order u/s\n148 of the I.T.Act should have been passed within one year from the\nend of Financial Year in which

DCIT, NEW DELHI vs. M/S. DHARAMPAL SATYAPAL LTD., DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 5611/DEL/2013[2004-05]Status: DisposedITAT Delhi08 Jan 2016AY 2004-05

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Showing 1–20 of 357 · Page 1 of 18

...
44
Search & Seizure29
Reassessment28
Limitation/Time-bar24
For Appellant: Shri R.S. Singhvi, CA and Shri Satyajeet Goel, CAFor Respondent: Ms. Nandita Kanchan, CIT DR
Section 115JSection 132Section 143(3)Section 14ASection 264Section 80I

reassessment is sought Held "............. There is no requirement in any of the provisions of the Act or any section laying down as a condition for the initiation of the proceedings that the reasons which induced the CIT to accord sanction to proceed under s. 34 must also be communicated to the assessee. The requirement regarding the communication of the reasons

M/S. DHARAMPAL SATYAPAL LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 5581/DEL/2013[2004-05]Status: DisposedITAT Delhi08 Jan 2016AY 2004-05

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

For Appellant: Shri R.S. Singhvi, CA and Shri Satyajeet Goel, CAFor Respondent: Ms. Nandita Kanchan, CIT DR
Section 115JSection 132Section 143(3)Section 14ASection 264Section 80I

reassessment is sought Held "............. There is no requirement in any of the provisions of the Act or any section laying down as a condition for the initiation of the proceedings that the reasons which induced the CIT to accord sanction to proceed under s. 34 must also be communicated to the assessee. The requirement regarding the communication of the reasons

ACIT CIRCLE-59(1), NEW DELHI vs. NEERAJ KUMAR SINGHAL, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 283/DEL/2021[2009-10]Status: DisposedITAT Delhi13 Sept 2023AY 2009-10

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

For Appellant: Shri Shri Amit Goel, CAFor Respondent: Ms. Smita Singh, Sr.DR
Section 139Section 143(3)Section 147Section 148Section 151(1)

reassessment proceedings initiated by the AO is bad in law and void ab initio, therefore, the same is quashed.” 10. The genesis of the controversy towards jurisdiction in the present case are the reasons recorded under Section 148(2) of the Act therefore, it may be relevant to reproduce the reasons recorded for ready reference. “Reasons for the belief that

BSES YAMUNA POWER LTD.,NEW DELHI vs. DCIT, CIRCLE- 5(1), NEW DELHI

The appeal of the assessee is allowed on legal issues

ITA 4852/DEL/2017[2007-08]Status: DisposedITAT Delhi16 Apr 2025AY 2007-08

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

u/s 148 which are as under: GOA No. 3 to 3.4-Validity of re-assessment proceedings 24. In the present case, reassessment proceedings under section 147/148 of the Act were initiated by the assessing officer vide notice dated 31.03.2014, ie, much beyond the period of 4 years and almost at the fag-end of the overall limitation period

BSES YAMUNA POWER LTD,DELHI vs. ACIT, CIRCLE-5(1), NEW DEL;HI

The appeal of the assessee is allowed on legal issues

ITA 4853/DEL/2017[2008-09]Status: DisposedITAT Delhi16 Apr 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

u/s 148 which are as under: GOA No. 3 to 3.4-Validity of re-assessment proceedings 24. In the present case, reassessment proceedings under section 147/148 of the Act were initiated by the assessing officer vide notice dated 31.03.2014, ie, much beyond the period of 4 years and almost at the fag-end of the overall limitation period

JINDAL STEEL & POWER LTD.,DELHI vs. DCIT, GURGAON

In the result, the appeal filed by the assessee is allowed for statistical

ITA 6698/DEL/2016[2005-06]Status: DisposedITAT Delhi08 Jun 2018AY 2005-06

Bench: Shri R. K. Panda & Smt. Beena A. Pillaiassessment Year : 2005-06 Jindal Steel & Power Ltd., Dcit, Circle- 1(1), Jindal Centre, Gurgaon. 12, Bhikaji Cama Place, Vs. Delhi.

For Appellant: Shri Ajay Vohra, Sr. Adv
Section 143(3)Section 147Section 263Section 80I

u/s 263 for the impugned assessment year, ld. counsel for the assessee submitted that the reassessment order was set aside by the CIT exercising revisionary jurisdiction under section 263 to the limited extent of examining issues relating to deduction under sections 80lA/80IB of the Act. In other words, the reassessment order dated 04.03.2013 under section 147

ADDL. CIT, NEW DELHI vs. M/S. IRCON INTERNATIONAL LTD., NEW DELHI

In the result, the appeal of the Revenue is accordingly dismissed

ITA 3768/DEL/2017[2009-10]Status: DisposedITAT Delhi22 Jan 2021AY 2009-10

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

Section 143(3)Section 148

u/s 147 within the period of four years from the end of relevant assessment year, even if there is a full and true disclosure of all material facts in the original assessment’ The relevant finding of the Hon’ble High Court is reproduced as under: “7. The crucial expression is "reason to believe". The expression predicates that AO must hold

LASCO CHEMIE PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD-15(2), NEW DELHI, DELHI

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

ITA 3811/DEL/2025[2012-13]Status: DisposedITAT Delhi08 Apr 2026AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarlasco Chemie Private Vs. Income Tax Officer, Limited, Ward-15(2), Delhi 10489 Kalptaru, Sadar Thana Road Motia Khan, New Delhi 110055 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcl 3502 E Appellant .. Respondent

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 147Section 148Section 149Section 151Section 250

147 cannot be regarded as having been validly initiated unless P a g e | 17 Lasco Chemie (P) Ltd. (AY 2012-13) reasons recorded for initiating the proceedings are served on the assessee within the period of limitation prescribed in section 149 of the Act, i.e, before the expiry of six years from the end of the relevant assessment year

DCIT, NEW DELHI vs. M/S. LANDBASE INDIA LTD, NEW DELHI

In the result, cross objections of the

ITA 3549/DEL/2009[2001-02]Status: DisposedITAT Delhi15 Jun 2016AY 2001-02

Bench: Shri Chandra Mohan Garg & Shri L.P. Sahu

For Appellant: Shri Rohit Jain, AdvFor Respondent: Smt. Sulekha Verma, CIT-DR
Section 143(3)Section 147Section 148

section 147 of the Act and consequently the assessment order was illegal and bad in law. The ld. AR reiterating his written submissions dated 28.10.2015 also contended that the reassessment proceedings were initiated by the AO on a mere change of opinion and there was no failure on the part of the assessee to disclose truly and fully all material

DCIT, NEW DELHI vs. M/S. LANDBASE INDIA LTD., NEW DELHI

In the result, cross objections of the

ITA 4847/DEL/2009[2003-04]Status: DisposedITAT Delhi15 Jun 2016AY 2003-04

Bench: Shri Chandra Mohan Garg & Shri L.P. Sahu

For Appellant: Shri Rohit Jain, AdvFor Respondent: Smt. Sulekha Verma, CIT-DR
Section 143(3)Section 147Section 148

section 147 of the Act and consequently the assessment order was illegal and bad in law. The ld. AR reiterating his written submissions dated 28.10.2015 also contended that the reassessment proceedings were initiated by the AO on a mere change of opinion and there was no failure on the part of the assessee to disclose truly and fully all material

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

In the result, appeals filed by the assessee are allowed

ITA 2936/DEL/2023[2015-16]Status: DisposedITAT Delhi30 Aug 2024AY 2015-16

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

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

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

In the result, appeals filed by the assessee are allowed

ITA 2938/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Aug 2024AY 2017-18

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

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

In the result, appeals filed by the assessee are allowed

ITA 2935/DEL/2023[2014-15]Status: DisposedITAT Delhi30 Aug 2024AY 2014-15

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

M/S. LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT (INTERNATIONAL TAXATION), NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

ITA 1946/DEL/2017[2007-08]Status: HeardITAT Delhi02 Sept 2019AY 2007-08

Bench: Smt Diva Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G. K. Dhall, CIT DR
Section 143(3)Section 147

171 (Delhi - Trib.). 3. That without prejudice to the above the conclusions of the AO / DRP are patently erroneous given that all transactions between the two companies were uninfluenced by their relationship and had met the Arm’s Length Price test in terms of Transfer Pricing Assessment. 4. That without prejudice the AO / DRP also erred in ignoring the provision

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

ITA 3327/DEL/2018[2013-14]Status: HeardITAT Delhi02 Sept 2019AY 2013-14

Bench: Smt Diva Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G. K. Dhall, CIT DR
Section 143(3)Section 147

171 (Delhi - Trib.). 3. That without prejudice to the above the conclusions of the AO / DRP are patently erroneous given that all transactions between the two companies were uninfluenced by their relationship and had met the Arm’s Length Price test in terms of Transfer Pricing Assessment. 4. That without prejudice the AO / DRP also erred in ignoring the provision

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- NOIDA, INTERNATIONAL TAXATION, NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

ITA 6916/DEL/2017[2008-09]Status: HeardITAT Delhi02 Sept 2019AY 2008-09

Bench: Smt Diva Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G. K. Dhall, CIT DR
Section 143(3)Section 147

171 (Delhi - Trib.). 3. That without prejudice to the above the conclusions of the AO / DRP are patently erroneous given that all transactions between the two companies were uninfluenced by their relationship and had met the Arm’s Length Price test in terms of Transfer Pricing Assessment. 4. That without prejudice the AO / DRP also erred in ignoring the provision

BALLU SINGH,GURGAON vs. ITO WARD -65(5), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 799/DEL/2020[2008-09]Status: DisposedITAT Delhi15 May 2023AY 2008-09

Bench: Shri Kul Bharat

Section 133(6)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 44ASection 69A

reassessment or computation of income u/s 147. As per section 148, it is mandatory that the Assessing Officer shall serve on the assessee a notice required him to furnish a return. The expression “Assessing Officer” used in the section 148 means ‘the Assessing Officer vested with the jurisdiction over the assessee as stipulated in the definition u/s

BALLU SINGH,GURGAON vs. ITO WARD -65(5), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 800/DEL/2020[2009-10]Status: DisposedITAT Delhi15 May 2023AY 2009-10

Bench: Shri Kul Bharat

Section 133(6)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 44ASection 69A

reassessment or computation of income u/s 147. As per section 148, it is mandatory that the Assessing Officer shall serve on the assessee a notice required him to furnish a return. The expression “Assessing Officer” used in the section 148 means ‘the Assessing Officer vested with the jurisdiction over the assessee as stipulated in the definition u/s