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1,450 results for “reassessment u/s 147”+ Section 2(22)(e)clear

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Key Topics

Section 147111Section 14868Addition to Income57Section 143(3)55Section 6838Section 153A33Section 143(2)33Reassessment29Section 153D

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)

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 for the AO to believe

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

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.

Showing 1–20 of 1,450 · Page 1 of 73

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27
Section 13226
Reopening of Assessment26
Search & Seizure24
Bench:
Section 147Section 148Section 2Section 2(22)Section 2(22)(e)

reassessment\nfrom AY 2004-05 to 2007-08 and additions in all amounting to Rs.\n18,94,69,803/- were made u/s 2 (22) (e), which were confirmed by CIT\n(Appeal) - 7 in February 2015 in all four cases.\n5. All four following appeals of the Appellant were represented by the same\nprevious counsel, who had represented the appeals

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)

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 for the AO to believe

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)

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 for the AO to believe

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)

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 for the AO to believe

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)

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 for the AO to believe

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

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)

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 of the Income

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)

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 of the Income

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)

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 of the Income

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)

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 of the Income

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)

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 of the Income

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)

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 of the Income

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)

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 of the Income

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)

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 of the Income

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)

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 of the Income

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)

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 of the Income

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

u/s 2 (22) (e) of the Act. 5.9 After due consideration of the facts it is held that the AO has rightly made the addition invoking the provision of section 2(22) (e) of the I.T. Act and treating the amount of Rs. 18.75 crore as deemed dividend in the hands of the appellant Sh. Anil Nanda.” 10 8. Aggrieved

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

ASHWANI KAPOOR,NEW DELHI vs. ITO, NEW DELHI

Appeal of the assessee is allowed

ITA 808/DEL/2013[2009-10]Status: DisposedITAT Delhi09 Nov 2017AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishiashwani Kapoor, Vs. Ito, A-44, Kailash Colony, Ward-3(2), New Delhi New Delhi Pan:Aigpk9963L (Appellant) (Respondent) Acit, Vs. Ashwani Kapoor, Circle-6(1), A-44, Kailash Colony, New Delhi New Delhi Pan:Aigpk9963L (Appellant) (Respondent) Assessee By : Shri K Sampath, Adv Revenue By: Shri Rc Pandey, Sr. Dr Date Of Hearing 28/08/2017 Date Of Pronouncement 09/11/2017

For Appellant: Shri K Sampath, AdvFor Respondent: Shri RC Pandey, Sr. DR
Section 143(3)Section 147Section 2(22)Section 2(22)(e)

reassessment proceedings. The assessee submitted that the above sum was received by assessee for advance against sale of property at basement of A-44, Kailash Colony, New Delhi and therefore, it is a business transaction hence, provisions of section 2(22)(e) of the Act do not apply. The ld Assessing Officer rejected the contention of the assessee and treated

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 proceedings under Section 147 of the Act upheld by the learned Commissioner of Income Tax (Appeals). This ground was not argued before us and, therefore, we dismiss it as infructuous. 8. In grounds no. 2 to 4, the assessee has challenged the addition of deemed dividend under Section 2(22)(e) of the Act in the hands