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1,270 results for “reassessment u/s 147”+ Section 32clear

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Key Topics

Section 147139Section 143(3)116Section 14894Addition to Income63Section 6846Reassessment46Section 153C36Reopening of Assessment32Section 153A

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 order u/s 147 dated 18.02.2015\n4\nCopy of Regular/ Original Assessment Order Dt. 09.12.2011\n5\nCopy of Form 35 B with Statement of Facts and Ground of\nAppeal filled with CIT (A)\n6\nCopy of Representation before CIT(A)-4 dated 29/10/15\n7\nCopy of Notice under section 148 Dated 11/03/2013 issued by\nDCIT Cir 11(1)\n8\nLetter

MAHESH KUMAR,DELHI vs. ITO,WARD-68(6), DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2650/DEL/2024[2012-13]Status: DisposedITAT Delhi06 Aug 2025AY 2012-13

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Showing 1–20 of 1,270 · Page 1 of 64

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Section 26321
Section 271(1)(c)18
Search & Seizure17
Section 10(38)Section 143(3)Section 147Section 148Section 68

32. Explanation 3, cannot consequently be read as enabling the AO to attempt to either deviate from the reasons originally recorded for initiating action under Section 147/148 of the Act nor can those Explanations be read as empowering the AO to improve upon, supplement or supplant the reasons which formed the bedrock for initiation of action under the aforenoted provisions

INCOME TAX OFFICER, WARD 3(1), DELHI, DELHI vs. ARTISTIC FINANCE PRIVATE LIMITED, DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2650/DEL/2023[2014-15]Status: DisposedITAT Delhi08 May 2025AY 2014-15

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 10(38)Section 143(3)Section 147Section 148Section 68

32. Explanation 3, cannot consequently be read as enabling the AO to attempt to either deviate from the reasons originally recorded for initiating action under Section 147/148 of the Act nor can those Explanations be read as empowering the AO to improve upon, supplement or supplant the reasons which formed the bedrock for initiation of action under the aforenoted provisions

SHYAM PRODUCTS P.LTD,NEW DELHI vs. ITO, WARD-23(3), NEW DELHI

In the result, appeal of the assessee is partly allowed as indicated above

ITA 4908/DEL/2018[2007-08]Status: DisposedITAT Delhi31 Jan 2023AY 2007-08

Bench: Shri Challa Nagendra Prasad, S.M.C.

For Appellant: Shri Suresh Kumar GuptaFor Respondent: Sr. D. R
Section 147Section 148Section 271Section 68Section 69C

reassessment proceedings based on Non-existing provision of law and also errors contained in the performa: Non application of mind is discernible from the performa (PB 14) filed by the Ld AO to take approval from the appropriate authority vls 151. Kindly refer question in item No.7 which says "Whether the provisions of sec. 147(a) or 147(b) applicable

OPTIMIST ELECTRONICS P.LTD,NEW DELHI vs. ITO, WARD-19(2), NEW DELHI

In the result, appeal of the assessee is partly allowed as indicated above

ITA 4907/DEL/2018[2008-09]Status: DisposedITAT Delhi31 Jan 2023AY 2008-09

Bench: Shri Challa Nagendra Prasad, S.M.C.

For Appellant: Shri Suresh Kumar GuptaFor Respondent: Sr. D. R
Section 147Section 148Section 271Section 68Section 69C

reassessment proceedings based on Non-existing provision of law and also errors contained in the performa: Non application of mind is discernible from the performa (PB 14) filed by the Ld AO to take approval from the appropriate authority vls 151. Kindly refer question in item No.7 which says "Whether the provisions of sec. 147(a) or 147(b) applicable

HURON BUILDERS PVT LTD,NEW DELHI vs. ITO WARD - 6(1), NEW DELHI

In the result the appeal is allowed on this preliminary

ITA 6251/DEL/2019[2013-14]Status: DisposedITAT Delhi03 Oct 2019AY 2013-14

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Shri S.K. Garg, Adv. & Shri AkarshFor Respondent: Ms. Sugandha Sharma, Sr.D.R
Section 147Section 148Section 68

32 I.T.A. No.6251/DEL/2019 assessee, and quite rightly, is that if the Revenue wants to invoke section 147 it should play by the rules of that section and cannot bog down. In other words, the expression “reason to believe” cannot have two different standards or sets of meaning, one applicable where the assessment was earlier made under section

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

147 and more when burden to prove the addition u/s 80IA(8) and 80IA(10) was on the revenue. 17. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in rejecting the audit report u/s 10CCB and that too without

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

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

147 and more when burden to prove the addition u/s 80IA(8) and 80IA(10) was on the revenue. 17. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in rejecting the audit report u/s 10CCB and that too without

PITNEY BOWES INDIA (P) LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, out of the five appeals of the assessee, the ITA Nos

ITA 289/DEL/2013[2005-06]Status: DisposedITAT Delhi29 May 2017AY 2005-06

Bench: Sh. I.C. Sudhir & Sh. O.P. Kant

Section 143(3)Section 147Section 32

section 143(3) of the Act on 09/12/2011 after disallowing depreciation on government approvals and rejecting the claim of depreciation on non-compete fee. In the appeal filed before the ld. CIT- (A), the assesee challenged validity of reassessment proceeding and contested disallowance made by the Assessing Officer. The assessee also raised additional ground seeking depreciation on goodwill

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

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

PASSION REALTECH PVT LTD,GURGAON vs. ;ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

ITA 1269/DEL/2025[2012-13]Status: DisposedITAT Delhi26 Nov 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

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

reassessment 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. AO without considering the fact that the reasons u/s 148 were recorded merely on the basis of suspicion

PASSION REALTECH PVT LTD,GURGAON vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

ITA 1268/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

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

reassessment 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. AO without considering the fact that the reasons u/s 148 were recorded merely on the basis of suspicion

RUBY SINGH ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2876/DEL/2022[2014-15]Status: DisposedITAT Delhi29 Sept 2023AY 2014-15

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2875/DEL/2022[2013-14]Status: DisposedITAT Delhi29 Sept 2023AY 2013-14

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2880/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Sept 2023AY 2018-19

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2877/DEL/2022[2015-16]Status: DisposedITAT Delhi29 Sept 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2878/DEL/2022[2016-17]Status: DisposedITAT Delhi29 Sept 2023AY 2016-17

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2879/DEL/2022[2017-18]Status: DisposedITAT Delhi29 Sept 2023AY 2017-18

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2881/DEL/2022[2019-20]Status: DisposedITAT Delhi29 Sept 2023AY 2019-20

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals