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1,100 results for “reassessment u/s 147”+ Section 36(1)(iii)clear

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Key Topics

Section 147107Section 14884Section 143(3)84Addition to Income57Section 153C40Section 6836Reassessment36Section 143(2)33Section 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

36, Statements of Facts and Ground of Appeal\n2\nCopy of Appeal Order of CIT(A) dated 07.01.2016\n3\nCopy of 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

SH. VALMIK THAPAR,NEW DELHI vs. ACIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

ITA 5767/DEL/2015[2007-08]Status: DisposedITAT Delhi11 Jun 2021AY 2007-08

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

Showing 1–20 of 1,100 · Page 1 of 55

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28
Reopening of Assessment24
Search & Seizure19
Section 13216
For Appellant: Shri Salil AgarwalFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 147Section 54Section 54E

reassessment proceedings, assessee submitted that the assessee entered into a collaboration agreement on 29th of April 2006 in financial year 2006 – 07, pertaining to assessment year 2007 – 08. Assessee entered into a collaboration agreement on 29 April 2006, which became effective from 11 April 2007 with the receipt of part consideration from the builder and handing over the property

SHRI VALMIK THAPAR,NEW DELHI vs. DCIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

ITA 6346/DEL/2014[2010-11]Status: DisposedITAT Delhi11 Jun 2021AY 2010-11

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

For Appellant: Shri Salil AgarwalFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 147Section 54Section 54E

reassessment proceedings, assessee submitted that the assessee entered into a collaboration agreement on 29th of April 2006 in financial year 2006 – 07, pertaining to assessment year 2007 – 08. Assessee entered into a collaboration agreement on 29 April 2006, which became effective from 11 April 2007 with the receipt of part consideration from the builder and handing over the property

ACIT, NEW DELHI vs. SH. VALMIK THAPAR, NEW DELHI

Appeals are disposed of by this common order as indicated above

ITA 6726/DEL/2014[2010-11]Status: DisposedITAT Delhi11 Jun 2021AY 2010-11

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

For Appellant: Shri Salil AgarwalFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 147Section 54Section 54E

reassessment proceedings, assessee submitted that the assessee entered into a collaboration agreement on 29th of April 2006 in financial year 2006 – 07, pertaining to assessment year 2007 – 08. Assessee entered into a collaboration agreement on 29 April 2006, which became effective from 11 April 2007 with the receipt of part consideration from the builder and handing over the property

DCIT, NEW DELHI vs. M/S. POWERLINK TRANSMISSION LTD., NEW DELHI

In the result, both the appeals filed by the Revenue for A

ITA 3870/DEL/2014[2010-11]Status: DisposedITAT Delhi21 Dec 2018AY 2010-11

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Sh. Manoneet Dalal, Adv. &For Respondent: Sh. Surender Pal, Sr. DR
Section 143(3)Section 147Section 148Section 36

36(1)(iii) of I.T. Act. Aggrieved, the Assessee filed appeal before Ld. CIT(A), who, vide impugned order dated 09/04/2014, deleted the disallowance. However, the Ld. CIT(A) upheld the reopening of assessment U/s 147 of I.T. Act. The relevant portion of the order of Ld. CIT(A) is reproduced as under: 5.1 The appellant has stated that

DCIT, NEW DELHI vs. M/S. POWERLINK TRANSMISSION LTD., NEW DELHI

In the result, both the appeals filed by the Revenue for A

ITA 3869/DEL/2014[2007-08]Status: DisposedITAT Delhi21 Dec 2018AY 2007-08

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Sh. Manoneet Dalal, Adv. &For Respondent: Sh. Surender Pal, Sr. DR
Section 143(3)Section 147Section 148Section 36

36(1)(iii) of I.T. Act. Aggrieved, the Assessee filed appeal before Ld. CIT(A), who, vide impugned order dated 09/04/2014, deleted the disallowance. However, the Ld. CIT(A) upheld the reopening of assessment U/s 147 of I.T. Act. The relevant portion of the order of Ld. CIT(A) is reproduced as under: 5.1 The appellant has stated that

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

ITA 2953/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

147, for the very same year is nothing but rowing and fishing enquiries, which is impermissible. 7. That on the facts & circumstances of the case and in law, the CIT(A) did not appreciate that the information based on which order u/s. 153A/143(3) of the Act was concluded, was already available with the Income-tax Department. Inter-alia, Assessing

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

ITA 2954/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

147, for the very same year is nothing but rowing and fishing enquiries, which is impermissible. 7. That on the facts & circumstances of the case and in law, the CIT(A) did not appreciate that the information based on which order u/s. 153A/143(3) of the Act was concluded, was already available with the Income-tax Department. Inter-alia, Assessing

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

ITA 2708/DEL/2025[2013-14]Status: DisposedITAT Delhi04 Feb 2026AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 4153 & 4008/Del/2025 (Assessment Year: 2012-13 & 2018-19) Dcit, Proform Interiors Pvt. Ltd., Central Circle-20, Ground Floor, Jmd Regent Room No. 269A, 2Nd Floor, Vs. Plaza, Mg Road, Gurgaon, Ara Centre, Jhandewalan Haryana-122001. Extn., Delhi-110055. Pan-Aahcs5999J

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

1). It empowers the AO to scrutinize that return if he considers that income has been understated or tax was underpaid. However, when a search u/s 132 takes place and materials are found indicating possible escapement of income, the statute envisages a different route for carrying out assessment or reassessment u/s 147 r.w.s. 148 which is special mechanism for bringing

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

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

36 and consequently in quashing the re-opening proceedings. In my view, the assessment was validly reopened and the AO made addition on the issue which was the basis of the reopening. Therefore, it is held that once the AO assumed the jurisdiction u/s 147/148 of the Act as per law and completed the reassessment as per law, then

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

36 and consequently in quashing the re-opening proceedings. In my view, the assessment was validly reopened and the AO made addition on the issue which was the basis of the reopening. Therefore, it is held that once the AO assumed the jurisdiction u/s 147/148 of the Act as per law and completed the reassessment as per law, then

DCIT, NEW DELHI vs. M/S. PUNJAB NATIONAL BANK, NEW DELHI

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

ITA 2954/DEL/2017[2013-14]Status: DisposedITAT Delhi13 May 2020AY 2013-14

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumarita No. 2954/Del/2012 : Asstt. Year : 2013-14 Dcit, Vs M/S Punjab National Bank, Circle-20(1), Ho: Finance Division, 5, Sansad New Delhi Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp0165G

For Appellant: Sh. S. Krishnan, AdvFor Respondent: Smt. Sushma Singh, CIT DR
Section 142(1)

section 14A of the Income Tax Act read with rule 8D and has disallowed a sum of Rs.2,86,69,45,381/-on a tax free income of Rs. 143,35,22,679/- from dividend and other tax-free income. In this connection we wish to submit as under:- 4.1 Bank has claimed the following income as exempt from

PUNJAB NATIONAL BANK,NEW DELHI vs. ADDL. CIT, NEW DELHI

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

ITA 3041/DEL/2017[2013-14]Status: DisposedITAT Delhi13 May 2020AY 2013-14

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumarita No. 2954/Del/2012 : Asstt. Year : 2013-14 Dcit, Vs M/S Punjab National Bank, Circle-20(1), Ho: Finance Division, 5, Sansad New Delhi Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp0165G

For Appellant: Sh. S. Krishnan, AdvFor Respondent: Smt. Sushma Singh, CIT DR
Section 142(1)

section 14A of the Income Tax Act read with rule 8D and has disallowed a sum of Rs.2,86,69,45,381/-on a tax free income of Rs. 143,35,22,679/- from dividend and other tax-free income. In this connection we wish to submit as under:- 4.1 Bank has claimed the following income as exempt from

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, DELHI

ITA 2716/DEL/2025[2021-22]Status: DisposedITAT Delhi04 Feb 2026AY 2021-22
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

36,27,600/ on account of service charges\nearned from various clients for facilitating, supervising and overseeing the work\nutsourced by them to outside vendors/contractors which was inadvertently missed\nwhile filing original return of income and due taxes alongwith interest as per law\nwere paid thereon. Thereafter, notice u/s 143(2) of the Act was issued on 22.02.2023\nfollowed

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

ITA 1291/DEL/2022[2018-19]Status: HeardITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 144BSection 144CSection 68

section 1448 of IT Act, the case was duly transferred to the jurisdiction AO, who has no previous idea about the assessment proceedings in the case. However it is pointed out, that, even during the DRP stage and even after providing opportunity by AO, the assessee could not submit any evidence with respect to bank statement of assessee and also

DESIGNARCH INFRASTRUCTURE P.LTD,NEW DELHI vs. ITO, WARD-7(1), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 8199/DEL/2019[2010-11]Status: DisposedITAT Delhi21 Oct 2020AY 2010-11

Bench: Sh. K. N. Charydr. B. R. R. Kumar(Through Video Conferencing) Ita No. 8199/Del/2019 : Asstt. Year : 2010-11 Designarch Infrastructure Pvt. Ltd., Vs. Income Tax Officer, L-7A(Lgf), South Extension, Part-Ii, Ward-7(1), New Delhi-110049 New Delhi-110002 (Appellant) (Respondent) Pan No. Aacfi4218C Assessee By : Sh. Raj Kumar, Ca Revenue By : Sh. Jagdish Singh, Sr. Dr Date Of Hearing: 12.10.2020 Date Of Pronouncement: 21.10.2020

For Appellant: Sh. Raj Kumar, CAFor Respondent: Sh. Jagdish Singh, Sr. DR
Section 127(1)Section 143(3)Section 147Section 148Section 151Section 68

1. Authorized Share Capital Rs.2,00,00,000 Rs.3,00,00,000 2. Issued, Subscribed and Paid Rs.1,78,76,000 Rs.1,96,36,000 up Capital 3. Securities premium Rs.5,75,00,000 Rs.7,77,40,000 Account/Share Application Money 4. Share application Money Rs. NIL Rs. NIL 5. I have carefully perused and analyzed the facts

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

ITA 2715/DEL/2025[2020-21]Status: DisposedITAT Delhi04 Feb 2026AY 2020-21
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

36,27,600/ on account of service charges\nearned from various clients for facilitating, supervising and overseeing the work\noutsourced by them to outside vendors/contractors which was inadvertently missed\nwhile filing original return of income and due taxes alongwith interest as per law\nwere paid thereon. Thereafter, notice u/s 143(2) of the Act was issued on 22.02.2023\nfollowed

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

ITA 2712/DEL/2025[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

36,27,600/ on account of service charges\nearned from various clients for facilitating, supervising and overseeing the work\noutsourced by them to outside vendors/contractors which was inadvertently missed\nwhile filing original return of income and due taxes alongwith interest as per law\nwere paid thereon. Thereafter, notice u/s 143(2) of the Act was issued on 22.02.2023\nfollowed

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for

ITA 2709/DEL/2025[2014-15]Status: DisposedITAT Delhi04 Feb 2026AY 2014-15
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

Section 119 of the Act as noticed above, we find that while Section\n119(1) of the Act, restrains the Board from issuing any instructions to subordinate\nauthorities, which may lay down instructions of such a nature requiring the Income\nTax Authorities to make particular assessment in a particular manner or to\ninterfere with the discretion of the Joint Commissioner

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

ITA 2713/DEL/2025[2018-19]Status: DisposedITAT Delhi04 Feb 2026AY 2018-19
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

36,27,600/ on account of service charges\nearned from various clients for facilitating, supervising and overseeing the work\noutsourced by them to outside vendors/contractors which was inadvertently missed\nwhile filing original return of income and due taxes alongwith interest as per law\nwere paid thereon. Thereafter, notice u/s 143(2) of the Act was issued on 22.02.2023\nfollowed