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86 results for “reassessment u/s 147”

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Key Topics

Section 148105Addition to Income65Section 6862Section 153A62Section 14758Section 143(3)51Section 25050Section 143(2)28Section 10(26)

KAUSHIK INDUSTRIES (P) LIMITED,TINSUKIA vs. INCOME TAX OFFICER, WARD-1, TINSUKIA

In the result, appeal of the assessee is allowed

ITA 11/GTY/2022[2011-12]Status: DisposedITAT Guwahati09 Jun 2023AY 2011-12

Bench: Shri Sanjay Garg & Shri Girish Agrawal

For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri N. T. Sherpa, JCIT
Section 143(3)Section 147Section 147(1)Section 148Section 263

147 clearly expunges that if notice for reopening of assessment was issued on one aspect and in course of reassessment proceedings another aspect was discovered, reassessment order would be valid, only if, aspect which led to reopening of assessment continues to form part of the reassessed income. If after issuing a notice u/s

Showing 1–20 of 86 · Page 1 of 5

25
Reassessment24
Reopening of Assessment14
Penalty13

ABCI INFRASTRUCTURES PRIVATE LIMITED,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI

In the result, the appeal of the assessee is allowed, whereas the appeal of the Revenue is dismissed

ITA 40/GTY/2022[2013-14]Status: HeardITAT Guwahati03 Apr 2023AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

For Appellant: (1) That on the facts and in the circumstances of the case
Section 143(3)Section 147Section 148Section 153Section 153C

reassessment proceeding u/s. 147 by issue of a notice u/s. 148, in spite of the fact that none of conditions

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee is allowed, whereas the appeal of the Revenue is dismissed

ITA 1/GTY/2023[2013-14]Status: HeardITAT Guwahati03 Apr 2023AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

For Appellant: (1) That on the facts and in the circumstances of the case
Section 143(3)Section 147Section 148Section 153Section 153C

reassessment proceeding u/s. 147 by issue of a notice u/s. 148, in spite of the fact that none of conditions

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1, GUWAHATI vs. BMG INFORMATICS PVT. LTD., GUWAHATI

In the result, both, the appeal of the revenue as well as cross objection of the assessee are dismissed

ITA 61/GTY/2022[2016-17]Status: DisposedITAT Guwahati07 Aug 2023AY 2016-17

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2016-17

For Respondent: Shri Amit Kumar Pandey, JCIT
Section 131Section 133ASection 143(3)Section 147Section 148Section 69A

reassessment u/s. 147 of the Act. 2.3. Ld. AO has implicated the assessee for unaccounted cash transactions with DSSPL and made

M/S. SEEMA HOLDING PVT. LTD.,KOLKATA vs. A.C.I.T., CIRCLE -1, GUWAHATI

In the result, appeal of the assessee in ITA No

ITA 67/GTY/2023[2014-15]Status: DisposedITAT Guwahati01 Sept 2023AY 2014-15

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 67/Gty/2023 Assessment Year: 2014-15 M/S. Seema Holding Pvt. Ltd. I.T.O. Ward-15(2), Kolkata Vs [Now, Acit, Central Circle-1, 89, Muktaram Babu Street Guwahati] Kolkata - 700007 [Pan : Aadcs5209H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

For Appellant: Shri Soumitra Choudhary, AdvocateFor Respondent: Shri Chandan Dutta, D/R
Section 143(3)Section 147Section 148Section 250

u/s 147 of the Act after a period of 4 years has been quashed. Similarly in the case of CIT vs Multiplex Trading & Industrial ((63 taxmann.com 170) (Delhi HC), the Hon’ble Delhi High Court has held that since the assessee has disclosed all the material facts at the time of making assessment, initiation of reassessment

M/S. SEEMA HOLDING PVT. LTD.,KOLKATA vs. A.C.I.T., CIRCLE -1, GUWAHATI

In the result, appeal of the assessee in ITA No

ITA 68/GTY/2023[2015-16]Status: DisposedITAT Guwahati01 Sept 2023AY 2015-16

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 67/Gty/2023 Assessment Year: 2014-15 M/S. Seema Holding Pvt. Ltd. I.T.O. Ward-15(2), Kolkata Vs [Now, Acit, Central Circle-1, 89, Muktaram Babu Street Guwahati] Kolkata - 700007 [Pan : Aadcs5209H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

For Appellant: Shri Soumitra Choudhary, AdvocateFor Respondent: Shri Chandan Dutta, D/R
Section 143(3)Section 147Section 148Section 250

u/s 147 of the Act after a period of 4 years has been quashed. Similarly in the case of CIT vs Multiplex Trading & Industrial ((63 taxmann.com 170) (Delhi HC), the Hon’ble Delhi High Court has held that since the assessee has disclosed all the material facts at the time of making assessment, initiation of reassessment

M/S. SEEMA HOLDING PVT. LTD.,KOLKATA vs. A.C.I.T., CIRCLE -1, GUWAHATI

In the result, appeal of the assessee in ITA No

ITA 69/GTY/2023[2015-16]Status: DisposedITAT Guwahati01 Sept 2023AY 2015-16

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 67/Gty/2023 Assessment Year: 2014-15 M/S. Seema Holding Pvt. Ltd. I.T.O. Ward-15(2), Kolkata Vs [Now, Acit, Central Circle-1, 89, Muktaram Babu Street Guwahati] Kolkata - 700007 [Pan : Aadcs5209H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

For Appellant: Shri Soumitra Choudhary, AdvocateFor Respondent: Shri Chandan Dutta, D/R
Section 143(3)Section 147Section 148Section 250

u/s 147 of the Act after a period of 4 years has been quashed. Similarly in the case of CIT vs Multiplex Trading & Industrial ((63 taxmann.com 170) (Delhi HC), the Hon’ble Delhi High Court has held that since the assessee has disclosed all the material facts at the time of making assessment, initiation of reassessment

ACIT CENTRAL CIRCLE 1 GUWAHATI, GUWAHATI vs. DS SYSTEMS PRIVATE LIMITED, GUWAHATI

In the result, appeal of the revenue is dismissed

ITA 284/GTY/2025[2016-17]Status: DisposedITAT Guwahati11 Feb 2026AY 2016-17

Bench: the Hon'ble

For Appellant: Sandeep Goel, Advocate
Section 133ASection 143(1)(a)Section 143(2)Section 147Section 148Section 151Section 250Section 69C

reassessment u/s 147 of the Act. Accordingly, notice u/s 148 3 DS Systems Private Limited of the Act was issued

RI-BHOI ISPAT & ROLLING MILLS,BYRNIHAT vs. ITO, WARD- BYRNIHAT, BYRNIHAT

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 241/GTY/2024[2018-2019]Status: DisposedITAT Guwahati12 Aug 2025AY 2018-2019

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 133ASection 147Section 250Section 69C

reassessment proceedings, the ground 1 of the appellant that the order passed u/s 147 is bad in law is duly

ASSAM VALLEY FINANCE AND INVESTMENT PVT LTD,GUWAHATI vs. D.C.I.T., CIRCLE 1, GUWAHATI

In the result, the appeal of the assessee is allowed

ITA 75/GTY/2025[2016-17]Status: DisposedITAT Guwahati18 Dec 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm Assam Valley Finance & Dcit, Circle 1 Investment Pvt. Ltd. Aayakar Bhawan, Christian Basti, House No.1, Niligiri Path, G.S Road, Guwahati-781005, Vs. Zoo Road, Guwahati-781024 Assam (Appellant) (Respondent) Pan No. Aabca6974B Assessee By : Shri Miraj D Shah, Ar Revenue By : Shri Santosh Kumar Karnani, Dr Date Of Hearing: 12.11.2025 Date Of Pronouncement: 18.12.2025 O R D E R Per Rajesh Kumar, Am:

For Appellant: Shri Miraj D Shah, ARFor Respondent: Shri Santosh Kumar Karnani
Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 151Section 151ASection 68

147 r.w.s. 148 of the Act with great care and caution as by exercising the reassessment jurisdiction u/s. 147, the AO unsettles

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, GUWAHATI vs. M/S. PAWAN CEMENT COMPANY PRIVATE LIMITED, GUWAHATI

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

ITA 73/GTY/2020[2013-14]Status: DisposedITAT Guwahati03 Mar 2023AY 2013-14

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

Section 132Section 139(1)Section 143(2)Section 153ASection 250Section 68

reassessment is that there is no need to resort to Section 147 of the I. T. Act and to consider the disallowance in the assessment to be made under section 153 of the I.T. Act? 1. Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal is correct in misinterpreting the CBDT's Circular

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, GUWAHATI vs. M/S. PAWAN CEMENT COMPANY PRIVATE LIMITED, GUWAHATI

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

ITA 72/GTY/2020[2011-12]Status: DisposedITAT Guwahati03 Mar 2023AY 2011-12

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

Section 132Section 139(1)Section 143(2)Section 153ASection 250Section 68

reassessment is that there is no need to resort to Section 147 of the I. T. Act and to consider the disallowance in the assessment to be made under section 153 of the I.T. Act? 1. Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal is correct in misinterpreting the CBDT's Circular

STATE HEALTH SOCIETY ASSAM,GUWAHATI vs. INCOME TAX OFFICER (EXEMPTION), WARD-2(3), GUWAHATI

In the result, the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 124/GTY/2020[2017-18]Status: DisposedITAT Guwahati20 Jul 2023AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

Section 133ASection 142(1)Section 147Section 148

147 shall be taken by the assessing officer in case of such trust or institution for any assessment year preceding the aforesaid assessment year only for non-registration of such trust or institution for the said assessment year:] 11. From the plain reading of the said proviso it transpire that the provisions of sec 11 and 12 shall apply

STAE HEALTH SOCIETY ASSAM,GUWAHATI vs. INCOME TAX OFFICER (EXEMPTION), WARD-2(3), GUWAHATI

In the result, the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 123/GTY/2020[2016-17]Status: DisposedITAT Guwahati20 Jul 2023AY 2016-17

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

Section 133ASection 142(1)Section 147Section 148

147 shall be taken by the assessing officer in case of such trust or institution for any assessment year preceding the aforesaid assessment year only for non-registration of such trust or institution for the said assessment year:] 11. From the plain reading of the said proviso it transpire that the provisions of sec 11 and 12 shall apply

STATE HEALTH SOCIETY ASSAM,GUWAHATI vs. INCOME TAX OFFICER (EXEMPTION), WARD-2(3), GUWAHATI

In the result, the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 120/GTY/2020[2013-14]Status: DisposedITAT Guwahati20 Jul 2023AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

Section 133ASection 142(1)Section 147Section 148

147 shall be taken by the assessing officer in case of such trust or institution for any assessment year preceding the aforesaid assessment year only for non-registration of such trust or institution for the said assessment year:] 11. From the plain reading of the said proviso it transpire that the provisions of sec 11 and 12 shall apply

STATE HEALTH SOCIETY ASSAM,GUWAHATI vs. INCOME TAX OFFICER, (EXEMPTION), WARD-2(3), GUWAHATI

In the result, the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 119/GTY/2020[2012-13]Status: DisposedITAT Guwahati20 Jul 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

Section 133ASection 142(1)Section 147Section 148

147 shall be taken by the assessing officer in case of such trust or institution for any assessment year preceding the aforesaid assessment year only for non-registration of such trust or institution for the said assessment year:] 11. From the plain reading of the said proviso it transpire that the provisions of sec 11 and 12 shall apply

STATE HEALTH SOCIETY ASSAM,GUWAHATI vs. INCOME TAX OFFICER, (EXEMPTION), WARD-2(3), GUWAHATI

In the result, the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 121/GTY/2020[2014-15]Status: DisposedITAT Guwahati20 Jul 2023AY 2014-15

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

Section 133ASection 142(1)Section 147Section 148

147 shall be taken by the assessing officer in case of such trust or institution for any assessment year preceding the aforesaid assessment year only for non-registration of such trust or institution for the said assessment year:] 11. From the plain reading of the said proviso it transpire that the provisions of sec 11 and 12 shall apply

STATE HEALTH SOCIETY ASSAM,GUWAHATI vs. INCOME TAX OFFICER, (EXEMPTION) WARD-2(3), GUWAHATI

In the result, the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 122/GTY/2020[2015-16]Status: DisposedITAT Guwahati20 Jul 2023AY 2015-16

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

Section 133ASection 142(1)Section 147Section 148

147 shall be taken by the assessing officer in case of such trust or institution for any assessment year preceding the aforesaid assessment year only for non-registration of such trust or institution for the said assessment year:] 11. From the plain reading of the said proviso it transpire that the provisions of sec 11 and 12 shall apply

JUGAL CHANDRA SAIKIA,GUWAHATI vs. INCOME TAX OFFICER, WARD-1(3), GUWAHATI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 259/GTY/2018[1993-94]Status: DisposedITAT Guwahati27 Jan 2025AY 1993-94

Bench: Sri Manomohan Das & Sri Rakesh Mishra

Section 143Section 250Section 254

reassessment order afresh in the light of findings of the Special Judge on the charge sheet filed against the appellant. (Tribunal's order at Page number 12 to 16 of the paper-book, at ANNEXURE-4) {emphasis supplied} 1.3 The learned AO has given effect to the Hon'ble Tribunal's order by the purported order u/s 254 (which should

JUGAL CHANDRA SAIKIA,GUWAHATI vs. INCOME TAX OFFICER, WARD-1(3), GUWAHATI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 258/GTY/2018[1992-93]Status: DisposedITAT Guwahati27 Jan 2025AY 1992-93

Bench: Sri Manomohan Das & Sri Rakesh Mishra

Section 143Section 250Section 254

reassessment order afresh in the light of findings of the Special Judge on the charge sheet filed against the appellant. (Tribunal's order at Page number 12 to 16 of the paper-book, at ANNEXURE-4) {emphasis supplied} 1.3 The learned AO has given effect to the Hon'ble Tribunal's order by the purported order u/s 254 (which should