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23 results for “reassessment u/s 147”+ Section 55(2)(b)clear

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Key Topics

Section 14838Section 6836Addition to Income21Section 143(3)18Section 25016Section 14715Section 143(2)12Reassessment12Section 270A

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 precedent existed and/or have been complied with and/or fulfilled by the Ld. A.O. (2) That the Ld. CIT(A) was wholly wrong in not considering the fact that proceeding initiated u/s 147 of the IT Act, 1961 is completely

Showing 1–20 of 23 · Page 1 of 2

7
Section 271A7
Penalty7
Disallowance6

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 precedent existed and/or have been complied with and/or fulfilled by the Ld. A.O. (2) That the Ld. CIT(A) was wholly wrong in not considering the fact that proceeding initiated u/s 147 of the IT Act, 1961 is completely

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, GUWAHATI vs. FORTUNE VANIJYA PRIVATE LIMITED, GUWAHATI

In the result both the appeal of the Revenue and the cross objections of the assessee stands partly allowed

ITA 21/GTY/2021[2011-12]Status: DisposedITAT Guwahati10 Dec 2021AY 2011-12

Bench: Shri P.M. Jagtap, Hon’Ble V.P (Kz) & Shri A. T. Varkey, Jm]

Section 132Section 132(4)Section 142(1)Section 153ASection 153CSection 68

147 of the Act in relation to the same sale proceeds received in the bank account. And pursuant to the re-opening, in the reassessment order passed u/s 147/143(3) dated 24-12-2018, the AO’s predecessor had recorded a categorical finding that the receipts pertained to sale of investments which had been verified by him. There

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

B. P. Poddar Foundation for Education (2022) 448 ITR 695 (Cal). 6. Per contra, Ld. Sr. DR placed reliance on the order of Ld. Pr. CIT and submitted that Explanation 3 to section 147 provides that Ld. AO may assess or re-assess the income in respect of any issue which has escaped assessment and such issue comes

SHRI BIMAL PAUL,SILCHAR vs. INCOME TAX OFFICER, WARD-1, SILCHAR

In the result, both the appeals of the assessee are dismissed

ITA 8/GTY/2016[2011-12]Status: DisposedITAT Guwahati06 Oct 2023AY 2011-12

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2010-11 & Assessment Year: 2011-12

For Appellant: N o n eFor Respondent: Shri Arun Bhowmick, JCIT
Section 142Section 143(2)Section 143(3)Section 153(1)

55 Taxman 497 (SC) ], which is as under: "The decisions of the Supreme Court in Navnit Lal C. Javeri v. KK Sen, Appellate Assistant Commissioner of Income-tax [1965] 56 ITR 198 (SC) and Ellerman Lines Ltd. v. Commissioner of Income-tax [1971] 82 ITR 913 (SC) must be considered to be the exceptional ones". 4.6 In the case

SHRI BIMAL PAUL,SILCHAR vs. INCOME TAX OFFICER, WARD-1, SILCHAR

In the result, both the appeals of the assessee are dismissed

ITA 211/GTY/2014[2010-11]Status: DisposedITAT Guwahati06 Oct 2023AY 2010-11

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2010-11 & Assessment Year: 2011-12

For Appellant: N o n eFor Respondent: Shri Arun Bhowmick, JCIT
Section 142Section 143(2)Section 143(3)Section 153(1)

55 Taxman 497 (SC) ], which is as under: "The decisions of the Supreme Court in Navnit Lal C. Javeri v. KK Sen, Appellate Assistant Commissioner of Income-tax [1965] 56 ITR 198 (SC) and Ellerman Lines Ltd. v. Commissioner of Income-tax [1971] 82 ITR 913 (SC) must be considered to be the exceptional ones". 4.6 In the case

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- JORHAT, JORHAT vs. M/S. TOOR FINANCE COMPANY LTD,, JORHAT

In the result, the appeal of the Revenue is dismissed

ITA 305/GTY/2018[2010-11]Status: DisposedITAT Guwahati20 Sept 2022AY 2010-11

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

Section 143(1)Section 147Section 148

b) The ld. CIT(Appeals) failed to appreciate the scope of Explanation 3 to Section 147, whether the ld. Assessing Officer cannot make any addition on any other ground unless some addition is made on the ground of which reassessment had been initiated. In other two grounds, the ld. CIT(Appeals) has deleted the additions on merit also

LALTANPUIA CHAWGHLUT,AIZAWL vs. INCOME TAX OFFICER WARD-1, SILCHAR, SILCHAR

In the result, both appeals filed by the assessee in ITA No

ITA 190/GTY/2025[2013-14]Status: DisposedITAT Guwahati11 Feb 2026AY 2013-14

Bench: The Itat Dated 15.09.2025 As Under:

For Respondent: Santosh Kumar Karnani, Addl. CIT
Section 10(26)Section 139Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69A

reassessment as per the provision of section 147 to 151 of the Act, the notice was issued u/s 148 of the Act on 30.03.2021 and time was granted to file return of income for 30 days but assessee did not file return of income. Subsequently, other statutory notices u/s 142(1) of the Act was issued to the assessee

LALTANPUIA CHAWGHLUT,AIZAWL vs. INCOME TAX OFFICER, WARD-1, SILCHAR

In the result, both appeals filed by the assessee in ITA No

ITA 191/GTY/2025[2014-15]Status: DisposedITAT Guwahati11 Feb 2026AY 2014-15

Bench: The Itat Dated 15.09.2025 As Under:

For Respondent: Santosh Kumar Karnani, Addl. CIT
Section 10(26)Section 139Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69A

reassessment as per the provision of section 147 to 151 of the Act, the notice was issued u/s 148 of the Act on 30.03.2021 and time was granted to file return of income for 30 days but assessee did not file return of income. Subsequently, other statutory notices u/s 142(1) of the Act was issued to the assessee

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

ITA 223/GTY/2024[2018-19]Status: DisposedITAT Guwahati21 Mar 2025AY 2018-19

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 148Section 250Section 270ASection 271ASection 68

reassessment proceeding. 2. For that the learned A.O. is not justified in making addition of Rs. 19,93,72,482/- u/s 68 of I.T. Act. 3. The Appellant craves the leave to take Additional Grounds and/or amend the above grounds of appeal at the time of hearing of Appeal. ITA No. 222/GTY/2024: 1. For that under the facts & circumstances

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

ITA 220/GTY/2024[2017-18]Status: DisposedITAT Guwahati21 Mar 2025AY 2017-18

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 148Section 250Section 270ASection 271ASection 68

reassessment proceeding. 2. For that the learned A.O. is not justified in making addition of Rs. 19,93,72,482/- u/s 68 of I.T. Act. 3. The Appellant craves the leave to take Additional Grounds and/or amend the above grounds of appeal at the time of hearing of Appeal. ITA No. 222/GTY/2024: 1. For that under the facts & circumstances

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

ITA 222/GTY/2024[2017-18]Status: DisposedITAT Guwahati21 Mar 2025AY 2017-18

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 148Section 250Section 270ASection 271ASection 68

reassessment proceeding. 2. For that the learned A.O. is not justified in making addition of Rs. 19,93,72,482/- u/s 68 of I.T. Act. 3. The Appellant craves the leave to take Additional Grounds and/or amend the above grounds of appeal at the time of hearing of Appeal. ITA No. 222/GTY/2024: 1. For that under the facts & circumstances

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

ITA 221/GTY/2024[2018-19]Status: DisposedITAT Guwahati21 Mar 2025AY 2018-19

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 148Section 250Section 270ASection 271ASection 68

reassessment proceeding. 2. For that the learned A.O. is not justified in making addition of Rs. 19,93,72,482/- u/s 68 of I.T. Act. 3. The Appellant craves the leave to take Additional Grounds and/or amend the above grounds of appeal at the time of hearing of Appeal. ITA No. 222/GTY/2024: 1. For that under the facts & circumstances

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

ITA 217/GTY/2024[2013-14]Status: DisposedITAT Guwahati21 Mar 2025AY 2013-14

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 148Section 250Section 270ASection 271ASection 68

reassessment proceeding. 2. For that the learned A.O. is not justified in making addition of Rs. 19,93,72,482/- u/s 68 of I.T. Act. 3. The Appellant craves the leave to take Additional Grounds and/or amend the above grounds of appeal at the time of hearing of Appeal. ITA No. 222/GTY/2024: 1. For that under the facts & circumstances

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

ITA 219/GTY/2024[2016-17]Status: DisposedITAT Guwahati21 Mar 2025AY 2016-17

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 148Section 250Section 270ASection 271ASection 68

reassessment proceeding. 2. For that the learned A.O. is not justified in making addition of Rs. 19,93,72,482/- u/s 68 of I.T. Act. 3. The Appellant craves the leave to take Additional Grounds and/or amend the above grounds of appeal at the time of hearing of Appeal. ITA No. 222/GTY/2024: 1. For that under the facts & circumstances

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

ITA 218/GTY/2024[2014-15]Status: DisposedITAT Guwahati21 Mar 2025AY 2014-15

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 148Section 250Section 270ASection 271ASection 68

reassessment proceeding. 2. For that the learned A.O. is not justified in making addition of Rs. 19,93,72,482/- u/s 68 of I.T. Act. 3. The Appellant craves the leave to take Additional Grounds and/or amend the above grounds of appeal at the time of hearing of Appeal. ITA No. 222/GTY/2024: 1. For that under the facts & circumstances

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

In the result, the appeal of the assessee for Assessment Year

ITA 2/GTY/2023[2014-15]Status: HeardITAT Guwahati05 Apr 2023AY 2014-15

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

Section 143(3)Section 250Section 44A

u/s 250 of the Act dated 27.07.2022 running into 1017 pages allowing the deduction claimed u/s.80IA of the Act and the crux of his finding is summarized as under: “(i) That, in respect of an assessment year whose proceedings had abated, a Return of Income filed in compliance to the Notice issued u/s 153A of the Act, substitutes the prior/earlier

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

In the result, the appeal of the assessee for Assessment Year

ITA 37/GTY/2022[2017-18]Status: HeardITAT Guwahati05 Apr 2023AY 2017-18

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

Section 143(3)Section 250Section 44A

u/s 250 of the Act dated 27.07.2022 running into 1017 pages allowing the deduction claimed u/s.80IA of the Act and the crux of his finding is summarized as under: “(i) That, in respect of an assessment year whose proceedings had abated, a Return of Income filed in compliance to the Notice issued u/s 153A of the Act, substitutes the prior/earlier

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

In the result, the appeal of the assessee for Assessment Year

ITA 38/GTY/2022[2018-19]Status: HeardITAT Guwahati05 Apr 2023AY 2018-19

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

Section 143(3)Section 250Section 44A

u/s 250 of the Act dated 27.07.2022 running into 1017 pages allowing the deduction claimed u/s.80IA of the Act and the crux of his finding is summarized as under: “(i) That, in respect of an assessment year whose proceedings had abated, a Return of Income filed in compliance to the Notice issued u/s 153A of the Act, substitutes the prior/earlier

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

In the result, the appeal of the assessee for Assessment Year

ITA 39/GTY/2022[2019-20]Status: HeardITAT Guwahati05 Apr 2023AY 2019-20

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

Section 143(3)Section 250Section 44A

u/s 250 of the Act dated 27.07.2022 running into 1017 pages allowing the deduction claimed u/s.80IA of the Act and the crux of his finding is summarized as under: “(i) That, in respect of an assessment year whose proceedings had abated, a Return of Income filed in compliance to the Notice issued u/s 153A of the Act, substitutes the prior/earlier