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54 results for “reassessment u/s 147”+ Set Off of Lossesclear

Sorted by relevance

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Key Topics

Section 143(3)61Section 14852Section 6847Addition to Income35Section 14732Section 25024Reopening of Assessment18Deduction12Reassessment

COMMISSIONER OF INCOME TAX -II, GUWAHATI vs. M/S. ARIHANT INTERNATIONAL LIMITED , GUWAHATI

In the result, the appeal filed by the Revenue is dismissed

ITA 275/GTY/2018[2009-10]Status: DisposedITAT Guwahati19 Oct 2022AY 2009-10

Bench: Dr. Manish Borad & Sri Sonjoy Sarma

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 43(5)Section 73

reassessment holding that the Revenue was unable to satisfy the conditions precedent in first proviso to Section 147 of the Act. 9.6. Further, in the case of Rajesh Jhaveri Stock Broking Pvt. Ltd Vs. CIT (291 ITR 500) Hon’ble Supreme Court held that an assessment originally completed u/s 143(1) can be reopened by an AO at any time

Showing 1–20 of 54 · Page 1 of 3

11
Section 80l10
Section 2638
Section 153A7

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

loss reported by the assessee, after calling for the explanation and details in respect of deposit of cash of Rs.9,66,400/- in the bank account and after having been satisfied on its examination by the Ld. AO. We also note from the reasons to believe recorded by the ld. AO that the income escaping assessment is alleged for deposit

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

Loss Account of the company, M/s Silverpoint Infratech Limited, were obtained from DDIT (Inv.) Unit-2(2); Guwahati and examined for the relevant year. The company had shown a turnover of more than Rs. 250 crores under the claimed field of operations, i.e., “Civil Contractors", however, the major expenditure amounting to Rs. 249 crores has been made on purchases

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

Loss Account of the company, M/s Silverpoint Infratech Limited, were obtained from DDIT (Inv.) Unit-2(2); Guwahati and examined for the relevant year. The company had shown a turnover of more than Rs. 250 crores under the claimed field of operations, i.e., “Civil Contractors", however, the major expenditure amounting to Rs. 249 crores has been made on purchases

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

set off against other income. The statutory notices were duly issued and served upon the assessee. The questionnaires issued, calling upon the assessee for furnishing various informations, were not complied with by the assessee. Finally, the assessment was framed u/s 147 r.w.s. 144 of the Act, vide order dt. 21/01/2022 interalia making additions of Rs.1,06,96,800/- on account

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

set off against other income. The statutory notices were duly issued and served upon the assessee. The questionnaires issued, calling upon the assessee for furnishing various informations, were not complied with by the assessee. Finally, the assessment was framed u/s 147 r.w.s. 144 of the Act, vide order dt. 21/01/2022 interalia making additions of Rs.1,06,96,800/- on account

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

set off against other income. The statutory notices were duly issued and served upon the assessee. The questionnaires issued, calling upon the assessee for furnishing various informations, were not complied with by the assessee. Finally, the assessment was framed u/s 147 r.w.s. 144 of the Act, vide order dt. 21/01/2022 interalia making additions of Rs.1,06,96,800/- on account

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2, DIBRUGARH vs. T & T PROJECTS LTD., GUWAHATI

In the result and for the reasons discussed above, we find no merit in this appeal

ITA 208/GTY/2017[2010-11]Status: DisposedITAT Guwahati02 Aug 2019AY 2010-11

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.208/Gau/2017 ("नधा"रणवष" / Assessment Year:2010-11)

For Appellant: Shri A.K. Bhardwaj, Addl. CITFor Respondent: Shri Ramesh Goenka, Advocate
Section 143(3)Section 147Section 148

Loss Accounts are held to be sufficient disclosure. Hon'ble Gujarat High Court, in the case of Pr. CIT v Lincoln Pharmaceuticals Ltd (2016) 66 taxmann.com 355 (Guj) held that when primary facts regarding value of plant and machinery was available in the Balance Sheet, reopening could not have been done after four years to disallow assessee's claim

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 dismissed. Accordingly, the ground 1 to 3 are dismissed. Ground 4: Claim of deduction u/s 80IE 6.5 The appellant has claimed the deduction u/s 80IE in the ROI. However AO has not discussed anything in this regard in the assessment

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

VINAY BAWRI,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, GUWAHATI

In the result, the appeal of the assessee is allowed

ITA 42/GTY/2021[2013-14]Status: DisposedITAT Guwahati22 Sept 2023AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 153(3)Section 153ASection 154Section 263Section 263(1)

u/s 154 of the Act dated 17.12.2016 , the carry forward was allowed.Now in the assessment under section 143(3) r.w.s 153A of the Act dated 31.12.2018, this issue was not subject matter of the proceedings at all. 7. Considering the facts of the case vis a vis the ratio laid down in the above decisions and the provisions of section

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

loss account & balance sheet in the return of income of the assessee are as under: AY. Purchases Sundry Creditors Addition to Sales Sundry Sr. Creditors Debtors

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

loss account & balance sheet in the return of income of the assessee are as under: AY. Purchases Sundry Creditors Addition to Sales Sundry Sr. Creditors Debtors

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

loss account & balance sheet in the return of income of the assessee are as under: AY. Purchases Sundry Creditors Addition to Sales Sundry Sr. Creditors Debtors

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

loss account & balance sheet in the return of income of the assessee are as under: AY. Purchases Sundry Creditors Addition to Sales Sundry Sr. Creditors Debtors

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

loss account & balance sheet in the return of income of the assessee are as under: AY. Purchases Sundry Creditors Addition to Sales Sundry Sr. Creditors Debtors

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

loss account & balance sheet in the return of income of the assessee are as under: AY. Purchases Sundry Creditors Addition to Sales Sundry Sr. Creditors Debtors

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

loss account & balance sheet in the return of income of the assessee are as under: AY. Purchases Sundry Creditors Addition to Sales Sundry Sr. Creditors Debtors

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)

u/s 143(3) passed by the Ld. AO in total violation of the guidelines issued by the CSDT vide F. No. 225/26/2006-ITA.II (Pt.), dated 08-09-2010. 3. That the Ld. CIT(A) has issued the appellate order after expiry of the limitation period prescribed by the CBDT vide Instruction No. 20/2003 dated 23-12-2003, as there has been

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)

u/s 143(3) passed by the Ld. AO in total violation of the guidelines issued by the CSDT vide F. No. 225/26/2006-ITA.II (Pt.), dated 08-09-2010. 3. That the Ld. CIT(A) has issued the appellate order after expiry of the limitation period prescribed by the CBDT vide Instruction No. 20/2003 dated 23-12-2003, as there has been