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180 results for “reassessment u/s 147”+ Natural Justiceclear

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Key Topics

Section 148174Section 147115Addition to Income80Section 143(3)71Section 148A70Section 153C50Natural Justice34Section 6932Reassessment

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

ITA 1717/HYD/2017[2009-10]Status: HeardITAT Hyderabad07 Oct 2024AY 2009-10

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

For Appellant: Shri K.K. ChaitanyaFor Respondent: Smt. Mamata Choudhary
Section 132Section 139(1)Section 143(3)Section 147Section 153ASection 80I

JUSTICE (Retd.) C.V. BHADANG, PRESIDENT, SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI G. MANJUNATHA, ACCOUNTANT MEMBER ITA Nos.1717 to 1720 & 1722/Hyd/2017 Assessment Years: 2009-10 to 2012-13 and 2014-15 Vs. M/s. SEW Infrastructure Deputy Commissioner of Limited, Income Tax, 6-3-871, Snehlata, Central Circle – Greenland Roads, 2(2), Hyderabad. Begumpet, Hyderabad. PAN : AADCS4061P (Appellant) (Respondent) Assessee

Showing 1–20 of 180 · Page 1 of 9

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31
Section 13226
Reopening of Assessment26
Section 69A23

HIMASAGAR KRISHNA MUTHAPPAGARI,TIRUPATI vs. ITO., WARD-2(3), TIRUPATI

ITA 687/HYD/2024[2016-17]Status: DisposedITAT Hyderabad12 Mar 2025AY 2016-17

Bench: Us.

For Appellant: Shri M. Uday Teja, C.AFor Respondent: Ms. M. Narmada, CIT-DR
Section 143(3)Section 147Section 148Section 263

147 r.w.s 144B and ordering for Re- Assessment, both in Law, Facts of the case, Equity and Natural Justice. 2. The Assessee filed Return of Income (ROI) on 31/03/2018 and selected for scrutiny in CASS and the assessment was completed U/s 143(3) on 24/12/2018 with some additions. The Assessee filed an Appeal on the Assessment Order before

RAMA MOHAN SOMA,ANANTAPUR vs. INCOME TAX OFFICER, WARD -1, HINDUPUR

In the result, the appeal of the assessee is allowed

ITA 180/HYD/2024[2012-13]Status: DisposedITAT Hyderabad09 May 2024AY 2012-13

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2012-13 Rama Mohan Soma, Vs. The Income Tax Officer, H.No.12-274-3, Bypass Ward – 1, Road, Kadiri, Anantapur, Hindupur. Andhra Pradesh – 515591. Pan : Aocps8172D (Appellant) (Respondent) Assessee By: Shri G. Srinivasa Rao, C.A. Revenue By: Shri Shakeer Ahamed, Sr.Ar. Date Of Hearing: 02.05.2024 Date Of Pronouncement: 09.05.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2012-13 Arises From Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dt.27.12.2023 Invoking Proceedings Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short, “The Act”). 2. The Grounds Raised By The Assessee Read As Under :

For Appellant: Shri G. Srinivasa Rao, C.AFor Respondent: Shri Shakeer Ahamed, Sr.AR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 156Section 254Section 69B

natural justice and hence the impugned order is liable for quashed. 2 6. That the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi erred in dismissing the ground no.5 of appeal without appreciating the fact that the Learned Assessing Officer has quoted the wrong assessment year in the demand notice issued u/s 156 of the Act which

SHIVA RANJANI VEJJA ,HYDERABAD vs. INCOME TAX OFFICER, WARD-12(2) , HYDERABAD

In the result, the appeal of the assessee is partly allowed

ITA 267/HYD/2020[2013-14]Status: DisposedITAT Hyderabad19 Jan 2024AY 2013-14

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Ms. Sheetal Sarin, Sr. AR
Section 144Section 147Section 148Section 2Section 69A

nature of activity and residential address the computer automatically selects the jurisdiction of the Assessing Officer, therefore, the returns were uploaded to the Assessing Officer Ward-10(4), Hyderabad. Considering the objections raised the learned CIT sought remand report from the Assessing Officer. The remand report which is reproduced at page 4,5 and 6 of the CIT(A) order

MAMATHA GUBBALA,HYDERABAD vs. ITO., WARD-15(1), HYDERABAD

ITA 1170/HYD/2025[2019-20]Status: DisposedITAT Hyderabad30 Jan 2026AY 2019-20
Section 127Section 142(1)Section 147Section 148Section 148ASection 250

natural justice so that he can produce the\nnecessary evidences/documents in order to help the Ld. AO to arrive\nat correct and real income. The Ld. AO is hereby directed to make all\nnecessary enquiries in order to verify the documents submitted by the\nappellant if deemed necessary by him.\n6.1.7. The appellant is also directed to appear before

THE PRAKASAM DISTRISET POLICE WELFARE ASSOCIATION,ONGOLE vs. ITO., WARD-1, ONGOLE

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 1305/HYD/2025[2018-19]Status: DisposedITAT Hyderabad27 Mar 2026AY 2018-19
Section 147Section 148Section 148ASection 151Section 69A

natural justice, as adequate opportunity was not provided to verify and correct the erroneous data despite specific explanations being furnished, and the submissions made were disregarded without cogent reasoning 3. Perverse finding and irrelevant considerations The CIT(A) wrongly relied on alleged inability to reconcile sales turnover to cash deposits, which is irrelevant to the present issue. The addition

SYED GULAM MOHIUDDIN,HYDERABAD vs. ITO, INTERNATIONAL TAXATION-1, HYDERABAD

In the result, appeal filed by the assessee is allowed

ITA 136/HYD/2023[2017-18]Status: DisposedITAT Hyderabad03 Jun 2024AY 2017-18

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha, G.आ.अपी.सं /Ita No.136/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Syed Gulam Vs. Income Tax Officer Mohiuddin (International Taxation)-1 Hyderabad Hyderabad Pan:Decpm0365H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 16/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Assessment Order Dated 12.01.2023 Of The Learned Assessing Officer (International Taxation-1), Hyderabad, Relating To A.Y.2017-18. 2. The Grounds Raised By The Assessee Read As Under: “1. The Final Assessment Order Passed By The Income Tax Officer (Int Taxn)-1,Hyd (Herein After Referred To As 'Ao) Is Erroneous Both On Facts & In Law To The Extent The Order Is Prejudicial To The Interest Of The Appellant.

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shiva Sewak, CIT(DR)
Section 147Section 148Section 148(2)Section 151Section 69

justice. 10. 11. 12. The Ld. A.O has erred in reopening the assessment without recording the reasons and without communicating the reasons for reopening which is incorrect and unjustified. 11. The Ld. A.O made a huge addition of Rs. 22,00,000/- on the basis of loose sheets those of which have been made based on the culled out seized

RATNA INFRASTRUCTURE PROJECTS PRIVATE LIMITED,HYDERABAD vs. ITO, WARD-3(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed

ITA 132/HYD/2023[2012-13]Status: DisposedITAT Hyderabad12 Feb 2025AY 2012-13

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2012-13 Ratna Infrastructure Projects Vs. The Income Tax Officer, Ward –3(3), Private Limited, Hyderabad. Hyderabad. Pan : Aadcr5836P. (Assessee) (Respondent) Assessee By: Shri Mohd. Afzal, Advocate. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 20.01.2025 Date Of Pronouncement: 12.02.2025

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri B. Balakrishna, CIT-DR
Section 143(3)Section 148Section 40A(3)

reassessment proceedings amounting to Rs.273,02,94,670/-. 5. The learned Commissioner ought to have appreciated that notice u/s 148 is issued on account of a letter from ADIT Kolkata, in respect of a transaction amounting to Rs.5,64,94,670/- and further in respect of transaction of Rs.267,38,00,000/-on merely a TEP. As there

ARKAY ENERGY (RAMESWARM) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

ITA 1562/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18
For Appellant: \nShri P. Murali Mohan Rao, C.AFor Respondent: \nShri Ranjan Agrawala, SR-DR
Section 147Section 148Section 148ASection 151ASection 250

natural justice.\n14. The Ld. CIT(A) ought to have appreciated the fact that the\ndisallowance was made u/s 36(1)(vii) of the Act, however the\nimpairment loss is claimable u/s 37(1) of the Act as business\nexpense incurred wholly and exclusively for the purpose of\nbusiness, as it is a mandatory accounting practice required by\nlaw

LANCO ENTERPRISE PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-5(1), HYDERABAD (ERSTWHILE DCIT, CIRCLE-16(1)), HYDERABAD ,, HYDERABAD

In the result, ITA Nos. 236 & 237/Hyd/2023 are allowed for statistical purposes and ITA No

ITA 237/HYD/2023[2014-15]Status: DisposedITAT Hyderabad28 Dec 2023AY 2014-15

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Chary

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Smt. T.H Vijaya Lakshmi, CIT(DR)
Section 143(2)Section 144Section 14A

147 of the Act are taken up in the appellant's case only to verify the disallowability of the claim made u/s 36(1 )(iii) of the Act which is not permissible as per the provisions of I.T Act,1961. (h) The Ld. CIT(A) ought to have appreciated that the reassessment is invalid on the ground that there

LANCO ENTERPRISE PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-5(1), HYDERABAD (ERSTWHILE DCIT, CIRCLE-16(1), HYDERABAD, HYDERABAD

In the result, ITA Nos. 236 & 237/Hyd/2023 are allowed for statistical purposes and ITA No

ITA 236/HYD/2023[2012-13]Status: DisposedITAT Hyderabad28 Dec 2023AY 2012-13

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Chary

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Smt. T.H Vijaya Lakshmi, CIT(DR)
Section 143(2)Section 144Section 14A

147 of the Act are taken up in the appellant's case only to verify the disallowability of the claim made u/s 36(1 )(iii) of the Act which is not permissible as per the provisions of I.T Act,1961. (h) The Ld. CIT(A) ought to have appreciated that the reassessment is invalid on the ground that there

LANCO ENTERPRISE PRIVATE LIMITED ,GURGAON vs. DCIT, CIRCLE-5(1), HYDERABAD (ERSTWHILE DCIT, CIRCLE-16(1)), HYDERABAD ,, HYDERABAD

In the result, ITA Nos. 236 & 237/Hyd/2023 are allowed for statistical purposes and ITA No

ITA 238/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Dec 2023AY 2017-18

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Chary

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Smt. T.H Vijaya Lakshmi, CIT(DR)
Section 143(2)Section 144Section 14A

147 of the Act are taken up in the appellant's case only to verify the disallowability of the claim made u/s 36(1 )(iii) of the Act which is not permissible as per the provisions of I.T Act,1961. (h) The Ld. CIT(A) ought to have appreciated that the reassessment is invalid on the ground that there

SRI EDUPAYALA VANA DURGA BHAVANI,HYDERABAD vs. INCOME TAX OFFICER, WARD-1, SANGAREDDY

ITA 399/HYD/2025[2016-17]Status: DisposedITAT Hyderabad08 Oct 2025AY 2016-17

Bench: Us:

Section 115BSection 142(1)Section 144Section 147Section 148Section 263Section 69A

natural justice as the appellant was not provided with a sufficient and proper opportunity to present their case. The appellant was deprived of the opportunity to substantiate the facts and provide relevant documentary evidence, which makes the order unsustainable in law. 3. The PCIT's findings that the original assessment order was erroneous and prejudicial to the interests

SANJEEV KUMAR NALAM,HYDERABAD vs. ITO, WARD-1, NIRMAL

In the result, the appeal of the assessee is allowed

ITA 669/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Dec 2025AY 2017-18

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.669/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Sanjeev Kumar Nalam Vs. Income Tax Officer Hyderabad Ward – 1 Pan:Avdpn0497L Adilabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 03/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri Waseem UR Rehman, Sr.DR
Section 147Section 148Section 148ASection 149(1)Section 151Section 153

justice.” 3. The brief facts of the case are that the assessee had filed an appeal before the Ld. CIT(A) against the order of the Learned Assessing Officer (“Ld. AO”) passed for Assessment Year 2017-18 under Section 147 r.w.s. 144 of the Income Tax Act, 1961(“the Act”), dated 31.05.2023. The Ld. CIT(A) dismissed the appeal

LATE RAJASEKHAR CHELIKANI,HYDERABAD vs. ACIT., CENTRAL CIRCLE 3(2), HYDERABAD

ITA 156/HYD/2025[2017-2018]Status: DisposedITAT Hyderabad29 Apr 2025AY 2017-2018

Bench: Us:

Section 133(6)Section 133ASection 142Section 147Section 148Section 159Section 2(22)(e)Section 251

natural justice will be not met if a fresh opportunity is not accorded in this case. In view of this, the assessments for the A.Ys i.e. 2011-12 to, 2014-15, 2016-17 & 2017-18 are set aside for fresh consideration by the AO. Since the assessments are set aside the grounds of appeal are not being separately adjudicated

KILARU VENKATA SATISH,KRISHNA DIST vs. DCIT, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 933/HYD/2025[2018-19]Status: DisposedITAT Hyderabad17 Dec 2025AY 2018-19

Bench: Us), Which Reads As Under:

Section 147Section 148Section 148ASection 151Section 68

natural justice. 2. Without prejudice to the above, the Id. CIT(A) erred in sustaining the addition made by the AO of Rs.50,00,000 as unexplained credit u/s.68 of the Act. The Id. CIT(A) failed to appreciate the evidence filed and thereby erred in confirming the addition without giving sufficient opportunity. 3. Any other ground that

KINETA GLOBAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

ITA 800/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

For Appellant: Sri S. VenkateswarluFor Respondent: Dr. Narendra Kumar Naik
Section 147Section 148Section 148ASection 151Section 151ASection 250(6)

natural justice are not followed in terms of not looking into the records. 5. The order of the Ld. CIT(A) is to be held as bad in law as the Ld. CIT(A) failed to pass a speaking order in terms of section 250(6) of the Act. 6. The appellant craves leave to add, alter or amend

VEERA REDDY POSHAM,NALGONDA vs. ACIT, CENTRAL CIRCLE1(1), HYDERABAD

In the result, ITA.No.1830/Hyd

ITA 1830/HYD/2025[2022-23]Status: DisposedITAT Hyderabad13 Mar 2026AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.Nos.1829 & 1830/Hyd/2025 Assessment Years 2020-2021 & 2022-2023 Veera Reddy Posham, The Acit, Nalgonda – 508 246 Central Circle-1(1), Vs. Telangana. Hyderabad. Telangana. Pan Aijpp0376P (Applicant) (Respondent) -None- िनधा"रती "ारा/Assessee By : राज" व "ारा/Revenue By : Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 09.03.2026 घोषणा की तारीख/Pronouncement: 13.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 132Section 143(3)Section 147Section 148Section 234FSection 250(6)Section 270ASection 80CSection 80C(2)(xvii)

147 was invalid in law as: a) The conditions precedent for assumption of jurisdiction were not satisfied; b) There was no tangible material linking any income escapement to the appellant; c) The notice u/s 148 was issued mechanically based only on search information of other entities (M/s Ira Group) without independent application of mind; and d) Accordingly, the reassessment order

LATE RAJASEKHAR CHELIKANI,HYDERABAD vs. ACIT., CENTRAL CIRCLE-3(2), HYDERABAD

Appeals are dismissed in terms of our aforesaid observations

ITA 148/HYD/2025[2012-2013]Status: DisposedITAT Hyderabad28 Apr 2025AY 2012-2013

Bench: Us:

Section 133ASection 143(1)Section 144Section 147Section 148Section 159Section 2(22)(e)Section 251

natural justice and procedural law, 3. The Assessing Officer erred in completing the assessment without making an effort to identify or bring the legal heirs of the deceased assessee on record as mandated under Section 159 of the Income Tax Act, 1961. The CIT(A) failed to appreciate this legal requirement.” 3. Succinctly stated, the assessee had filed his return

LATE RAJASEKHAR CHELIKANI,HYDERABAD vs. ACIT., CENTRAL CIRLCE 3(2), HYDERABAD

Appeals are dismissed in terms of our aforesaid observations

ITA 154/HYD/2025[2014-2015]Status: DisposedITAT Hyderabad28 Apr 2025AY 2014-2015

Bench: Us:

Section 133ASection 143(1)Section 144Section 147Section 148Section 159Section 2(22)(e)Section 251

natural justice and procedural law, 3. The Assessing Officer erred in completing the assessment without making an effort to identify or bring the legal heirs of the deceased assessee on record as mandated under Section 159 of the Income Tax Act, 1961. The CIT(A) failed to appreciate this legal requirement.” 3. Succinctly stated, the assessee had filed his return