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12 results for “reassessment u/s 147”+ Section 194clear

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Key Topics

Section 143(2)9Section 1477Section 143(3)5Section 1725Section 1945Section 10B4Section 1424Section 403Reopening of Assessment

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

ITA 368/HYD/2024[2005-06]Status: DisposedITAT Hyderabad04 Feb 2026AY 2005-06

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 10ASection 142(1)Section 143(2)Section 147Section 40

reassessment proceedings under section 147 of the Act. b) No evidence of any new tangible material has been referred to by the Ld. AO in the reasons for re-opening the assessment and hence, it is a mere change of opinion, and the Ld. AO does not have any reason to believe that income has escaped assessment. c) There

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

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

3
Addition to Income3
Disallowance2
ITA 27/HYD/2018[2015-16]Status: DisposedITAT Hyderabad27 Apr 2022AY 2015-16

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

For Appellant: Shri A.V. RaghuramFor Respondent: Shri T. Sunil Goutam
Section 172Section 194

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLOR vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

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

ITA 25/HYD/2018[2015-16]Status: DisposedITAT Hyderabad27 Apr 2022AY 2015-16

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

For Appellant: Shri A.V. RaghuramFor Respondent: Shri T. Sunil Goutam
Section 172Section 194

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED,NELLORE vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), NELLORE

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

ITA 26/HYD/2018[2015-16]Status: DisposedITAT Hyderabad27 Apr 2022AY 2015-16

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

For Appellant: Shri A.V. RaghuramFor Respondent: Shri T. Sunil Goutam
Section 172Section 194

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO ,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION) , NELLORE

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

ITA 550/HYD/2021[2014-15]Status: DisposedITAT Hyderabad27 Apr 2022AY 2014-15

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

For Appellant: Shri A.V. RaghuramFor Respondent: Shri T. Sunil Goutam
Section 172Section 194

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

PACC CONTAINER LINE PTE LIMITED ,SINGAPORE REP BY ITS INDIAN AGENT M/S J M BAXI & CO,NELLORE vs. INCOME TAX OFFICERS ,(INTERNATIONAL TAXATION), NELLORE

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

ITA 551/HYD/2021[2018-19]Status: DisposedITAT Hyderabad27 Apr 2022AY 2018-19

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

For Appellant: Shri A.V. RaghuramFor Respondent: Shri T. Sunil Goutam
Section 172Section 194

reassessment or recomputation under section 147 or section 150; (c) an order under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections; (d) an order made under section 163 treating the assessee as the agent

VINOD OJHA,HYDERABAD vs. INCOME TAX OFFICER, WARD-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1231/HYD/2024[2016-17]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1231/Hyd/2024 (िनधा"रण वष"/Assessment Year 2016-2017) Vinod Ojha, The Income Tax Officer, Ward-5(1), Hyderabad-500012. Vs. Hyderabad – 500 057. Telangana. Telangana. Pan Aahpo3171F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Kumar Pal Tated राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr

For Appellant: CA Kumar Pal TatedFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 139(1)Section 144Section 147Section 148Section 149

reassessment under Section 147, 148 and 148A of the Act in a faceless manner 6. The Ld. CIT(A) erred in not considering that the appellant is a commission, cheque discounting agent, thus, estimating at higher rate of 29.26% of the total gross collections is bad in law 6 ITA.No.1231/Hyd./2024 7. The Ld. CIT(A) erred

RAIN CEMENTS LIMITED, HYD,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD, HYDERABAD

In the result, appeal filed by the assessee is allowed

ITA 864/HYD/2017[2008-09]Status: DisposedITAT Hyderabad31 May 2023AY 2008-09

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2008-09 M/S. Rain Cements Ltd Vs. Dy. Commissioner Of (Formerly Known As Rain Income Tax, Circle 3 (1) Cii Carbon (India) Ltd Hyderabad Hyderabad Pan:Aabcr8858F (Appellant) (Respondent) Assessee By: Advocate Prathishta Singh & Advocate Deepak Chopra Revenue By: Dr.Rajendra Kumar, Cit-Dr Date Of Hearing: 20/03/2023 Date Of Pronouncement: 31/05/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 24.03.2017 Passed U/S 143(3) R.W.S. 144C(5) R.W.S. 260 Of The I.T. Act For The A.Y 2008-09. 2. This Appeal Was Earlier Decided By The Tribunal Vide Order Dated 18.10.2019. Subsequently Vide Ma No.15/Hyd/2020, Dated 23.3.2021, The Tribunal Recalled The Entire Order For Fresh Adjudication. Therefore, This Is A Recalled Matter.

For Appellant: Advocate Prathishta Singh &For Respondent: Dr.Rajendra Kumar, CIT-DR
Section 10BSection 115JSection 143(2)Section 143(3)Section 147Section 148Section 92C

147(6) of the Income-tax Act, 1961" Page 25 of 35 ITA No 864 of 2017 Rain Cements Ltd Hyderabad 5. In Indian Eastern Newspaper Society's case (supra), the court further held that in every case, the Income-tax Officer must determine for himself what is the effect and consequence of the law mentioned in the audit note

MBS JEWELLER PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3, HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

ITA 331/HYD/2018[2010-11]Status: DisposedITAT Hyderabad04 Jan 2022AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Y.V.S.T. Sai, CIT-DR
Section 142Section 143(2)Section 143(3)

194), the Hon’ble High Court of Madhya Pradesh held that whether a particular notice is served or not is not a pure question of law. Therefore, the reliance by the assessee on the judgement of Hon’ble Supreme Court in the case of NTPC Limited is misplaced and the assessee is not entitled to raise the additional grounds

MBS IMPES PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

ITA 330/HYD/2018[2010-11]Status: DisposedITAT Hyderabad04 Jan 2022AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Y.V.S.T. Sai, CIT-DR
Section 142Section 143(2)Section 143(3)

194), the Hon’ble High Court of Madhya Pradesh held that whether a particular notice is served or not is not a pure question of law. Therefore, the reliance by the assessee on the judgement of Hon’ble Supreme Court in the case of NTPC Limited is misplaced and the assessee is not entitled to raise the additional grounds

SRIDHAR REDDY JAGAN NAGARI SATYA.,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-15(1)., HYDERABAD.

In the result, the appeals of the assessee are allowed”

ITA 1248/HYD/2017[A.Y- 2012-13,]Status: DisposedITAT Hyderabad29 Jul 2022

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year:2012-13 Sridhar Reddy Jagan Vs. Dy. C.I.T. Nagari Satya, Circle 15(1) Secunderabad Hyderabad Pan:Adapj3782D (Appellant) (Respondent) Assessment Year:2012-13 A.C.I.T. Vs. Sridhar Reddy Jagan Circle 15(1) Nagari Satya, Hyderabad Secunderabad Pan:Adapj3782D (Appellant) (Respondent) Assessee By: Sri P. Murali Mohan, Ca Revenue By: Sri Rajendra Kumar, Cit(Dr) Date Of Hearing: 08/06/2022 Date Of Pronouncement: 29/07/2022 Order Per R.K. Panda, A.M These Are Cross Appeals. The First One Is Filed By The Assessee & The 2Nd One Is Filed By The Revenue & Are Directed Against The Order Dated 27.3.2017 Cit (A)-7, Hyderabad Relating To The A.Y 2012-13. For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Sri P. Murali Mohan, CAFor Respondent: Sri Rajendra Kumar, CIT(DR)
Section 142(1)Section 143(2)

u/s 148 was issued on 26.03.2007 and was served upon the assessee through affixture on 16.04.2007. This fact has been recorded by the AO also on Page 2 of the Assessment Order. There is no other evidence on record to even suggest that efforts were made earlier to serve the notice on the assessee. The short question which arises

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-15(1)., HYDERABAD vs. SRIDHAR REDDY JAGAN NAGARI SATYA., HYDERABAD

In the result, the appeals of the assessee are allowed”

ITA 1347/HYD/2017[2012-13]Status: DisposedITAT Hyderabad29 Jul 2022AY 2012-13

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year:2012-13 Sridhar Reddy Jagan Vs. Dy. C.I.T. Nagari Satya, Circle 15(1) Secunderabad Hyderabad Pan:Adapj3782D (Appellant) (Respondent) Assessment Year:2012-13 A.C.I.T. Vs. Sridhar Reddy Jagan Circle 15(1) Nagari Satya, Hyderabad Secunderabad Pan:Adapj3782D (Appellant) (Respondent) Assessee By: Sri P. Murali Mohan, Ca Revenue By: Sri Rajendra Kumar, Cit(Dr) Date Of Hearing: 08/06/2022 Date Of Pronouncement: 29/07/2022 Order Per R.K. Panda, A.M These Are Cross Appeals. The First One Is Filed By The Assessee & The 2Nd One Is Filed By The Revenue & Are Directed Against The Order Dated 27.3.2017 Cit (A)-7, Hyderabad Relating To The A.Y 2012-13. For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Sri P. Murali Mohan, CAFor Respondent: Sri Rajendra Kumar, CIT(DR)
Section 142(1)Section 143(2)

u/s 148 was issued on 26.03.2007 and was served upon the assessee through affixture on 16.04.2007. This fact has been recorded by the AO also on Page 2 of the Assessment Order. There is no other evidence on record to even suggest that efforts were made earlier to serve the notice on the assessee. The short question which arises