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19 results for “reassessment”+ Rectification u/s 154clear

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Key Topics

Section 26345Section 15423Section 143(3)13Addition to Income13Rectification u/s 1549Revision u/s 2637Condonation of Delay7Cash Deposit6Section 1475Section 90

THE ACIT- 4(1), INDORE, INDORE vs. M/S PRESTIGE FEED MILLS LTD., INDORE

In the result, the appeal of revenue is dismissed

ITA 194/IND/2023[2014-15]Status: DisposedITAT Indore13 Oct 2023AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniacit-4(1) Prestige Feed Mills Ltd. Indore 30, Jaora Compound Vs. Indore (Appellant / Revenue) (Assessee) Pan: Aabcp0412H Assessee By Shri Ashish Goyal & N.D. Patwa, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.10.2023 Date Of Pronouncement 13.10.2023

Section 143(3)Section 154

u/s 154 is beyond the jurisdiction and scope of section 154 of the Act as it is not a mistake apparent from the record but the AO has made reassessment in the garb of rectification

MAHAVIR KUMAR JAIN,UJJAIN vs. I.T.O. 1(1), UJJAIN

In the result, All appeals of the assessee are partly allowed

ITA 419/IND/2023[2009-10]Status: DisposedITAT Indore
4
Section 2533
Section 2503
31 May 2024
AY 2009-10

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

rectification application u/s 154 before the AO but no avail. Thus, it is clear that by filing these appeals belatedly there was no malafide intention to take any undue advantage by assessee. The assessee has acted on the advice of the tax consultant for not filing the appeal within the period of limitation and therefore, in the facts and circumstances

MAHAVIR KUMAR JAIN,UJJAIN vs. I.T.O. 1(1), UJJAIN

In the result, All appeals of the assessee are partly allowed

ITA 424/IND/2023[2015-16]Status: DisposedITAT Indore31 May 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

rectification application u/s 154 before the AO but no avail. Thus, it is clear that by filing these appeals belatedly there was no malafide intention to take any undue advantage by assessee. The assessee has acted on the advice of the tax consultant for not filing the appeal within the period of limitation and therefore, in the facts and circumstances

MAHAVIR KUMAR JAIN,UJJAIN vs. ITO 1(1), UJJAIN

In the result, All appeals of the assessee are partly allowed

ITA 421/IND/2023[2012-13]Status: DisposedITAT Indore31 May 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

rectification application u/s 154 before the AO but no avail. Thus, it is clear that by filing these appeals belatedly there was no malafide intention to take any undue advantage by assessee. The assessee has acted on the advice of the tax consultant for not filing the appeal within the period of limitation and therefore, in the facts and circumstances

MAHAVIR KUMAR JAIN,UJJAIN vs. ITO 1(1), UJJAIN

In the result, All appeals of the assessee are partly allowed

ITA 422/IND/2023[2013-14]Status: DisposedITAT Indore31 May 2024AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

rectification application u/s 154 before the AO but no avail. Thus, it is clear that by filing these appeals belatedly there was no malafide intention to take any undue advantage by assessee. The assessee has acted on the advice of the tax consultant for not filing the appeal within the period of limitation and therefore, in the facts and circumstances

MAHAVIR KUMAR JAIN,UJJAIN vs. I.T.O. 1(1), UJJAIN

In the result, All appeals of the assessee are partly allowed

ITA 423/IND/2023[2014-15]Status: DisposedITAT Indore31 May 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

rectification application u/s 154 before the AO but no avail. Thus, it is clear that by filing these appeals belatedly there was no malafide intention to take any undue advantage by assessee. The assessee has acted on the advice of the tax consultant for not filing the appeal within the period of limitation and therefore, in the facts and circumstances

MAHAVIR KUMAR JAIN,UJJAIN vs. I.T.O. 1(1), UJJAIN

In the result, All appeals of the assessee are partly allowed

ITA 420/IND/2023[2010-11]Status: DisposedITAT Indore31 May 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 154

rectification application u/s 154 before the AO but no avail. Thus, it is clear that by filing these appeals belatedly there was no malafide intention to take any undue advantage by assessee. The assessee has acted on the advice of the tax consultant for not filing the appeal within the period of limitation and therefore, in the facts and circumstances

SHIPIJ RATHORE,INDORE vs. INCOME TAX OFFICER 1(2), INDORE

Appeal is allowed for statistical purpose

ITA 557/IND/2025[2021-2022]Status: DisposedITAT Indore19 Feb 2026AY 2021-2022
Section 143(1)Section 154Section 90

rectification-application u/s 154\nto AO seeking amendment of intimation u/s 143(1) for giving relief u/s 90/90A.\nHowever, the AO rejected assessee's application. Aggrieved, the assessee\ncarried matter in first-appeal before CIT(A) but did not get any relief. Now,\nthe assessee has come in next appeal before us.\n4.\nThe grievance of assessee in present case

SANTOSH RATHORE,INDORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, INDORE - 1, INDORE

Appeal is allowed

ITA 451/IND/2024[2015-16]Status: DisposedITAT Indore14 Oct 2025AY 2015-16
Section 139Section 143(2)Section 147Section 148Section 151Section 263

154. The\nbench minutely analysed law in this regard and applying the\nprinciple of 'coram non judice' and following aforesaid judgments of\nthe supreme court, it was held that if an assessee seeks to challenge\nthe reassessment proceedings as being without jurisdiction, when\naction for rectification is sought to be taken on the assumption of the\nvalidity of the reassessment

MADHO BIHARI AGRAWAL,BURHANPUR vs. ACIT CIRCLE - 4(1), INDORE

Appeal is allowed

ITA 845/IND/2024[2016-17]Status: DisposedITAT Indore30 Oct 2025AY 2016-17
Section 139Section 143(2)Section 154Section 194HSection 69C

rectification-order dated 23.12.2022 passed by learned ITO-Circle-4(1), Indore [“AO”] u/s 154/143(3) of Income-tax Act, 1961 [“the Act"] for Assessment-Year [“AY”] 2016-17, the assessee has filed this appeal on following grounds:\n“1.The Ld. CIT(A) NFAC has erred in upholding the addition of Rs.1,46,13,858/- as income u/s

ANAMIKA GARG ,DEWAS vs. CIT, UJJAIN

ITA 214/IND/2020[2015-16]Status: DisposedITAT Indore02 Jan 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2015-16 Smt. Anamika Garg, Pcit, 117, Tukoganj Marg, Ujjain बनाम/ Nayapura, Vs. Dewas (Assessee / Appellant) (Revenue / Respondent) Pan: Aiwpg 3922 D Assessee By Shri Suresh Gupta, Ar Revenue By Ms. Simran Bhullar, Cit Dr Date Of Hearing 02.11.2023 Date Of Pronouncement 02.01.2024

Section 143(3)Section 263Section 54B

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp

M/S M.P.WAREHOUSING & LOGISTIC CORPORATION,BHOPAL vs. THE PR CIT-1, BHOPAL

In the result, the appeal is allowed

ITA 106/IND/2021[2015-16]Status: DisposedITAT Indore31 Mar 2023AY 2015-16

Bench: Ms. Suchitra Kamble & Shri B.M. Biyaniassessment Year: 2015-16 M/S M.P. Warehousing Pr. Cit-1 & Logistic Corporation, Bhopal बनाम/ Office Complex, Block-1, Gautam Nagar, Vs. Bhopal (Appellant / Assessee) (Respondent / Revenue) Pan: Aadcm 7742 B Assessee By Shri S.S. Deshpande, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 20.03.2023 Date Of Pronouncement 31.03.2023

Section 143(3)Section 263Section 36(1)(va)Section 43B

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp

M/S DBL TIKAAMGARH NOWGON,BHOPAL vs. PR CIT -1, BHOPAL

ITA 145/IND/2020[2015-16]Status: DisposedITAT Indore31 Jul 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

For Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 263

reassess the earlier assessment in terms of section 147 or carry out Page 8 of 10 M/s DBL vs. Pr. CIT I, Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 rectification u/s 154

M/S DBL BETUL SARMI TOLLWAYAS,BHOPAL vs. PR CIT-1, INDORE

ITA 144/IND/2020[201516]Status: DisposedITAT Indore31 Jul 2023

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

For Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 263

reassess the earlier assessment in terms of section 147 or carry out Page 8 of 10 M/s DBL vs. Pr. CIT I, Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 rectification u/s 154

M/S DBL ASHOKNAGAR VIDISHA TOLLWAYS LTD,BHOPAL vs. PR CIT-1, BHOPAL

ITA 146/IND/2020[2015-16]Status: DisposedITAT Indore31 Jul 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

For Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 263

reassess the earlier assessment in terms of section 147 or carry out Page 8 of 10 M/s DBL vs. Pr. CIT I, Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 rectification u/s 154

M/S DBL JAORA SAIANA TOLLWAYA LTD,BHOPAL vs. PR CIT-1, BHOPAL

ITA 147/IND/2020[2015-16]Status: DisposedITAT Indore31 Jul 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

For Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 263

reassess the earlier assessment in terms of section 147 or carry out Page 8 of 10 M/s DBL vs. Pr. CIT I, Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 rectification u/s 154

SHAILESH KALWADIA (HUF),UJJAIN vs. INCOME TAX OFFICER, BPL-C(91)(1), BHOPAL

The appeal of the assessee is allowed for statistical purpose

ITA 464/IND/2025[2013-14]Status: DisposedITAT Indore27 Mar 2026AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 147Section 246ASection 250Section 253

reassessment proceedings under section 147/148 based solely on third-party information, without granting the assessee any opportunity for cross-examination or verification of such information, which is bad in law. 2. Addition of?18,42,978/-on Account of Alleged Bogus LTCG: The learned CIT(A) has erred in confirming the addition of?18,42,978/- as unexplained income under

SHAILESH KALWADIA (HUF) ,UJJAIN vs. INCOME TAX OFFICER BPL-C-(91)(1), UJJAIN

The appeal of the assessee is allowed for statistical purpose

ITA 160/IND/2026[2013-14]Status: DisposedITAT Indore27 Mar 2026AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 147Section 246ASection 250Section 253

reassessment proceedings under section 147/148 based solely on third-party information, without granting the assessee any opportunity for cross-examination or verification of such information, which is bad in law. 2. Addition of?18,42,978/-on Account of Alleged Bogus LTCG: The learned CIT(A) has erred in confirming the addition of?18,42,978/- as unexplained income under

BABITA CHELAWAT,INDORE vs. DCIT/ACIT 1(1), INDORE, INDORE

The appeal of the assessee is allowed & the impugned order is set aside

ITA 611/IND/2025[2012-13]Status: DisposedITAT Indore27 Mar 2026AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250Section 253

154. However, the rectification request does not impact the correctness of the assessment order. Further, the department has launched a portal for easy, transparent and effective communication with the taxpayers and order and notices are bring served on that portal which is a legally complaint system. Hence, there is no merit in the ground raised by the appellant and hence