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

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Key Topics

Section 26333Section 15418Section 143(3)14Addition to Income13Rectification u/s 1547Cash Deposit6Condonation of Delay6Revision u/s 2636Section 1485Section 147

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. ITO 1(1), UJJAIN

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

ITA 421/IND/2023[2012-13]Status: DisposedITAT Indore
4
Section 2533
Section 2503
31 May 2024
AY 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 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

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. 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 Indore31 May 2024AY 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 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

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 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

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

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

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

SHRI VIKRAM SINGH PUAR SON & LR OF LATE TUKOJI ROA PUAR,DEWAS vs. THE PR. CIT-1, BHOPAL

The appeal of the assessee is hereby allowed

ITA 407/IND/2016[2011-12]Status: DisposedITAT Indore20 May 2020AY 2011-12

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2011-12 Vikram Singh Paur, Pr. Cit Son & Legal Heir Of Late Shri Bhopal बनाम/ Tukoji Rao Puar Vs. Dewas (Appellant) (Revenue ) P.A. No.Agdpp8186B Appellant By Shri Girish Agrawal, Ca Revenue By Shri S.B. Prasad, Cit-Dr Date Of Hearing: 27.01.2020 Date Of Pronouncement: 20 .05.2020 आदेश / O R D E R Per Kul Bharat, J.M: This Appeal By The Assessee Is Directed Against Order Of Pr. Cit, Bhopal Dated 18.03.2016 For The Assessment Year

Section 263Section 292B

reassessment proceedings and same cannot be made applicable for revisional proceedings as contemplated under section 263 [In favour of assessee] 6. Assessee submits that the invalidity of passing of an order in the name of deceased assessee, Late Shri Tukoji Rao Puar even when the fact of death was informed cannot be rectified under the provisions of section 154. Reliance

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

SANDHYA SINGH ,BHOPAL vs. ITO (2)(3), BHOPAL

In the result, the appeal of the assessee in ITA No

ITA 585/IND/2025[2014-15]Status: DisposedITAT Indore17 Apr 2026AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Sandhya Singh Nfac, 121, Rohit Nagar, New Delhi बनाम/ Bawadia Kala, Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aycps9215K Assessee By Shri Gagan Tiwari & Ms. Priyal Jain, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 19.03.2026 Date Of Pronouncement 17.04.2026

Section 139Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 69A

u/s 148 of the Act after following due procedure for Α.Υ.2017-18.” 6. On a specific query raised by the Court, learned Senior Standing Counsel Ms. Mehta appearing for the respondent submitted that no notice under Sec.148A(b) of the Act was issued as per the directions of the Hon'ble Apex Court in the case of Union

M/S SHRI GURMUKHDAS CONTRACTORS P LTD,BHOPAL vs. DCIT-CENRRAL-1, BHOPAL

In the result, Revenue’s appeals in I

ITA 208/IND/2020[2017-18]Status: DisposedITAT Indore14 Dec 2022AY 2017-18

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri Sunil Agrawal, ARFor Respondent: Assessee by
Section 127Section 132Section 143(3)Section 153Section 153ASection 153DSection 271A

u/s 153D of the Act, it would be appropriate to first visit the provisions of section 153D of the Act, which for the sake of completeness are reproduced below: "SECTION 153D. Prior approval necessary for assessment in cases of search or requisition [No order of assessment or reassessment shall be passed by an Assessing Officer below the rank of Joint