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20 results for “reassessment u/s 147”+ Section 133A(5)clear

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Key Topics

Section 14748Section 14821Section 26319Section 69A18Addition to Income14Section 143(3)12Survey u/s 133A12Reassessment11Section 68

SANJEEV AGRAWAL ,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL-2, BHOPAL

Appeal is allowed

ITA 38/IND/2024[2017-18]Status: DisposedITAT Indore21 Feb 2025AY 2017-18
Section 131Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 69C

reassessment proceedings.”\nThus, in the light of judicial rulings cited above, it is clear that the\nAO's action of resorting to re-assessment u/s 147 by-passing the\ncompulsory scrutiny mandated by CBDT Instruction, is invalid and hence\nthe assessment framed by AO u/s 147 cannot be sustained. Therefore, we\nquash the order passed by AO. The assessee succeeds

6
Section 153C6
Disallowance6
Section 69C5

NARENDRA KUMAR AGRAWAL,BURHANPUR vs. PCIT INDORE-1, INDORE

In the result, appeal of the assessee is allowed

ITA 345/IND/2024[2016-17]Status: DisposedITAT Indore29 Aug 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninarendra Kumar Agrawal Pcit (1) 203, Ck Campus Aaykar Bhawan Bahadarpur Road Vs. Indore Burhanpur (Appellant / Assessee) (Respondent/ Revenue) Pan: Adapa0131B Assessee By Shri S.N. Agrawal & Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 20.08.2024 Date Of Pronouncement 29.08.2024

Section 142(1)Section 143(3)Section 144BSection 147Section 148Section 263

5,35,510/-. The case was selected for limited scrutiny and assessment was completed u/s 143(3) on 09.12.2018 accepting the returned income. In this connection, information available in Insight portal shows that in pursuance to survey action u/s 133A by Investigation Unit Mumbai under Project Falcon, it was found that various brokers are engaged in facilitating fictitious losses through

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

u/s\n263 is also not sustainable. We therefore quash the revision-order.\n30.\nSince, the order of revision passed by PCIT u/s 263 of the Act has\nbeen quashed on the issue of reopening u/s 148 of the Act, we are not\nrequired to examine the merit of revision-order. Accordingly, the same is not\nadjudicated.\n31. Resultantly, this appeal

AJIT KUMAR JAIN,BHOPAL vs. THE ITO 1(1), BHOPAL

In the result, the appeal of the Assessee is allowed

ITA 349/IND/2020[2006-07]Status: DisposedITAT Indore10 Nov 2022AY 2006-07

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyaniassessment Year: 2006-07

Section 133ASection 147Section 148Section 234ASection 234BSection 69C

133A was conducted on the premises of Sarvja Jankalyan Parmarthik Nyas on 09.08.2005. During the course of such proceedings, some documents/loose papers were found and impounded from briefcase of Shri Ram Vilas Vijayvarigya. On perusal of the loose papers, it was found that these documents record amounts received by People’s College of Medical Science and Research Centre in lieu

NILIMA KOTHARI,INDORE vs. THE INCOME TAX OFFICER, NATIONAL FACELESS ASSTT. CENTRE, INDORE

In the result appeal of the assessee is allowed as per terms indicated above

ITA 259/IND/2024[2016-17]Status: DisposedITAT Indore20 Sept 2024AY 2016-17

Bench: Shri Manish Boradsmt. Neelima Kothari, Income Tax Officer, 601, N.R.K. Villas, Delhi Vs. 22/2 Manoramaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Adnpk7832J Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 08.08.2024 Date Of Pronouncement 20.09.2024

Section 10(38)Section 147Section 148Section 151Section 68

reassessment proceedings firstly, stating that the proceedings are time barred secondly, that no valid approval u/s 148 of the Act has been taken and thirdly, there was no proper reason to believe about escapement of income for initiating proceedings u/s 148 of the Act. Submissions filed by the assesse on these three legal issues reads as under: 5 Smt. Nilima

ACIT (CENTRAL UJJAIN, UJJAIN vs. M/S ARIHANT FUTURE AND COMMODITIES LTD, INDORE

ITA 734/IND/2019[2016-17]Status: DisposedITAT Indore31 Mar 2022AY 2016-17

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

Section 143(3)Section 147Section 36Section 36(1)(ii)Section 37(1)Section 68Section 69C

133A was carried out on 29.12.2015 which continued till 02.01.2016. Regular assessment u/s 143(3) was made by Deputy Commissioner of Income Tax (Central – 1), Indore on 16.12.2016 wherein the returned income was accepted. Later on the case was reopened u/s 148 vide notice dated 10.12.2018 and the reassessment proceedings were completed by passing the order u/s 143(3) r.w.s

THE ACIT, CENTRAL - UJJAIN, INDORE vs. M/S ARIHANT FUTURE & COMMADITIES LTD , INDORE

ITA 10/IND/2021[2014-15]Status: DisposedITAT Indore21 Mar 2022AY 2014-15

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

Section 143(3)Section 147Section 36Section 36(1)(ii)Section 37(1)Section 68Section 69C

133A was carried out on 29.12.2015 which continued till 02.01.2016. Regular assessment u/s 143(3) was made by Deputy Commissioner of Income Tax (Central – 1), Indore on 16.12.2016 wherein the returned income was accepted. Later on the case was reopened u/s 148 vide notice dated 10.12.2018 and the reassessment proceedings were completed by passing the order u/s 143(3) r.w.s

THE ACIT ,CENTRAL-UJJAIN, INDORE vs. M/S ARIHANT CAPITALS MARKETS LTD , INDORE

ITA 11/IND/2021[2014-15]Status: DisposedITAT Indore21 Mar 2022AY 2014-15

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

Section 143(3)Section 147Section 36Section 36(1)(ii)Section 37(1)Section 68Section 69C

133A was carried out on 29.12.2015 which continued till 02.01.2016. Regular assessment u/s 143(3) was made by Deputy Commissioner of Income Tax (Central – 1), Indore on 16.12.2016 wherein the returned income was accepted. Later on the case was reopened u/s 148 vide notice dated 10.12.2018 and the reassessment proceedings were completed by passing the order u/s 143(3) r.w.s

SUNIL SAHU,RAIPUR vs. ACIT(CENTRAL)-2, BHOPAL

ITA 156/IND/2019[2010-11]Status: DisposedITAT Indore30 Nov 2022AY 2010-11

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Revenue byFor Respondent: Shri Ashish Porwal, Sr.D.R
Section 143(3)Section 147Section 69A

147 of the I.T. Act, 1961, in a Lawful manner and as such the same are liable to be quashed. In view of the above discussion, we set aside the Orders of the authorities below and quash the reopening of the assessment. Resultantly, all additions stand deleted. Since we have quashed the reopening of the assessment, therefore, there is nothing

THE ACIT CENTRAL -1, BHOPAL vs. SHRI SUNIL SAHU , RAIPUR

ITA 355/IND/2020[2013-14]Status: DisposedITAT Indore30 Nov 2022AY 2013-14

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Revenue byFor Respondent: Shri Ashish Porwal, Sr.D.R
Section 143(3)Section 147Section 69A

147 of the I.T. Act, 1961, in a Lawful manner and as such the same are liable to be quashed. In view of the above discussion, we set aside the Orders of the authorities below and quash the reopening of the assessment. Resultantly, all additions stand deleted. Since we have quashed the reopening of the assessment, therefore, there is nothing

SUNIL SAHU,RAIPUR vs. ACIT(CENTRAL)-2, BHOPAL

ITA 157/IND/2019[2011-12]Status: DisposedITAT Indore30 Nov 2022AY 2011-12

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Revenue byFor Respondent: Shri Ashish Porwal, Sr.D.R
Section 143(3)Section 147Section 69A

147 of the I.T. Act, 1961, in a Lawful manner and as such the same are liable to be quashed. In view of the above discussion, we set aside the Orders of the authorities below and quash the reopening of the assessment. Resultantly, all additions stand deleted. Since we have quashed the reopening of the assessment, therefore, there is nothing

SUNIL SAHU,RAIPUR vs. ACIT(CENTRAL)-2, BHOPAL

ITA 158/IND/2019[2012-13]Status: DisposedITAT Indore30 Nov 2022AY 2012-13

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Revenue byFor Respondent: Shri Ashish Porwal, Sr.D.R
Section 143(3)Section 147Section 69A

147 of the I.T. Act, 1961, in a Lawful manner and as such the same are liable to be quashed. In view of the above discussion, we set aside the Orders of the authorities below and quash the reopening of the assessment. Resultantly, all additions stand deleted. Since we have quashed the reopening of the assessment, therefore, there is nothing

HARISH CHANDRA PUROHIT,RATLAM vs. INCOME TAX OFFICER - 1, RATLAM, RATLAM

In the result- the Impugned order is set aside as and by way

ITA 221/IND/2025[2018-19]Status: DisposedITAT Indore09 Jan 2026AY 2018-19

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshiassessment Year: 2018-19

Section 142(1)Section 147Section 148Section 148ASection 250Section 253Section 69A

reassessment proceedings are wrong and contrary to the provisions of Section 147, Section 148, Section 148A and Section 151 of the Act. The appellant craves leave to add, alter, amend or withdraw any of the grounds of appeal.” 3. Record of Hearing 3.1 That the hearing in the matter took place before this Tribunal on 19.11.2025 when

RAKESH KUMAR SOMANI,KHANDWA vs. ITO-1, KHANDWA, KHANDWA

In the result, both the appeals are dismissed

ITA 215/IND/2024[2011-12]Status: DisposedITAT Indore31 Jul 2024AY 2011-12

Bench: Shri Manish Boradrakesh Kumar Somani, Ito-1, 10, Ramganj Road, Khandwa Vs. Khandwa (M.P) (Appellant / Assessee) (Respondent/ Revenue) Pan: Azgps3988J Assessee By Shri S.N. Agrawal, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 29.07.2024 Date Of Pronouncement 31.07.2024 O R D E R

Section 133ASection 147

133A of the Act was conducted at the business premises of the Rakesh Kumar Somani assessee on 27.7.2012 and so far as the relevant appeal is concerned a Saudha Chitthi dated 30.09.2010 was found at his premises which contained the transaction of sale of agriculture land situated at Gram Torni, Tehsil Khandwa for a consideration of Rs.91

DEPUTY COMMISSIONER OF INCOME TAX-2 (1), INDORE, INDORE vs. M/S DTHRI HEALTH CARE PVT. LTD. (M.P), INDORE

In the result Ground No.2 of the revenue stands

ITA 604/IND/2017[2013-14]Status: DisposedITAT Indore02 Jan 2019AY 2013-14

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2013-14 Dcit-2(1), M/S. Dthri Health Care Indore Vs. Pvt. Ltd (M.P), Pu-4, Scheme No.54, Near A.B. Road, Indore (Appellant) (Respondent ) Pan No.Aabcd4095N Revenue By Shri R.P. Mourya, Sr.Dr Assessee By S/Shri Sumit Neema, Sr.Adv & Gagan Tiwari, Adv Date Of Hearing 17.12.2018 Date Of Pronouncement 02.01.2019 O R D E R

Section 115BSection 133ASection 143(3)Section 147Section 148

147 of the Act were Dthri Health Care Pvt. Ltd initiated by issuing notice u/s 148 of the Act dated 15.2.2016 duly served upon the assessee after recording reason of satisfaction for reopening the case that income has escaped assessment within the meaning of section 147/148. During the course of reassessment proceedings Learned Assessing Officer (In short ‘Ld. A.O’) observed

SHRI MANUEL MEDA,BHOPAL vs. THE ACIT-2(1), BHOPAL

In the result, Cross Objection by the assessee in CO

ITA 196/IND/2016[2007-08]Status: DisposedITAT Indore18 Jul 2019AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradit(Ss)A No.89/Ind/2016 Assessment Year: 2006-07 Acit 1(1) M/S. L.N. Gupta Mathur Vaishya बनाम/ Charitable Trust Bhopal Vs. E-1/55, Arera Colony, Bhopal (Revenue) (Respondent) Pan: Aaatl4820E

Section 11(2)Section 12Section 12ASection 132Section 153CSection 234B

5. From perusal of the above grounds we find that the assessee’s Cross Objection in CO No.31/Ind/2016 and in assessee’s appeal in IT(SS)A Nos.195 & 196/Ind/2016 common issue has been raised contending that the assessment proceedings carried out u/s 153C of the Act are bad in law and are without jurisdiction since no proper satisfaction was recorded

KHOJEMA BOHRA,INDORE vs. INCOME TAX OFFICER, NFAC, DELHI

Appeals are allowed

ITA 812/IND/2024[2014-2015]Status: DisposedITAT Indore22 Jan 2026AY 2014-2015
Section 115BSection 147Section 250Section 253Section 271(1)(c)Section 68

147 r.w.s 144B of\nthe Act the total income of the assessee was computed &\nassessed at Rs.29,56,940/-. The total income as per the\nreturn of income was at Rs.6,56,940/-. The addition u/s 68\nof Rs.23,00,000/- was made. The aforesaid assessment order\nis hereinafter referred to as the \"Impugned Assessment\nOrder\". The relevant portion

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 219/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

147 of the Act was initiated against the assessee and the AO passed reassessment order with the conclusion that the appellant has earned sufficient profits in MCX and NCDEX and incurred losses on NMCE platform so as to set off the profits against such losses and disallowed the impugned amount. Before the authorities below it was contended by the assessee

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 218/IND/2021[2012-13]Status: DisposedITAT Indore30 Jan 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

147 of the Act was initiated against the assessee and the AO passed reassessment order with the conclusion that the appellant has earned sufficient profits in MCX and NCDEX and incurred losses on NMCE platform so as to set off the profits against such losses and disallowed the impugned amount. Before the authorities below it was contended by the assessee

DCIT-3(1), BHOPAL, BHOPAL vs. MANIDHARI JEWELLERS, BHOPAL

The appeal are allowed

ITA 533/IND/2024[2017-18]Status: DisposedITAT Indore09 May 2025AY 2017-18

Bench: Bhagirath Mal Biyani & Shri Paresh M Joshidcit-3(1), Manidhari Jewellers, बनाम/ Bhopal Room No.202, Vs. Metro Walk Bulding, Bitten Market, Arera Colony, Bhopal (Pan: Abafm6546L) (Revenue) (Respondent) Assessee By Shri Yashwant Sharma, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2025 Date Of Pronouncement 09.05.2025 आदेश/ O R D E R

Section 04Section 139Section 143(3)Section 147Section 148Section 24Section 25Section 250Section 253

Section 253 of the Income Tax Act, 1961 (hereinafter referred to as the “Act” for sake of brevity) before this Tribunal. The revenue is aggrieved by the order bearing Number ITBA/NFAC/S/250/2024- 25/1064957812(1) dated 17.05.2024 of Ld. CIT(A) passed u/s 250 of the Act which is hereinafter referred to as the “Impugned order”. The relevant Assessment Year