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46 results for “reassessment u/s 147”+ Section 263(1)clear

Sorted by relevance

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Key Topics

Section 263133Section 14790Section 143(3)75Section 14834Addition to Income24Reassessment23Revision u/s 26317Section 153A14Section 68

AGROH INFRASTRUCTURE DEVELOPERS P LTD,MHOW vs. PR CIT CENTRAL CIRCLE BHOPAL, BHOPAL

In the result, appeal of assessee is allowed

ITA 95/IND/2021[2008-09]Status: DisposedITAT Indore11 Apr 2023AY 2008-09

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Agroh Infrastructure Pr. Cit (Central) Developers Pvt. Ltd. Bhopal Aqua Point, A.B.Road, Vs. Umaria, Mhow, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaeca 2752 L Assessee By Shri Manish Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.04.2023 Date Of Pronouncement 11.04.2023

Section 143(1)Section 143(3)Section 147Section 148Section 263

1) and thereafter, it was reopened by issuing notice u/s 148 of the Income Tax Act and reassessment order was passed on 03.03.2016. Thereafter, Pr. CIT invoked the provisions of section 263 against the reassessment order dated 03.03.2016, on the issue of loan transactions found recorded in the seized material but were not considered and added

Showing 1–20 of 46 · Page 1 of 3

14
Section 50C12
Disallowance12
Section 5411

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

reassessment order. Once, the\nreassessment order per se framed by the Ld. AO is not sustainable in the eyes\nof law, any revision order passed thereon u/s 263 seeking to revise such\nunsustainable order cannot be accepted in the eyes of law and consequential\nrevision order also passed u/s 263 of the Act deserves to be quashed. Our\nview

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

1 That on the facts and in the circumstances of the case and in law, the Ld. Pr. CIT erred in setting aside the Assessment order as passed by the Ld. A.O. U/s 147 of the Act on 28.03.2022 and invoking proceedings u/s 263 of the Act even when the said assessment order as passed by the ITANo.345/Ind/2024 Narendra Kumar

SHRI BHAWANI SHANKAR PARASHAR,INDORE vs. THE DCIT/ACIT 1 (2), INDORE

In the result, appeal of assessee is allowed

ITA 411/IND/2022[2012-13]Status: DisposedITAT Indore21 Jun 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Bhawani Shankar Pr. Cit-1 Prashar Indore 28, Lasudia Mori, Vijay Vs. Nagar, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Bgbpp 2475 G Assessee By Shri S.N. Agrawal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 02.05.2023 Date Of Pronouncement 21.06.2023

Section 263

reassessment proceedings since those notices were in their knowledge as they were served physically. However, show cause notices and order passed by the Ld Principal Commissioner of Income Tax-1, Indore was never served physically to the appellant as a result of which the appellant was totally unaware of the fact that show cause notices had been issued and order

S GANDHI JEWELLERY PRIVATE LIMITED,INDORE vs. PCIT-1, INDORE, INDORE

Appeal is allowed

ITA 311/IND/2024[2017-18]Status: DisposedITAT Indore21 Feb 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Dinesh Mohan Sinhaassessment Year: 2017-18 S. Gandhi Jewellery Pcit-1, Private Limited, Indore C/O Adv. Hitesh Chimnani, बनाम/ Ug-37 Trade Centre, Vs. 18, South Tukoganj, Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aamcs1613G Assessee By Shri Hitesh Chimnani, Ar Revenue By Shri Ram Kumar Yadav, Sr. Dr Date Of Hearing 10.02.2025 Date Of Pronouncement 21.02.2025

Section 143(2)Section 143(3)Section 147Section 263

147. Therefore, the order of re- Page 3 of 12 S Gandhi Jewellery Private Limited ITA No. 311/Ind/2024 – AY 2017-18 assessment passed by AO is erroneous-cum-prejudicial to the interest of revenue. The PCIT has also observed that since the section 263 has been amended and Explanation 2 as reproduced below had been introduced therein, the assessment-order

SHRI ARVIND KUMAR SINGH ,BHOPAL vs. THE PR CIT-1, BHOPAL

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

ITA 133/IND/2021[2013-14]Status: DisposedITAT Indore10 Nov 2022AY 2013-14

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S.S. Deshpandey, C.AFor Respondent: Shri P.K. Mitra, CIT-DR
Section 143(3)Section 147Section 148Section 263Section 69A

1. Out of unexplained money u/s69A Rs.&4,87,360/- Assessed Income Rs-70,23,010/- 7. The appellant filed an appeal before the Ld.CIT(A), Bhopal vide Ack. No. 383778091020218 dated 02.02.2018 contesting the addition made in the order under Section 147 of the Act. 8. Subsequently, a notice dated 23.10.2019 was issued to the appellant under section 263

SHRI ARVIND KUMAR SINGH ,BHOPAL vs. THE PR CIT-1, BHOPAL

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

ITA 132/IND/2021[2012-13]Status: DisposedITAT Indore10 Nov 2022AY 2012-13

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S.S. Deshpandey, C.AFor Respondent: Shri P.K. Mitra, CIT-DR
Section 143(3)Section 147Section 148Section 263Section 69A

1. Out of unexplained money u/s69A Rs.&4,87,360/- Assessed Income Rs-70,23,010/- 7. The appellant filed an appeal before the Ld.CIT(A), Bhopal vide Ack. No. 383778091020218 dated 02.02.2018 contesting the addition made in the order under Section 147 of the Act. 8. Subsequently, a notice dated 23.10.2019 was issued to the appellant under section 263

SHRI ARVIND KUMAR SINGH ,BHOPAL vs. THE PR CIT-1, BHOPAL

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

ITA 134/IND/2021[2014-15]Status: DisposedITAT Indore10 Nov 2022AY 2014-15

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S.S. Deshpandey, C.AFor Respondent: Shri P.K. Mitra, CIT-DR
Section 143(3)Section 147Section 148Section 263Section 69A

1. Out of unexplained money u/s69A Rs.&4,87,360/- Assessed Income Rs-70,23,010/- 7. The appellant filed an appeal before the Ld.CIT(A), Bhopal vide Ack. No. 383778091020218 dated 02.02.2018 contesting the addition made in the order under Section 147 of the Act. 8. Subsequently, a notice dated 23.10.2019 was issued to the appellant under section 263

SHRI ARVIND KUMAR SINGH ,BHOPAL vs. THE PR CIT-1, BHOPAL

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

ITA 135/IND/2021[2015-16]Status: DisposedITAT Indore10 Nov 2022AY 2015-16

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S.S. Deshpandey, C.AFor Respondent: Shri P.K. Mitra, CIT-DR
Section 143(3)Section 147Section 148Section 263Section 69A

1. Out of unexplained money u/s69A Rs.&4,87,360/- Assessed Income Rs-70,23,010/- 7. The appellant filed an appeal before the Ld.CIT(A), Bhopal vide Ack. No. 383778091020218 dated 02.02.2018 contesting the addition made in the order under Section 147 of the Act. 8. Subsequently, a notice dated 23.10.2019 was issued to the appellant under section 263

SUNAYANA INVESTMENT COMPANY LTD,INDORE vs. PCIT-1, INDORE, INDORE

The appeal of the assessee is allowed

ITA 218/IND/2024[2017-18]Status: DisposedITAT Indore11 Oct 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisunayana Investment Company Pcit-1, Ltd, Indore Part-B Of 417 Chetak Centre Annex, Vs. R.N.T. Marg, Near Hotel Shreemaya, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaucs5765M Assessee By Shri Sohit Gupta & Ms. Alifiya Ali, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 08.10.2024 Date Of Pronouncement 11.10.2024 O R D E R

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 263

1. That the order u/s 263 of the Act passed by Ld. PCIT is bad in law and is passed in contravention of prevailing law as well as facts of the case, therefore liable to be annulled. 2. That the proceedings u/s 263 of the Act initiated in the case of assessee are void-ab-initio invalid as has been

SHRI PREMNARAYAN,HARSUD, KHANDWA vs. THE PCIT-1, INDORE, INDORE

In the result, appeals of the assesse in ITANo

ITA 262/IND/2024[2014-15]Status: DisposedITAT Indore30 Aug 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Premnarayan Pcit (1) 31, Somgaon Khurd, Aaykar Bhawan Harsud, Vs. Indore Khandwa (Appellant / Assessee) (Respondent/ Revenue) Pan: Cjzpp1164J Smt. Sharda Pcit (1) A/45, Naya Harsud, Aaykar Bhawan Vs. Khandwa Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Fdxps2997P Assessee By Shri S.N. Agrawal & Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 21.08.2024 Date Of Pronouncement 30.08.2024

Section 144BSection 147Section 148Section 2(14)(iii)Section 263Section 54B

1 That on the facts and in the circumstances of the case and in law, the Ld. Pr. CIT erred in setting- aside the order passed by the Assessing Officer by invoking the provisions of section 263 of the Income-Tax Act, 1961 even when the assessment order was passed after conducting necessary enquiries and after due application of mind

SMT. SHARDA,HARSUD, KHANDWA vs. THE PCIT-1, INDORE, INDORE

In the result, appeals of the assesse in ITANo

ITA 263/IND/2024[2014-15]Status: DisposedITAT Indore30 Aug 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Premnarayan Pcit (1) 31, Somgaon Khurd, Aaykar Bhawan Harsud, Vs. Indore Khandwa (Appellant / Assessee) (Respondent/ Revenue) Pan: Cjzpp1164J Smt. Sharda Pcit (1) A/45, Naya Harsud, Aaykar Bhawan Vs. Khandwa Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Fdxps2997P Assessee By Shri S.N. Agrawal & Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 21.08.2024 Date Of Pronouncement 30.08.2024

Section 144BSection 147Section 148Section 2(14)(iii)Section 263Section 54B

1 That on the facts and in the circumstances of the case and in law, the Ld. Pr. CIT erred in setting- aside the order passed by the Assessing Officer by invoking the provisions of section 263 of the Income-Tax Act, 1961 even when the assessment order was passed after conducting necessary enquiries and after due application of mind

LATE SMT SUSHILA BISARYA, BHOPAL vs. THE PR CIT-1, BHOPAL

In the result, we are Shri Jignesh Lilachand Shah vs

ITA 89/IND/2021[2010-11]Status: DisposedITAT Indore16 Aug 2023AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanilate Smt. Sushila Bisarya Pr. Cit-1 L.H. Pramod Bisarya Bhopal Vs. 125 Malviya Nagar, Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aewpb 2587 D Assessee By Shri Gagan Tiwari, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 10.08.2023 Date Of Pronouncement 16.08.2023

Section 147Section 148Section 263

section 263 when the assessment order itself is not valid and sustainable in law. The Pr. CIT did not accept these objections of the assesse and passed the impugned revision order whereby the assessment order passed u/s 147 r.w.s. 143(3) dated 31st July 2017 was held to be erroneous and prejudicial to the interest of the revenue and consequently

PRASAM RAKESH CHOUDHARY,GIRNAR SOCIETY, BAPURAO GALLI, ITWARI, NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, BHOPAL , BHOPAL

Appeal is dismissed

ITA 529/IND/2025[2018 -2019]Status: HeardITAT Indore22 Dec 2025

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

Section 10Section 271(1)(c)Section 43(1)

263, the AO re-framed assessment wherein he disallowed assessee’s claim, (iii) the AO thereafter imposed penalty u/s 271(1)(c) treating it as a case of furnishing inaccurate particulars by assessee. Thus, the penalty imposed by AO hinges on the point that the assessee had furnished inaccurate particulars of income by making wrong claim of depreciation. However

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), BHOPOAL, BHOPAL vs. M/S RASHTRIYA TAKNIKI SHIKSHAK PRASHIKSHAN EVAM ANUNSANDHAN SANSTHAN, BHOPAL

Appeal is dismissed

ITA 509/IND/2025[2014-15]Status: DisposedITAT Indore22 Dec 2025AY 2014-15

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

Section 10Section 271(1)(c)Section 43(1)

263, the AO re-framed assessment wherein he disallowed assessee’s claim, (iii) the AO thereafter imposed penalty u/s 271(1)(c) treating it as a case of furnishing inaccurate particulars by assessee. Thus, the penalty imposed by AO hinges on the point that the assessee had furnished inaccurate particulars of income by making wrong claim of depreciation. However

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ITO-2(1), BHOPAL

In the result, appeal for A

ITA 277/IND/2023[2014-15]Status: DisposedITAT Indore30 May 2024AY 2014-15

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

Section 143(3)Section 147Section 148Section 271E

reassessment. 2. On the facts and in the circumstances of the case, the honourable CIT(A) was not justified in upholding that the receipt from job work of mixing of rubber at Rs. 34,19,894 was not the business receipts/income and in confirming the same was income from other sources. 3.On the facts and in the circumstances

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ADDL. CIT-RANGE-3, BHOPAL

In the result, appeal for A

ITA 276/IND/2023[2009-10]Status: DisposedITAT Indore30 May 2024AY 2009-10

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

Section 143(3)Section 147Section 148Section 271E

reassessment. 2. On the facts and in the circumstances of the case, the honourable CIT(A) was not justified in upholding that the receipt from job work of mixing of rubber at Rs. 34,19,894 was not the business receipts/income and in confirming the same was income from other sources. 3.On the facts and in the circumstances

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ACIT-3(1), BHOPAL

In the result, appeal for A

ITA 275/IND/2023[2008-09]Status: DisposedITAT Indore30 May 2024AY 2008-09

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

Section 143(3)Section 147Section 148Section 271E

reassessment. 2. On the facts and in the circumstances of the case, the honourable CIT(A) was not justified in upholding that the receipt from job work of mixing of rubber at Rs. 34,19,894 was not the business receipts/income and in confirming the same was income from other sources. 3.On the facts and in the circumstances

THE NIMAR EDUCATIONAL SOCIETY,KHANDWA vs. THE CIT (EXEMPTION), BHOPAL, BHOPAL

Appeal is partly allowed

ITA 343/IND/2024[2017-18]Status: DisposedITAT Indore20 Sept 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 The Nimar Educational Cit(Exemption) , Society, Bhopal बनाम/ Harsud Road, Civil Lines, East Nimar, Vs. Khandwa (Assessee/Appellant) (Revenue/Respondent) Pan: Aabtt1409K Assessee By Shri S.N. Agrawal & Shri Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit Dr Date Of Hearing 20.08.2024 Date Of Pronouncement 20.09.2024

Section 10Section 11Section 12ASection 139Section 147Section 148Section 263Section 68

section 263 of the Act on an issue which was not the subject matter of the reassessment of the proceedings. The decision rendered by the Tribunal takes note of the correct legal position and, therefore, does not call for any interference. Page 6 of 11 The Nimar Educational Society, Khandwa ITA No. 343/Ind/2024 – AY 2017-18 [Emphasis supplied] Another decision

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

1) of section 263 of the Act is an enabling provision which confers jurisdiction on the CIT to revise an assessment order which he considers erroneous and prejudicial to the interests of revenue. The process of revision u/s 263 of the Act initiates only when the CIT calls for and examines the record of any proceeding under this