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67 results for “reassessment u/s 147”+ Unexplained Investmentclear

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Key Topics

Section 147115Section 14874Section 143(3)64Addition to Income63Section 6833Section 69A27Reassessment26Section 153A22Section 143(2)

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

147 of the Act by issuing notice u/s 148 of the Act on 31.03.2021. The assessee even in the reassessment proceedings has filed the submissions dated 17.12.2021 placed at page No. 115 to 117 of the 7 Sunayana Investment Company Limited paper book wherein the assessee has submitted that the assessee has not taken any accommodation entry from Shri Jignesh

Showing 1–20 of 67 · Page 1 of 4

20
Unexplained Investment19
Section 142(1)18
Reopening of Assessment16

M/S SHIVALIKA REALITIES P LTD,INDORE vs. ITO 5(1) , INDORE

In the result of appeals of the assessee for AY 2008-09 and AY 2009-10 vide ITA no

ITA 94/IND/2018[2009-10]Status: DisposedITAT Indore04 Oct 2021AY 2009-10

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing Assessment Year: 2008-09 & Assessment Year: 2009-10

Unexplained investment in purchase of Rs. 10,63,37,500/- land on substantive basis Total Assessed Income Rs. 10,63,37,500/- Rounded off Rs. 10,63,37,500/- Being aggrieved with the assessment orders for both the 6. A.Y. 2008-09 and A.Y. 2009-10, the appellant company preferred appeals before the learned CIT(A)-2, Indore. During

M/S SHIVALIKA REALITIES P LTD,INDORE vs. ITO 5(1) , INDORE

In the result of appeals of the assessee for AY 2008-09 and AY 2009-10 vide ITA no

ITA 95/IND/2018[2008-09]Status: DisposedITAT Indore04 Oct 2021AY 2008-09

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing Assessment Year: 2008-09 & Assessment Year: 2009-10

Unexplained investment in purchase of Rs. 10,63,37,500/- land on substantive basis Total Assessed Income Rs. 10,63,37,500/- Rounded off Rs. 10,63,37,500/- Being aggrieved with the assessment orders for both the 6. A.Y. 2008-09 and A.Y. 2009-10, the appellant company preferred appeals before the learned CIT(A)-2, Indore. During

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-1, INDORE vs. SHRI RITESH JAIN, INDORE

ITA 794/IND/2018[2010-11]Status: DisposedITAT Indore12 Jan 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani & It(Ss)Ano.14/Ind/2022 (Assesssment Year 2011-12

Section 139Section 143(2)Section 147Section 148

reassessment framed by the AO u/s 147 r.w. section 143(3) without a valid notice u/s 143(2) is not valid and liable to be quashed as held by the Hon’ble Supreme Court in case of ACIT vs. Hotel Blue Moon 321 ITR 362. 7. The next objection of the assessee is against the validity of the order passed

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

unexplained expenditure u/s 69C of the Income Tax Act, 1961\nbased on a print out of a hand written document impounded from the i-phone,\nsuch findings are wholly injudicious and opposed to facts and, therefore, be\nquashed and the addition of Rs.14,20,00,000/- as per para 8 of the order is\nwholly unjustified and unlawful and, therefore

ANIL FIROJIYA,BHAKT NAGAR UJJAIN vs. DY COMMISIONER OF INCOME TAX, AAYKAR BHAWAN

Appeal is allowed for statistical purpose

ITA 413/IND/2023[2018-19]Status: DisposedITAT Indore12 Jul 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2018-19 Shri Anil Firojiya, Dy. Commissioner Of 6, Bhakt Nagar, Income-Tax, बनाम/ Dashera Maidan, Assessment Unit, Vs. Ujjain New Delhi (Assessee/Appellant) (Revenue/Respondent) Pan: Aaipf7302A Assessee By Shri Manoj Fadnis, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 04.07.2024 Date Of Pronouncement 12.07.2024

Section 115BSection 139Section 142(1)Section 143(3)Section 147Section 148Section 69

reassessing the case under consideration, the AO has added Rs. 10,29,672/- on account of unexplained investment and issued order u/s 147

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

ITA 81/IND/2014[1988-89]Status: DisposedITAT Indore18 Mar 2024AY 1988-89

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

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

reassessment order. The AO has not brought any material cord to show that the assessee was earning income from a particular source. Furthermore, the AO has estimated the income of the assessee at Rs. 2,50,000/- without any basis. In our view, the Ld. CIT(A) has rightly observed that the action u/s 147 cannot be justified Page

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

ITA 82/IND/2014[1989-90]Status: DisposedITAT Indore18 Mar 2024AY 1989-90

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

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

reassessment order. The AO has not brought any material cord to show that the assessee was earning income from a particular source. Furthermore, the AO has estimated the income of the assessee at Rs. 2,50,000/- without any basis. In our view, the Ld. CIT(A) has rightly observed that the action u/s 147 cannot be justified Page

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

ITA 85/IND/2014[1992-93]Status: DisposedITAT Indore18 Mar 2024AY 1992-93

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

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

reassessment order. The AO has not brought any material cord to show that the assessee was earning income from a particular source. Furthermore, the AO has estimated the income of the assessee at Rs. 2,50,000/- without any basis. In our view, the Ld. CIT(A) has rightly observed that the action u/s 147 cannot be justified Page

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

ITA 83/IND/2014[1990-91]Status: DisposedITAT Indore18 Mar 2024AY 1990-91

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

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

reassessment order. The AO has not brought any material cord to show that the assessee was earning income from a particular source. Furthermore, the AO has estimated the income of the assessee at Rs. 2,50,000/- without any basis. In our view, the Ld. CIT(A) has rightly observed that the action u/s 147 cannot be justified Page

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

ITA 84/IND/2014[1991-97]Status: DisposedITAT Indore18 Mar 2024AY 1991-97

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

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

reassessment order. The AO has not brought any material cord to show that the assessee was earning income from a particular source. Furthermore, the AO has estimated the income of the assessee at Rs. 2,50,000/- without any basis. In our view, the Ld. CIT(A) has rightly observed that the action u/s 147 cannot be justified Page

MOHD HUSSAIN KAGDI,RATLAM vs. THE IT&TP, BHOPAL

Appeal is allowed

ITA 120/IND/2021[2011-12]Status: DisposedITAT Indore05 Feb 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year:2011-12 Mohd. Hussain Kagdi, Ito (I.T. & T.P.), 15, Tripoliya Gate, Bhopal बनाम/ Ratlam Vs. (Appellant/Assessee) (Respondent/Revenue) Pan: Atzpk 4811 B Assessee By Shri Rajesh Mehta, Ca & Shri Apurva Mehta, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 04.01.2024 Date Of Pronouncement 05.02.2024

Section 143(2)Section 143(3)Section 147Section 148Section 149Section 151Section 254(2)Section 69Section 69A

investment of the assessee u/s 69 of the Act and the Ld. CIT(A) has further erred in treating the same as unexplained cash in hand u/s 69A/69B of the Act which is wrong and contrary to the facts of the case and provisions of the Act. Thus, the addition of Rs. 37,75,000/- is liable to be deleted

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

investment made; since it is not necessary to earn dividend income during the year for working of 14A disallowance as is clarified by the CBDT’s Circular No. 5/2014 dated 11th February, 2014. 7. On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in deleting the aforesaid addition u/s 14A, while incorrectly observing

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

investment made; since it is not necessary to earn dividend income during the year for working of 14A disallowance as is clarified by the CBDT’s Circular No. 5/2014 dated 11th February, 2014. 7. On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in deleting the aforesaid addition u/s 14A, while incorrectly observing

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

investment made; since it is not necessary to earn dividend income during the year for working of 14A disallowance as is clarified by the CBDT’s Circular No. 5/2014 dated 11th February, 2014. 7. On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in deleting the aforesaid addition u/s 14A, while incorrectly observing

MAHENDRA KUMAR VERMA,INDORE vs. ITO-4(1), INDORE, INDORE

ITA 482/IND/2024[2013-14]Status: DisposedITAT Indore24 Jun 2025AY 2013-14

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshiआयकर अपील सं./I.T.A. No. 482/Ind/2024 (िनधा"रण वष" / Assessment Year : 2013-14) बनाम/ Mahendra Kumar Verma Ito-4(1) Flat No.301, Classic Indore Vs. Dream, 5-6, Paliwal Nagar, Indore (M.P.) -452011 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Acspv2701P (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri S. N. Agrawal & Shri Pankaj Mongra, A.Rs. ""यथ" क" ओर से/Respondent By : Shri Ashish Porwal, Sr.Dr 17/04/2025 Date Of Hearing Date Of Pronouncement 24/06/2025

For Appellant: Shri S. N. Agrawal & Shri PankajFor Respondent: Shri Ashish Porwal, Sr.DR
Section 147Section 148Section 151Section 250Section 69B

reassessment proceedings initiated under section 147 of the Income-Tax Act, 1961 even when reopening was done without obtaining proper sanction from the competent authority as mandated by the provisions of section 151 of the Act 6. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in confirming the addition

THE ACIT (CENTRAL)-1, INDORE vs. DILIP KUMAR MAHENDRA KUMAR JAIN HUF, INDORE

In the result Revenue’s appeal is dismissed

ITA 809/IND/2019[2011-12]Status: DisposedITAT Indore09 Feb 2021AY 2011-12

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year: 2011-12 Dilip Kumar Mahendra Acit (Central)-1, Vs. Kumar Jain, 6, Near Jagdale School, Indore Janki Nagar, Indore (Revenue ) (Appellant) Pan No.Aaehd1394J Revenue By Shri Harshit Bari, Sr.Dr Appellant By Shri Mahesh Agrawal, Adv. Date Of Hearing 05.01.2021 Date Of Pronouncement .02.2021 O R D E R

Section 132Section 142(1)Section 143(3)Section 147Section 69

reassessment completed u/s 143(3) r.w.s. 147 of the Act on 30.11.2018 assessing income at Rs.1,92,70,500/- adding unexplained investment

RAJESH KUMAR RATHORE,SEHORE vs. INCOME TAX OFFICER- WARD 5, SEHORE, SEHORE

In the result, the impugned order is set aside as & by way of\nremand back to the file of the Ld

ITA 535/IND/2025[2018-19]Status: DisposedITAT Indore19 Feb 2026AY 2018-19
Section 133(6)Section 142(1)Section 147Section 148Section 148ASection 250Section 253Section 69

unexplained investments\", to be\ntaxed as per the provisions of Section 115BBE of the\nIncome tax Act, 1961.\"\n2.3\nThat it is also recorded in the “Impugned Assessment\nOrder” that following opportunities were given to the assessee\nwhich is tabulated & is reproduced herein :\n\" 1. Details of opportunities given\nType of notice\nCommunication\nDate of Notice\ncommunication\nDate of\ncompliance

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

unexplained expenditure u/s 69C at Rs. 1,22,341/-. Income assessed at Rs.30,11,605/-. Aggrieved the assessee preferred an appeal before the CIT(A) raising various legal issues and grounds on merit but failed to succeed. 3.2 Now the assesse is in appeal before this tribunal. The assesse has raised legal issues challenging the validity of notice issue u/s

INCOME TAX OFFICER-1(2), INDORE, INDORE vs. DIVINE INFRACREATION AND TRADING PRIVATE LIMITED, MUMBAI

Accordingly quash the assessment-order made by AO.\nThe assessee's ground is allowed

ITA 272/IND/2024[2010-11]Status: DisposedITAT Indore28 Feb 2025AY 2010-11
Section 144Section 148Section 68Section 68(1)

reassessment proceeding u/s 147/144\n{mistakenly mentioned 143(3)} relying upon the decision of Delhi High\nCourt in the case of PCIT vs. Jai Shiv Shankar Traders Pvt. Ltd. 383\nITR 448 whereas the facts of the case are distinguishable that the\nreturn of income in the present case was not filled within the time\nallowed in the notice u/s