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7 results for “reassessment u/s 147”+ Addition to Incomeclear

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Key Topics

Section 143(3)12Section 1488Section 2638Section 1477Section 2506Section 271(1)(c)6Addition to Income6Reassessment6Section 144

SHRI DIGPAL JAISWAL,KATNI vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2, JABALPUR

In the result appeal of the assessee is allowed

ITA 83/JAB/2019[2011-12]Status: DisposedITAT Jabalpur30 Nov 2023AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. K P Dewani, AdvFor Respondent: Sh. Shravan Kumar Gotru, CIT-DR
Section 1Section 142(1)Section 143Section 143(3)Section 148Section 263Section 271(1)(b)Section 40

reassessment framed pursuance to notice u/s 148 at para 2 & 3 that sum of Rs.3,23,670/- was not claimed as interest expenses in profit and loss A/c and therefore there was no case for making any disallowance. A.O. further proceeded to assess the same income as determined in regular assessment framed u/s

5
Section 249(4)(b)4
Penalty4
Reopening of Assessment3

SHRI DIGPAL JAISWAL,KATNI vs. INCOME TAX OFFICER, WARD -1 , KATNI

In the result appeal of the assessee is allowed

ITA 42/JAB/2021[2011-12]Status: DisposedITAT Jabalpur30 Nov 2023AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. K P Dewani, AdvFor Respondent: Sh. Shravan Kumar Gotru, CIT-DR
Section 1Section 142(1)Section 143Section 143(3)Section 148Section 263Section 271(1)(b)Section 40

reassessment framed pursuance to notice u/s 148 at para 2 & 3 that sum of Rs.3,23,670/- was not claimed as interest expenses in profit and loss A/c and therefore there was no case for making any disallowance. A.O. further proceeded to assess the same income as determined in regular assessment framed u/s

ASSISTANT COMMISSIONER OF INCOME TAX C 2(1) , JABALPUR vs. SHRI RAKESH JAISHWAL , JABALPUR

In the result, the appeal is partly allowed

ITA 35/JAB/2018[2008-09]Status: DisposedITAT Jabalpur18 Sept 2023AY 2008-09

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadaleacit, Circle 2(1), Vs. Shrirakeshjaiswal, Annexe Building, Bunglow No. 6, Aayakar Bhawan, Civil Lines, Napier Town, Jabalpur-482001, Jabalpur-482001, Madhya Pradesh. Madhya Pradesh. Pan/Gir No. : Aefpj7779E Appellant .. Respondent Assessee By : Shri.Sanjay Seth Ca & Shri.Sachin Vajpayee, Adv.Ar Revenue By : Shri.Rajesh Kumar Gupta. Sr. Dr Date Of Hearing 14.09.2023 Date Of Pronouncement 18.09.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-1,Jabalpur Passed U/S 143(3) R.W.S 147 & 250 Of The Act. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Shri.Sanjay Seth CA &For Respondent: Shri.Rajesh Kumar Gupta. Sr. DR
Section 143(3)Section 69B

Income Tax (Appeals)-1,Jabalpur passed u/s 143(3) r.w.s 147 and 250 of the Act. The revenue has raised the following grounds of appeal: 1. The Ld. CIT(A) erred in Law and on facts in deleting the addition Rs. 1,10,58,722/- made by the Assessing Officer u/s 69B on account of difference between investment in firm

VISHWANATH SINGH RATHODE,HOSHANGABAD vs. INCOME TAX OFFICER-1,, ITARSI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 142/JAB/2023[2017-18]Status: DisposedITAT Jabalpur09 Jan 2025AY 2017-18

Bench: Shri Kul Bharatassessment Year: 2017-18 Vishwanath Singh Rathode V. Income Tax Officer-1 Village Chapda Grahan, Income Tax Officer-1, Seonimalwa, Seonimalwa, Niyas Coloni Itarsi, Dist Madhya Pradesh-461221. Narmadapuram, Mp- 461111. Pan:Aezpr6401F (Appellant) (Respondent) Appellant By: Shri Abhijeet Shrivastava, Adv. Respondent By: Shri Bharat Sheogankar, Sr. Cit(Dr) Date Of Hearing: 08 01 2025 Date Of Pronouncement: 09 01 2025 O R D E R

For Appellant: Shri Abhijeet Shrivastava, AdvFor Respondent: Shri Bharat Sheogankar, Sr. CIT(DR)
Section 144Section 249Section 249(4)Section 249(4)(a)Section 249(4)(b)Section 69

147 for reassessment which is not justified and bad in law. 5. The assesse reserves the right to append, alter or delete any ground (S) of appeal upto the time of hearing of appeal.” Page 2 of 4 2. The facts giving rise to the present appeal are in this case the case was taken up for scrutiny

SUNIL KUMAR PATHAK,REWA vs. INCOME TAX OFFICER WARD -1, , REWA

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

ITA 37/JAB/2023[2014-15]Status: DisposedITAT Jabalpur13 Nov 2023AY 2014-15

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadalesunil Kumar Pathak Vs. Ito, Ward – 1, 3Rd Floor, A Block, Shilpi Rewa-486001, Plaza, Pili Kothi, Madhya Pradesh. Rewa-486001, Madhya Pradesh. Pan/Gir No. : Arwpp9628A Appellant .. Respondent Appellant By : Shri.Dhiraj Ghai.Fca.Ar Respondentby : Shri.Shiv Kumar. Sr.Dr Date Of Hearing 15.09.2023 Date Of Pronouncement 10.11.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The National Faceless Appeal Centre (Nfac) / Cit(A) Passed U/Sec 144 & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri.Dhiraj Ghai.FCA.ARFor Respondent: Shri.Shiv Kumar. Sr.DR
Section 147Section 148

reassessment proceedings though the reasseement notice issue by the Assessing officer is defective and further the CIT(A) erred in confirming the action of the assessing is sustaining the addition overlooking the voluminous material evidences filed in the assessment and appellate proceedings. On the first issue of validity of issue of notice U/sec148 of the Act, we find the Assessing

DINESH JAT,SAGAR vs. CIT (A), SAGAR

ITA 195/JAB/2025[2013-2014]Status: DisposedITAT Jabalpur28 Aug 2025AY 2013-2014

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Jaiswal Sancheti, C.AFor Respondent: Shri. N.M. Prasad, Sr. DR
Section 144Section 147Section 250Section 251(1)(a)Section 271(1)(c)Section 44ASection 69A

Reassessment is Without Proper Foundation - Absence of Tangible Material The reopening of the assessment under section 147 is purely based on AIR-reported bank deposits without any independent verification or tangible evidence. This amounts to a borrowed satisfaction, which has been consistently held by judicial forums (including Harmeet Singh vs. ITO) as invalid and unsustainable in law. 5. Addition

DINESH JAT,SAGAR vs. CIT(A), NFAC

ITA 196/JAB/2025[2013-14]Status: DisposedITAT Jabalpur28 Aug 2025AY 2013-14

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Jaiswal Sancheti, C.AFor Respondent: Shri. N.M. Prasad, Sr. DR
Section 144Section 147Section 250Section 251(1)(a)Section 271(1)(c)Section 44ASection 69A

Reassessment is Without Proper Foundation - Absence of Tangible Material The reopening of the assessment under section 147 is purely based on AIR-reported bank deposits without any independent verification or tangible evidence. This amounts to a borrowed satisfaction, which has been consistently held by judicial forums (including Harmeet Singh vs. ITO) as invalid and unsustainable in law. 5. Addition