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17 results for “reassessment u/s 147”+ Section 80P(4)clear

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Key Topics

Section 26344Section 14737Section 14825Addition to Income11Section 80P10Section 2509Section 143(3)8Deduction8Section 80P(2)(d)

KATRATHAL GRAM SEWA SAHKARI SAMITI LIMITED ,KATRATHAL vs. ITO WARD 1 SIKAR, SIKAR

ITA 1001/JPR/2025[2019-20]Status: DisposedITAT Jaipur27 Oct 2025AY 2019-20
For Appellant: Sh. Shrawan Kumar Gupta, Adv.\rFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT\r
Section 139(1)Section 143(2)Section 144BSection 147Section 147rSection 148Section 148ASection 151Section 234ASection 250

147 and section 148 of the Income\r\nTax Act 1961 itself provide the opportunity to assessee for filing the return of\r\nincome, hence we could not say that the Income Tax Return was late filed. And\r\nthe Return filed u/s 148 is treated as filed u/s 139 and all the provision are\r\napplicable for the same

7
Section 80P(2)(a)7
Natural Justice6
Unexplained Cash Credit4

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

ITA 245/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Oct 2025AY 2015-16
For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT
Section 147Section 250

4. On going through the changes, quoted above, made to section 147 of the Act, we find that, prior to\nDirect Tax Laws (Amendment) Act, 1987, re- opening could be done under above two conditions and\nfulfilment of the said conditions alone conferred jurisdiction on the Assessing Officer to make a back\nassessment, but in section 147

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

ITA 244/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT
Section 147Section 250

4. On going through the changes, quoted above, made to section 147 of the Act, we find that, prior to\nDirect Tax Laws (Amendment) Act, 1987, re- opening could be done under above two conditions and\nfulfilment of the said conditions alone conferred jurisdiction on the Assessing Officer to make a back\nassessment, but in section 147

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

ITA 246/JPR/2025[2016-17]Status: DisposedITAT Jaipur13 Oct 2025AY 2016-17
For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT
Section 147Section 250

4. On going through the changes, quoted above, made to section 147 of the Act, we find that, prior to\nDirect Tax Laws (Amendment) Act, 1987, re- opening could be done under above two conditions and\nfulfilment of the said conditions alone conferred jurisdiction on the Assessing Officer to make a back\nassessment, but in section 147

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

ITA 243/JPR/2025[2013-14]Status: DisposedITAT Jaipur13 Oct 2025AY 2013-14
For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT
Section 147Section 250

4. On going through the changes, quoted above, made to section 147 of the Act, we find that, prior to\nDirect Tax Laws (Amendment) Act, 1987, re- opening could be done under above two conditions and\nfulfilment of the said conditions alone conferred jurisdiction on the Assessing Officer to make a back\nassessment, but in section 147

PALSANA GRAM SEWA SAHKARI SAMITI LTD.,JAIPUR vs. PCIT-2, JAIPUR

In the result, all these three appeals of the assessee are allowed

ITA 37/JPR/2021[2012-13]Status: DisposedITAT Jaipur02 Nov 2021AY 2012-13

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 35 To 37/Jp/2021 Assessment Years: 2010-11 To 2012-13 Palsana Gram Sewa Sahkari Samiti Cuke Pr.Cit-2, Vs. Limited, Jaipur. Village- Palsana Main Market, Palsana, Dist.- Sikar- 332402 (Raj) Pan No.: Aabap 8390 A Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shrawan Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Pr.Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 04/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Assessee Against The Separate Order Of The Ld. Pr.Cit-2, Jaipur All Dated 31/03/2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short, The Act) For The A.Y. 2010-11 To 2012-13. 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

For Appellant: Shri Shrawan Kr. Gupta (Adv)For Respondent: Shri B.K. Gupta (Pr.CIT-DR)
Section 143(2)Section 147Section 148Section 263Section 80P(2)(a)Section 80P(2)(d)

147 rws143(3) dt. 30.06.2017 by taking a reasonable and possible view. Here we want to say that if the ld. AO has not examined the issues and claim of deduction u/s 80P he could have not made the assessment. When the assessee has filed reply on deduction u/s 80P (PB8-11) with all the bank details and income

PALSANA GRAM SEWA SAHKARI SAMITI LTD.,PALSANA vs. PCIT-2, JAIPUR

In the result, all these three appeals of the assessee are allowed

ITA 35/JPR/2021[2010-11]Status: DisposedITAT Jaipur02 Nov 2021AY 2010-11

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 35 To 37/Jp/2021 Assessment Years: 2010-11 To 2012-13 Palsana Gram Sewa Sahkari Samiti Cuke Pr.Cit-2, Vs. Limited, Jaipur. Village- Palsana Main Market, Palsana, Dist.- Sikar- 332402 (Raj) Pan No.: Aabap 8390 A Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shrawan Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Pr.Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 04/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Assessee Against The Separate Order Of The Ld. Pr.Cit-2, Jaipur All Dated 31/03/2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short, The Act) For The A.Y. 2010-11 To 2012-13. 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

For Appellant: Shri Shrawan Kr. Gupta (Adv)For Respondent: Shri B.K. Gupta (Pr.CIT-DR)
Section 143(2)Section 147Section 148Section 263Section 80P(2)(a)Section 80P(2)(d)

147 rws143(3) dt. 30.06.2017 by taking a reasonable and possible view. Here we want to say that if the ld. AO has not examined the issues and claim of deduction u/s 80P he could have not made the assessment. When the assessee has filed reply on deduction u/s 80P (PB8-11) with all the bank details and income

PALSANA GRAM SEWA SAHKARI SAMITI LTD.,PALASANA vs. PCIT-2, JAIPUR

In the result, all these three appeals of the assessee are allowed

ITA 36/JPR/2021[2011-12]Status: DisposedITAT Jaipur02 Nov 2021AY 2011-12

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 35 To 37/Jp/2021 Assessment Years: 2010-11 To 2012-13 Palsana Gram Sewa Sahkari Samiti Cuke Pr.Cit-2, Vs. Limited, Jaipur. Village- Palsana Main Market, Palsana, Dist.- Sikar- 332402 (Raj) Pan No.: Aabap 8390 A Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shrawan Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Pr.Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 04/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Assessee Against The Separate Order Of The Ld. Pr.Cit-2, Jaipur All Dated 31/03/2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short, The Act) For The A.Y. 2010-11 To 2012-13. 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

For Appellant: Shri Shrawan Kr. Gupta (Adv)For Respondent: Shri B.K. Gupta (Pr.CIT-DR)
Section 143(2)Section 147Section 148Section 263Section 80P(2)(a)Section 80P(2)(d)

147 rws143(3) dt. 30.06.2017 by taking a reasonable and possible view. Here we want to say that if the ld. AO has not examined the issues and claim of deduction u/s 80P he could have not made the assessment. When the assessee has filed reply on deduction u/s 80P (PB8-11) with all the bank details and income

M/S JAIPUR ZILA DUGDH UTPADAK SAHKARI SANGH LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6, JAIPUR

In the result, the appeals of the assessee are allowed for A

ITA 512/JPR/2019[2011-12]Status: DisposedITAT Jaipur09 Nov 2022AY 2011-12
For Appellant: Shri P.C. Parwal, CAFor Respondent: Smt. Runi Pal, Addl. CIT-DR
Section 147Section 80PSection 80P(2)(d)

147 of the Act (only for A.Y 2011-12- & 2012- 13). (ii) Whether the ld. CIT(A) has erred on facts and in law in allowing deduction u/s 80P (2)(d) of the Act on proportionate basis instead of on the entire 3. On the first issue which relates to AY 2011-12 & 2012-13 where assessee has challenged

SOYALA GRAM SEWA SAHAKARI SAMITI LIMITED,TONK vs. ITO, TONK, TONK

In the result, appeal of the assessee is allowed

ITA 1116/JPR/2024[2015-16]Status: DisposedITAT Jaipur08 Jan 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Mukesh Khandelwal (CA)For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 147Section 250Section 253(3)Section 80A(5)Section 80P

4. We have heard both the sides in respect of admission of additional ground. The additional ground raised by the assessee is purely legal in nature and also goes to the root of the matter regarding the validity of the assessment. The assessee has disputed the action of the AO in violation of provisions of section 147

INCOME TAX OFFICER, RAWATBHATA ROAD vs. BOREKHEDA GRAM SEWA SAHAKARI SAMITI, HEAD OFFICE NEAR DWARKADIS

In the result, the appeal of the Revenue is dismissed

ITA 599/JPR/2024[2014-15]Status: DisposedITAT Jaipur24 Jul 2024AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR DIPAK P. RIPOTE (Accountant Member)

For Appellant: Shri Siddharth Ranka, AdvocateFor Respondent: Shri Rajesh Kumar Meena, Addl. CIT-DR
Section 143(3)Section 147Section 80Section 80PSection 80P(2)Section 80P(2)(d)

reassessment proceedings u/s 148 culminating in passing the Impugned order cannot be sustained- in the facts and circumstances of the 4 ITO, WARD 2(2), KOTA VS BOREKHEDA GRAM SEWA SAHAKARI SAMITI LTD, KOTA present matter-as discussed above, and accordingly, the corresponding ground is to be treated as ALLOWED. Before parting it is mentioned that since the ground/contentions

NIRMAL KUMAR AGRAWAL,JAIPUR vs. DCIT, CIRCLE - 4 , JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1224/JPR/2024[2013-2014]Status: DisposedITAT Jaipur13 Feb 2025AY 2013-2014
For Appellant: Sh. Tarun Mittal, CAFor Respondent: Mrs. Swapnil Parihar, JCIT-DR
Section 133ASection 147Section 148Section 68Section 69C

80P - Assessee against impugned order filed appeal before Commissioner (Appeals) with a delay of 11 days and sought condonation of delay in filing appeal stating that delay was due to non-availability of its legal consultant - Commissioner (Appeals) refused to condone delay and dismissed appeal in limine - Whether since filing an appeal in tax matters 13 Nirmal Kumar Agrawal

BALITHAL GRAM SEVA SAHAKARI SAMITI LIMITED,TONK vs. RJN-W-(107)(5), TONK

In the result, the appeal of the assessee is allowed

ITA 1306/JPR/2024[2019-20]Status: DisposedITAT Jaipur21 May 2025AY 2019-20

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalbalithal Gram Seva Sahakari Samiti Limited, Balithal Uniara Tonk, 304024 Pan No.: Aabab4614R ...... Appellant Vs.

For Appellant: Mr. Hemang Gargieya, Adv., Ld. ARFor Respondent: Mr. Gautam Singh Choudhary, Addl. CIT, Ld. Sr. DR
Section 139Section 139(1)Section 147Section 148Section 148ASection 234ASection 234FSection 250Section 80P

4. In this case, reasons assigned for re-opening was cash deposit in the Central Cooperative Bank Ltd., The Uniyara, Tonk, Rajasthan amounting to Rs. 1,51,68,000/-, whereas there is no addition made on this account and rather a disallowance was made amounting to Rs. 13,04,658/- u/s. 80P of the Act claimed by the assessee, which

SH. BADALURAM,FAULADPUR, ALWAR vs. ITO, WARD-BEHROR, BEHROR

In the result, the appeal of the assessee is allowed

ITA 720/JPR/2023[2017-18]Status: DisposedITAT Jaipur09 Apr 2024AY 2017-18
For Appellant: Shri P.C. Parwal, (C.A.)For Respondent: Shri A.S. Nehra (Addl.CIT)
Section 142(1)Section 147Section 148Section 69

4,69,750/- for the year which doesn't corroborate with the huge transaction amount of Rs 1 crore being debited from the account as shown above in figure. 32 Further, the assessee claims that the case Bhupinder Singh was opened in Contral Circle Alwar for the same reopening reason and assessee also produced the assessment order passed

ANIL KUMAR BATAR,SIKAR vs. PCIT-JAIPUR-2, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 418/JPR/2025[2018-19]Status: DisposedITAT Jaipur09 Sept 2025AY 2018-19
For Appellant: Shri Shrawan Kumar Gupta, Adv. &For Respondent: Shri Gorav Avasthi, JCIT-DR
Section 143(3)Section 144BSection 147Section 263

147 read with section 144B of the\nIncome Tax Act, 1961 on 18.03.2023 at returned income of Rs.\n19,89,250/-. Subsequently, the ld. PCIT on examination of the\nassessment record noted that during the course of survey proceedings, it\nwas found that the firm M/s. Matrix JEE Academy, Sikar runs its\nbusiness from a rented building which was owned

RAGHAV KUMAR DHOOT,JAIPUR vs. DCIT CENTRAL CIRCLE 1, JAIPUR

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

ITA 491/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 Aug 2025AY 2018-19
For Appellant: Shri C.M. Agarwal, C.AFor Respondent: Shri Rajesh Ojha, CIT- DR
Section 143(2)Section 143(3)Section 153ASection 292BSection 68

reassessment notice upon him-Held, yes-\n2.4 With regard to the contention of the assessee that the assessment\ncompleted is invalid in absence of notice u/s 143(2) by the DOT, Central\nCircle-1, Jaipur who had completed the assessment u/s 143(3) of the IT\nAct, 1961 on 18/04/2021, it is to be stated here that notice u/s

SAJJAD ALI,CHITTORGARH vs. DCIT(INTL)- JAIPUR, JAIPUR

ITA 459/JPR/2024[2016-17]Status: DisposedITAT Jaipur24 Jun 2024AY 2016-17

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Rajesh Ojha (CIT-DR)
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 263Section 54

147 r.w.s. 144 of the Act, by the DCIT, Circle (Intl. Tax), Jaipur. 2. Assessee challenged the order of the CIT(IT)-Delhi-1 by raising the following grounds of appeal; “1. That the Impugned order u/s 263 of the Act dated 27.03.2024 and notice u/s 263 are bad in law and on facts of the case and hence