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26 results for “reassessment u/s 147”+ Section 263clear

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Key Topics

Section 143(3)68Section 26343Section 153A23Section 14820Addition to Income18Section 14714Section 36(1)(viia)12Disallowance12Section 145

AJMER DEVELOPMENT AUTHORITY,AJMER vs. CIT(EXEMPTION)/ ITO (EXEMPTION), JAIPUR / JODHPUR

In the result, the stay application filed by the assessee is dismissed

ITA 89/JODH/2022[2012-13]Status: DisposedITAT Jodhpur22 Mar 2023AY 2012-13

Bench: Shri Kul Bharatshri Manish Borad

Section 143(3)Section 147Section 263

reassessment proceedings and also therefore, cannot be subject matter of revisionary proceedings u/s 263 of the Act. The facts are not disputed that in this case, the Assessment Order passed u/s 147 / 143 dt. 12.12.2019 has been subjected to revision u/s 263 by the Ld. CIT. A Notice u/s 148 was issued on 29.03.2019 for A.Y. 2012- 13 under consideration

PARASMAL SAREMAL GOGAD,PALI vs. ITO, , PALI

In the result, appeal of the assessee is allowed

Showing 1–20 of 26 · Page 1 of 2

9
Section 1446
Depreciation6
Penalty6
ITA 301/JODH/2024[2013-14]Status: Disposed
ITAT Jodhpur
28 May 2025
AY 2013-14
Section 143(3)Section 147Section 148Section 153ASection 263

reassessment proceedings u/s 147 were initiated based on search proceedings related to an investment of Rs. 21,60,000/- for plot purchase which was not disclosed by the assessee. The PCIT invoked Section 263

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ACIT, PALI

Appeals are disposed off in the terms indicated as above

ITA 519/JODH/2018[2011-12]Status: DisposedITAT Jodhpur10 Nov 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Goutam Chand Baid, C.AFor Respondent: Sh. Lovish Kumar, CIT-DR
Section 143(3)Section 147Section 148Section 14ASection 263Section 36(1)(viia)

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ADDITIONAL CIT, PALI

Appeals are disposed off in the terms indicated as above

ITA 520/JODH/2018[2012-13]Status: DisposedITAT Jodhpur10 Nov 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Goutam Chand Baid, C.AFor Respondent: Sh. Lovish Kumar, CIT-DR
Section 143(3)Section 147Section 148Section 14ASection 263Section 36(1)(viia)

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ADDITIONAL CIT, PALI

Appeals are disposed off in the terms indicated as above

ITA 521/JODH/2018[2013-14]Status: DisposedITAT Jodhpur10 Nov 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Goutam Chand Baid, C.AFor Respondent: Sh. Lovish Kumar, CIT-DR
Section 143(3)Section 147Section 148Section 14ASection 263Section 36(1)(viia)

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ACIT, PALI

Appeals are disposed off in the terms indicated as above

ITA 517/JODH/2018[2007-08]Status: DisposedITAT Jodhpur10 Nov 2023AY 2007-08

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Goutam Chand Baid, C.AFor Respondent: Sh. Lovish Kumar, CIT-DR
Section 143(3)Section 147Section 148Section 14ASection 263Section 36(1)(viia)

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ACIT, PALI

Appeals are disposed off in the terms indicated as above

ITA 518/JODH/2018[2010-11]Status: DisposedITAT Jodhpur10 Nov 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Goutam Chand Baid, C.AFor Respondent: Sh. Lovish Kumar, CIT-DR
Section 143(3)Section 147Section 148Section 14ASection 263Section 36(1)(viia)

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

ACIT, CIRCLE, PALI. vs. M/S. RAJASTHAN MARUDHARA GRAMIN BANK, , JODHPUR

Appeals are disposed off in the terms indicated as above

ITA 504/JODH/2018[2010-11]Status: DisposedITAT Jodhpur10 Nov 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Goutam Chand Baid, C.AFor Respondent: Sh. Lovish Kumar, CIT-DR
Section 143(3)Section 147Section 148Section 14ASection 263Section 36(1)(viia)

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

OCHHAB LAL JAIN,UDAIPUR vs. DCIT CENTRAL CIRCLE-1, UDAIPUR, UDAIPUR

In the result, both the appeals of the assessee are allowed

ITA 429/JODH/2025[2016-17]Status: DisposedITAT Jodhpur29 May 2025AY 2016-17
Section 132Section 132(1)Section 132(4)Section 139(1)Section 143(3)Section 153ASection 69A

263 of the Act In category of case falling under\nclause (d) and (f), appropriate action under section 147 of the Act can be taken to\ntax the income which has escaped assessment or had remained to be taxed. There\ncan be situation where an item has been dealt with in the body of the order of\nassessment

OCHHAB LAL JAIN,UDAIPUR vs. DCIT, CENTRAL CIRCLE-1, UDIAPUR, UDAIPUR

In the result, both the appeals of the assessee are allowed

ITA 428/JODH/2025[2014-15]Status: DisposedITAT Jodhpur29 May 2025AY 2014-15
Section 132Section 132(1)Section 132(4)Section 139(1)Section 143(3)Section 153ASection 69A

263 of the Act In category of case falling under\nclause (d) and (f), appropriate action under section 147 of the Act can be taken to\ntax the income which has escaped assessment or had remained to be taxed. There\ncan be situation where an item has been dealt with in the body of the order of\nassessment

JS ENGINEERING WORKS,SAWA, CHITTORGARH vs. DCIT, CENTRAL CIRCLE, CHITTORGARH

In the result, all these 6 appeals filed by the assessee are allowed

ITA 621/JODH/2024[2013-14]Status: DisposedITAT Jodhpur26 Feb 2026AY 2013-14

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

Section 131(3)Section 133ASection 143(3)Section 144Section 148Section 263

263 of the Income Tax Act, 1961, verification of claim of shut down wage expenses was undertaken, and shutdown register for Financial Year 2014-15 was impounded u/s 131(3) of the Income Tax Act on 15.10.2018. Later, a survey u/s 133A of the Income Tax was conducted on 17.10.2018 at the business premise of the firm to verify

JS ENGINEERING WORKS,SAWA, CHITTORGARH vs. DCIT, CENTRAL CIRCLE, CHITTORGARH

In the result, all these 6 appeals filed by the assessee are allowed

ITA 622/JODH/2024[2014-15]Status: DisposedITAT Jodhpur26 Feb 2026AY 2014-15

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

Section 131(3)Section 133ASection 143(3)Section 144Section 148Section 263

263 of the Income Tax Act, 1961, verification of claim of shut down wage expenses was undertaken, and shutdown register for Financial Year 2014-15 was impounded u/s 131(3) of the Income Tax Act on 15.10.2018. Later, a survey u/s 133A of the Income Tax was conducted on 17.10.2018 at the business premise of the firm to verify

JS ENGINEERING WORKS,SAWA, CHITTORGARH vs. DCIT, CENTRAL CIRCLE, CHITTORGARH

In the result, all these 6 appeals filed by the assessee are allowed

ITA 628/JODH/2024[2017-18]Status: DisposedITAT Jodhpur26 Feb 2026AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

Section 131(3)Section 133ASection 143(3)Section 144Section 148Section 263

263 of the Income Tax Act, 1961, verification of claim of shut down wage expenses was undertaken, and shutdown register for Financial Year 2014-15 was impounded u/s 131(3) of the Income Tax Act on 15.10.2018. Later, a survey u/s 133A of the Income Tax was conducted on 17.10.2018 at the business premise of the firm to verify

JS ENGINEERING WORKS,SAWA CHITTORGARH vs. DCIT, CENTRAL CIRCLE, CHITTORGARH

In the result, all these 6 appeals filed by the assessee are allowed

ITA 624/JODH/2024[2015-16]Status: DisposedITAT Jodhpur26 Feb 2026AY 2015-16

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

Section 131(3)Section 133ASection 143(3)Section 144Section 148Section 263

263 of the Income Tax Act, 1961, verification of claim of shut down wage expenses was undertaken, and shutdown register for Financial Year 2014-15 was impounded u/s 131(3) of the Income Tax Act on 15.10.2018. Later, a survey u/s 133A of the Income Tax was conducted on 17.10.2018 at the business premise of the firm to verify

JS ENGINEERING WORKS,SAWA, CHITTORGARH vs. DCIT, CENTRAL CIRCLE, CHITTORGARH

In the result, all these 6 appeals filed by the assessee are allowed

ITA 625/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 Feb 2026AY 2016-17

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

Section 131(3)Section 133ASection 143(3)Section 144Section 148Section 263

263 of the Income Tax Act, 1961, verification of claim of shut down wage expenses was undertaken, and shutdown register for Financial Year 2014-15 was impounded u/s 131(3) of the Income Tax Act on 15.10.2018. Later, a survey u/s 133A of the Income Tax was conducted on 17.10.2018 at the business premise of the firm to verify

JS ENGINEERING WORKS,SAWA, CHITTORGARH vs. DCIT, CHITTORGARH

In the result, all these 6 appeals filed by the assessee are allowed

ITA 620/JODH/2024[2012-13]Status: DisposedITAT Jodhpur26 Feb 2026AY 2012-13

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

Section 131(3)Section 133ASection 143(3)Section 144Section 148Section 263

263 of the Income Tax Act, 1961, verification of claim of shut down wage expenses was undertaken, and shutdown register for Financial Year 2014-15 was impounded u/s 131(3) of the Income Tax Act on 15.10.2018. Later, a survey u/s 133A of the Income Tax was conducted on 17.10.2018 at the business premise of the firm to verify

ASHIANA BUILDPROP PRIVATE LIMITED,UDAIPUR vs. DCIT, CENTRAL CIRCLE-1, UDAIPUR, UDAIPUR

ITA 706/JODH/2024[2013-14]Status: DisposedITAT Jodhpur26 May 2025AY 2013-14
Section 132Section 145(3)Section 153ASection 234ASection 250

147, 148, 149, 151 and 153. However, they do not override the\nmandatory provisions of Sections 142(2) or 143(2)”.\n10\nITA Nos. 706 to 709/Jodh/2024\nAshiana Buildprop Pvt. Ltd., Udaipur.\nIn DCIT Sushil Kumar Jain 134 TTJ 844 (Indore)that “Time-limit of service of notice\nunder s. 143(2) shall also apply in respect of assessments framed

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 143/JODH/2022[2017-18]Status: DisposedITAT Jodhpur12 Oct 2023AY 2017-18
Section 143(3)Section 145Section 153A

147. In the appellate order for AY 11-12 Ld. CIT(A) even though granted relief to the assessee due to reason (mistake in total) but branch wise figures were duly accepted by Ld. CIT(A). Authenticity and data of branch wise gross receipts were duly accepted by Ld CIT(A) also. It is also worthwhile to mention in that

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 144/JODH/2022[2018-19]Status: DisposedITAT Jodhpur12 Oct 2023AY 2018-19
Section 143(3)Section 145Section 153A

147. In the appellate order for AY 11-12 Ld. CIT(A) even though granted relief to the assessee due to reason (mistake in total) but branch wise figures were duly accepted by Ld. CIT(A). Authenticity and data of branch wise gross receipts were duly accepted by Ld CIT(A) also. It is also worthwhile to mention in that

ACIT, CENTRAL CIRCLE-2, UDAIPUR, UDAIPUR vs. M/S MEWAR HOSPITAL PVT. LTD., UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 167/JODH/2022[2016-17]Status: DisposedITAT Jodhpur12 Oct 2023AY 2016-17
Section 143(3)Section 145Section 153A

147. In the appellate order for AY 11-12 Ld. CIT(A) even though granted relief to the assessee due to reason (mistake in total) but branch wise figures were duly accepted by Ld. CIT(A). Authenticity and data of branch wise gross receipts were duly accepted by Ld CIT(A) also. It is also worthwhile to mention in that