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13 results for “reassessment u/s 147”+ Section 151Aclear

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Mumbai111Hyderabad62Delhi57Chennai49Ahmedabad30Visakhapatnam27Pune26Jaipur19Chandigarh18Kolkata13Raipur10Rajkot6Agra5Lucknow5Amritsar4Surat4Guwahati3Patna2Bangalore2Indore2Nagpur2Karnataka1Cochin1Ranchi1Dehradun1

Key Topics

Section 14829Section 14725Section 151A21Section 25012Addition to Income11Section 144B10Reassessment10Section 142(1)9Section 143(2)

ALBATROSS INVESTMENT PVT. LTD.,,KOLKATA vs. ITO, WARD 3(1),, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 400/KOL/2025[2013-14]Status: DisposedITAT Kolkata02 Dec 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Albatross Investment Pvt. Ltd. Ito, Ward 3(1) 1, 7Th Floor, Room No.707, Aaykar Bhawan, P-7 British Indian Street, Chworinghee Square, Vs. Kolkata-700069, West Bengal Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aacca6069N Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Pankaj Pandey, Dr Date Of Hearing: 14.10.2025 Date Of Pronouncement: 02.12.2025

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Pankaj Pandey, DR
Section 139(1)Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 151A

reassessment in this case has been done by the National Faceless Assessment Centre and order has been passed on 22.09.2021 which is the subject matter of present appeal. However the powers were conferred on the NFAC only w.c.f 29.03.2022 vide Notification dated 18 of 2022. The issue is squarely covered by plethora of judgement of Coordinate Bench of this Tribunal

8
Section 143(3)7
Limitation/Time-bar7
Reopening of Assessment4

DELTA DEALERS PRIVATE LIMITED,KOLKATA vs. INCOME TAX OFFICER WARD NO. 13(1), KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2582/KOL/2025[2013-14]Status: DisposedITAT Kolkata26 Feb 2026AY 2013-14
Section 139(1)Section 142(1)Section 144Section 144BSection 147Section 148Section 151A

147 of the Act by issuing notice u/s 148 of the Act\non 11.05.2020, Thereafter, the notice u/s 142(1) of the Act was\nissued by NFAC on 02.02.2022 and likewise a show cause notice was\nissued on 24.02.2022. We note that the second show cause notice\nwas issued on 07.03.2022 by NFAC. The NFAC issued a final draft\nassessment

TATUN GUHA,SILIGURI vs. I.T.O., WARD - 1(1),, SILIGURI

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

ITA 1644/KOL/2025[2013-2014]Status: DisposedITAT Kolkata27 Oct 2025AY 2013-2014

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2013-14 Tatun Guha………..………….……………………….……….……….……Appellant Namita Nilay, College Para, Siliguri, W.B - 734001.. [Pan: Ahbpg6041R] Vs. Ito, Ward-1(1), Siliguri………………………………….....……...…..…..Respondent Appearances By: Shri Sujit Basu & Rajib Mukherjee, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 09, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 01.07.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 151ASection 250Section 282

reassessment case u/s 147 prior to 29.03.2022 in faceless manner, hence the NFAC erred in having jurisdiction u/s 151A r.w.s. 144B of the Act and they have not empowered under any notification prior to 29.03.2022. 5. The ld. DR supports the impugned order and submit that the ld. AR did not raise this issue before the Assessing Officer

RAJIB SARKAR,RAIGANJ vs. ITO, WARD 2(4),, RAIGANJ

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

ITA 2781/KOL/2025[2015-2016]Status: DisposedITAT Kolkata24 Feb 2026AY 2015-2016

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 142(1)Section 143(1)Section 144BSection 147Section 148Section 151ASection 250Section 69

147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, to the extent provided in section 144B of the Act with reference

NABIUL INDUSTRIAL METAL PVT. LTD.,PASCHIM MEDINIPUR vs. I.T.O., WARD - 39(2), MIDNAPORE, PASCHIM MEDINIPUR

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

ITA 1328/KOL/2024[2017-2018]Status: DisposedITAT Kolkata15 Oct 2024AY 2017-2018

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

Section 142(1)Section 147Section 151ASection 250Section 68

u/s 142(1) of the Act. c) Show cause notice dated 28.03.2022. 1.4. Ld. D/R though supports the impugned order but did not raise any objection on the legal ground. 2. We have perused the records and the papers filed by the assessee. It appears that Notification with respect to Section 151A of the Act has been made with effect

STREAM SUPPLIERS PVT. LTD.,,KOLKATA vs. ITO, WARD 7(1),, KOLKATA

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1936/KOL/2025[2016-2017]Status: DisposedITAT Kolkata28 Jan 2026AY 2016-2017

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144BSection 148Section 149(1)(b)Section 151ASection 250

reassessment proceedings are governed by Section 144B read with Sections 148 and 151A, requiring issuance by the Faceless Assessing Officer, whereas the impugned notice was wrongly issued by the Jurisdictional AO, Ward 7(1), Kolkata. 2. For That Appellate Authority failed to appreciate that the notice under Section 148 is barred by limitation in accordance with Section

TIGERHILL TRADELINK PRIVATE LIMITED,KOLKATA vs. ITO, WARD 10(2), , KOLKATA

In the result, the appeal of the Appellant is Dismissed

ITA 955/KOL/2025[2014-2015]Status: DisposedITAT Kolkata03 Oct 2025AY 2014-2015
Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 250Section 68

u/s 147 r.w.s.\n144B of the Act dated 29.05.2023, respectively. Since the issues in both\nthe appeals are for the same assessee, they were heard together and are\nbeing decided by this common order for the sake of convenience and\nbrevity\n2. The assessee is in appeal before the Tribunal raising the following\ngrounds of appeal:\nI. ITA No.: 956/KOL/2025

TIGERHILL TRADELINK PRIVATE LIMITED,KOLKATA vs. ITO, WARD 10(2), , KOLKATA

In the result, the appeal of the Appellant is Dismissed

ITA 956/KOL/2025[2014-2015]Status: DisposedITAT Kolkata03 Oct 2025AY 2014-2015
Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 250Section 68

u/s 147 r.w.s.\n144B of the Act dated 29.05.2023, respectively. Since the issues in both\nthe appeals are for the same assessee, they were heard together and are\nbeing decided by this common order for the sake of convenience and\nbrevity\n2. The assessee is in appeal before the Tribunal raising the following\ngrounds of appeal:\nI. ITA No.: 956/KOL/2025

M/S FANTASTIC FINANCIAL CONSULTANTS PVT. LTD.,KOLKATA vs. ITO, WARD-9(1), KOLKATA, KOLKATA

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 253/KOL/2025[2013-14]Status: DisposedITAT Kolkata04 Jul 2025AY 2013-14

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 1Section 142(2)Section 143(3)Section 147Section 148Section 148ASection 250Section 251Section 251(1)Section 69A

147 r.w.s 144 of the Act to the file of the AO for fresh assessment after affording reasonable opportunities to the appellant and diligently adhering to the principle of natural justice. The appellant is directed to comply with notices issued by the AO. 6.3 The AO is therefore directed to frame the assessment afresh after giving the appellant reasonable opportunity

AMALENDU KUMAR MODAK,KOLKATA vs. INCOME TAX OFFICER , 50(1), KOLKATA

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

ITA 1367/KOL/2024[2017-18]Status: DisposedITAT Kolkata19 Nov 2024AY 2017-18

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraassessment Year: 2017-18 Amalendu Kumar Modak, Income Tax Officer, 50(1), Karer Ganga, Laha Bagan, Garia, Income Tax Office, Civil Centre, Vs Garia Main Road, Kolkata-700084, Uttarapan Complex, West Bengal Manicktala, Kolkata-700 067, West Bengal (Appellant) (Respondent) Pan: Aekpm9399G Present For: Appellant By : Shri Indranil Banerjee, Ar Respondent By : Shri Pradip Kumar Biswas, Dr Date Of Hearing : 14.11.2024 Date Of Pronouncement : 19.11.2024 O R D E R Per Rakesh Mishra: This Appeal Filed By The Assessee Is Against The Order Of The National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “The Ld. Cit (A)”] Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For Ay 2017-18 Dated 14.11.2024, Which Has Been Passed Against The Assessment Order U/S 147 Read With Section 144 Read With Section 144B Of The Act, Dated 29.05.2023. 2. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Under:

For Appellant: Shri Indranil Banerjee, ARFor Respondent: Shri Pradip Kumar Biswas, DR
Section 144Section 144BSection 147Section 148Section 148ASection 149Section 149(1)(a)Section 151Section 151ASection 250

u/s 147 read with section 144 read with section 144B of the Act, dated 29.05.2023. 2. The grounds of appeal raised by the assessee are reproduced as under: “A. Grounds concerning dismissal of the Appeal, consequent upon the rejection of Condonation Petition , duly presented with regard to delayed filing of Appeal . A1. That on the facts and circumstances

ARYA ROADWAYS COMPANY PVT. LTD.,KOLKATA vs. I.T.O., WARD - 12(1), KOLKATA

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 3/KOL/2025[2011-2012]Status: DisposedITAT Kolkata02 Apr 2026AY 2011-2012

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 133(6)Section 143(1)Section 143(2)Section 147Section 148Section 151Section 151ASection 250

section 151A r.w.s. notifications issued there under, thereby vitiating the reassessment order. ITA No(s). 3/KOL/2025 Assessment Year(s) 2011-12 Arya Roadways Company Pvt. Ltd. 3. For that the Ld. CIT(A) ought to have held that the re-assessment order is vitiated in law inasmuch as there was absolutely no independent application of mind and no independent enquiry

CHHANDA KAR,TAMLUK vs. ITO, WARD 27(3),, HALDIA

Appeal of the assessee is allowed for statistical purposes

ITA 1343/KOL/2025[2015-2016]Status: DisposedITAT Kolkata30 Oct 2025AY 2015-2016

Bench: The Ld. Commissioner Of Income Tax (Appeals), Nfac Through E-Filling.

Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 250Section 253(3)Section 69

147 r. w. s 144 read with section144B of the Income Tax Act, 1961 on 17/09/2021 4. That I had been filed an appeal before the Ld. Commissioner of Income Tax (Appeals), NFAC through e-filling. 2 Chhanda Kar 5. That the Ld. Commissioner of Income Tax, (Appeals). National Face Less Appeal Centre (NFAC) passed an order, vide DIN & Order

INCOME TAX OFFICER, WARD-1(1), KOLKATA, KOLKATA vs. AVINASH COMMERCIAL PRIVATE LIMITED, KOLKATA

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

ITA 1603/KOL/2024[2012-13]Status: DisposedITAT Kolkata08 Sept 2025AY 2012-13

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(2)Section 143(3)Section 147Section 148Section 149Section 250Section 69

151A. Therefore, issue of notice u/s 148 and passing the order u/s 143(3)/147 is beyond Jurisdiction and liable to be set aside. 6. For that, on the facts and circumstance of the case, the Ld. Ld. ITO, Ward- 1 (3) erred in law in completing the assessment u/s 143(3)/147 when notice u/s 148 was issued