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16 results for “reassessment”+ Permanent Establishmentclear

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Key Topics

Section 1132Section 1516Section 2(15)16Section 143(3)12Survey u/s 133A10Section 1478Section 12A8Section 41(1)8Exemption8Condonation of Delay

ASSISTANT COMMISSIONER OF INCOME TAX-5, KANPUR vs. M.K.U PVT. LTD., KANPUR

In the result, appeal in ITA No

ITA 509/LKW/2018[2011-12]Status: DisposedITAT Lucknow29 Aug 2025AY 2011-12

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

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 143Section 143(3)Section 147Section 250

reassessment proceedings. The ld. AO also pointed out that the re-assessment proceedings had not been finalized and due opportunity would be provided to the assessee in the case. He also rejected the second set of objections filed by the assessee regarding the issuance of notice beyond time, pointing out that since the amount escaped was likely to be Rs.1

5
Section 1324
Search & Seizure3

MOHD. ASFAND AKHTAR,KANPUR vs. DEPUTI COMMISSIONER OF INCOME TAX CC-2, KANPUR

In the result, the appeal of Revenue in ITA

ITA 139/LKW/2022[2018-19]Status: DisposedITAT Lucknow26 Sept 2025AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2018-19 Dcit, Cc-2 V. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar V. Dcit, Central Circle-Ii Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Ashish Jaiswal, AdvocateFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 143(3)Section 36(1)(va)Section 37Section 41Section 41(1)Section 68Section 69C

established the unsecured loans received by the appellant from M/s Wise Financial Advisor Services Pvt. Ltd. has been treated as bogus and both additions were made on the basis of these facts. It is strange to see that when the AO is same and within a span of 4 months from December 2017 till April 2018 if a lender

DY.COMMISSIONER OF INCOME TAX,CC-2,, KANPUR vs. SHRI.MOHAMMAD ASFAND AKHTAR, KANPUR

In the result, the appeal of Revenue in ITA

ITA 144/LKW/2022[2018-19]Status: DisposedITAT Lucknow26 Sept 2025AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2018-19 Dcit, Cc-2 V. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar V. Dcit, Central Circle-Ii Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Ashish Jaiswal, AdvocateFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 143(3)Section 36(1)(va)Section 37Section 41Section 41(1)Section 68Section 69C

established the unsecured loans received by the appellant from M/s Wise Financial Advisor Services Pvt. Ltd. has been treated as bogus and both additions were made on the basis of these facts. It is strange to see that when the AO is same and within a span of 4 months from December 2017 till April 2018 if a lender

SHRI NARESH KUMAR YADAV,LUCKNOW vs. INCOME TAX OFFICER- 1(5), LUCKNOW

In the result, the appeal of the assessee is allowed

ITA 186/LKW/2020[2011-12]Status: DisposedITAT Lucknow26 Jul 2022AY 2011-12

Bench: Shri. A. D. Jainassessment Year: 2011-12 Shri Naresh Kumar Yadav V. Ito-1(5) Vill. & Post Madiyaon Lucknow Lucknow Tan/Pan:Aebpy8040D (Appellant) (Respondent) Appellant By: Shri Prashant Kumar Verma, Advocate Respondent By: Shri Harish Gidwani, D.R. Date Of Hearing: 12 07 2022 Date Of Pronouncement: 26 07 2022 O R D E R This Is Assessee’S Appeal Against The Order Of The Ld. Cit(A)-1, Lucknow, Dated 11.10.2019, For Assessment Year 2011- 12, Raising The Following Original Grounds Of Appeal: 1. Because, The Whole Assessment Order Impugned In The Present Appeal Stands Wholly Vitiated As There Can Be No Reason To Believe That Income Has Escaped Assessment U/S 147/144 On The Ground Of Mere Cash Deposits In The Bank Account Amounting To Rs.12,98,000/- Therefore, The Entire Assessment Proceedings Are Liable To Be Held As Nullity & Without Jurisdiction. 2. Because, The Assessment Order Impugned In The Present Appeal Stands Wholly Vitiated As There Can Be No Reason To Believe On The Basis Of Air Information That Income Has Escaped Assessment U/S 147/144 On The Ground Of Mere Cash Deposits In Bank Account Amounting Rs.12,98,000/-. Therefore, The Entire Assessment Proceedings Are Liable To Be Held As Nullity & Without Jurisdiction.

For Appellant: Shri Prashant Kumar VermaFor Respondent: Shri Harish Gidwani, D.R
Section 147Section 148

permanent account number is being done with the help of computers. Quoting of such numbers in high value transactions may be made to a statutory requirement. 41.2. At present the provisions of sub-section (6) of section 133 empower income-tax authorities to call for information which is useful for, or relevant to, any proceeding under the Act which means

KHANDELWAL SOYA INDUSTRIES LIMITED ,RAMPUR vs. ACIT(CENTERAL), BAREILLY

In the result, appeal of the assessee is partly allowed in the\nterms indicated hereinbefore

ITA 93/LKW/2022[F.Y.2005-06]Status: DisposedITAT Lucknow29 Aug 2025
Section 127Section 132Section 153ASection 153DSection 194H

reassess taking into consideration the other material\nin respect of completed assessments/unabated assessments.\nMeaning thereby, in respect of completed/unabated assessments, no\naddition can be made by the AO in absence of any incriminating material\nfound during the course of search under section 132 or requisition\nunder section 132A of the Act, 1961. However, the completed/unabated\nassessments can be re-opened

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 349/LKW/2025[2016-17]Status: DisposedITAT Lucknow11 Dec 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

reassessment proceeding. In response to which department has provided copy of order sheet on 24.10.2025. In which reasons are not recorded while issuing notice u/s 148 and approval taken from specified authority were also not provided. Though the case was selected for income escaping assessment of assessee covered by sec. 132 and Assessing Officer while issuing notice u/s 148, shall

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 351/LKW/2025[2018-19]Status: DisposedITAT Lucknow11 Dec 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

reassessment proceeding. In response to which department has provided copy of order sheet on 24.10.2025. In which reasons are not recorded while issuing notice u/s 148 and approval taken from specified authority were also not provided. Though the case was selected for income escaping assessment of assessee covered by sec. 132 and Assessing Officer while issuing notice u/s 148, shall

ACIT, CENTRAL CIRCLE-II, LUCKNOW, LUCKNOW vs. RAKESH KUMAR PANDEY, GONDA U.P.

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 460/LKW/2025[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

reassessment proceeding. In response to which department has provided copy of order sheet on 24.10.2025. In which reasons are not recorded while issuing notice u/s 148 and approval taken from specified authority were also not provided. Though the case was selected for income escaping assessment of assessee covered by sec. 132 and Assessing Officer while issuing notice u/s 148, shall

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 24/LKW/2017[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

Establish That It Had Intention To Do Business-at The Relevant Time The Company Was Not Express And Intention To Resume Business- Thus, no Business was Carried On-facts That It had To Pay The Government Half Share of Profits For Some time and That It Had To Return Deposits To Consumers Would Not Indicate That It was Carrying

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 164/LKW/2017[2011-12]Status: DisposedITAT Lucknow08 Jun 2022AY 2011-12

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

Establish That It Had Intention To Do Business-at The Relevant Time The Company Was Not Express And Intention To Resume Business- Thus, no Business was Carried On-facts That It had To Pay The Government Half Share of Profits For Some time and That It Had To Return Deposits To Consumers Would Not Indicate That It was Carrying

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 631/LKW/2016[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

Establish That It Had Intention To Do Business-at The Relevant Time The Company Was Not Express And Intention To Resume Business- Thus, no Business was Carried On-facts That It had To Pay The Government Half Share of Profits For Some time and That It Had To Return Deposits To Consumers Would Not Indicate That It was Carrying

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 165/LKW/2017[2012-13]Status: DisposedITAT Lucknow08 Jun 2022AY 2012-13

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

Establish That It Had Intention To Do Business-at The Relevant Time The Company Was Not Express And Intention To Resume Business- Thus, no Business was Carried On-facts That It had To Pay The Government Half Share of Profits For Some time and That It Had To Return Deposits To Consumers Would Not Indicate That It was Carrying

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 630/LKW/2016[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

Establish That It Had Intention To Do Business-at The Relevant Time The Company Was Not Express And Intention To Resume Business- Thus, no Business was Carried On-facts That It had To Pay The Government Half Share of Profits For Some time and That It Had To Return Deposits To Consumers Would Not Indicate That It was Carrying

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 210/LKW/2017[2013-14]Status: DisposedITAT Lucknow08 Jun 2022AY 2013-14

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

Establish That It Had Intention To Do Business-at The Relevant Time The Company Was Not Express And Intention To Resume Business- Thus, no Business was Carried On-facts That It had To Pay The Government Half Share of Profits For Some time and That It Had To Return Deposits To Consumers Would Not Indicate That It was Carrying

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 211/LKW/2017[2014-15]Status: DisposedITAT Lucknow08 Jun 2022AY 2014-15

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

Establish That It Had Intention To Do Business-at The Relevant Time The Company Was Not Express And Intention To Resume Business- Thus, no Business was Carried On-facts That It had To Pay The Government Half Share of Profits For Some time and That It Had To Return Deposits To Consumers Would Not Indicate That It was Carrying

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 23/LKW/2017[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

Establish That It Had Intention To Do Business-at The Relevant Time The Company Was Not Express And Intention To Resume Business- Thus, no Business was Carried On-facts That It had To Pay The Government Half Share of Profits For Some time and That It Had To Return Deposits To Consumers Would Not Indicate That It was Carrying