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98 results for “reassessment u/s 147”+ Section 1clear

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Key Topics

Section 148132Section 147121Section 143(3)103Section 26394Section 153C91Addition to Income73Section 153A72Section 6854Reassessment

VISHAL KISHORILAL JAIN,NAGPUR vs. DCIT/ACIT CIRCLE-4, NAGPUR

In the result, assessee’s appeal for A

ITA 108/NAG/2025[2016-17]Status: DisposedITAT Nagpur15 May 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mukesh AgrawalFor Respondent: Shri Abhay Y. Marathe
Section 132Section 139(1)Section 143(1)Section 147Section 148Section 2(40)Section 68Section 69

reassessment u/s 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C. Corollary being that after seizing of operational 18 February, 2025 WP3057_2019.DOC period of Section 153A to 153D, the cases being dealt thereunder were circumscribed in the scope of newly substituted Section

Showing 1–20 of 98 · Page 1 of 5

44
Section 25040
Reopening of Assessment27
Condonation of Delay14

LATITUDE INFRAVENTURES,NAGPUR vs. PCIT,NAGPUR-1, NAGPUR

In the result, appeal filed by the assessee for assessment year 2017–18

ITA 349/NAG/2024[2016-17]Status: DisposedITAT Nagpur22 Oct 2024AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 143(1)Section 143(3)Section 147Section 148Section 263Section 263(2)

147 of the Act. 3. Whether where jurisdiction under section 263 was sought to be exercised with reference to issues which were not subject of reopening of assessment, period of limitation provided in section 263(2) would commence from date of order of assessment u/s 143(1) and not from date on which order of reassessment

LATITUDE INFRAVENTURES,NAGPUR vs. PCIT,NAGPUR-1, NAGPUR

In the result, appeal filed by the assessee for assessment year 2017–18

ITA 350/NAG/2024[2017-18]Status: DisposedITAT Nagpur22 Oct 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 143(1)Section 143(3)Section 147Section 148Section 263Section 263(2)

147 of the Act. 3. Whether where jurisdiction under section 263 was sought to be exercised with reference to issues which were not subject of reopening of assessment, period of limitation provided in section 263(2) would commence from date of order of assessment u/s 143(1) and not from date on which order of reassessment

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), NAGPUR vs. M/S. RADHA MADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 140/NAG/2021[2018-19]Status: DisposedITAT Nagpur29 Jul 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under Section 132 or books of account, other documents or any assets are requisitioned under Section 132-A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish

ASSTT.COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(1), NAGPUR vs. M/S RADHA MADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 26/NAG/2020[2014-15]Status: DisposedITAT Nagpur29 Jul 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under Section 132 or books of account, other documents or any assets are requisitioned under Section 132-A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), NAGPUR vs. M/S. RADHA RADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 49/NAG/2021[2013-14]Status: DisposedITAT Nagpur29 Jul 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under Section 132 or books of account, other documents or any assets are requisitioned under Section 132-A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish

ASSTT.COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(1), NAGPUR vs. M/S RADHA MADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 27/NAG/2020[2015-16]Status: DisposedITAT Nagpur29 Jul 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under Section 132 or books of account, other documents or any assets are requisitioned under Section 132-A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1),NAGPUR, NAGPUR vs. M/S. RADHA MADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 48/NAG/2021[2012-13]Status: DisposedITAT Nagpur29 Jul 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under Section 132 or books of account, other documents or any assets are requisitioned under Section 132-A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), NAGPUR vs. M/S. RADHA MADHAV DEVELOPER , NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 47/NAG/2021[2011-12]Status: DisposedITAT Nagpur29 Jul 2024AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under Section 132 or books of account, other documents or any assets are requisitioned under Section 132-A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish

M/S NEW VIRAJ HOUSING AGENCY,NAGPUR vs. ACIT, CENTRAL CIRCLE-1(1), NAGPUR

In the result, the appeals filed by the assessee for all the three years is allowed

ITA 183/NAG/2017[2010-11]Status: DisposedITAT Nagpur28 Jun 2022AY 2010-11

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Sudesh Banthia CAFor Respondent: Shri Piyush Kolhe (CIT-DR)
Section 132Section 133ASection 133A(3)(ia)Section 139Section 143(2)Section 153ASection 153C

u/s 153A, it is necessary to analyze the provisions of section 132(1) and 153A. The provisions of section 132(1) and 153A are reproduced as under: 12 ITA183/NAG/2017 NEW VIRAJ HOUSING AGENCY VS ACIT , C.C. 1(1), NAGPUR 153A. (1) Notwithstanding anything contained in section 139, section 147, section 148,section 149, section-151 and section

ASHOKKUMAR GOKULCHAND SANANDA,BULDHANA vs. ASSISTANT COMMISIONER OF INCOME TAX AKOLA CIRCLE, AKOLA

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

ITA 427/NAG/2024[2014-15]Status: DisposedITAT Nagpur06 Apr 2026AY 2014-15

Bench: Shri Pawan Singh & Shri Khettra Mohan Royashokkumar Gokulchand Acit, Akola Circle, Akola Sananda, Rana Traders, Vs Gandhi Chowk, Khamgaon, Dist. Buldhan, Khamgaon Pan : Adpps 755I L Assessee Respondent Assessee By : Shri K.P. Dewani, Adv Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 20.02.2026 Date Of Pronouncement : 06.04.2026

For Appellant: Shri K.P. Dewani, AdvFor Respondent: Shri Surjit Kumar Saha, Sr. DR
Section 132Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 2Section 234BSection 250Section 35(1)(ii)

Reassessment framed without providing reasons recorded for issue of notice u/s 148 is not in accordance with law and contrary to decision of Hon’ble Jurisdictional High Court in the case of CIT vs. Videsh Sanchar Nigam Ltd. reported at 340 ITR 66 (Bom.) and liable to be cancelled. 6) The addition made by A.O. at Rs.17

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

ITA 112/NAG/2024[2013-14]Status: DisposedITAT Nagpur26 Dec 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 153ASection 153CSection 250

147 to 149, 151 and 153. By virtue of the 2017 Amending Act, significant amendments came to be introduced in section 153A. These included, inter alia, the search assessment block being enlarged to 10 AYs consequent to the addition of the stipulation of “relevant AY” and which was defined to mean those years which would fall beyond the 6 year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

ITA 111/NAG/2024[2012-13]Status: DisposedITAT Nagpur26 Dec 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 153ASection 153CSection 250

147 to 149, 151 and 153. By virtue of the 2017 Amending Act, significant amendments came to be introduced in section 153A. These included, inter alia, the search assessment block being enlarged to 10 AYs consequent to the addition of the stipulation of “relevant AY” and which was defined to mean those years which would fall beyond the 6 year

M/S MAHESHWARI COAL BENEFICATION& INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

ITA 110/NAG/2024[2011-12]Status: DisposedITAT Nagpur26 Dec 2024AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 153ASection 153CSection 250

147 to 149, 151 and 153. By virtue of the 2017 Amending Act, significant amendments came to be introduced in section 153A. These included, inter alia, the search assessment block being enlarged to 10 AYs consequent to the addition of the stipulation of “relevant AY” and which was defined to mean those years which would fall beyond the 6 year

M/S MAHESHWARI COAL BENEFICATION& INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

ITA 109/NAG/2024[2010-11]Status: DisposedITAT Nagpur26 Dec 2024AY 2010-11

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 153ASection 153CSection 250

147 to 149, 151 and 153. By virtue of the 2017 Amending Act, significant amendments came to be introduced in section 153A. These included, inter alia, the search assessment block being enlarged to 10 AYs consequent to the addition of the stipulation of “relevant AY” and which was defined to mean those years which would fall beyond the 6 year

M/S MAHESHWARI COAL BENEFICATION& INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

ITA 108/NAG/2024[2009-10]Status: DisposedITAT Nagpur26 Dec 2024AY 2009-10

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 153ASection 153CSection 250

147 to 149, 151 and 153. By virtue of the 2017 Amending Act, significant amendments came to be introduced in section 153A. These included, inter alia, the search assessment block being enlarged to 10 AYs consequent to the addition of the stipulation of “relevant AY” and which was defined to mean those years which would fall beyond the 6 year

DY. COMMISSIONER OF INCOME TAX, CIRCLE-3, NAGPUR, NAGPUR vs. VINODKUMAR RAJENDRALAL KOCHHAR, KAMPTEE

In the result, the appeal filed by the department is dismissed

ITA 386/NAG/2023[2016]Status: DisposedITAT Nagpur31 Jul 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe, Sr. DR
Section 139(1)Section 142Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 44A

u/s 147 of the Act and change of opinion is not permissible even within 4 years. “Reopening of an assessment on mere change of opinion without any tangible material is unsustainable - Assessing Officer deemed to have applied his mind if facts are on record and reopening under section 147 on change of opinion is not permissible even within 4 years

NIRMALKUMAR AGRAWAL HUF,NAGPUR vs. INCOME TAX OFFICER, WARD-2, BHANDARA

In the result, assessee’s appeal stands allowed

ITA 242/NAG/2025[2018-19]Status: DisposedITAT Nagpur22 Sept 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rohan Loya a/wFor Respondent: Shri Pankaj Kumar
Section 139(1)Section 143(1)(a)Section 144BSection 147Section 148Section 263

reassessment order dated 24.03.2023 passed by AO u/s 147 read with 5 Nirmalkumar Agrawal (HUF) ITA no.242/Nag./2025 section 144B of the Act for A.Y. 2018-19 in the case of the assessee is set aside, with a direction to the Assessing Officer to pass a fresh Assessment Order denovo, after giving opportunity of being heard to the assessee

DATTU SAMPAT VANKHEDE,NAGPUR vs. PCIT-2, NAGPUR

In the result, appeal filed by the assessee is dismissed

ITA 581/NAG/2024[2014-15]Status: DisposedITAT Nagpur29 Jan 2025AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Dilip LohiyaFor Respondent: Shri Sandipkumar Salunke
Section 143(3)Section 147Section 148Section 263

1. The order passed by the Pr. Commissioner of Income Tax, Nagpur-2 U/s 263 under the Income Tax Act, 1961 is illegal, invalid and bad in law. 2. The Pr. Commissioner of Income Tax, Nagpur-2 ought to have considered order passed U/s. 143(3) rws 147 since all the issues of sale of two immovable property transaction were

SMT. NALINI SHYAM MOUNDEKAR,,NAGPUR vs. ITO, WARD- 4(1),, NAGPUR

In the result, these appeals by the assessee stand allowed as above

ITA 516/NAG/2014[2003-04]Status: DisposedITAT Nagpur27 Mar 2017AY 2003-04

Bench: Shri Shamim Yahya & Shri Ram Lal Negi..

For Appellant: Shri K.P. DewaniFor Respondent: Shri A.R. Ninawe
Section 144Section 148Section 5

147 of the Act.” 11. Against the above order the assessee is in appeal before the ITAT. 12. The contentions of the learned counsel of the assessee are summarized as under : “A) AO has observed that notices u/s 148 of I.T. Act, 1961 are served by affixture on 26/03/2009. In the assessment proceeding assessee has submitted before A.O. that notice