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51 results for “reassessment”+ Section 68clear

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Key Topics

Section 153A126Section 26360Addition to Income39Section 143(3)29Section 14826Section 14722Survey u/s 133A22Section 69A19Section 25018Section 132(1)

ACIT, CENTRAL CIRCLE-2, PATNA vs. M/S GAURAV RICE & FOOD PROCESSING PVT LTD, PATNA

In the result, the appeal of the Revenue is dismissed

ITA 16/PAT/2021[2016-17]Status: HeardITAT Patna09 Dec 2025AY 2016-17
Section 132Section 132(1)Section 153ASection 68

reassessment of the\nconcluded assessment does not arise. It has further been held by the High Court that\nthe provisions of section 153A to 153C cannot be interpreted to be further innings to\nthe assessing officer and/or assessee beyond the provisions of section 139 (return of\nincome), 139(5) (revised return of income), 147 (income escaping assessment) and\n263 (revision

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

Showing 1–20 of 51 · Page 1 of 3

17
Unexplained Money17
Limitation/Time-bar11
ITA 62/PAT/2021[2016-17]Status: Disposed
ITAT Patna
30 Aug 2023
AY 2016-17

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 132Section 153Section 153C

68 of the Income Tax Act. Accordingly, ld. Assessing Officer has made an addition of Rs.2,00,04,931/- in A.Y. 2016-17. In A.Y. 2017-18, the ld. CIT(Appeals) has observed that the assessee-company has taken a loan of Rs.1,06,02,895/- from M/s. Trailblazer Edusol (P) Limited and concurring his view with regard

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

ITA 63/PAT/2021[2017-18]Status: DisposedITAT Patna30 Aug 2023AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 132Section 153Section 153C

68 of the Income Tax Act. Accordingly, ld. Assessing Officer has made an addition of Rs.2,00,04,931/- in A.Y. 2016-17. In A.Y. 2017-18, the ld. CIT(Appeals) has observed that the assessee-company has taken a loan of Rs.1,06,02,895/- from M/s. Trailblazer Edusol (P) Limited and concurring his view with regard

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 183/PAT/2023[2015-16]Status: DisposedITAT Patna29 Jan 2025AY 2015-16

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 181/PAT/2023[2014-15]Status: DisposedITAT Patna29 Jan 2025AY 2014-15

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 180/PAT/2023[2013-14]Status: DisposedITAT Patna29 Jan 2025AY 2013-14

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 179/PAT/2023[2011-12]Status: DisposedITAT Patna29 Jan 2025AY 2011-12

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 182/PAT/2023[2015-16]Status: DisposedITAT Patna29 Jan 2025AY 2015-16

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

ACIT, CIRCLE-4, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 94/PAT/2020[2012-13]Status: HeardITAT Patna07 Nov 2023AY 2012-13

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

ACIT, CENTRAL CIRCLE-2, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 98/PAT/2021[2016-17]Status: HeardITAT Patna07 Nov 2023AY 2016-17

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

DCIT, CIRCLE-4, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 89/PAT/2020[2012-13]Status: HeardITAT Patna07 Nov 2023AY 2012-13

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

KUMAR ARUNOSAYA,PATNA vs. A.O., CIRCLE-6, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 33/PAT/2020[2013-14]Status: HeardITAT Patna07 Nov 2023AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

KUMAR ARUNODAYA,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX - 6, PATNA [NEW – DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, PATNA], PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

ITA 96/PAT/2021[2016-17]Status: HeardITAT Patna07 Nov 2023AY 2016-17

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 23

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

ACIT vs. INTERNATIONAL SCHOOL OF SOCIAL WELFARE HUMAN RESOURCES,

In the result, the appeal filed by the Revenue is allowed while the Cross Objection filed by the assessee is dismissed

ITA 119/PAT/2011[2005-06]Status: DisposedITAT Patna30 Oct 2024AY 2005-06

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

For Appellant: Shri Abhi Sarkar, AdvFor Respondent: Ld. DR. Lalita Kumari, Sr. DR
Section 12ASection 143(2)Section 144Section 147Section 148Section 250

reassessment order was cancelled. Subsequently, the Ld. AO reopened the assessment by recording reasons on16.04.2009 i.e. after the Ld. CIT(A) had cancelled the assessment made on 19.12.2007 on account of non-service of the notice u/s 143(2) the Act. The reasons recorded on 18.01.2007 for the 1st reopening and those recorded on 16.04.2009 for the 2 nd reopening

ACIT, CENTRAL CIRCLE-1, PATNA vs. SONAMOTI AGROTECH PVT LTD, PATNA

ITA 110/PAT/2019[2012-13]Status: DisposedITAT Patna23 Feb 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 132Section 143(2)Section 153ASection 68

68 was inserted by the Finance Act, 2012 w.e.f. 01.04.2013 wherein the onus of proving identity, genuineness and creditworthiness of the creditor to the satisfaction of the AO 13 Assessment Year: 2012-2013 & C.O. No. 04/PAT/2022 (in ITA No. 110/PAT/2019) Assessment Year: 2012-2013 Sonamoti Agrotech Pvt. Limited has entirely shifted to the assessee. In this regard the relevant proviso

MANOJ KUMAR DAS,BEGUSARAI vs. ASSESSMENT UNIT INCOME TAX DEPARTMENT, DELHI

Appeal is allowed for statistical purposes

ITA 391/PAT/2025[2015-16]Status: DisposedITAT Patna30 Oct 2025AY 2015-16

Bench: 19/07/2025. The Appeal Is Delayed By Around 37 Days. 4. That The Assessee States That The Reason For Delay Is That The Assessee Is Suffering From Hiv Aids & Is Constantly Under Treatment. Copy Of Medical Treatment Is Enclosed.

Section 115BSection 142(1)Section 144Section 147Section 148Section 250Section 68

68 read with section 115BBE of the Act, notwithstanding the fact that the reassessment proceeding was initiated on the basis

RANJEET SINGH,PATNA vs. ITO, WARD- 5 (5), PATNA

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

ITA 304/PAT/2024[2017-18]Status: DisposedITAT Patna17 Mar 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 148Section 250Section 250(2)Section 69A

reassessment proceeding is questionable and is not sustainable in the eye of law. In the absence of issue and service of notice u/s 143(2) the assessment become null and void. The appellant would like to place reliance on the decision of the Hon’ble High Court in the case of ACIT v. Geno Pharmaceuticals Ltd. [32 taxmann.com 162] wherein

SHANKAR CONSTRUCTION,PANCHGACHIA vs. ITO, WARD-3(1), PURNEA

In the result, the appeal of the assessee is allowed

ITA 565/PAT/2024[2016-17]Status: DisposedITAT Patna18 Nov 2024AY 2016-17

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumari.T.A. No. 565/Pat/2024 Assessment Year: 2016-2017 Shankar Construction,………………..…….……Appellant Panchgachia, Panchgachia-852124, Bihar [Pan:Abofs0800R] -Vs.- Income Tax Officer,………………….……..……Respondent Ward-3(1), Purnea, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate, Appeared On Behalf Of The Assessee Shri Ashok Kumar, Cit (Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: October 22, 2024 Date Of Pronouncing The Order: November 18, 2024 O R D E R

Section 143(1)Section 147Section 148Section 69A

section 68 of the Act. In this regard, enquiry was carried out on ITBA, e-filling portal and ITD database and on perusal of 12 Shankar Construction the ITR as filed by the assessee, it was observed that the assessee has not Page 2 of 4 ABOFS0800R SHANKAR CONSTRUCTION Α.Υ. 2016-17 ITBA/AST/F/147/(SCN)2021- 22/1041820954(1) declared such

SANGAM ALMIRAH PRIVATE LIMITED,MUZAFFARPUR vs. NFAC, DELHI

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

ITA 338/PAT/2025[2018-19]Status: DisposedITAT Patna27 Oct 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 250Section 270ASection 270A(9)

68 on 22/01/2021, the order for which was to be passed within a month from the end of the month in which the application was received by the Ld. AO i.e. by 28.02.2021; but the penalty order was passed much later on 10.02.2022 and no separate order for the application for immunity was passed. It was submitted that the penalty

ZAIMUR RAHMAN,EAST CHAMPARAN vs. INCOME TAX DEPARTMENT, NFAC, DELHI

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

ITA 321/PAT/2025[2015-16]Status: DisposedITAT Patna07 Oct 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144BSection 147Section 148Section 149Section 250Section 68Section 69A

68 read with section 115BBE of the Act and assessed the same under the Act. I.T.A. No.: 321/PAT/2025 Assessment Year: 2015-16 Zaimur Rahman. 11. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer, without giving any opportunity, much less sufficient opportunity, has erred in holding that Rs.11,43,600 shown as sales