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104 results for “reassessment u/s 147”+ Addition to Incomeclear

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Key Topics

Section 153A97Section 14787Addition to Income79Section 25075Section 14874Section 270A48Section 143(3)43Section 14438Section 69A38

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

reassess such income, other than the income involving matters which are the subject matters of any appeal, reference or revision, which is chargeable to tax and has escaped assessment." 6. By this second innings of section 147 and subsequent Assessment Order, the order of CIT(A)-II, Patna dated 16.01.2009 has been reduced to a nullity and the same time

Showing 1–20 of 104 · Page 1 of 6

Survey u/s 133A38
Reassessment25
Unexplained Money23

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

income at Rs. 8,18,08,606/- by making addition on account of long term capital gain of Rs. 7,31,02,196/- vide order dated 10.12.2019. 15. In the appellate proceedings the Ld. CIT(A) allowed the appeal of the assessee on legal issue as well as on merit. The Ld. CIT(A) called for a remand report from

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

income at Rs. 8,18,08,606/- by making addition on account of long term capital gain of Rs. 7,31,02,196/- vide order dated 10.12.2019. 15. In the appellate proceedings the Ld. CIT(A) allowed the appeal of the assessee on legal issue as well as on merit. The Ld. CIT(A) called for a remand report from

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

income at Rs. 8,18,08,606/- by making addition on account of long term capital gain of Rs. 7,31,02,196/- vide order dated 10.12.2019. 15. In the appellate proceedings the Ld. CIT(A) allowed the appeal of the assessee on legal issue as well as on merit. The Ld. CIT(A) called for a remand report from

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

income at Rs. 8,18,08,606/- by making addition on account of long term capital gain of Rs. 7,31,02,196/- vide order dated 10.12.2019. 15. In the appellate proceedings the Ld. CIT(A) allowed the appeal of the assessee on legal issue as well as on merit. The Ld. CIT(A) called for a remand report from

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

income at Rs. 8,18,08,606/- by making addition on account of long term capital gain of Rs. 7,31,02,196/- vide order dated 10.12.2019. 15. In the appellate proceedings the Ld. CIT(A) allowed the appeal of the assessee on legal issue as well as on merit. The Ld. CIT(A) called for a remand report from

NAND KUMAR PRASAD SAH,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

ITA 170/PAT/2023[2019-20]Status: HeardITAT Patna29 Aug 2024AY 2019-20

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri SK Tulsiyan, &For Respondent: Shri Ashwani Kr. Singal, DR
Section 132Section 139(1)Section 143(3)Section 153ASection 270A

additional income of ₹5,15,000/-. The learned Assessing Officer carried out the assessment proceeding but finally accepted the returned income. In nutshell, there is no difference between the assessed income and the returned income shown in the return filed u/s 153A of the Act. 08. Now, the learned Assessing Officer has initiated the penalty proceedings for under reporting income

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

ITA 164/PAT/2023[2018-19]Status: HeardITAT Patna29 Aug 2024AY 2018-19

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri SK Tulsiyan, &For Respondent: Shri Ashwani Kr. Singal, DR
Section 132Section 139(1)Section 143(3)Section 153ASection 270A

additional income of ₹5,15,000/-. The learned Assessing Officer carried out the assessment proceeding but finally accepted the returned income. In nutshell, there is no difference between the assessed income and the returned income shown in the return filed u/s 153A of the Act. 08. Now, the learned Assessing Officer has initiated the penalty proceedings for under reporting income

NAND KUMAR PRASAD SAH,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

ITA 172/PAT/2023[2020-21]Status: HeardITAT Patna29 Aug 2024AY 2020-21

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri SK Tulsiyan, &For Respondent: Shri Ashwani Kr. Singal, DR
Section 132Section 139(1)Section 143(3)Section 153ASection 270A

additional income of ₹5,15,000/-. The learned Assessing Officer carried out the assessment proceeding but finally accepted the returned income. In nutshell, there is no difference between the assessed income and the returned income shown in the return filed u/s 153A of the Act. 08. Now, the learned Assessing Officer has initiated the penalty proceedings for under reporting income

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

ITA 163/PAT/2023[2017-18]Status: HeardITAT Patna29 Aug 2024AY 2017-18

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri SK Tulsiyan, &For Respondent: Shri Ashwani Kr. Singal, DR
Section 132Section 139(1)Section 143(3)Section 153ASection 270A

additional income of ₹5,15,000/-. The learned Assessing Officer carried out the assessment proceeding but finally accepted the returned income. In nutshell, there is no difference between the assessed income and the returned income shown in the return filed u/s 153A of the Act. 08. Now, the learned Assessing Officer has initiated the penalty proceedings for under reporting income

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

ITA 165/PAT/2023[2019-20]Status: HeardITAT Patna29 Aug 2024AY 2019-20

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri SK Tulsiyan, &For Respondent: Shri Ashwani Kr. Singal, DR
Section 132Section 139(1)Section 143(3)Section 153ASection 270A

additional income of ₹5,15,000/-. The learned Assessing Officer carried out the assessment proceeding but finally accepted the returned income. In nutshell, there is no difference between the assessed income and the returned income shown in the return filed u/s 153A of the Act. 08. Now, the learned Assessing Officer has initiated the penalty proceedings for under reporting income

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

ITA 166/PAT/2023[2020-21]Status: HeardITAT Patna29 Aug 2024AY 2020-21

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri SK Tulsiyan, &For Respondent: Shri Ashwani Kr. Singal, DR
Section 132Section 139(1)Section 143(3)Section 153ASection 270A

additional income of ₹5,15,000/-. The learned Assessing Officer carried out the assessment proceeding but finally accepted the returned income. In nutshell, there is no difference between the assessed income and the returned income shown in the return filed u/s 153A of the Act. 08. Now, the learned Assessing Officer has initiated the penalty proceedings for under reporting income

PUNRASAR JUTE PARK LIMITED,PURNEA vs. CIT, PURNEA

In the result, the appeal of the assessee is allowed

ITA 432/PAT/2024[2015-16]Status: DisposedITAT Patna05 Sept 2024AY 2015-16

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 142(2)Section 143(1)Section 143(3)Section 147Section 148

u/s. 143(3) of the Act, dated 27/12/2017. Notice u/s.148 of the Act was thereafter issued by the A.O on 30/03/2021. Accordingly, as the case of the assessee was reopened beyond a period of 4 years from the end of the relevant assessment year, therefore, as per the "first proviso" to section 147 of the Act the case could have

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

income-tax Act, 1961 which is mandatory requirement for assuming jurisdiction u/s 148. Thus, validity 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

MADHURI DEVI,SAHARSA vs. ITO WARD- 3 (4), SAHARSA

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

ITA 238/PAT/2024[2017-18]Status: DisposedITAT Patna19 Feb 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(2)Section 144Section 145(3)Section 148Section 250Section 69A

reassessment notice would be without jurisdiction. 4. For that, the Learned AO has erred in framing assessment proceeding without issuing/serving Notice under section 143(2). The Ld AO never issued /served notice u/s 142(1) till date of passing of re-assessment order. 5. For that the Learned AO has erred in making addition

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 182/PAT/2025[2017-18]Status: DisposedITAT Patna21 Aug 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271ASection 271FSection 272A(1)(d)

u/s 142(1) dated 29/06/2021 was issued asking to furnish the return as was asked for through the Notice The whole order is bad in law and not prepared on facts requires to deleted for that early opportunity may please be provided to save us from the hardship as the LD. AO had made unnecessary addition which may be verified

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 181/PAT/2025[2017-18]Status: DisposedITAT Patna21 Aug 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271ASection 271FSection 272A(1)(d)

u/s 142(1) dated 29/06/2021 was issued asking to furnish the return as was asked for through the Notice The whole order is bad in law and not prepared on facts requires to deleted for that early opportunity may please be provided to save us from the hardship as the LD. AO had made unnecessary addition which may be verified

SHARDINDU PRASAD SINGH,PATNA vs. ITO, WARD-6(4), PATNA

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

ITA 630/PAT/2024[2016-17]Status: DisposedITAT Patna15 Oct 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 250Section 271(1)(c)

reassessment proceedings u/s 148 is totally arbitrary, illegal and totally based on suspicion after information collected u/s 133(6) from Registry Office, Danapur, Patna about signature of joint development agreement (JDA) having no information of escapement of income. As such, the assessee's submission of return in response to invalid notice u/s 148 is not the valid return

DOLLY GHOSH,BHAGALPUR vs. ACIT CENTRAL CIRCLE 1 PATNA, PATNA

In the result, the appeal of the assessee is allowed

ITA 182/PAT/2022[2012-13]Status: DisposedITAT Patna08 Oct 2024AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 234ASection 269SSection 269TSection 271DSection 271E

147 of the Act to the appellant. Under the circumstances, it is clear that the appellant had accepted the notice u/s 148, filed return of income in compliance to this notice and also corresponded with the Assessing Officer. Therefore, it appears that many of the objections raised against re- assessment proceedings are superfluous. Ongoing through the record, it is found

M/S GANESH RAM DOKANIA,PATNA vs. ACIT CENTRAL CIRCLE-2, PATNA

In the result, the appeal of the assessee is allowed on legal issue

ITA 263/PAT/2023[2012-13]Status: DisposedITAT Patna15 Oct 2024AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey]

Section 132Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148(2)Section 153ASection 68

reassessment proceedings u/s 148 of the Act which is wrong, invalid, illegal and unjustified in the facts and circumstances of the case. 3. Facts in brief are that the premises of the assessee were searched u/s 132 of the Act on 01.08.2024 which finally culminated in passing of assessment order u/s 153A read with Section 144 of the Act dated