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38 results for “reassessment u/s 147”+ Condonation of Delayclear

Sorted by relevance

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Key Topics

Section 14744Section 270A42Section 25029Section 14828Section 153A24Addition to Income23Section 14422Condonation of Delay21Limitation/Time-bar

SAROJ DEVI,PATNA vs. ITO, WARD- 6 (4), PATNA

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

ITA 242/PAT/2025[2016-17]Status: DisposedITAT Patna29 Sept 2025AY 2016-17

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 250

condone the delay and admit the appeal for adjudication. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that the grounds of appeal hereto are without prejudice to each other. 2. For that the Learned CIT(A) has erred in confirming the Assessment Order dated 16.12.2019 as passed u/s 143(3) read

G D MOTHER EDUCATIONAL SOCIETY,MUZAFFARPUR vs. ACIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are allowed

ITA 308/PAT/2024[2019-20]Status: DisposedITAT Patna

Showing 1–20 of 38 · Page 1 of 2

20
Reassessment19
Section 143(3)14
Penalty14
25 Sept 2024
AY 2019-20

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

Section 148Section 249Section 253Section 3Section 5

reassessment order by issuance of a notice under section 148(a) of the Income Tax Act. At first instance, the assessee thought that there was no need to file the appeal, but later on when it consulted with ld. Sr. Counsel, it was advised to file an appeal. In that process, the delay of 14 days had occurred. The assessee

G D MOTHER EDUCATIONAL SOCIETY,MUZAFFARPUR vs. ACIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are allowed

ITA 309/PAT/2024[2020-21]Status: DisposedITAT Patna25 Sept 2024AY 2020-21

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

Section 148Section 249Section 253Section 3Section 5

reassessment order by issuance of a notice under section 148(a) of the Income Tax Act. At first instance, the assessee thought that there was no need to file the appeal, but later on when it consulted with ld. Sr. Counsel, it was advised to file an appeal. In that process, the delay of 14 days had occurred. The assessee

G D MOTHER EDUCATIONAL SOCIETY,MUZAFFARPUR vs. ACIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are allowed

ITA 307/PAT/2024[2018-19]Status: DisposedITAT Patna25 Sept 2024AY 2018-19

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

Section 148Section 249Section 253Section 3Section 5

reassessment order by issuance of a notice under section 148(a) of the Income Tax Act. At first instance, the assessee thought that there was no need to file the appeal, but later on when it consulted with ld. Sr. Counsel, it was advised to file an appeal. In that process, the delay of 14 days had occurred. The assessee

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)

reassessment proceedings are bad in law in the absence of reasons recorded for issuing a reopening notice under section 148 of the Act being furnished to the assessee when sought for. It is axiomatic that power to reopen a completed assessment under the Act is an exceptional power and whenever revenue seeks to exercise such power, they must strictly comply

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)

reassessment proceedings are bad in law in the absence of reasons recorded for issuing a reopening notice under section 148 of the Act being furnished to the assessee when sought for. It is axiomatic that power to reopen a completed assessment under the Act is an exceptional power and whenever revenue seeks to exercise such power, they must strictly comply

RAJESH KUMAR,PATNA vs. ITO, WARD- 3 (2), GAYA

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

ITA 171/PAT/2025[2018-19]Status: DisposedITAT Patna18 Sept 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 147Section 234ASection 250Section 271FSection 69A

condone the delay and hears the appeal on merits.” 5. Rival contentions were heard and the record and the submissions made have been examined. Both before the Ld. AO as well as before the I.T.A. No.: 171/PAT/2025 Assessment Year: 2018-19 Rajesh Kumar. Ld. CIT(A), the assessee could not be represented properly and the Ld. AR requested that

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

PRERNA AGENCY PVT LTD,KOLKATA vs. INCOME TAX OFFICER, WARD 2(1), PATNA

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

ITA 285/PAT/2023[2013-2014]Status: DisposedITAT Patna26 Mar 2025AY 2013-2014

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 143(3)Section 147Section 148Section 151

delay is hereby condoned. 4. Brief facts of the case of the assessee are that the assessee M/s Prerna Agency pvt. Ltd. derived income from share trading, filed its return of income for AY 2013-14, and assessment u/s 143(3) of the Act was completed on 29.02.2016. Subsequently on an information received from investigation wing that M/s Prerna Agency

SAVITA DEVI,SUPAUL, BIHAR, INDIA vs. INCOME-TAX OFFICER, WARD-3(4), SAHARSA, SAHARSA,BIHAR

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

ITA 157/PAT/2025[2015-16]Status: DisposedITAT Patna04 Dec 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 148Section 149Section 250Section 69

reassessment on the basis of a false information beyond the limitation period envisaged in sec. 149 is illegal and unsustainable. The consequent assessment order is liable to be quashed. 3 in the Penalty Oder CIA remarks in Point 2 Sub Point 6,7,8 and Point 5 Last Para where it is clearly mention to follow the Natural Justice principal

VIBHUTI BHUSHAN SINHA,DWARKA vs. ITO, WARD-6(2), PATNA

In the result, both the appeals are treated as allowed for statistical purposes

ITA 2/PAT/2022[2015-16]Status: DisposedITAT Patna12 Aug 2024AY 2015-16

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.02/Pat/2022 Assessment Years: 2015-16 Vibhuti Bhushan Sinha………………………….....…...……………....Appellant C-601, Shivam Apartment, Virmeshwar Nagar, Dwarka, Gujrat-361335. [Pan: Aigps7118D] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent I.T.A. No.03/Pat/2022 Assessment Years: 2016-17 Sonam Raj…………..………………………….....…...……………....Appellant W/O Shri Deepak Verma, 2Nd Floor, House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [Pan: Dfsps6397E] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances By: Shri Sudipta Sannigrahi, Ca, Appeared On Behalf Of The Appellant. Shri Sushil Kr. Mishra, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 28, 2024 Date Of Pronouncing The Order : August 12, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By Two Different Assessees Against The Separate Orders Dated 30.04.2021 & 01.03.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To

Section 144Section 147Section 148Section 250

delay in filing the present appeal is hereby condoned. The assessee in this appeal has taken the following grounds of 3. appeal: “1. For that, on the fact & circumstances of the case, the Initiation of reassessment proceeding U/s. 147

SONAM RAJ,NEW DELHI vs. ITO, WARD-6(2), PATNA

In the result, both the appeals are treated as allowed for statistical purposes

ITA 3/PAT/2022[2016-17]Status: DisposedITAT Patna12 Aug 2024AY 2016-17

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.02/Pat/2022 Assessment Years: 2015-16 Vibhuti Bhushan Sinha………………………….....…...……………....Appellant C-601, Shivam Apartment, Virmeshwar Nagar, Dwarka, Gujrat-361335. [Pan: Aigps7118D] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent I.T.A. No.03/Pat/2022 Assessment Years: 2016-17 Sonam Raj…………..………………………….....…...……………....Appellant W/O Shri Deepak Verma, 2Nd Floor, House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [Pan: Dfsps6397E] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances By: Shri Sudipta Sannigrahi, Ca, Appeared On Behalf Of The Appellant. Shri Sushil Kr. Mishra, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 28, 2024 Date Of Pronouncing The Order : August 12, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By Two Different Assessees Against The Separate Orders Dated 30.04.2021 & 01.03.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To

Section 144Section 147Section 148Section 250

delay in filing the present appeal is hereby condoned. The assessee in this appeal has taken the following grounds of 3. appeal: “1. For that, on the fact & circumstances of the case, the Initiation of reassessment proceeding U/s. 147

SARIKA CHOUDHARY,PATNA vs. ACIT, CIRCLE-4, PATNA

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

ITA 254/PAT/2024[2011-12]Status: DisposedITAT Patna04 Apr 2025AY 2011-12

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(3)Section 250

delay in filing the appeal is hereby condoned and the appeal is admitted for adjudication. Page 3 of 7 I.T.A. No.: 254/PAT/2024 Assessment Year: 2011-12 Sarika Choudhary. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that on the facts and circumstances of the case the learned CIT (Appeal), Patna

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

condone the delay and admit the appeal for adjudication on merits. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that, The Learned Assessing Officer, being ITO, Ward-3(4), Saharsa (Here in after called the "AO") has erred in Assessing the appellant on a total Income of Rs 7001665/- as against

MOHAMMAD TANWEER ALI IMAM,PATNA vs. ITO, WARD- 5(1), PATNA

In the result, the appeal of the assessee is allowed

ITA 110/PAT/2025[2016-17]Status: DisposedITAT Patna22 Jul 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Mohammad Tanweer Ali Imam, Income Tax Officer, Darul Aman Po Bv College, Ward 5(1), Patna Samanpura, Rajabazar, Vs. Patna-800014 (Appellant) (Respondent) Pan No. Aanpi1722J Assessee By : Shri Manish Rastogi, Ar Revenue By : Shri Ashwani Kr. Singal, Dr Date Of Hearing: 08.07.2025 Date Of Pronouncement: 22.07.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Ashwani Kr. Singal, DR
Section 144Section 144BSection 147Section 201(1)

condone the delay and adjudicate the appeal. 04. The assessee has assailed the assessment order passed u/s 144 read with section 144B of the Income-tax Act, 1961 (the Act) dated 29.03.2022, assessing the income at ₹1,10,00,000/-. 05. The facts in brief are that the assessee has not filed any return of income. As per information received

VEENA DEVI,MUZAFFARPUR vs. PR.CIT-1, PATNA

In the result, appeal of the assessee is allowed

ITA 41/PAT/2021[2011-12]Status: DisposedITAT Patna06 Jun 2023AY 2011-12

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Dr. Manish Borad, Hon’Blei.T.A. No. 41/Pat/2021 Assessment Year: 2011-12 Veena Devi Pr. Cit, Patna-1 Vs Krishnapuri, Nh 28 Bhagwanpur Chowk Muzaffarpur - 842001 [Pan: Aoyps8291P] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ashish Maskara, Advocate Revenue By : Smt. Rinku Singh, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 29/05/2023 घोषणा क" तारीख /Date Of Pronouncement: 06/06/2023 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Learned Principal Commissioner Of Income Tax, Patna-1, (Hereinafter The “Ld. Pr. Cit”) Dt. 23/03/2021, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2011-12. 2. The Registry Has Pointed Out That There Is A Delay Of Eighteen (18) Days In Filing Of This Appeal In Time Before The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay Stating The Reasons Of Delay. After Perusing The Same, We Find That The Assessee Was Prevented By Sufficient Cause From Filing The Appeal In Time Before The Tribunal. Hence, The Delay Is Condoned & The Appeal Is Admitted. 3. The Assessee Has Raised The Following Grounds Of Appeal:- “1. For That The Order Passed U/S 263 Of The It Act By The Ld Pcit, Patna Is Wrong, Illegal, Arbitrary & Against The Fact & Circumstances Of The Case.

For Appellant: Shri Ashish Maskara, AdvocateFor Respondent: Smt. Rinku Singh, CIT, D/R
Section 143(3)Section 147Section 148Section 250Section 263

delay is condoned and the appeal is admitted. 3. The assessee has raised the following grounds of appeal:- “1. For that the order passed U/s 263 of the IT Act by the Ld PCIT, Patna is wrong, illegal, arbitrary & against the fact & circumstances of the case. I.T.A. No. 41/Pat/2021 Assessment Year: 2011-12 Veena Devi 2 2. For that

SMT. RANJU KUMARI,JAMUI vs. INCOME TAX OFFICER, WARD- 2 (5), LAKHISARAI

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

ITA 339/PAT/2023[2017-18]Status: DisposedITAT Patna20 Nov 2024AY 2017-18

Bench: Sri Rajpal Yadav & Dr. Manish Borad

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

u/s 147 r.w.s. 144 r.w.s. 144B of the Act dated 25.03.2022. 1.1. The assessee is in appeal before this Tribunal raising the following grounds of appeal: “1. For that the National Faceless Appeal Centre (NFAC), Delhi, ['the CIT(A)'] erred on facts and in law in dismissing the appeal filed by the appellant, vide order passed under section

DEEPAK SHRAWAN BUDHIA,MUMBAI vs. PR. COMMISSIONER OF I.T., PATNA-1, PATNA

In the result, appeal of the assessee is dismissed

ITA 365/PAT/2025[2018-19]Status: DisposedITAT Patna19 Jan 2026AY 2018-19

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 147Section 263Section 40

condone the delay and taking up for adjudication. 4. Briefly stated the facts of the case are that the Ld. Pr.CIT called the assessment record and observed that order passed by the AO u/s 147 r.w.s. 143(3) r.w.s. 144B of the Act was completed on 19.03.2023 assessed the total income at Rs. 68,24,861/- in which he observed

BINDESHWARI LAL MAHTO,KATIHAR vs. NFAC, DELHI

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

ITA 349/PAT/2025[2015-16]Status: DisposedITAT Patna09 Dec 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 148Section 250Section 44ASection 69A

reassessment proceedings under section 148 of the Act merely on the ground that an income has escaped assessment within the meaning of Section 147 of the Act. 3. For that the learned assessing officer has erred in passing an ex-parte order of assessment under section 147 read with Section 144 and 144B of the Act. ITA No.: 349/PAT/2025 Assessment

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

delay is hereby condoned and the appeal is admitted for adjudication. 2. On the last date of hearing, none appeared on behalf of the assessee but it was decided to proceed ahead with the adjudication, with the help of Ld. DR. 2.1 This appeal arises from order u/s 250 of the Income Tax Act, 1961 (hereafter “the Act”), passed