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82 results for “reassessment u/s 147”+ Reopening of Assessmentclear

Sorted by relevance

Mumbai1,780Delhi1,611Chennai533Ahmedabad533Kolkata441Jaipur386Bangalore284Hyderabad259Pune254Chandigarh211Rajkot207Raipur176Surat151Indore134Visakhapatnam90Patna82Nagpur76Agra69Guwahati69Amritsar64Cochin55Lucknow50Cuttack46Dehradun40Jodhpur36Allahabad33Ranchi13Panaji12Jabalpur7SC6Varanasi5

Key Topics

Section 14899Section 14798Section 25067Section 153A51Addition to Income50Section 143(3)43Section 69A30Reassessment30Reopening of Assessment

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

Showing 1–20 of 82 · Page 1 of 5

26
Section 142(1)25
Survey u/s 133A25
Section 14424

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. At this juncture, it would be of relevance to bring attention to erstwhile sec. 147 of the Income Tax Act, 1961, as applicable for the relevant assessment year, relevant extract of which reproduced as under: "If the Assessing Officer, has reason to believe that any income chargeable to tax has escaped assessment

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

reopening of the assessment in this case is held as bad in law by way of various counts as discussed above. Therefore, the consequential reassessment order passed u/s. 147

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

reopening of the assessment in this case is held as bad in law by way of various counts as discussed above. Therefore, the consequential reassessment order passed u/s. 147

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

reopening of the assessment in this case is held as bad in law by way of various counts as discussed above. Therefore, the consequential reassessment order passed u/s. 147

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

reopening of the assessment in this case is held as bad in law by way of various counts as discussed above. Therefore, the consequential reassessment order passed u/s. 147

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

reopening of the assessment in this case is held as bad in law by way of various counts as discussed above. Therefore, the consequential reassessment order passed u/s. 147

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

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

reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 28.03.2019. The assessee has filed return of income in response thereto on 27.04.2019 which was found to be invalid due to some reasons however no defective notice u/s 139(9) was issued before treating the return as invalid by the AO. Besides

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

reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 28.03.2019. The assessee has filed return of income in response thereto on 27.04.2019 which was found to be invalid due to some reasons however no defective notice u/s 139(9) was issued before treating the return as invalid by the AO. Besides

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

reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 28.03.2019. The assessee has filed return of income in response thereto on 27.04.2019 which was found to be invalid due to some reasons however no defective notice u/s 139(9) was issued before treating the return as invalid by the AO. Besides

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

reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 28.03.2019. The assessee has filed return of income in response thereto on 27.04.2019 which was found to be invalid due to some reasons however no defective notice u/s 139(9) was issued before treating the return as invalid by the AO. Besides

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

reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 28.03.2019. The assessee has filed return of income in response thereto on 27.04.2019 which was found to be invalid due to some reasons however no defective notice u/s 139(9) was issued before treating the return as invalid by the AO. Besides

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

147 of the Act does not postulate conferment of power upon the learned Assessing Officer to initiate reassessment I.T.A. Nos.02&03/Pat/2022 Assessment Years: 2015-16 & 2016-17 Vibhuti Bhushan Sinha & Sonam Raj proceeding on his mere change of opinion. If reasons to believe of the learned Assessing Officer is founded on an information which might have been received

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

147 of the Act does not postulate conferment of power upon the learned Assessing Officer to initiate reassessment I.T.A. Nos.02&03/Pat/2022 Assessment Years: 2015-16 & 2016-17 Vibhuti Bhushan Sinha & Sonam Raj proceeding on his mere change of opinion. If reasons to believe of the learned Assessing Officer is founded on an information which might have been received

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

u/s 153A additions need not be restricted or limited to incriminating material found during the course of search?" 16. Hon'ble Court concurred with the decision of Hon'ble Delhi High Court. We deem it appropriate to take note of relevant part of the decision, which reads as under: "16. Section 153A bears the heading "Assessment in case of search

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 62/PAT/2021[2016-17]Status: DisposedITAT Patna30 Aug 2023AY 2016-17

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

Section 132Section 153Section 153C

u/s 153A additions need not be restricted or limited to incriminating material found during the course of search?" 16. Hon'ble Court concurred with the decision of Hon'ble Delhi High Court. We deem it appropriate to take note of relevant part of the decision, which reads as under: "16. Section 153A bears the heading "Assessment in case of search

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

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

reopening the assessment. The majority of the learned Judges in the High Court, in our opinion, were not in error in holding that the said material could not have led to the formation of the belief that the income of the assessee respondent had escaped assessment because of his failure or omission to disclose fully and truly all material facts

THE MUZAFFARPUR CENTRAL CO-OPERATIVE BANK LTD,MUZAFFARPUR vs. ACIT, CIRCLE-2, MUZAFFARPUR

In the result, the appeal of the assessee stands dismissed

ITA 224/PAT/2019[2009-10]Status: HeardITAT Patna11 Jul 2024AY 2009-10

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.224/Pat/2019 Assessment Year: 2009-10 The Muzaffarpur Central Co-Operative Bank Ltd....…...……………....Appellant Sadar Hospital Road, Muzaffarpur, Bihar – 842001. [Pan: Aabat7831Q] Vs. Acit, Circle-2, Muzaffarpur….................................................…..…..... Respondent Appearances By: Shri Sanjeev Kr. Anwar, Advocate, 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 : July 11, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 30.07.2019 Of The Commissioner Of Income (Appeal), Muzzafarpur [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Though The Assessee In This Appeal Has Taken As Many As Six Grounds Of Appeal, However, The Sole Issue Raised By The Assessee In This Appeal Is Relating To The Validity Of The Reopening Of The Assessment. 3. The Brief Facts Of The Case Are That The Assessee Is A Cooperative Bank & Derives Income From Banking Business. The Assessing Officer Noted That The Assessee Had Not Filed Its Return Of Income For The Assessment Year 2009-10 Despite Having Taxable Income. He, Therefore

Section 142(1)Section 147Section 148Section 250Section 36(1)(viia)

reopening of the assessment. 3. The brief facts of the case are that the assessee is a cooperative bank and derives income from banking business. The Assessing Officer noted that the assessee had not filed its return of income for the assessment year 2009-10 despite having taxable income. He, therefore I.T.A. No.224/Pat/2019 Assessment Year: 2009-10 The Muzaffarpur Central