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5 results for “reassessment u/s 147”+ Revision u/s 263clear

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Key Topics

Section 143(3)18Section 14718Section 26316Section 1486Reassessment4Addition to Income3Revision u/s 2633Limitation/Time-bar3Section 143(2)

ALKEM LABORATORIES LTD,PATNA vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is allowed

ITA 22/PAT/2021[2012-13]Status: DisposedITAT Patna08 Mar 2022AY 2012-13

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

Section 115JSection 143Section 143(3)Section 147Section 148Section 148(2)Section 154Section 263Section 263(1)Section 35

u/s 148(2) of the Act. We note that in assessment proceedings which culminated under section 143(3) order dated 31.03.2016 the AO did not examine this issue of commission payment. In the reopened assessment under section 147 read with section 148 of the Act as finalised vide order dated 31.12.2018, this issue did not come to the notice

2
Section 271D2
Section 1432
Section 263(1)2

ALKEM LABORATORIES LTD,PATNA vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is allowed

ITA 23/PAT/2021[2014-15]Status: DisposedITAT Patna08 Mar 2022AY 2014-15

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

Section 115JSection 143Section 143(3)Section 147Section 148Section 148(2)Section 154Section 263Section 263(1)Section 35

u/s 148(2) of the Act. We note that in assessment proceedings which culminated under section 143(3) order dated 31.03.2016 the AO did not examine this issue of commission payment. In the reopened assessment under section 147 read with section 148 of the Act as finalised vide order dated 31.12.2018, this issue did not come to the notice

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

263 of the IT Act revising the order passed U/s 143(3) r.w.s. 147 by the Ld ACIT, Cir -2 (1), Muzaffarpur on 26.12.2018 is wrong, illegal and against the facts and circumstances of the case and should be quashed. 3. For that the Ld PCIT should have considered the fact that the Assessing Officer has thoroughly examined

M/S MANISH FINLEASE (P) LTD,PATNA vs. ITO, WARD-2(1), PATNA

ITA 25/PAT/2019[2010-11]Status: DisposedITAT Patna09 Aug 2019AY 2010-11

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahuassessment Year : 2010-2011 Manish Finlease Pvt Ltd., Vs. Ito, Ward 2(1), Patna Chandi House Exhibition Road, Patna Pan/Gir No.Aaccm 6252 B (Appellant) .. ( Respondent) Assessee By : Shri A.K.Rastogi & Rakesh Kumar, Ars Revenue By : Shri Indrajeet Singh, Dr Date Of Hearing : 20/06/ 2019 Date Of Pronouncement : 09/08/ 2019 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Cit(A)-1, Patna Dated 27.9.2018 For The Assessment Year 2010-2011. 2. The Appeal Filed By The Assessee Is Delayed By 51 Days. The Assessee Has Filed Application For Condonation Of Delay Stating The Reasons For Not Filing The Appeal In Time Before The Tribunal. After Hearing The Submissions Of The Parties, We Are Satisfied That The Assessee Had A Bonafide Reason For Not Filing The Appeal In Time. Therefore, We Condone The Delay & Proceed To Decide The Appeal Of The Assessee On Merits.

For Appellant: Shri A.K.Rastogi & Rakesh Kumar, ARsFor Respondent: Shri Indrajeet Singh, DR
Section 133(6)Section 143(2)Section 143(3)Section 147Section 148(1)Section 68

revised return neither any claim was disallowed nor any addition was made. On appeal, the Commissioner (Appeals) quashed the reassessment proceedings holding that the assessee had disclosed all the facts and no new fact was available to the Assessing Officer. Therefore, it was mere change of opinion on the part of the Assessing Officer and as such, the reassessment proceedings

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

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 that the appellant has filed written submission, the content of 5 Assessment Year: 2012-2013 Dolly Ghosh which