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10 results for “reassessment u/s 147”+ Section 251clear

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Key Topics

Section 25012Section 14712Section 14410Section 69A9Section 1487Addition to Income7Limitation/Time-bar6Condonation of Delay6Section 143(2)

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

147. The impugned reassessment order as passed is fit to be declared annulled. 5. For that the learned CIT(A) has erred in rejecting the ground of the appellant that the assessment in this case has been completed without service of notice u/s 143(2). The Assessment Order as passed and confirmed by learned CIT(A) is ab-initio void

ARCHANA,PATNA vs. ITO, WARD- 4 (1), PATNA

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

ITA 338/PAT/2023[2013-14]Status: DisposedITAT Patna07 Jan 2025
3
Section 115B3
Reassessment3
Section 148A2
AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(2)Section 144Section 147Section 250Section 69A

reassessment proceeding has been initiated for making roving and fishing enquiry. The order of assessment as sustained u/s 147 rws 144 rws 144B is arbitrary, unjustified, without jurisdiction, void ab-initio, bad in law, vitiated in law and invalid. The order as passed u/s 147 is fit to be quashed / cancel / annulled. 1.2 For that the order of the assessment

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

147 of the Act was initiated after obtaining prior approval of the competent authority and a notice u/s 148 of the Act dated 01.08.2018 was generated and issued to the assessee for filing the return of income within 30 days from the service of the notice. But the assessee did not comply to the notice. Subsequent notices u/s

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

147 r.w.s. 144 r.w.s. 144B of the Act. 6. The Ld. DR though relied upon the order of the Ld. CIT(A), had no serious objection for remanding the matter back to the Ld. AO. 7. We have considered the submissions made. A perusal of the appellate order shows that while the Ld. CIT(A) has discussed non- compliance

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

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

AMRENDRA PRATAP SINGH,VARANASI vs. INCOME TAX OFFICER WARD- 3(1), GAYA

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

ITA 101/PAT/2025[2012-13]Status: DisposedITAT Patna07 Oct 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144Section 147Section 250Section 251Section 69A

147 of the Act. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who has gone through the facts of the case and has held that the burden of proof lies on the assessee to prove that the facts and findings of the Ld. AO were incorrect and in the instant case

RAJ KUMAR SINGH ,PATNA vs. ITO,WARD-6(4),PATNA , PATNA

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

ITA 341/PAT/2025[2016-17]Status: DisposedITAT Patna30 Dec 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133(6)Section 144Section 250

u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2016-17 dated 07.10.2024. 1.1 The Registry has informed that there is a delay of 224 days in filing of this appeal, which has been requested to be condoned by the assessee by an application for condonation of delay as under: “Most respectfully

MADHU DEVI,NAWADA vs. ITO, WARD 2 (3), BIHARSHARIF, PATNA

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

ITA 516/PAT/2025[2014-15]Status: DisposedITAT Patna30 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139Section 143Section 147Section 148ASection 250

reassessment proceeding in question is amount to review and based on change in opinion which is not permissible under the income tax act, as such, whole of the proceeding of re-assessment is bad and illegal and order passed on such illegal proceeding is also bad and without jurisdiction. 3. For that the order under challenge is otherwise

ALOK KUMAR,MADHEPURA vs. ITO WARD 3(5), SAHARSA

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

ITA 467/PAT/2024[2012-13]Status: DisposedITAT Patna19 Nov 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraalok Kumar, Ito Ward-3(5), S/O Sri Dasrath Mehata, Saharsha Village- Ganeshpur, M.S. Vs Yogiraj, Purani Madhepura, Dist- Madhepura – 852116 (Bihar) (Pan: Bpkpk1186D) (Appellant) (Respondent) Present For: Appellant By : K.P. Jalan, Ar Respondent By : Ashwani Kr. Singal, Jcit Date Of Hearing : 16.10.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per Rakesh Mishra: This Appeal Filed By The Assessee Is Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “The Ld. Cit(A) Dated 14.05.2024. 2 Alok Kumar, Ay: 2012-13 2. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Under:

For Appellant: K.P. Jalan, ARFor Respondent: Ashwani Kr. Singal, JCIT
Section 147Section 148Section 2Section 292BSection 54F

147 wherein the AO has assessed the appellant on a total income of Rs.1,67,12,410.00 as against return income of Rs.1,36,810.00. 02. For that the Ld. CIT(A) has erred in passing order dismissing the appeal without merit and without affording proper opportunity of being heard to the appellant and had violated the principles of equity