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9 results for “reassessment u/s 147”+ Section 292clear

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Key Topics

Section 136Section 143(3)6Addition to Income6Section 235Section 272A(2)(e)4Section 2503Section 1473Penalty3Section 194J

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
2
Section 44A2
TDS2
Disallowance2

147, 148 and 149 of the Act from the corresponding Section 34 of the 1922 Act, the legal requirement of service of notice upon the Assessee in terms of Section 148 read with Section 282 (1) and Section 153 (2) of the Act is a jurisdictional pre-condition to finalizing the reassessment. (iv) The onus is on the Revenue

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

292(8) of the Act and therefore inference can only be drawn on the facts and provisions of law of the Act after long drawn discussion. Therefore under such circumstances, the provisions of Section 154 of the ITA Nos. 96 & 98/PAT/2021 C.O Nos. 2 & 3/ PAT/2021 AY: 2012-13,2013-14 ,2016-17 Kumar Arunodaya Act cannot be invoked

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

292(8) of the Act and therefore inference can only be drawn on the facts and provisions of law of the Act after long drawn discussion. Therefore under such circumstances, the provisions of Section 154 of the ITA Nos. 96 & 98/PAT/2021 C.O Nos. 2 & 3/ PAT/2021 AY: 2012-13,2013-14 ,2016-17 Kumar Arunodaya Act cannot be invoked

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

292(8) of the Act and therefore inference can only be drawn on the facts and provisions of law of the Act after long drawn discussion. Therefore under such circumstances, the provisions of Section 154 of the ITA Nos. 96 & 98/PAT/2021 C.O Nos. 2 & 3/ PAT/2021 AY: 2012-13,2013-14 ,2016-17 Kumar Arunodaya Act cannot be invoked

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

292(8) of the Act and therefore inference can only be drawn on the facts and provisions of law of the Act after long drawn discussion. Therefore under such circumstances, the provisions of Section 154 of the ITA Nos. 96 & 98/PAT/2021 C.O Nos. 2 & 3/ PAT/2021 AY: 2012-13,2013-14 ,2016-17 Kumar Arunodaya Act cannot be invoked

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

292(8) of the Act and therefore inference can only be drawn on the facts and provisions of law of the Act after long drawn discussion. Therefore under such circumstances, the provisions of Section 154 of the ITA Nos. 96 & 98/PAT/2021 C.O Nos. 2 & 3/ PAT/2021 AY: 2012-13,2013-14 ,2016-17 Kumar Arunodaya Act cannot be invoked

IIT PATNA,PATNA vs. DC/AC EXEMPTION CIR PATNA, PATNA BIHAR

In the result the appeal of the assessee is allowed

ITA 337/PAT/2025[2017-18]Status: DisposedITAT Patna25 Nov 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.337/Pat/2025 Assessment Year: 2017-18 Iit, Patna……………………………………………………………....Appellant Admin Block Bihta, Patna-801106. [Pan: Aaaai2401A] Vs. Dc/Ac, Exemption, Circle-Patna.……………..………………….…..... Respondent Appearances By: Shri Ankit Kumar, Ca Appeared On Behalf Of The Appellant. Md. A H Chowdhary, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 20, 2025 Date Of Pronouncing The Order : November 25, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 19.05.2025 Passed By The Nfac, Delhi [The ‘Cit(A)’] Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee, Iit Patna, Did Not File Its Return Of Income For The Assessment Year 2017–18. The Assessing Officer (Ao) Relied Upon Information Available Regarding: Cash Deposits: ₹10593857/- Term Deposits: ₹62,69,99,990/- Contract Receipt: ₹8,51,325/- Interest U/S 194A Of The Act : ₹31,59,501/-

Section 139Section 144BSection 147Section 148Section 194ASection 250Section 272A(2)(e)

u/s 194A of the Act : ₹31,59,501/- I.T.A. No.337/Pat/2025 IIT, Patna purchases of Foreign currency: ₹329,39,39,545/- Foreign remittance: ₹10,40,20,292 On the basis of the above, the AO reopened the assessment under section 147, finalised it under section 144B of the Act by determined the total income. Subsequently, penalty proceedings were initiated under section

SHEKHAR NARAYAN,PATNA vs. NFAC, DELHI

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

ITA 355/PAT/2025[2018-19]Status: DisposedITAT Patna29 Jan 2026AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 13Section 194Section 194JSection 250Section 44A

u/s 147 r.w.s. 144B of the Act. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who considered the facts of the case, the written submission filed and the case laws relied upon by the assessee and held as under: “6.1 Grounds No.1 to 8: In these grounds, the appellant has challenged the additions

SHEKHAR NARAYAN,PATNA vs. NFAC, DELHI

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

ITA 354/PAT/2025[2017-18]Status: DisposedITAT Patna29 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 13Section 194Section 194JSection 250Section 44A

u/s 147 r.w.s. 144B of the Act. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who considered the facts of the case, the written submission filed and the case laws relied upon by the assessee and held as under: “6.1 Grounds No.1 to 8: In these grounds, the appellant has challenged the additions