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25 results for “reassessment u/s 147”+ Section 41(1)clear

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Key Topics

Section 25027Section 143(3)25Addition to Income18Section 14711Section 14810Section 153C9Section 376Section 80I6Deduction

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

41,773/-. After the case being processed under section 143(1) of the Act, it was selected for limited scrutiny for two reasons- (i) sales turnover mismatch; (ii) unsecured loans and the same was followed by issuance of valid notices under sections 143(2) and 142(1) of the Act. During the course of assessment proceedings, ld. Assessing Officer asked

Showing 1–20 of 25 · Page 1 of 2

6
TDS6
Section 235
Reopening of Assessment4

BIHAR STATE ROAD DEVELOPMENT CORPN.LTD.,PATNA vs. CIT (APPEAL), DELHI

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

ITA 335/PAT/2024[2018-19]Status: DisposedITAT Patna24 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reassessment proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

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

ITA 332/PAT/2024[2014-15]Status: DisposedITAT Patna24 Jul 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reassessment proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

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

ITA 331/PAT/2024[2013-14]Status: DisposedITAT Patna24 Jul 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reassessment proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ACIT, COR-2, PATNA

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

ITA 334/PAT/2024[2017-18]Status: DisposedITAT Patna24 Jul 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reassessment proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

BIHAR STATE ROAD DEVELOPMENT CORPORATION LTD,PATNA vs. ACIT, CIR-2, P)ATNA

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

ITA 333/PAT/2024[2014-15]Status: DisposedITAT Patna24 Jul 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reassessment proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ITO WARD 2(1) PATNA, PATNA

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

ITA 330/PAT/2024[2012-13]Status: DisposedITAT Patna24 Jul 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

reassessment proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

ACIT, CENTRAL CIRCLE-2, PATNA vs. NUZHAT NASREEN, L/H AHMAD ASHFAQUEKARIM OF NUZHAT NASREEN, PATNA

In the result, all the appeals of the revenue i

ITA 69/PAT/2021[2014-15]Status: DisposedITAT Patna25 Jul 2024AY 2014-15

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

For Appellant: Shri Sudipta Sannigrahi, C.AFor Respondent: Smt. Rinku Singh, CIT D/R
Section 250

147, 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person

ACIT, CENTRAL CIRCLE-2, PATNA vs. M/S AL-KARIM EDUCATIONAL TRUST, PATNA

In the result, all the appeals of the revenue i

ITA 67/PAT/2021[2013-14]Status: DisposedITAT Patna25 Jul 2024AY 2013-14

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

For Appellant: Shri Sudipta Sannigrahi, C.AFor Respondent: Smt. Rinku Singh, CIT D/R
Section 250

147, 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person

ACIT, CENTRAL CIRCLE-2, PATNA vs. M/S AL-KARIM EDUCATIONAL TRUST, PATNA

In the result, all the appeals of the revenue i

ITA 68/PAT/2021[2014-15]Status: DisposedITAT Patna25 Jul 2024AY 2014-15

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

For Appellant: Shri Sudipta Sannigrahi, C.AFor Respondent: Smt. Rinku Singh, CIT D/R
Section 250

147, 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person

ACIT CENTRAL CIRCLE-2, PATNA vs. AHMAD ASHFAQUE KARIM, PATNA

In the result, all the appeals of the revenue i

ITA 70/PAT/2021[2014-15]Status: DisposedITAT Patna25 Jul 2024AY 2014-15

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

For Appellant: Shri Sudipta Sannigrahi, C.AFor Respondent: Smt. Rinku Singh, CIT D/R
Section 250

147, 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person

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

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

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

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

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

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

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

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

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

reassessment; such failure cannot be condoned by referring to section292BB of the Act. 4. In the case of CIT Vs. Fomento Finance and Investment(P.) Ltd. [2020] 113taxmann.com 237 (Bombay), the Hon'ble Bombay High Court has held thatfor block assessment of undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable

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

41 DTR 353], it was held that- mere issue of warrant of authorization without there being search of the premises mentioned in the warrant of authorization would be meaningless and would not serve the purpose of section 132, therefore, actual search shall have to be carried out necessarily before proceeding u/s 153A of the Act. Assessment Years

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

41 DTR 353], it was held that- mere issue of warrant of authorization without there being search of the premises mentioned in the warrant of authorization would be meaningless and would not serve the purpose of section 132, therefore, actual search shall have to be carried out necessarily before proceeding u/s 153A of the Act. Assessment Years

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 is reproduced

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, PATNA, C.R. BUILDING, PATNA vs. DEEPSHREE PROPERTIES PVT. LTD., SAGUNA KHAGAUL DANAPUR PATNA

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

ITA 239/PAT/2023[2018-19]Status: DisposedITAT Patna08 Jan 2025AY 2018-19

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

Section 133ASection 143(2)Section 143(3)Section 153ASection 153CSection 250Section 69ASection 69C

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that...." does not preclude assessment u/s 143(3)/144 by issue of notice u/s 143(2) where satisfaction of the assessing officer of the searched person making assessment u/s 153A is not relevant. (iii) That on the facts and in the circumstances