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33 results for “reassessment u/s 147”+ Section 69Aclear

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Key Topics

Section 14741Section 69A32Section 25031Section 14831Addition to Income27Section 153A21Section 14418Unexplained Money13Reassessment13

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

Section-115BBE and consequentially taxation @60%. 14. For that sustenance of addition of Rs. 12,00,000/- and Rs.8,00,000/- u/s 69A are wrong, illegal and unjustified in the facts and circumstances of the appellant’s case. 15. For that the appellant reserves its right to furnish detailed written submission along with documents and evidences on or before date

SAROJ BALA,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PATNA

Showing 1–20 of 33 · Page 1 of 2

Section 142(1)12
Cash Deposit12
Section 115B8

In the result, ITA Nos.233-235/PAT/2024, ITA Nos

ITA 233/PAT/2024[2014-15]Status: DisposedITAT Patna14 Oct 2025AY 2014-15
Section 132(1)Section 139(1)Section 153ASection 153DSection 69A

reassessment\nis passed pursuant to a search operation is a mandatory\nrequirement of Section 153D of the Act and that such approval is\nnot meant to be given mechanically. The Court also concurs with\nthe finding of the ITAT that in the present cases such approval was\ngranted mechanically without application of mind by the Additional\nCIT resulting in vitiating

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

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

ITA 182/PAT/2025[2017-18]Status: DisposedITAT Patna21 Aug 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271ASection 271FSection 272A(1)(d)

147 unless reasons are communicated. In the instant case, the contention of the assessee is that the assessee has complied with the notice under section 148 and the assessing officer has not furnished the reasons recorded for issuance of notice under section 148 despite the request made by the assessee. The Revenue could not place any evidence to controvert

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

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

ITA 181/PAT/2025[2017-18]Status: DisposedITAT Patna21 Aug 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271ASection 271FSection 272A(1)(d)

147 unless reasons are communicated. In the instant case, the contention of the assessee is that the assessee has complied with the notice under section 148 and the assessing officer has not furnished the reasons recorded for issuance of notice under section 148 despite the request made by the assessee. The Revenue could not place any evidence to controvert

PAVAN KUMAR BHAGAT,SAHARSA vs. ITO, WARD-3(4), SAHARSA, SAHARA

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 281/PAT/2024[2017-18]Status: DisposedITAT Patna02 Sept 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 144Section 147Section 148Section 250Section 37Section 69A

reassessment proceeding under Section 147 of the Act and has grossly acted in violation of the directions of the Hon'ble Supreme Court in the case of GKN Driveshafts (India) Ltd vs ITO reported in [2002] 125 Taxman 963 (SC) and [2003] 259 ITR 19 (SC). 10. For that the Ld. Assessing officer has erred not serving any notice u/s

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 2025AY 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

SMT. RANJU KUMARI,JAMUI vs. INCOME TAX OFFICER, WARD- 2 (5), LAKHISARAI

In the result, the appeal filed by the assessee is partly allowed

ITA 339/PAT/2023[2017-18]Status: DisposedITAT Patna20 Nov 2024AY 2017-18

Bench: Sri Rajpal Yadav & Dr. Manish Borad

Section 115BSection 144Section 147Section 148Section 250Section 69A

147 read with section 144 and 144B of the Act, vide order dated 25-03-2022 at an income of Rs 2,62,77,730/- against the current years income of Rs 3,07,646/-, by making addition of Rs 2,62,77,730/- after treating the entire deposits in bank account as unexplained money under section 69A

ZAIMUR RAHMAN,EAST CHAMPARAN vs. INCOME TAX DEPARTMENT, NFAC, DELHI

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

ITA 321/PAT/2025[2015-16]Status: DisposedITAT Patna07 Oct 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144BSection 147Section 148Section 149Section 250Section 68Section 69A

reassessment proceeding under Section 147 of the Act and has grossly acted in violation of the directions of the Hon'ble Supreme Court in the case of GKN Driveshafts (India) Ltd vs ITO reported in [2002] 125 Taxman 963 (SC) and [2003] 259 ITR 19 (SC). 17. For that the appellant shall place any other point/points at the time

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

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

69A of the I.T. Act, 1961 and assessed taxed U/s 115 BBE of the Act at the rate of 60 percent.” 4. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who issued notices for hearing after condoning the delay but since the assessee did not respond, he inferred that the assessee

BHOLA PRASAD YADAV,PATNA vs. INCOME TAX OFFICER, WARD- 4(1), PATNA

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

ITA 288/PAT/2025[2017-18]Status: DisposedITAT Patna12 Nov 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 144Section 144BSection 147Section 148Section 250Section 69A

section 148 of the Act. Since the assessee failed to furnish any explanation for the source of cash deposits made during the demonetization period, the Assessing Officer (hereinafter referred to as Ld. 'AO') treated the total cash deposits during the period of demonetization as unexplained money u/s 69A r.w.s. 115BBE of the Act and added the same to the income

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

69A of the act. So far as the cash of Rs.2,19,20,000/- seized from the residence of Ahmed Ashfaque Karim, substantive addition was made in the hands of assessee trust (which is part of the addition of Rs.4.92 Cr. made in AY 2014-15) but prospective addition of Rs.1.5 Cr. & Rs.1.22 Cr. made in the hands of Nuzhat

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

69A of the act. So far as the cash of Rs.2,19,20,000/- seized from the residence of Ahmed Ashfaque Karim, substantive addition was made in the hands of assessee trust (which is part of the addition of Rs.4.92 Cr. made in AY 2014-15) but prospective addition of Rs.1.5 Cr. & Rs.1.22 Cr. made in the hands of Nuzhat

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

69A of the act. So far as the cash of Rs.2,19,20,000/- seized from the residence of Ahmed Ashfaque Karim, substantive addition was made in the hands of assessee trust (which is part of the addition of Rs.4.92 Cr. made in AY 2014-15) but prospective addition of Rs.1.5 Cr. & Rs.1.22 Cr. made in the hands of Nuzhat

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

69A of the act. So far as the cash of Rs.2,19,20,000/- seized from the residence of Ahmed Ashfaque Karim, substantive addition was made in the hands of assessee trust (which is part of the addition of Rs.4.92 Cr. made in AY 2014-15) but prospective addition of Rs.1.5 Cr. & Rs.1.22 Cr. made in the hands of Nuzhat

USHASHREE DEVI,BHAGALPUR vs. PR.CIT-1, PATNA

In the result, appeal of the assessee is allowed for statistical purposes

ITA 42/PAT/2021[2017-18]Status: DisposedITAT Patna22 Jul 2024AY 2017-18

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No. 42/Pat/2021 Assessment Year: 2017-18 Ushashree Devi, Sabjee Chowk, Barari, Bhagalpur - 812003 [Pan: Aeppd6663K] ……….......................…...……………....Appellant Vs. Principal Commissioner Of Income Tax, Patna – 1, Central Revenue Building, Birchand Patel Marg, Patna - 800001 ............…..........................…..…..... Respondent

Section 142(1)Section 147Section 148Section 151Section 250Section 69A

u/s 69A of the LT. Act, 1961 in the bank account of the appellant based on wrong facts of the case The action of Id. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case as sum of Rs.5,45,000/- only was deposited in savings Bank account 12. For that the provisions of section 69A

UPAM SHREE,BHAGALPUR vs. PR.CIT-1, PATNA

In the result, appeal of the assessee is allowed for statistical purposes

ITA 40/PAT/2021[2017-18]Status: DisposedITAT Patna16 Jul 2024AY 2017-18

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No. 40/Pat/2021 Assessment Year: 2017-18 Upam Shree, C/O Ashok Kumar Mandal, Sabjee Chowk, Barari, Bhagalpur - 812003 [Pan: Ecfps5292P] ……….......................…...……………....Appellant Vs. Principal Commissioner Of Income Tax, Patna – 1, Central Revenue Building, Birchand Patel Marg, Patna - 800001 ............…..........................…..…..... Respondent

Section 142(1)Section 147Section 148Section 151Section 250Section 69A

u/s 69A of the I.T. Act, 1961 in the bank account of the appellant based on wrong facts of the case. The action of ld. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case as sum of Rs.2,50,000/- only was deposited in savings Bank account. 14. For that the provisions of section 69A

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

69A of the Income Tax Act. 3. Brief facts of the case are that the assessee is engaged in construction activity. It has filed its return of income on 13th October, 2016 declaring taxable income of Rs.35,36,520/-. This return was processed under section 143(1) of the Income Tax Act. The ld. Assessing Officer thereafter observed that

BINDESHWARI LAL MAHTO,KATIHAR vs. NFAC, DELHI

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

ITA 349/PAT/2025[2015-16]Status: DisposedITAT Patna09 Dec 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 148Section 250Section 44ASection 69A

reassessment proceedings under section 148 of the Act merely on the ground that an income has escaped assessment within the meaning of Section 147 of the Act. 3. For that the learned assessing officer has erred in passing an ex-parte order of assessment under section 147 read with Section 144 and 144B of the Act. ITA No.: 349/PAT/2025 Assessment

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

69A of the Act and I.T.A. No.: 101/PAT/2025 Assessment Year: 2012-13 Amrendra Pratap Singh. assessed the same under Section 115BBE of the Act, solely on the basis of some information shared by the Assistant Director of Income Tax (Inv.), Unit- 1, Varanasi, notwithstanding the fact that the said amount was from sale of ancestral agricultural land which was outside