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20 results for “reassessment u/s 147”+ TDSclear

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Key Topics

Section 25029Section 14720Section 143(3)18TDS13Section 14810Deduction10Section 142(1)7Section 377Section 136Section 40

BIJAY KUMAR SARAF,DALDALI BAZAR, MUZAFFARPUR vs. DC/AC CIRCLE 1,MUZFFARPUR, IT-OFFICE, POLICE LINE, SIKANDERPUR MUZZAFFARPUR

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

ITA 205/PAT/2025[2014-15]Status: DisposedITAT Patna30 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(3)Section 147Section 148Section 194(7)Section 194C(6)Section 250

147 is beyond jurisdiction. 7. For that the learned commissioner of income tax (Appeals) had failed to appreciate the fact that the appellant has disclosed all material facts, produced books of account, audit report, TDS statement in Form 26Q, etc. at the time of assessment. The books of account had been accepted by the AO during regular assessment

6
Addition to Income6
Limitation/Time-bar6

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 was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS

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 was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS

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 was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS

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 was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS

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 was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS

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 was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS

PRERNA AGENCY PVT LTD,KOLKATA vs. INCOME TAX OFFICER, WARD 2(1), PATNA

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

ITA 285/PAT/2023[2013-2014]Status: DisposedITAT Patna26 Mar 2025AY 2013-2014

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 143(3)Section 147Section 148Section 151

147 can only be initiated if income chargeable to tax has escaped assessment due to the assessee’s failure to fully and truly disclose all the material facts necessary for the reassessment. As per the assessment order the AO issued notice u/s 142(1) of the Act seeking details of loan transaction and assessee submitted all the relevant documents

MD IFTAKHAR ALAM,ARARIA vs. ITO, PURNEA

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

ITA 389/PAT/2024[2017-18]Status: DisposedITAT Patna09 Oct 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 147Section 148Section 194HSection 250Section 69A

TDS is being deducted u/s 194H of the Income Tax Act 1961 further an accumulated commission of Rs.76,569 only has been received by assessee during the financial year 2016-17 relevant to it's AY 2017-18. 7. For that on the facts and circumstances of the case the deposits made during the period of demonetization

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

SARIKA CHOUDHARY,PATNA vs. ACIT, CIRCLE-4, PATNA

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

ITA 254/PAT/2024[2011-12]Status: DisposedITAT Patna04 Apr 2025AY 2011-12

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(3)Section 250

TDS deduction status, and appeal filing/hearing status and thereby got to know that the appeal was rejected by the appellate authority in a mechanical manner. The statutory period of 60 days was expiring on 28.04.2024 and in between the assessee approached her Counsel in the first week of February 2024 for filing of appeal before the Hon'ble Tribunal

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

MOHAMMAD TANWEER ALI IMAM,PATNA vs. ITO, WARD- 5(1), PATNA

In the result, the appeal of the assessee is allowed

ITA 110/PAT/2025[2016-17]Status: DisposedITAT Patna22 Jul 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Mohammad Tanweer Ali Imam, Income Tax Officer, Darul Aman Po Bv College, Ward 5(1), Patna Samanpura, Rajabazar, Vs. Patna-800014 (Appellant) (Respondent) Pan No. Aanpi1722J Assessee By : Shri Manish Rastogi, Ar Revenue By : Shri Ashwani Kr. Singal, Dr Date Of Hearing: 08.07.2025 Date Of Pronouncement: 22.07.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Ashwani Kr. Singal, DR
Section 144Section 144BSection 147Section 201(1)

TDS was deducted and deposited on the transfer of the said amount during the F.Y. 2015-16 and accordingly, the income of the assessee has escaped of ₹1,10,00,000/- within the meaning of 147 of the act on account of failure on the part of the assessee to disclose fully and truly all material facts. Finally, the assessment

ANIL KUMAR,NALANDA vs. ITO, WARD- 2 (3), BIHARSHARIF

In the result, the appeal of the assessee is allowed

ITA 361/PAT/2023[2014-15]Status: DisposedITAT Patna03 Oct 2024AY 2014-15

Bench: Shri Rajpal Yadav & Shri Dr. Manish Boradi.T.A. No. 361/Pat/2023 Assessment Year: 2014-15 Anil Kumar National Faceless Assessment Centre M/S Raj Trading Company, Nfac, Delhi Harnaut, Nalanda, Patna-803110 Vs Bihar [Pan : Azopc268H] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

For Appellant: Shri AK Rastogi, Sr. AdvFor Respondent: Shri Ashwani Kumar, Sr. DR
Section 144BSection 147Section 194JSection 40

147 read with section 144B of the Income-tax Act, 1961 (the Act) dated 22nd August, 2021, framed by Income Tax officer, NFAC. 2. The registry has informed that the appeal is time barred by 46 days. The assessee had filed an application for condonation of delay. Perusal of the same indicates that the assessee did not came to know

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

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

DEEPAK SHRAWAN BUDHIA,MUMBAI vs. PR. COMMISSIONER OF I.T., PATNA-1, PATNA

In the result, appeal of the assessee is dismissed

ITA 365/PAT/2025[2018-19]Status: DisposedITAT Patna19 Jan 2026AY 2018-19

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 147Section 263Section 40

147 r.w.s. 143(3) r.w.s. 144B of the Act was completed on 19.03.2023 assessed the total income at Rs. 68,24,861/- in which he observed that that as per section 40(a)(ia) of the Act the AO has not disallowed the certain payments made towards freight charges are covered under the TDS provision , the TDS default is made

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

TDS, TCS and self- assessment tax. Ground No. 10-General in nature. During the course of appellate proceedings appellant raised additional ground which is as under: - “That on the facts and circumstances of the case, the Assessing officer erred in making an addition of Rs. 5,50,00,000/- on the basis of seized documents found in third party

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

TDS, TCS and self- assessment tax. Ground No. 10-General in nature. During the course of appellate proceedings appellant raised additional ground which is as under: - “That on the facts and circumstances of the case, the Assessing officer erred in making an addition of Rs. 5,50,00,000/- on the basis of seized documents found in third party