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15 results for “reassessment u/s 147”+ Unexplained Investmentclear

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Key Topics

Section 14817Section 153A16Addition to Income15Section 69C13Survey u/s 133A11Section 14710Section 133A10Section 2509Section 143(3)

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
7
Reopening of Assessment7
Section 143(2)6
Search & Seizure6

invest the Income-tax Officer with authority to reassess the income of the Respondent pursuant to such return." On the facts of that case it was held that the Revenue had sufficiently discharged the onus by producing the affidavit of the process server. 35. Under Section 282 (1) of the Act, service of notice may be made by delivering

RANJEET KUMAR (INDIVIDUAL),BEGUSARAI vs. INCOME TAX OFFICER, WARD- 2 (1), BEGUSARAI

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

ITA 198/PAT/2025[2015-16]Status: DisposedITAT Patna06 Aug 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144BSection 147Section 148Section 250Section 271(1)(b)Section 271(1)(c)Section 271FSection 282Section 69

Unexplained investments in immovable property. 9. For that the Ld. CIT(A) has erred in upholding the order passed by the Ld. A.O as the initiation of reassessment u/s 147/148 of the Act, reopening the case and consequent reassessment proceedings/order are illegal, ab initio void as provisions of sec. 147

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 183/PAT/2023[2015-16]Status: DisposedITAT Patna29 Jan 2025AY 2015-16

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 179/PAT/2023[2011-12]Status: DisposedITAT Patna29 Jan 2025AY 2011-12

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 180/PAT/2023[2013-14]Status: DisposedITAT Patna29 Jan 2025AY 2013-14

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 181/PAT/2023[2014-15]Status: DisposedITAT Patna29 Jan 2025AY 2014-15

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

ITA 182/PAT/2023[2015-16]Status: DisposedITAT Patna29 Jan 2025AY 2015-16

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 133ASection 143(3)Section 148Section 153ASection 250

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken

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

147 that the assessee has escaped income as the assessee has already disclosed the purchase value of land in the audited balance with source of purchase. 2. For that the assessing officer as well as ld. CIT Appeal has failed to construe that the assessee has disclosed the investment in land in the balance sheet in regular course and said

MANOJ KUMAR DAS,BEGUSARAI vs. ASSESSMENT UNIT INCOME TAX DEPARTMENT, DELHI

Appeal is allowed for statistical purposes

ITA 391/PAT/2025[2015-16]Status: DisposedITAT Patna30 Oct 2025AY 2015-16

Bench: 19/07/2025. The Appeal Is Delayed By Around 37 Days. 4. That The Assessee States That The Reason For Delay Is That The Assessee Is Suffering From Hiv Aids & Is Constantly Under Treatment. Copy Of Medical Treatment Is Enclosed.

Section 115BSection 142(1)Section 144Section 147Section 148Section 250Section 68

unexplained investment in purchase of property credited from undisclosed sources u/s 68 read with section 115BBE of the Act and assessed the same under the Act. 10. For that the Id. assessing officer has grossly erred in holding the entire cash deposits as undisclosed income, notwithstanding the fact that it was apparent from the bank statement itself that purchases have

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

147 of the Act. Merely because the revenue classifies a fact already on record as “information” may vest it with the power to issue a notice of re assessment u/s 148A(b) but would certainly not vest it with the power to issue a re-assessment notice u/s 148 post an order u/s 148A(d). As per clause

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

MERIDIAN CONSTRUCTION INDIA LIMITED,PATNA vs. ACIT CIRCLE-2, PATNA

The appeals of the assessee are allowed for statistical purposes

ITA 261/PAT/2023[2016-17]Status: DisposedITAT Patna13 Aug 2024AY 2016-17

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133ASection 142(1)Section 143(2)Section 144Section 148Section 271(1)(b)Section 69CSection 70

unexplained expenditure incurred by the assessee for construction of three real estate properties, i.e. Patna One Mall, Boring Road Project and Phulwarisharif Patna Project. The assessee has sold the properties in these assessment years. The details of those properties have been tabulated in the assessment orders. The ld. Assessing Officer found that sale considerations disclosed by the assessee are lower

MERIDIAN CONSTRUCTION INDIA LIMITED,PATNA BIHAR vs. ACIT CIRCLE-2 PATNA, PATNA

The appeals of the assessee are allowed for statistical purposes

ITA 262/PAT/2023[2017-18]Status: DisposedITAT Patna13 Aug 2024AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133ASection 142(1)Section 143(2)Section 144Section 148Section 271(1)(b)Section 69CSection 70

unexplained expenditure incurred by the assessee for construction of three real estate properties, i.e. Patna One Mall, Boring Road Project and Phulwarisharif Patna Project. The assessee has sold the properties in these assessment years. The details of those properties have been tabulated in the assessment orders. The ld. Assessing Officer found that sale considerations disclosed by the assessee are lower

MERIDIAN CONSTRUCTION INDIA LIMITED,PATNA, BIHAR vs. ACIT CIRCLE-2 PATNA, PATNA

The appeals of the assessee are allowed for statistical purposes

ITA 259/PAT/2023[2014-15]Status: DisposedITAT Patna13 Aug 2024AY 2014-15

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133ASection 142(1)Section 143(2)Section 144Section 148Section 271(1)(b)Section 69CSection 70

unexplained expenditure incurred by the assessee for construction of three real estate properties, i.e. Patna One Mall, Boring Road Project and Phulwarisharif Patna Project. The assessee has sold the properties in these assessment years. The details of those properties have been tabulated in the assessment orders. The ld. Assessing Officer found that sale considerations disclosed by the assessee are lower

MERIDIAN CONSTRUCTION INDIA LIMITED,PATNA BIHAR vs. ACIT CIRCLE-2 PATNA, PATNA

The appeals of the assessee are allowed for statistical purposes

ITA 260/PAT/2023[2015-16]Status: DisposedITAT Patna13 Aug 2024AY 2015-16

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133ASection 142(1)Section 143(2)Section 144Section 148Section 271(1)(b)Section 69CSection 70

unexplained expenditure incurred by the assessee for construction of three real estate properties, i.e. Patna One Mall, Boring Road Project and Phulwarisharif Patna Project. The assessee has sold the properties in these assessment years. The details of those properties have been tabulated in the assessment orders. The ld. Assessing Officer found that sale considerations disclosed by the assessee are lower