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100 results for “reassessment”+ Section 58(4)clear

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Key Topics

Section 148140Section 143(3)91Section 14786Addition to Income66Section 13238Section 12A37Reassessment37Reopening of Assessment34Section 26328Section 11

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

ITA 1260/PUN/2025[2020-21]Status: DisposedITAT Pune24 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Vyomesh PathakFor Respondent: Shri Vidya Ratna Kishore
Section 143(3)Section 154Section 155(18)Section 270ASection 270A(2)Section 270A(6)(a)Section 270A(7)Section 270A(8)Section 270A(9)

reassessment, referred to in clause (a) of sub-section (1), in a case where an order under sub- section (4) has been made accepting the application." 20. Sub-section (18) of Section 155 of the Income Tax Act is inserted vide Finance Act, 2022 w.e.f. 01.04.2022. The above referred provisions provide that deduction of any surcharge, cess, which

Showing 1–20 of 100 · Page 1 of 5

28
Section 10(20)24
Survey u/s 133A23

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

ITA 987/PUN/2025[2014-15]Status: DisposedITAT Pune27 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Subodh Ratnaparkhi, CAFor Respondent: Shri Amit Bobde, CIT
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 250

reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C Corollary being that after seizing of operational period of Section 153A to 153D. the cases being dealt thereunder were circumscribed in the scope of newly substituted Section 148." We are in complete agreement

AHAMAD BIN MUBARAK CHAUOSE,NANDED vs. ITO, WARD (1), NANDED, NANDED

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

ITA 1545/PUN/2025[2012-13]Status: DisposedITAT Pune08 Aug 2025AY 2012-13

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1545/Pun/2025 िनधा"रण वष" / Assessment Year: 2012-13 Ahamad Bin Mubarak V The Income Tax Officer, Chauose, S Ward-(1), Nanded. H.No.1-7-1349, Peerburhan Nagar, Nanded – 431506. Maharashtra. Pan: Alzpc8261D Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Ajay D. Kulkarni – Addl.Cit(Dr) Date Of Hearing 07/08/2025 Date Of Pronouncement 08/08/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(A), Kanpur Passed Under Section 250 Of The Income Tax Act, 1961 Dated 18.10.2024 For The A.Y.2012-13 Emanating From The Assessment Order Under Section 144 Of The Income Tax Act, 1961, Dated

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 153(2)Section 250Section 44A

4. That the reassessment order passed under section 147/144 is illegal and unsustainable in law as the reasons recorded were never communicated to the Appellant, contrary to settled legal principles and precedents. 5. That the reassessment proceedings were barred by limitation as per the provisions of section 153(2) of the Act, and hence, the assessment framed on 09/03/2016

SATISH VISHNU THOMBARE, INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR vs. VARSHA PRAFULLA ZENDE, AHMEDNAGAR

In the result, the appeal of the Revenue is dismissed

ITA 1656/PUN/2024[2010-11]Status: DisposedITAT Pune29 Oct 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

For Appellant: Miss Shivani Shah (Virtual)For Respondent: Shri Akhilesh Srivastva
Section 132(1)Section 147Section 148Section 151Section 68

58,67,123/-, on account of unsecured loans and the interest thereon. 5.5. However, the appellant has strongly argued that the reasons recorded were wrong and the reassessment proceedings were initiated on the basis of wrong reasons. The appellant stated that reassessment proceedings were initiated after recording reasons that "bogus companies run by Mr. Anand Sharma and group had provided

ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, PUNE vs. ZEAL EDUCATION SOCIETY, PUNE

In the result, appeal of the Revenue is dismissed

ITA 1642/PUN/2024[2017-2018]Status: DisposedITAT Pune08 May 2025AY 2017-2018

Bench: Shri Manish Borad & Ms. Astha Chandra

For Appellant: Shri S.N. Puranikh, CAFor Respondent: Shri Arvind Desai, Addl.CIT-DR
Section 11Section 11(1)Section 11(1)(a)Section 12ASection 143(3)Section 270ASection 274

58,75,26,422/- (declared as per income and expenditure account). The relevant observations and findings of the Ld. CIT(A) are reproduced below:- “6.4. During the appellate proceedings, the appellant has furnished written submissions by stating that it has filed ITR declaring total income at Rs. Nil, return is processed u/s.143(1)(a) by assessing income

RAJENDRA CHANDRAKANT CHINCHNIKAR,PUNE vs. CIT(A)-11, PUNE

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

ITA 1700/PUN/2025[2019-20]Status: DisposedITAT Pune29 Sept 2025AY 2019-20

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2019-20 Rajendra Chandrakant Chinchnikar Acit, Central Circle, 2165, B Ward, Koshti Galli, Vs. Kolhapur Mangalwar Peth, Pune – 416012 Pan: Acppc3559D (Appellant) (Respondent) Assessee By : Shri Tanzil Padvekar Department By : Shri Milind Debaje, Jcit Date Of Hearing : 25-08-2025 Date Of Pronouncement : 29-09-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Tanzil PadvekarFor Respondent: Shri Milind Debaje, JCIT
Section 133ASection 139(5)Section 143(1)(a)Section 143(2)Section 270ASection 270A(2)(a)Section 270A(9)(e)Section 274Section 69A

4. On the facts and in law, the Ld. CIT(A) erred by failing put to the notice of the Appellant of limb under which the Penalty was sought to be levied under Section 270A of the Act. 5. On the facts and in law, the impugned Notice for levy of Notice under Section 270A of the Act and impugned

INCOME-TAX OFFICER vs. PIMPRI CHINCHWAD NEW TOWN DEVELOPMENT AUTHORITY,, PUNE

In the result, all the appeals of assessee are allowed and cross objections and appeals of Revenue are dismissed

ITA 945/PUN/2014[2005-06]Status: DisposedITAT Pune27 Jun 2019AY 2005-06

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.929 To 932/Pun/2014 यििाारण वषा / Assessment Years : 2003-04 To 2005-06 & 2008-09

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan, CIT-DR
Section 143(3)

reassessment, is higher than income originally assessed, after the original assessment was set aside by Hon'ble ITAT. 5. The Hon'ble ITAT may kindly hold that the lease of land and/or property for 99 years does not tantamount to sale of property. In alternative if transaction of held as sale, cost of sale be allowed as deduction

PIMPRI CHINCHWAD NEW TOWN DEVELOPMENT AUTHORITY,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed and cross objections and appeals of Revenue are dismissed

ITA 931/PUN/2014[2005-06]Status: DisposedITAT Pune27 Jun 2019AY 2005-06

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.929 To 932/Pun/2014 यििाारण वषा / Assessment Years : 2003-04 To 2005-06 & 2008-09

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan, CIT-DR
Section 143(3)

reassessment, is higher than income originally assessed, after the original assessment was set aside by Hon'ble ITAT. 5. The Hon'ble ITAT may kindly hold that the lease of land and/or property for 99 years does not tantamount to sale of property. In alternative if transaction of held as sale, cost of sale be allowed as deduction

PIMPRI CHINCHWAD NEW TOWN DEVELOPMENT AUTHORITY,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed and cross objections and appeals of Revenue are dismissed

ITA 930/PUN/2014[2004-05]Status: DisposedITAT Pune27 Jun 2019AY 2004-05

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.929 To 932/Pun/2014 यििाारण वषा / Assessment Years : 2003-04 To 2005-06 & 2008-09

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan, CIT-DR
Section 143(3)

reassessment, is higher than income originally assessed, after the original assessment was set aside by Hon'ble ITAT. 5. The Hon'ble ITAT may kindly hold that the lease of land and/or property for 99 years does not tantamount to sale of property. In alternative if transaction of held as sale, cost of sale be allowed as deduction

PIMPRI CHINCHWAD NEW TOWN DEVELOPMENT AUTHORITY,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed and cross objections and appeals of Revenue are dismissed

ITA 929/PUN/2014[2003-04]Status: DisposedITAT Pune27 Jun 2019AY 2003-04

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.929 To 932/Pun/2014 यििाारण वषा / Assessment Years : 2003-04 To 2005-06 & 2008-09

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan, CIT-DR
Section 143(3)

reassessment, is higher than income originally assessed, after the original assessment was set aside by Hon'ble ITAT. 5. The Hon'ble ITAT may kindly hold that the lease of land and/or property for 99 years does not tantamount to sale of property. In alternative if transaction of held as sale, cost of sale be allowed as deduction

INCOME-TAX OFFICER vs. PIMPRI CHINCHWAD NEW TOWN DEVELOPMENT AUTHORITY,, PUNE

In the result, all the appeals of assessee are allowed and cross objections and appeals of Revenue are dismissed

ITA 944/PUN/2014[2004-05]Status: DisposedITAT Pune27 Jun 2019AY 2004-05

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.929 To 932/Pun/2014 यििाारण वषा / Assessment Years : 2003-04 To 2005-06 & 2008-09

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan, CIT-DR
Section 143(3)

reassessment, is higher than income originally assessed, after the original assessment was set aside by Hon'ble ITAT. 5. The Hon'ble ITAT may kindly hold that the lease of land and/or property for 99 years does not tantamount to sale of property. In alternative if transaction of held as sale, cost of sale be allowed as deduction

PIMPRI CHINCHWAD NEW TOWN DEVELOPMENT AUTHORITY,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed and cross objections and appeals of Revenue are dismissed

ITA 932/PUN/2014[2008-09]Status: DisposedITAT Pune27 Jun 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.929 To 932/Pun/2014 यििाारण वषा / Assessment Years : 2003-04 To 2005-06 & 2008-09

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan, CIT-DR
Section 143(3)

reassessment, is higher than income originally assessed, after the original assessment was set aside by Hon'ble ITAT. 5. The Hon'ble ITAT may kindly hold that the lease of land and/or property for 99 years does not tantamount to sale of property. In alternative if transaction of held as sale, cost of sale be allowed as deduction

SHRIKANT GAJANAN VYAVAHARE,NASHIK vs. INCOME TAX OFFICER, NASHIK

In the result, appeal of the assessee in ITA No

ITA 916/PUN/2023[2018-19]Status: DisposedITAT Pune12 Apr 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.915 & 916/Pun/2023 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Shrikant Gajanan Vyavahare, The Income Tax Officer, Plot No.06, S.No.16/3/1, V Nashik. Samarth Bungla, Near S Modakeshwar Mandir, Modakeshwar Nagar, Kamatwade, Nashik – 422010. Pan: Aakpv1138N Appellant/ Assessee Respondent /Revenue Assessee By Miss Abhilasha Sanjay Pawar – Ar Revenue By Shri Sourabh Nayak – Addl.Cit-Dr Date Of Hearing 14/02/2024 Date Of Pronouncement 12/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 15.02.2023, Emanating From Penalty Order Under Section 270A Of The Act Dated 19.01.2022 & 20.01.2022 For A.Y.2017-18 & 2018-19 Respectively. Since Issue Involved Is

Section 148Section 250Section 270ASection 270A(10)

58,817/- Revised return 28.08.2017 Rs.8,64,630/- Rs.3,52,500/- Revised return 28.11.2017 Rs.4,02,000/- Rs.1,60,818/- Return filed in Response to 13.3.2020 Rs.8,73,080/- notice u/s 148 3. The Assessing Officer(AO) passed re-assessment order assessing the total income at Rs.8,81,897/-. The AO initiated ITA Nos.915 & 916/PUN/2023 for A.Y’s.2017-18

SHRIKANT GAJANAN VYAVAHARE,KAMATWADE vs. INCOME TAX OFFICER, NASHIK

In the result, appeal of the assessee in ITA No

ITA 915/PUN/2023[2017-18]Status: DisposedITAT Pune12 Apr 2024AY 2017-18

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.915 & 916/Pun/2023 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Shrikant Gajanan Vyavahare, The Income Tax Officer, Plot No.06, S.No.16/3/1, V Nashik. Samarth Bungla, Near S Modakeshwar Mandir, Modakeshwar Nagar, Kamatwade, Nashik – 422010. Pan: Aakpv1138N Appellant/ Assessee Respondent /Revenue Assessee By Miss Abhilasha Sanjay Pawar – Ar Revenue By Shri Sourabh Nayak – Addl.Cit-Dr Date Of Hearing 14/02/2024 Date Of Pronouncement 12/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 15.02.2023, Emanating From Penalty Order Under Section 270A Of The Act Dated 19.01.2022 & 20.01.2022 For A.Y.2017-18 & 2018-19 Respectively. Since Issue Involved Is

Section 148Section 250Section 270ASection 270A(10)

58,817/- Revised return 28.08.2017 Rs.8,64,630/- Rs.3,52,500/- Revised return 28.11.2017 Rs.4,02,000/- Rs.1,60,818/- Return filed in Response to 13.3.2020 Rs.8,73,080/- notice u/s 148 3. The Assessing Officer(AO) passed re-assessment order assessing the total income at Rs.8,81,897/-. The AO initiated ITA Nos.915 & 916/PUN/2023 for A.Y’s.2017-18

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE

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

ITA 2646/PUN/2024[2013-14]Status: DisposedITAT Pune14 May 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

Section 142(1)Section 143(3)Section 148

reassessment u/s 147. The learned CITA failed to consider the submissions made against the aforesaid addition and failed to appreciate that- 4.1 The appellant had accumulated and capitalised the expenses incurred on tooling and dies at the behest and on behalf of the Customers of Rs.6,00,43,068/- under Capital Work in Progress (CWIP) in the General Ledger

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, PUNE

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

ITA 2647/PUN/2024[2018-19]Status: DisposedITAT Pune14 May 2025AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandra

Section 142(1)Section 143(3)Section 148

reassessment u/s 147. The learned CITA failed to consider the submissions made against the aforesaid addition and failed to appreciate that- 4.1 The appellant had accumulated and capitalised the expenses incurred on tooling and dies at the behest and on behalf of the Customers of Rs.6,00,43,068/- under Capital Work in Progress (CWIP) in the General Ledger

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLIGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

ITA 506/PUN/2025[2015-16]Status: DisposedITAT Pune25 Aug 2025AY 2015-16

Bench: Shri R. K. Panda & Ms. Astha Chandrasr No 1

For Appellant: S/Shri Nikhil Pathak andFor Respondent: S/Shri Amol Khairnar, CIT-DR and
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)Section 35Section 35(1)Section 80I

58,47,391/- which was denied by the Assessing Officer on the ground that the relevant R & D unit was not approved by DSIR u/s 35(2AB) and therefore, the assessee is not entitled to claim the deduction. He submitted that before the Assessing Officer it was clarified that the assessee had made an application before DSIR and merely because

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

ITA 1660/PUN/2024[2014-15]Status: DisposedITAT Pune25 Aug 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandrasr No 1

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)Section 35Section 35(1)Section 80I

58,47,391/- which was denied by the Assessing Officer on the ground that the relevant R & D unit was not approved by DSIR u/s 35(2AB) and therefore, the assessee is not entitled to claim the deduction. He submitted that before the Assessing Officer it was clarified that the assessee had made an application before DSIR and merely because

CHITRA NARENDRA PARMAR,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

In the result, all the appeals filed by the respective assessees are allowed

ITA 1269/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127 is assigned in favour

RAMANLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

ITA 1264/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127 is assigned in favour