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13 results for “reassessment u/s 147”+ Rectification u/s 154clear

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Key Topics

Section 12A37Section 1125Section 10(20)24Section 26320Section 143(3)18Section 270A15Section 15410Addition to Income9Section 147

BRIG. (RETD.) JITENDRA KUMAR NARANG,NOIDA vs. ITO, WARD 11(3), PUNE, PUNE

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

ITA 228/PUN/2025[2007-08]Status: DisposedITAT Pune28 May 2025AY 2007-08

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Sankalp Malik (Virtual)For Respondent: Shri Aviyogi Ambadkar
Section 143(1)Section 143(3)Section 147Section 148Section 154

reassessment proceedings u/s 147 of the IT Act after getting approval from higher authority and issued notice u/s 148 of the IT Act. The assessee in response submitted that the original return already filed may kindly be treated as filed in response to the notice issued u/s 148 of the IT Act, since according to the assessee

8
Exemption7
TDS6
Rectification u/s 1544

ASHIRWAD CHARITABLE TRUST,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS) CIRCLE, PUNE

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

ITA 190/PUN/2024[2015-16]Status: DisposedITAT Pune20 Jun 2025AY 2015-16

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

For Appellant: Shri Raja B. SinghFor Respondent: Shri Ramnath P. Murkunde
Section 11Section 11(1)(a)Section 11(1)(d)Section 11(2)Section 12ASection 143(3)Section 147Section 154Section 2(15)

147- (a) by changing his opinion on matters already considered in the Order of Assessment under Section 143(3) as well as in the subsequent Order of Rectification under Section 154: (b) without disposing the objection specifically raised during the reassessment proceeding; and (c) without affording the appellant an opportunity of being heard. 6. The Appellant craves leave

HOTEL SAI SIDDHI PVT. LTD.,,NASHIK vs. PRINCIPAL COMMISSIONER OF INCOME-TAX-1, NASHIK

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

ITA 687/PUN/2021[2014-15]Status: DisposedITAT Pune16 Jan 2026AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15 M/S. Hotel Sai Siddhi Pvt. Ltd. Pcit-1, Nashik 3/4, Poush Sector, Lekha Nagar, Vs. Mumbai Agra Road, Nashik – 422009 Pan: Aabch4310G (Appellant) (Respondent) Assessee By : Shri Sanket Joshi Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 08-01-2026 Date Of Pronouncement : 16-01-2026 O R D E R

For Appellant: Shri Sanket JoshiFor Respondent: Shri Amol Khairnar, CIT-DR
Section 147Section 148Section 263

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp

SHRI PREMRAJ DHANRAJ BAFNA,PUNE vs. PR. COMMISSIONER OF INCOME-TAX -5, , PUNE

In the result, the appeal of assessee is allowed

ITA 317/PUN/2020[2010-11]Status: DisposedITAT Pune21 Oct 2022AY 2010-11

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri Sanket JoshiFor Respondent: Shri Sardar Singh Meena
Section 147Section 154Section 263

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp

UDAY UTTAMRAO NEVASE,PUNE vs. THE ASSESSING OFFICER / ASSESSMENT UNIT, PUNE

In the result, appeal of the assessee in ITA No

ITA 2606/PUN/2025[2022-23]Status: DisposedITAT Pune10 Feb 2026AY 2022-23

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2606/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Uday Uttamrao Nevase, V The Assessing Officer / Saugandh Niwas, Hind Colony S Assessment Unit, Pune. Lane No.1 A, Bhekrai Nagar, Phursungi, Pune – 412308. Pan: Akqpn1150Q Appellant/ Assessee Respondent /Revenue Assessee By Ca Rohan Gupta Revenue By Shri Harshit Bari – Addl.Cit(Virtual) Date Of Hearing 16/12/2025 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2022-23 Dated 04.09.2025 Emanating From The Penalty Order Passed Under Section 270A, Dated 17.09.2024. The Assessee Has Raised The Following Grounds Of Appeal : “Ground 1 Section 270Aa Immunity Cit A Erred In Law By Confirming The Penalty Of Rs 629382 Under Section 270A Without Considering And

Section 143(3)Section 250Section 270A

rectification u/s 154 because as per section 139(5), if any person, having furnished a return under sub-section (1) or sub-section (4), discovers any omission or any wrong statement therein, he may furnish a revised return at any time before three months prior to the end of the relevant assessment year or before the completion

BVG INDIA LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), PUNE, PUNE

In the result, the appeal of the assessee is allowed

ITA 516/PUN/2023[2020-21]Status: DisposedITAT Pune19 Oct 2023AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

For Appellant: Shri Vijay Mehta & Sneha M. PadhiarFor Respondent: S/Shri Ajay Kumar Kesari & Abdhesh Kumar
Section 132Section 142(1)Section 144Section 153ASection 153D

147 taxmann.com 288 (Allahabad) and argued that the purpose for having approval from Addl. CIT to ensure determination of correct tax and to protect interest of assessee by avoiding arbitrary, baseless addition. 17. Further, he drew our attention to the assessment orders for A.Ys. 2014-15, 2015-16 and 2016-17, argued that the actual taxability u/s

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)

rectification applications filed which is subject matter of the JAO and does not have any bearing to the penalty proceedings by the Faceless Penalty Officer. Therefore, the further contention of the assessee to keep the penalty proceeding in abeyance is baseless. Accordingly, it is inferred that this is a fit case for levying penalty u/s. 270A of Income

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

rectification request. The relevant observations of the Tribunal have already been reproduced in the preceding paragraphs. ITA Nos.1153, 1155 & 1154/MUM/2016 40. We find although the Tribunal had rejected the submission of the Revenue, however, the Assessing Officer has denied the claim of the assessee on the very same procedural grounds i.e. not claiming exemption u/s 11 in the return

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 545/PUN/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

rectification request. The relevant observations of the Tribunal have already been reproduced in the preceding paragraphs. ITA Nos.1153, 1155 & 1154/MUM/2016 40. We find although the Tribunal had rejected the submission of the Revenue, however, the Assessing Officer has denied the claim of the assessee on the very same procedural grounds i.e. not claiming exemption u/s 11 in the return

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

rectification request. The relevant observations of the Tribunal have already been reproduced in the preceding paragraphs. ITA Nos.1153, 1155 & 1154/MUM/2016 40. We find although the Tribunal had rejected the submission of the Revenue, however, the Assessing Officer has denied the claim of the assessee on the very same procedural grounds i.e. not claiming exemption u/s 11 in the return

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1153/MUM/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

rectification request. The relevant observations of the Tribunal have already been reproduced in the preceding paragraphs. ITA Nos.1153, 1155 & 1154/MUM/2016 40. We find although the Tribunal had rejected the submission of the Revenue, however, the Assessing Officer has denied the claim of the assessee on the very same procedural grounds i.e. not claiming exemption u/s 11 in the return

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

rectification request. The relevant observations of the Tribunal have already been reproduced in the preceding paragraphs. ITA Nos.1153, 1155 & 1154/MUM/2016 40. We find although the Tribunal had rejected the submission of the Revenue, however, the Assessing Officer has denied the claim of the assessee on the very same procedural grounds i.e. not claiming exemption u/s 11 in the return

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

rectification request. The relevant observations of the Tribunal have already been reproduced in the preceding paragraphs. ITA Nos.1153, 1155 & 1154/MUM/2016 40. We find although the Tribunal had rejected the submission of the Revenue, however, the Assessing Officer has denied the claim of the assessee on the very same procedural grounds i.e. not claiming exemption u/s 11 in the return