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18 results for “reassessment u/s 147”+ Section 155clear

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Key Topics

Section 12A36Section 10(20)24Section 1124Section 14821Section 143(3)20Addition to Income13Section 234E12Section 2639TDS

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

155 taxmann.com 432 (Madras) has held that Section 153C of the IT Act is only an enabling provision to issue a notice notwithstanding anything contained in Sections 139, 147, 148 etc of the IT Act. However, it does not preclude the Department from issuing notice for reopening the assessment under Section 147. 4.0 The Bombay High Court decision in Sejal

9
Section 1478
Exemption6
Reassessment3

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)

155 before it came into force w.e.f. 01.04.2022, the petitioner-company is entitled for immunity from imposition of penalty under Section 270A of the Act though the proceedings against it were initiated for imposition of penalty. Moreover, while initiating the said proceedings vide order dated 22.09.2022, the Assessing Officer has failed to specify that which part of sub-Section

INCOME TAX OFFICER,WARD-1,AHMEDNAGAR, AHMEDNAGAR vs. NARENDRA SAMPATLAL BAFNA, AHMEDNAGAR

In the result, the appeal filed by the Revenue and the CO filed by the assessee are dismissed

ITA 688/PUN/2024[2017-18]Status: DisposedITAT Pune19 Aug 2024AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Shri Prasad BhandariFor Respondent: Shri Keyur Patel, CIT
Section 1Section 132Section 132(4)Section 143(3)

147 of the Income Tax Act, 1961 and the addition made of Rs.6,20,00,000 under section 69A of the Income Tax Act on account of unexplained cash loans availed from various parties through Sh. Sachin M. Nahar. All these grounds of appeal are taken up together for adjudication. An analysis of letter No.Pn/DCIT. Cen. Cir.1(1)/Sharing

A.C.I.T ,WARDHA CIRCLE , WARDHA , WARDHA vs. M/S KAPIL SOLVEX PVT .LTD , YAVATMAL

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

ITA 221/NAG/2017[2009-20010]Status: Trans-OutITAT Pune26 Sept 2024

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(1)Section 147Section 148

u/s. 148 of the I. T. Act. Dated: 24/01/2014 (TANVI S. SAVANT) 16 Income-Tax Officer 7(1)(1), Mumbai." 21) In the light of this factual position, it would not be proper for us to permit the Revenue to take a contrary stand. We are of the opinion that in the present case, the contents of the notice

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

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

ITA 2011/PUN/2024[2016-17]Status: DisposedITAT Pune10 Mar 2025AY 2016-17
Section 143(3)Section 147Section 148Section 148ASection 151

147 by issuing notice u/s 148A(d) of the Act on 25.07.2022 by recording\nas under:\n\"GOVERNMENT OF INDIA\nMINISTRY OF FINANCE\nINCOME TAX DEPARTMENT\nOFFICE OF THE ASSISTANT\nCOMMISSIONER OF INCOME TAX\nCIRCLE 7, PUNE\nTo\nKOLTE-PATIL\nLIMITED\nINTEGRATED\nTOWNSHIPS\nSURVEY NO. 74, MARUNJIHINJEWADI\nMARUNJI, KASARSAI ROAD, TAL MULSHI\nPUNE PUNE 411057, Maharashtra India\nPAN:\n Assessment

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

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

ITA 2023/PUN/2024[2014-15]Status: DisposedITAT Pune10 Mar 2025AY 2014-15
Section 143(3)Section 147Section 148Section 148ASection 151

147 by issuing notice u/s 148A(d) of the Act on 25.07.2022 by recording\nas under:\n“GOVERNMENT OF INDIA\nMINISTRY OF FINANCE\nINCOME TAX DEPARTMENT\nOFFICE OF THE ASSISTANT\nCOMMISSIONER OF INCOME TAX\nCIRCLE 7, PUNE\nTo\nKOLTE-PATIL\nINTEGRATED\nTOWNSHIPS\nLIMITED\nSURVEY NO. 74, MARUNJI HINJEWADI\nMARUNJI, KASARSAI ROAD, TAL MULSHI\nPUNE PUNE 411057, Maharashtra India\nPAN

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT , PUNE

In the result, appeal of the assessee is dismissed

ITA 929/PUN/2023[2013-14]Status: DisposedITAT Pune16 Feb 2024AY 2013-14

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

Section 201Section 234Section 234ESection 246ASection 250

u/s 234 had been charged. 3. The Department of Income Tax, through its Officers send such letters and intimidate the Assessee, leading him to spend money on the proceedings besides causing mental anguish. The ITD may be directed to pay and amount of Rs.25,000/- to the Indian Army Welfare Fund as compensation for this frivolous action. ITA No.929/PUN/2023

PADMAKAR VISHWAS DATE,,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

ITA 930/PUN/2023[2014-15]Status: DisposedITAT Pune16 Feb 2024AY 2014-15

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

Section 201Section 234Section 234ESection 246ASection 250

u/s 234 had been charged. 3. The Department of Income Tax, through its Officers send such letters and intimidate the Assessee, leading him to spend money on the proceedings besides causing mental anguish. The ITD may be directed to pay and amount of Rs.25,000/- to the Indian Army Welfare Fund as compensation for this frivolous action. ITA No.929/PUN/2023

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

ITA 931/PUN/2023[2015-16]Status: DisposedITAT Pune16 Feb 2024AY 2015-16

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

Section 201Section 234Section 234ESection 246ASection 250

u/s 234 had been charged. 3. The Department of Income Tax, through its Officers send such letters and intimidate the Assessee, leading him to spend money on the proceedings besides causing mental anguish. The ITD may be directed to pay and amount of Rs.25,000/- to the Indian Army Welfare Fund as compensation for this frivolous action. ITA No.929/PUN/2023

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE vs. FIAT INDIA AUTOMOBILES LTD,, PUNE

In the result, appeal of the Revenue is dismissed

ITA 2294/PUN/2017[2008-09]Status: DisposedITAT Pune26 Oct 2021AY 2008-09

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

For Appellant: Shri Percy PardiwalaFor Respondent: Smt. Divya Bajpai
Section 143(3)Section 144CSection 148

147 of the Act. We find the Hon‟ble Bombay High Court in the case of Pr. Commissioner of Income Tax Vs. Vaman International Pvt. Ltd., ITA No.1940 of 2017 has held that mere reliance by the Assessing Officer on information obtained from the Sales Tax Department or the statements of two persons made before the Sales Tax Department would

ADESH BHUJANGRAO NAGAWADE,SHRIGONDA vs. INCOME TAX OFFICER, WARD-1, AHILYANAGAR, AHILYANAGAR

In the result appeal of the assessee is partly allowed as per terms indicated herein above

ITA 71/PUN/2025[2017-18]Status: DisposedITAT Pune30 Jul 2025AY 2017-18

Bench: Dr. Manish Boradआयकर अपील सं. / Ita No.71/Pun/2025 िनधा"रण वष" / Assessment Year: 2017-2018

For Appellant: Shri Prasad BhandariFor Respondent: Shri Dayanand Jawalikar
Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69A

147 r.w.s 144 dated 30.03.2022. 2. Assessee has raised following grounds of appeal:- “1. On the facts and the prevailing circumstances of the case and in Law, the learned CIT(A)-NFAC erred in confirming the addition made by the Ld. Assessing Officer without considering the fact that the notice under section 148 has been issued by the Ld. Assessing

SONU GOMA BHANGALE,JALGAON vs. ITO WARD 2(1) JALGAON, JALGAON

In the result, appeal of the Assessee is allowed for\nstatistical purposes

ITA 2350/PUN/2025[2010-11]Status: DisposedITAT Pune27 Nov 2025AY 2010-11
For Appellant: Shri Vinay Kawadia (virtual)For Respondent: Shri Umesh Phade, Addl.CIT
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 263Section 68

155/- in the\nsavings bank account held with Godavari Laxmi Cooperative\nBank, Jalgaon, the assessee was served notice u/s.148 of the\nAct. In compliance to which, return of income was furnished\non 24/07/2017 declaring income of Rs.1,25,840/- and\nagricultural income of Rs.65,00,000/-. The Ld.AO completed\nthe assessment proceedings u/s.143(3) r.w.s.147 of the Act\nvide order