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218 results for “reassessment u/s 147”+ Section 2(15)clear

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Key Topics

Section 148195Section 147121Section 143(3)78Addition to Income68Section 25040Reassessment35Section 13231Section 14A31Reopening of Assessment

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

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

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

15. As the controversy revolves around the applicability of Section 153A and more particularly, as to whether Section 153A read with Section 153C vis- a-vis the provisions of Section 147 of the I.T. Act, it will be appropriate to extract the said provisions, which reads thus: "147. Income escaping assessment.--If the Assessing Officer has reason to believe that

Showing 1–20 of 218 · Page 1 of 11

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29
Section 148A28
Section 153A28
Deduction19

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

ASHOK DHANRAJ CHORDIA ,PUNE vs. PCIT, PUNE-1, PUNE

ITA 977/PUN/2024[2017-18]Status: DisposedITAT Pune30 Jul 2025AY 2017-18
Section 132Section 143(1)Section 143(2)Section 147Section 148Section 263

15-11-2021 and the learned AO has also\ngiven finding to that effect vide order dated 13-12-2021.\n5.\nThe appellant craves leave to add, alter, clarify, explain, modify, delete any\nof the grounds of appeal, and to seek any just and fair relief.\n8.\nThe assessee has also raised the following additional grounds:\n6.\nLearned PCIT

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

reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application in the facts of this case. The basic postulate which underlines section 147 is the formation of the belief

SHRI SHANTINATH BHAGWAN JAIN SHWETAMBAR MURTIPUJAK SANGH,PUNE vs. CIT, EXEMPTION,, PUNE

Appeal is allowed

ITA 203/PUN/2021[2010-11]Status: DisposedITAT Pune23 Aug 2022AY 2010-11

Bench: Shri S.S. Godara & Shri G.D. Padmahshali

For Appellant: Shri V.L. JainFor Respondent: Shri Sardar Singh Meena
Section 147Section 148Section 148(2)Section 263

u/s. 263 of the Income Tax Act, 1961; in short “the Act”. Heard both the parties. Case file perused. 2 ITA No.203/PUN/2021, A.Y. 2010-11 2. It emerges at the outset that the CIT(E)’s impugned order exercising section 263 revision jurisdiction terms the corresponding assessment /reassessment herein dated 29-09-2017 as an erroneous one causing prejudice

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, , NASHIK

Appeals are allowed in above terms

ITA 210/PUN/2021[2012-13]Status: DisposedITAT Pune25 Nov 2022AY 2012-13

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Hariom TulsiyanFor Respondent: Shri Sardar Singh Meena &
Section 143(3)Section 147Section 148Section 263

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. INCOME-TAX OFFICER, WARD - 1,, LATUR

Appeals are allowed in above terms

ITA 1694/PUN/2019[2012-13]Status: DisposedITAT Pune25 Nov 2022AY 2012-13

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Hariom TulsiyanFor Respondent: Shri Sardar Singh Meena &
Section 143(3)Section 147Section 148Section 263

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. INCOME-TAX OFFICER, WARD - 1,, LATUR

Appeals are allowed in above terms

ITA 1693/PUN/2019[2011-12]Status: DisposedITAT Pune25 Nov 2022AY 2011-12

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Hariom TulsiyanFor Respondent: Shri Sardar Singh Meena &
Section 143(3)Section 147Section 148Section 263

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

MAHATMA GANDHI NAGRI SAHAKARI PAT SANSTHA MYDT UDGIR,LATUR vs. INCOME TAX OFFICER- WARD 1 -LATUR, LATUR

In the result, the appeal of the assessee is allowed

ITA 671/PUN/2025[2020-21]Status: DisposedITAT Pune09 Sept 2025AY 2020-21
For Appellant: \nDepartment by
Section 142(1)Section 80P(2)(a)Section 80P(2)(d)

reassessment\nproceedings under Section 147 and has strenuously submitted\nthat the Assessing Officer has rightly observed that the interest\nderived from the credit provided to its member is deductible\nunder Section 80P(2)(a)(i) of the Act, however, on verification of\nthe case record at the stage of scrutiny assessment, it was\nnoticed that the assessee had received interest

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE

ITA 1178/PUN/2023[2011-12]Status: DisposedITAT Pune19 Feb 2025AY 2011-12
Section 132Section 132(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

Section 80IA/IB of the Act.\nIt must follow that there is due application of mind by the Assessing\nOfficer to the issue raised.\nThe above observations apply on all fours to this Petition, so far as the\nRevenue's submission of no change of opinion is concerned.\n11. The further submission of Mr. Walve that in the absence

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 1089/PUN/2025[2016-17]Status: DisposedITAT Pune12 Nov 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha
Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

section 147 of the Act. Since admittedly the Assessing Officer in the instant case has reopened the assessment on the basis of information that emerged at the time of search action u/s 132 of the Act at the premises of M/s. Shri Renuka Mata Multistate Credit Society Ltd.. Therefore, we hold that the initiation of proceedings u/s 147

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 439/PUN/2025[2013-14]Status: DisposedITAT Pune12 Nov 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha
Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

section 147 of the Act. Since admittedly the Assessing Officer in the instant case has reopened the assessment on the basis of information that emerged at the time of search action u/s 132 of the Act at the premises of M/s. Shri Renuka Mata Multistate Credit Society Ltd.. Therefore, we hold that the initiation of proceedings u/s 147

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 1092/PUN/2025[2013-14]Status: DisposedITAT Pune12 Nov 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha
Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

section 147 of the Act. Since admittedly the Assessing Officer in the instant case has reopened the assessment on the basis of information that emerged at the time of search action u/s 132 of the Act at the premises of M/s. Shri Renuka Mata Multistate Credit Society Ltd.. Therefore, we hold that the initiation of proceedings u/s 147

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 440/PUN/2025[2015-16]Status: DisposedITAT Pune12 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha
Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

section 147 of the Act. Since admittedly the Assessing Officer in the instant case has reopened the assessment on the basis of information that emerged at the time of search action u/s 132 of the Act at the premises of M/s. Shri Renuka Mata Multistate Credit Society Ltd.. Therefore, we hold that the initiation of proceedings u/s 147

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)

2(15) of the Act (pages 1 to 156 of the paper book refers). The Ld. AR also raised another contention that the assessment u/s 143(3) for AY 2015-16 having been made on 29.12.2017, the initiation of reassessment proceedings on 28.03.2021 by the Ld. AO, are in violation of the first proviso to section 147

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)

147, as the case may be, has been paid within the period specified in such notice of demand; and (b) no appeal against the order referred to in clause (a) has been filed. 8 ITA No.1260/PUN/2025, AY 2020-21 (2) An application referred to in sub-section (1) shall be made within one month from the end of the month

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

ITA 1121/PUN/2024[2012-13]Status: DisposedITAT Pune18 Dec 2025AY 2012-13

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

15. Contention-4-Approval: As per facts, the approval availed by learned AO was for proposed taxation of donations u/s 68 of the ITA, 1961. As against, the final taxation is u/s 115BBC. Per se, no approval is sought for taxation u/s 148 for the said Section 115BBC. As an effect, it transpires that, the entire taxation made by learned

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

ITA 1124/PUN/2024[2015-16]Status: DisposedITAT Pune18 Dec 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

15. Contention-4-Approval: As per facts, the approval availed by learned AO was for proposed taxation of donations u/s 68 of the ITA, 1961. As against, the final taxation is u/s 115BBC. Per se, no approval is sought for taxation u/s 148 for the said Section 115BBC. As an effect, it transpires that, the entire taxation made by learned

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

ITA 1126/PUN/2024[2017-18]Status: DisposedITAT Pune18 Dec 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

15. Contention-4-Approval: As per facts, the approval availed by learned AO was for proposed taxation of donations u/s 68 of the ITA, 1961. As against, the final taxation is u/s 115BBC. Per se, no approval is sought for taxation u/s 148 for the said Section 115BBC. As an effect, it transpires that, the entire taxation made by learned

DIMPLE RAJESH OSWAL,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

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

ITA 1506/PUN/2025[2016-17]Status: DisposedITAT Pune14 Oct 2025AY 2016-17

Bench: Shri R. K. Pandaassessment Year : 2016-17

For Appellant: Shri Bharat ShahFor Respondent: Ms. Sailee Dhole, JCIT
Section 143(2)Section 143(3)Section 148Section 148ASection 56(2)(vii)

u/s 143(3) r.w.s. 147 of the Act has determined the total income at Rs.19,60,971/-, however, in the computation statement he has determined the same at Rs.31,97,261/- which is not correct. 7. The second plank of his argument is that the assessee has purchased the property during the year 2012 for a consideration of Rs.46