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18 results for “reassessment u/s 147”+ Section 255clear

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Key Topics

Section 12A36Section 14728Section 143(3)25Section 10(20)24Section 1124Section 14815Section 271(1)(c)12Addition to Income12Section 263

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, proceedings must be initiated under Section 153C, not Section 147. The Hon. Court held that the AO lacked jurisdiction under Section 147, rendering the notice invalid. Consequently, the court quashed and set aside the notice under Section 148 and allowed the petition of the assessee. (Relevant paragraphs 16 to 24). • In the case of Shyam Sunder Khandelwal vs. ACIT

11
Reassessment9
Reopening of Assessment8
Exemption7

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. 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

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

GOPAL EXTRUSIONS PVT LTD,,JALGAON vs. INCOME-TAX OFFICER, WARD - 1(2),, JALGAON

ITA 1633/PUN/2017[2008-09]Status: DisposedITAT Pune29 Apr 2025AY 2008-09

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita. No.1633/Pun/2017 Assessment Year : 2008-09

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ramnath Murkunde
Section 143(3)

147, the impugned assessment proceedings are not valid in law. 13 Gopal Extrusions Pvt. Ltd. Without prejudice to the above: c. Approval mechanical: The Approval is mechanical and does not show any application of mind on escapement of income and the material so as to show escapement of income. The approval is granted on the proposal and further directs

AKTIEBOLAGET TETRA PAK,PUNE vs. ASISTANT COMMISSIONER OF INCOME TAX (INT TAX), PUNE

In the result, both the appeals are allowed

ITA 265/PUN/2021[2012-13]Status: HeardITAT Pune09 Dec 2021AY 2012-13

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.265 & 211/Pun/2021 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14

Section 142(1)Section 143(3)Section 144C(1)Section 147Section 148Section 92C

u/s. 143(3) of the Income-tax Act, 1961 (hereinafter also called `the Act’) was completed on 28-03-2016. Thereafter, the AO issued notice u/s.148 dated 29-03-2019 on the ground that a sum of Rs.7,81,23,918/- declared by the assessee as non-taxable got accepted in the assessment as such, which ought to have been

AKTIEBOLAGET TETRA PAK,PUNE vs. ASISTANT COMMISSIONER OF INCOME TAX (INT TAX), PUNE

In the result, both the appeals are allowed

ITA 211/PUN/2021[2013-14]Status: HeardITAT Pune09 Dec 2021AY 2013-14

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.265 & 211/Pun/2021 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14

Section 142(1)Section 143(3)Section 144C(1)Section 147Section 148Section 92C

u/s. 143(3) of the Income-tax Act, 1961 (hereinafter also called `the Act’) was completed on 28-03-2016. Thereafter, the AO issued notice u/s.148 dated 29-03-2019 on the ground that a sum of Rs.7,81,23,918/- declared by the assessee as non-taxable got accepted in the assessment as such, which ought to have been

NATHARAM PANAJI CHOUDHARY,PUNE vs. I.T.O. WARD 8(1), PUNE, PUNE

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

ITA 1823/PUN/2024[2015-16]Status: DisposedITAT Pune21 Jan 2026AY 2015-16

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

For Appellant: Shri Bharat Kumar (Virtually)For Respondent: Shri Amol Khairnar
Section 132Section 142(1)Section 147Section 148Section 69A

147 is permissible even if the Assessing officer gathers his reasons to believe from the very same record as has been the subject matter of the completed assessment proceedings. There might indeed be a presumption that the assessment proceedings have been regularly conducted, but there can be no presumption that even when the order of assessment is silent, all possible

NATHARAM PANAJI CHOUDHARY,PUNE vs. I.T.O. WARD 8(1), PUNE, PUNE

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

ITA 1826/PUN/2024[2016-17]Status: DisposedITAT Pune21 Jan 2026AY 2016-17

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

For Appellant: Shri Bharat Kumar (Virtually)For Respondent: Shri Amol Khairnar
Section 132Section 142(1)Section 147Section 148Section 69A

147 is permissible even if the Assessing officer gathers his reasons to believe from the very same record as has been the subject matter of the completed assessment proceedings. There might indeed be a presumption that the assessment proceedings have been regularly conducted, but there can be no presumption that even when the order of assessment is silent, all possible

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

255 (SC), he submitted that it has been categorically observed that any claim for giving benefit of Section 11 on the basis of information supplied subsequent to the completion of assessment would mean that the assessment order will have to be re-opened and the Act does not contemplate such re-opening of the assessment. Therefore, in view

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

255 (SC), he submitted that it has been categorically observed that any claim for giving benefit of Section 11 on the basis of information supplied subsequent to the completion of assessment would mean that the assessment order will have to be re-opened and the Act does not contemplate such re-opening of the assessment. Therefore, in view

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

255 (SC), he submitted that it has been categorically observed that any claim for giving benefit of Section 11 on the basis of information supplied subsequent to the completion of assessment would mean that the assessment order will have to be re-opened and the Act does not contemplate such re-opening of the assessment. Therefore, in view

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

255 (SC), he submitted that it has been categorically observed that any claim for giving benefit of Section 11 on the basis of information supplied subsequent to the completion of assessment would mean that the assessment order will have to be re-opened and the Act does not contemplate such re-opening of the assessment. Therefore, in view

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

255 (SC), he submitted that it has been categorically observed that any claim for giving benefit of Section 11 on the basis of information supplied subsequent to the completion of assessment would mean that the assessment order will have to be re-opened and the Act does not contemplate such re-opening of the assessment. Therefore, in view

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

255 (SC), he submitted that it has been categorically observed that any claim for giving benefit of Section 11 on the basis of information supplied subsequent to the completion of assessment would mean that the assessment order will have to be re-opened and the Act does not contemplate such re-opening of the assessment. Therefore, in view

SACHIN BADRINARAYAN SOMANI,PUNE vs. ITO WARD , HINGOLI

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

ITA 2112/PUN/2025[2013-14]Status: DisposedITAT Pune18 Dec 2025AY 2013-14

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 2112 & 2113/Pun/2025 धििेंारण वर्ा /Assessment Year: 2013-14 Sachin Badrinarayan Somani, Ito Ward, Hingoli Rathi Rathi & Co., 501-504, Akshay Landmarks, Oppo. Pu Vs. La Garden, Sinhagad Road, Pune-411030 Maharashtra Pan-Cncps2724N अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Nemin Shah Department By: Shri Ganesh B. Budruk-Addl. Cit Date Of Hearing: 18-12-2025 Date Of Pronouncement: 23-12-2025 आदीश /Order

For Appellant: Shri Nemin ShahFor Respondent: Shri Ganesh B. Budruk-Addl. CIT
Section 250Section 271(1)(c)Section 274Section 69A

u/s 271(1)(c) of the Act. 6. We note that the assessee is an individual and in the reassessment proceedings carried out by Ld. AO based on the information about cash deposit in saving bank account with M/s Shri Renuka Mata Multi State Urban Co-operative Society Ltd. to the tune of Rs. 2,32,53,205/-, the assessee

SACHIN BADRINARAYAN SOMANI,PUNE vs. ITO WARD , HINGOLI

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

ITA 2113/PUN/2025[2013-14]Status: DisposedITAT Pune18 Dec 2025AY 2013-14

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 2112 & 2113/Pun/2025 धििेंारण वर्ा /Assessment Year: 2013-14 Sachin Badrinarayan Somani, Ito Ward, Hingoli Rathi Rathi & Co., 501-504, Akshay Landmarks, Oppo. Pu Vs. La Garden, Sinhagad Road, Pune-411030 Maharashtra Pan-Cncps2724N अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Nemin Shah Department By: Shri Ganesh B. Budruk-Addl. Cit Date Of Hearing: 18-12-2025 Date Of Pronouncement: 23-12-2025 आदीश /Order

For Appellant: Shri Nemin ShahFor Respondent: Shri Ganesh B. Budruk-Addl. CIT
Section 250Section 271(1)(c)Section 274Section 69A

u/s 271(1)(c) of the Act. 6. We note that the assessee is an individual and in the reassessment proceedings carried out by Ld. AO based on the information about cash deposit in saving bank account with M/s Shri Renuka Mata Multi State Urban Co-operative Society Ltd. to the tune of Rs. 2,32,53,205/-, the assessee