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69 results for “reassessment u/s 147”+ Section 45(2)clear

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Delhi1,161Mumbai1,035Bangalore424Chennai340Ahmedabad240Jaipur221Kolkata188Hyderabad175Chandigarh139Rajkot93Raipur85Amritsar72Pune69Surat68Indore59Lucknow38Patna35Allahabad35Telangana34Visakhapatnam34Cuttack32Guwahati32Jodhpur30Nagpur28Cochin20Karnataka16Agra7Orissa6Panaji3SC3Kerala3Jabalpur2Varanasi1Dehradun1Uttarakhand1Rajasthan1Ranchi1

Key Topics

Section 148107Section 143(3)73Section 14761Addition to Income47Section 12A37Section 115B34Section 14A32Section 6827Section 11

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

u/s 147 of the Act, the Hon’ble Bombay High Court accepted the contention of the petitioner and quashed the re-assessment proceedings by observing as under: “12. We have heard learned counsel for the parties and with their assistance, we have perused the record. At the outset, we may observe that the (2023) 149 taxmann.com

Showing 1–20 of 69 · Page 1 of 4

25
Reopening of Assessment25
Reassessment21
Exemption15

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

45 (Rajasthan) [ref para 62] & the Karnataka High Court decision in Pr. CIT v. VSL Mining Company (P.) Ltd. [2024] 167 taxmann.com 373 (Karnataka) [ref para 64]. 2. Amar Jewellers Ltd vs Paras 46, 47, 48, 49, 52, 53, 55, 76 & 84. ACIT (2022) 444 ITR 97 Even assessments completed u/s 153A (Guj) dtd 31-01-2022 were reopened u/s

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

2. Pune.\nSir/Madam.\nSub: Sharing of Information in the case of Shri Sachin Nahar- reg.\nRef: This office letter No. Pa/DCIT/CC 1(1)/Info./2019-20 dated 10.06.2019\nReference may kindly be made to this office letter No. Pn/DCIT/CC\n1(1)/Info./2019-20 dated 10/06/2019 vide which information about the cash loan was\nprovided to you. In the case of Shri

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

ITA 2017/PUN/2024[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

45,690/-\n7.\nThe assessee filed an appeal before the Ld. CIT(A) against this order also.\nThe Ld. CIT(A) in the consolidated order dated 10.10.2023 passed the order i.e. in\nrespect of order passed u/s 143(3) r.w.s.147 and u/s 143(3) r.w.s.263 of the Act\nand dismissed both the appeals.\n8.\nAggrieved with such order

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

45,690/-\n7.\nThe assessee filed an appeal before the Ld. CIT(A) against this order also.\nThe Ld. CIT(A) in the consolidated order dated 10.10.2023 passed the order i.e. in\nrespect of order passed u/s 143(3) r.w.s.147 and u/s 143(3) r.w.s.263 of the Act\nand dismissed both the appeals.\n8.\nAggrieved with such order

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)

45,890) after adjusting the incremental liability that may arise on disallowing health and education Cess. He, therefore, submitted that there is no basis for holding that the assessee has under-reported its income or done any act without good faith and due diligence and hence the provisions of section 270A of the Act do not apply 5 ITA No.1260/PUN/2025

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

147 order, appears to have proceeded on the analogy that, some taxable income has escaped assessment. As against, vide Section 115BBC, mere rate of tax is differentiated from normal income. As stated earlier, entire charge of the learned AO at the stage of formation of belief of 'escapement of income' by resorting to Section

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

147 order, appears to have proceeded on the analogy that, some taxable income has escaped assessment. As against, vide Section 115BBC, mere rate of tax is differentiated from normal income. As stated earlier, entire charge of the learned AO at the stage of formation of belief of 'escapement of income' by resorting to Section

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

147 order, appears to have proceeded on the analogy that, some taxable income has escaped assessment. As against, vide Section 115BBC, mere rate of tax is differentiated from normal income. As stated earlier, entire charge of the learned AO at the stage of formation of belief of 'escapement of income' by resorting to Section

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

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

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

ITA 1123/PUN/2024[2014-15]Status: DisposedITAT Pune18 Dec 2025AY 2014-15
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

reassessment u/s 147, the\n'reason' has to be specific and the same can't be extended /\nenhanced /supplemented, etc. This ratio emerges from the\ncelebrated decision in the case of Hindustan Lever v. R B Wadkar-\n268 ITR 332 (Вот)... (сору enclosed and marked as Annexure-6.)\n14. Conention-3-Erroneous/Improper charge of escapement of\nincome\nAs per facts

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

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

ITA 1125/PUN/2024[2016-17]Status: DisposedITAT Pune18 Dec 2025AY 2016-17
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

reassessment u/s 147, the\n'reason' has to be specific and the same can't be extended /\nenhanced /supplemented, etc. This ratio emerges from the\ncelebrated decision in the case of Hindustan Lever v. R B Wadkar-\n268 ITR 332 (Вот)... (сору enclosed and marked as Annexure-6.)\n14. Conention-3-Erroneous/Improper charge of escapement of\nincome\nAs per facts

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

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

ITA 1122/PUN/2024[2013-14]Status: DisposedITAT Pune18 Dec 2025AY 2013-14
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

reassessment u/s 147, the\n'reason' has to be specific and the same can't be extended /\nenhanced /supplemented, etc. This ratio emerges from the\ncelebrated decision in the case of Hindustan Lever v. R B Wadkar-\n268 ITR 332 (Bom)... (сору enclosed and marked as Annexure-6.)\n14. Conention-3-Erroneous/Improper charge of escapement of\nincome\nAs per facts

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 469/PUN/2022[2013-14]Status: DisposedITAT Pune18 Sept 2024AY 2013-14

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 139Section 143(3)Section 14ASection 153A

reassessment’ used in this section has to be understood in the context of section 153A alone. The word 'assessment’ is used in a number of provisions in a comprehensive sense and if can comprehend the whole procedure for ascertaining and imposing liability upon the taxpayer and the machinery for enforcement thereof. The concept of expression ‘assessment’ is used

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 468/PUN/2022[2012-13]Status: DisposedITAT Pune18 Sept 2024AY 2012-13

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 139Section 143(3)Section 14ASection 153A

reassessment’ used in this section has to be understood in the context of section 153A alone. The word 'assessment’ is used in a number of provisions in a comprehensive sense and if can comprehend the whole procedure for ascertaining and imposing liability upon the taxpayer and the machinery for enforcement thereof. The concept of expression ‘assessment’ is used

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 467/PUN/2022[2011-12]Status: DisposedITAT Pune18 Sept 2024AY 2011-12

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 139Section 143(3)Section 14ASection 153A

reassessment’ used in this section has to be understood in the context of section 153A alone. The word 'assessment’ is used in a number of provisions in a comprehensive sense and if can comprehend the whole procedure for ascertaining and imposing liability upon the taxpayer and the machinery for enforcement thereof. The concept of expression ‘assessment’ is used

GULAMAHEMAD HAMIDULLA KHAN,PUNE vs. ITO WARD 14(3), PUNE

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

ITA 165/PUN/2025[2015-16]Status: DisposedITAT Pune11 Sept 2025AY 2015-16

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

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Ramnath Murkunde
Section 139Section 148Section 148ASection 69A

45,130/- and as such the nature and sources of the credits cannot be ascertained during the year under consideration. Hence, the nature and sources of the credits of Rs. 2,20,79,550/- made in his bank account remains unexplained in view of the provisions of section 69A of the Act. In the above context, Rs. 2

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