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86 results for “reassessment u/s 147”+ Deductionclear

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Key Topics

Section 147151Section 263102Section 14881Section 143(3)75Addition to Income58Section 25046Reopening of Assessment20Deduction19Reassessment

THE ACIT, CEN. CIR.-2,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK PVT. LTD.,, RAJKOT-GUJARAT

The appeals of the Revenue are dismissed for assessment years 2005-06 and 2006-07

ITA 211/RJT/2015[2005-06]Status: DisposedITAT Rajkot10 Aug 2022AY 2005-06
For Appellant: Shri D.M. Rindani, A.RFor Respondent: Shri Aarsi Prasad, CIT-D.R
Section 132Section 143(3)Section 153ASection 801A(4)

147, is of immense importance as in this case initial assessment was made under section 143(3) of the Act and deduction under section 80IA was wrongly allowed to the assessee as the assessee was not eligible for deduction in that particular assessment year, the argument of the assessee that there was no failure on the part of the assessee

CLASSIC NETWORKS PVT. LTD.,,RAJKOT-GUJARAT vs. THE DY. COMMR. OF INCOME TAX, CEN. CIR.2,, RAJKOT-GUJARAT

Showing 1–20 of 86 · Page 1 of 5

18
Survey u/s 133A17
Section 143(1)15
Section 133A13

The appeals of the Revenue are dismissed for assessment years 2005-06 and 2006-07

ITA 216/RJT/2015[2005-06]Status: DisposedITAT Rajkot10 Aug 2022AY 2005-06
For Appellant: Shri D.M. Rindani, A.RFor Respondent: Shri Aarsi Prasad, CIT-D.R
Section 132Section 143(3)Section 153ASection 801A(4)

147, is of immense importance as in this case initial assessment was made under section 143(3) of the Act and deduction under section 80IA was wrongly allowed to the assessee as the assessee was not eligible for deduction in that particular assessment year, the argument of the assessee that there was no failure on the part of the assessee

THE ACIT, CEN. CIR.-2,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK PVT. LTD.,, RAJKOT-GUJARAT

The appeals of the Revenue are dismissed for assessment years 2005-06 and 2006-07

ITA 203/RJT/2015[2006-07]Status: DisposedITAT Rajkot10 Aug 2022AY 2006-07
For Appellant: Shri D.M. Rindani, A.RFor Respondent: Shri Aarsi Prasad, CIT-D.R
Section 132Section 143(3)Section 153ASection 801A(4)

147, is of immense importance as in this case initial assessment was made under section 143(3) of the Act and deduction under section 80IA was wrongly allowed to the assessee as the assessee was not eligible for deduction in that particular assessment year, the argument of the assessee that there was no failure on the part of the assessee

CLASSIC NETWORKS PVT. LTD.,,RAJKOT-GUJARAT vs. THE DY. COMMR. OF INCOME TAX, CEN. CIR.2,, RAJKOT-GUJARAT

The appeals of the Revenue are dismissed for assessment years 2005-06 and 2006-07

ITA 217/RJT/2015[2006-07]Status: DisposedITAT Rajkot10 Aug 2022AY 2006-07
For Appellant: Shri D.M. Rindani, A.RFor Respondent: Shri Aarsi Prasad, CIT-D.R
Section 132Section 143(3)Section 153ASection 801A(4)

147, is of immense importance as in this case initial assessment was made under section 143(3) of the Act and deduction under section 80IA was wrongly allowed to the assessee as the assessee was not eligible for deduction in that particular assessment year, the argument of the assessee that there was no failure on the part of the assessee

TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

ITA 378/RJT/2024[2013-14]Status: DisposedITAT Rajkot01 Oct 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT DR
Section 147Section 263

147 r.w.s. 1448 of the Income-tax Act, 1961 on 28.03.2022 is set aside for fresh assessment only the extent of the issues discussed supra and direct the Assessing Officer to pass a fresh assessment order after making necessary enquiries relating to cash transactions made by the assessee with M/s National Shroff and if not found satisfactorily, appropriate addition under

TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

ITA 380/RJT/2024[2014-15]Status: DisposedITAT Rajkot01 Oct 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT DR
Section 147Section 263

147 r.w.s. 1448 of the Income-tax Act, 1961 on 28.03.2022 is set aside for fresh assessment only the extent of the issues discussed supra and direct the Assessing Officer to pass a fresh assessment order after making necessary enquiries relating to cash transactions made by the assessee with M/s National Shroff and if not found satisfactorily, appropriate addition under

TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

ITA 383/RJT/2024[2015-16]Status: DisposedITAT Rajkot01 Oct 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT DR
Section 147Section 263

147 r.w.s. 1448 of the Income-tax Act, 1961 on 28.03.2022 is set aside for fresh assessment only the extent of the issues discussed supra and direct the Assessing Officer to pass a fresh assessment order after making necessary enquiries relating to cash transactions made by the assessee with M/s National Shroff and if not found satisfactorily, appropriate addition under

AMRAPAR SEVA SAHKARI MANDLI LTD,AMRAPAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is dismissed

ITA 324/RJT/2025[2018-19]Status: DisposedITAT Rajkot17 Apr 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 324/Rjt/2025 Assessment Year: (2018-19) Amrapar Seva Sahkari Mandali Ltd. Vs. The Principal Commissioner Of C/O., Sarda & Sarda, Sakar, 1St Floor, Income Tax – 1, Dr. Radha Krishna Road, Opp. Aayakar Bhavan, Race Course Rajkumar Collage, Rajkot - 360001 Ring Road, Rajkot – 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaaa0819N (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar : Shri Sanjay Punglia, Ld. Cit(Dr) Respondent By Date Of Hearing : 18/03/2026 : 17/04/2026 Date Of Pronouncement

For Appellant: Shri Vimal Desai, Ld. AR
Section 139(1)Section 147Section 148Section 263Section 80ASection 80PSection 80P(2)(d)

147 r.w.s. 144B and directing a de-novo assessment on an issue that was never part of the reasons recorded for reopening. 4. The Ld. PCIT has exceeded jurisdiction by setting aside the reassessment order on an issue unrelated to the reason recorded for reopening the assessment when no income was assessed in respect of the issue of reopening

JAYESH KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

ITA 6/RJT/2024[2012-13]Status: DisposedITAT Rajkot09 Sept 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 10(38)Section 147Section 263

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

MANSUKHLAL KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

ITA 3/RJT/2024[2012-13]Status: DisposedITAT Rajkot09 Sept 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 10(38)Section 147Section 263

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

MANSUKHLAL KHIMJI KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

ITA 4/RJT/2024[2013-14]Status: DisposedITAT Rajkot09 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 10(38)Section 147Section 263

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

BHANUBEN MANSUKHLAL KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

ITA 5/RJT/2024[2012-13]Status: DisposedITAT Rajkot09 Sept 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 10(38)Section 147Section 263

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

ITA 499/RJT/2025[2020-21]Status: DisposedITAT Rajkot08 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

deducting the TDS u/s 194A of the Act; d) The Ld. assessing officer did not conduct any sort of enquiry/investigation and had not issued any notices u/s.133(6)/131 to the lenders and their bankers to verify the transactions; e) The Ld. assessing officer had not provided the copies of contrary material/evidence and statements of 3rd parties for rebuttal

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

ITA 498/RJT/2025[2015-16]Status: DisposedITAT Rajkot08 Dec 2025AY 2015-16
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

deducting the TDS\nu/s 194A of the Act;\nd) The Ld. assessing officer did not conduct any sort of\nenquiry/investigation and had not issued any notices u/s.133(6)/131_to\nthe lenders and their bankers to verify the transactions;\ne) The Ld. assessing officer had not provided the copies of contrary\nmaterial/evidence and statements of 3rd parties for rebuttal and also

SHRI NAGICHANA MAHILA DOODH UTPADAK SAHAKARI MANDALI LTD.,AT. NAGICHANA, TAL. MANGROL, DIST. JUNAGADH vs. THE ITO WARD-1, JUNAGADH

In the result, the appeal of the assessee is allowed

ITA 847/RJT/2024[2018-19]Status: DisposedITAT Rajkot02 Jun 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, ld.SR.DR
Section 144BSection 147Section 147rSection 148Section 148ASection 151Section 250Section 80ASection 80PSection 80P(2)(d)

147 r.w.s. 148 of the Act that income chargeable to tax has escaped assessment for the year under consideration 7. Therefore, based on the above observations which originate from the material/information available on record with the assessing officer, income to the tune of Rs.2,87,70,000/- has escaped assessment for the year under consideration. In view of the above

SHRI KHODIDAS PREMJIBHAI BHAGIYA,,RAJKOT-GUJARAT vs. THE PR. CIT-3,, RAJKOT-GUJARAT

In the result, all the appeals of the assessee are allowed

ITA 177/RJT/2017[2009-10]Status: DisposedITAT Rajkot03 Oct 2018AY 2009-10

Bench: Shri Waseem Ahmed & Smt Madhumita Roy

For Appellant: Shri Kalpesh Doshi, A.RFor Respondent: Shri Jitendra Kumar, CIT-D.R
Section 143(3)Section 147Section 148Section 263Section 263(1)

u/s 147 of the Act on account of deposit of cash in the bank accounts, therefore, the source of cash was duly enquired by the AO during the reassessment proceedings which was sufficiently explained to the AO. However, the ld CIT disregarded the contention of the assessee and held the order of the AO as erroneous and prejudicial

BHARTIBEN PINAKIN BAJAJ,RAJKOT vs. THE INCOME TAX OFFICER, WARD-2(1)(4),, RAJKOT

In the result, the grounds raised by the assessee are rejected and the appeals are dismissed

ITA 446/RJT/2018[2010-11]Status: DisposedITAT Rajkot07 Sept 2022AY 2010-11
For Appellant: Written SubmissionFor Respondent: Shri B.D. Gupta, Sr.D.R
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 234A

147 of the Act. 3. Aggrieved against the reassessment order, the assessee filed an appeal before the Ld. CIT(A)-Rajkot on 09.01.2018. The ld. CIT(A) fixed the case for hearing on 19.04.2018, 14.05.2018, 05.06.2018, 22.06.2018, 10.07.2018, 10.08.2018 and 05.10.2018. In all the seven occasions none appeared on behalf of the assessee. The reassessment also being an ex parte

BHARTIBEN PINAKIN BAJAJ,RAJKOT vs. THE INCOME TAX OFFICER, WARD-2(1)(4),, RAJKOT

In the result, the grounds raised by the assessee are rejected and the appeals are dismissed

ITA 447/RJT/2018[2015-16]Status: DisposedITAT Rajkot07 Sept 2022AY 2015-16
For Appellant: Written SubmissionFor Respondent: Shri B.D. Gupta, Sr.D.R
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 234A

147 of the Act. 3. Aggrieved against the reassessment order, the assessee filed an appeal before the Ld. CIT(A)-Rajkot on 09.01.2018. The ld. CIT(A) fixed the case for hearing on 19.04.2018, 14.05.2018, 05.06.2018, 22.06.2018, 10.07.2018, 10.08.2018 and 05.10.2018. In all the seven occasions none appeared on behalf of the assessee. The reassessment also being an ex parte

JITENDRABHAI DEVAJIBHAI BODAR,RAJKOT vs. INCOME TAX OFFICER, WARD-2(1)(1), RAJKOT, RAJKOT

In the result, the appeal is dismissed as not admitted”

ITA 549/RJT/2025[2013-14]Status: DisposedITAT Rajkot10 Mar 2026AY 2013-14

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Digant Kiyada, Ld. AR
Section 142(1)Section 147Section 148Section 234ASection 250Section 271(1)(b)

deduction under chapter VI of Rs.1,10,000/-. The case was selected for u/s 147 for reopening the case for reassessment

M/S. PREMJI VALJI & SONS (JEWELLERS) P. LTD.,RAJKOT vs. THE DCIT, CIRCLE - 2 (1), RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is partly allowed for the statistical purposes

ITA 257/RJT/2022[2010-11]Status: DisposedITAT Rajkot31 Oct 2023AY 2010-11

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed, Accountant, Judic Member आयकरअपीलसं./Ita Nos.257 & 223/Rjt/2022 निर्धररवरध/Asstt. Years: 2010-11 & 2012-13 M/S Premji Valji & Sons D.C.I.T, (Jewellers) Pvt. Ltd. Vs. Circle-2(1), “Kuvarjibhai Tower” Rakot. Palace Road, Rajkot-360001. Pan: Aaccp2555N

For Appellant: Shri Ranjit Lalchandani, A.RFor Respondent: Shri Ashish Kumar Pandey, Sr. D.R
Section 132Section 143(3)Section 147Section 148

reassessment. A perusal of the reasons recorded indicates that the AO has duly and properly applied his mind to the information so received by him. To my mind therefore, the reopening made by the AO cannot be faulted. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx As regards the contention of the assessee that he is covered by the 1st proviso to 4.9 sec 147