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15 results for “reassessment u/s 147”+ Section 127clear

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Key Topics

Section 14818Section 14715Section 143(3)7Addition to Income6Section 1515Penalty5Reopening of Assessment5Section 234A4Section 142(1)

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

ITA 611/RJT/2025[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

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

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)
4
Section 153A4
Section 1324
Deduction4

reassessment under Section 148 within the prescribed time limits. Further, Section 151 requires assessing officers to obtain sanction of the specified authority before issuing notice under Section 148. In Chhugamal Rajpal v. S P Chaliha, a three-Judge Bench of this Court held that Section 151 must be strictly adhered to because it contains "important safeguards." 65 Section 151 imposes

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

ITA 612/RJT/2025[2016-17]Status: DisposedITAT Rajkot10 Mar 2026AY 2016-17

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

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

reassessment under Section 148 within the prescribed time limits. Further, Section 151 requires assessing officers to obtain sanction of the specified authority before issuing notice under Section 148. In Chhugamal Rajpal v. S P Chaliha, a three-Judge Bench of this Court held that Section 151 must be strictly adhered to because it contains "important safeguards." 65 Section 151 imposes

ATUL VRAJLAL KARIA,RAJKOT vs. AC / DC (INT.TXN), RAJKOT

In the result, appeal filed by the assessee is allowed in above terms

ITA 133/RJT/2025[2012-13]Status: DisposedITAT Rajkot29 Oct 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.133/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2012-13 Atul Vrajlal Karia Ac/Dc (Int. Txn), बनाम C/O. D.S. Karia & Co. Ca, 203, Rajkot Cosmo Complex, Mahila College Vs. Chowk, Kalawad Road, Rajkot Pan : Adwpk6568J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

For Appellant: Shri Kalpesh Doshi, ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 127Section 147Section 148Section 151Section 153CSection 250Section 282Section 69

147 SCN 16/11/2019 AC/DC (INT.TXN) RAJKOT A notice u/s 142(1) of the Act dated 27/08/2019 issued by the other Income Tax Officer (ITO) – 2 which has been filed by the assessee, before the Bench, which is placed on page no. 18 of the assessee`s paper book. On perusal of the aforesaid table, we noticed that, the notice u/s

DHANJI MURJI HIRANI,KUTCH vs. ITO.(INT.TXN)GANDHIDHAM, GANDHIDHAM

In the result, the appeal of the assessee is allowed

ITA 131/RJT/2025[2019-20]Status: DisposedITAT Rajkot05 Aug 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.131/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2019-20 Dhanji Murji Hirani, Baladia Ito (Int.Txn), बनाम Bhuj, Kutch, Gandhidham Gujarat 370427 Vs. Pan : Afaph0463B (अपीलाथ"/Appellant) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr

For Appellant: Shri Kalpesh Doshi, ld.ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 115BSection 127Section 139Section 147Section 148Section 148ASection 234ASection 271ASection 69

section 147 r.w.s 144C(13) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), dated 02.12.2024. 2. The grounds of appeal raised by the assessee are as follows: 1. That, the reassessment u/s 148 of the I.T. Act has wrongly been made without having any information in possession. 2. That, the jurisdiction has been transferred from Bhavnagar

JITENDRABHAI BHAGVANBHAI DALVADI,SURENDRANAGAR vs. ITO WARD 2, MORBI

In the result, the appeal of the assessee is allowed

ITA 466/RJT/2024[2011-12]Status: DisposedITAT Rajkot30 Sept 2025AY 2011-12

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 124Section 127Section 143(3)Section 147Section 234ASection 250Section 254Section 271(1)(c)Section 68

147 of the Income Tax Act, 1961 is passed without order u/s 127 of the Income Tax Act, 1961. Ground No. 8: That, the reasons recorded are undated and unsigned and therefore, the assessment reopened on the basis of such reasons is bad-in- law. 4. Shri Kalpesh Doshi, Learned Counsel for the assessee, pleads that above additional ground

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

ITA 44/RJT/2023[2006-07]Status: DisposedITAT Rajkot19 Jun 2025AY 2006-07

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

u/s 263 of the Act, and directed the assessing officer to verify the source of cash deposited in the bank accounts, which have been left out, during the course of original assessment proceedings. Accordingly, assessing officer made addition of peak credit in individual bank accounts. However, on further appeal by assessee, before

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

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 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 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

LATE OGHADBHAI KARABHAI ODEDRA (L/H BABUBHAI ODEDRA),PORBANDAR vs. INCOME TAX OFFICER, WARD - 2(4), PORBANDAR, PORBANDAR

In the result, appeal filed by the assessee is partly allowed, in above terms

ITA 915/RJT/2024[2010-11]Status: DisposedITAT Rajkot29 May 2025AY 2010-11

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.915/Rjt/2024 िनधा"रणवष" / Assessment Year: (2010-11) (Hybrid Hearing) Late Oghadbhai Karabhai Odedara Vs. Income Tax Officer, (L/H Babubhai Oghadbhai Odedara) Ward-2(4), At Bavalvav, Porbandar, Porbandar Gujarat-360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aajpo3410B (Appellant) (Respondent) Appellant By : Shri Dushyant Maharshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. (Dr) Date Of Hearing : 05/ 03/2025 Date Of Pronouncement : 29/05/2025 आदेश / O R D E R Dr. Arjun Lal Saini, Am

For Appellant: Shri Dushyant Maharshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 127(1)Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 69A

u/s. 147 of the Act which is invalid as the case has been re-opened by Non-Jurisdictional Assessing Officer. 2. Re-opening u/s.147 of the Act is not valid as the certified copy of the reasons have not been provided by the Ld. AO within 30 days of the filing of the return by the assessee as per directions

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

ITA 46/RJT/2023[2013-14]Status: DisposedITAT Rajkot19 Jun 2025AY 2013-14

u/s 263 of the Act, and directed the\nassessing officer to verify the source of cash deposited in the bank accounts, which have\nbeen left out, during the course of original assessment proceedings. Accordingly,\nassessing officer made addition of peak credit in individual bank accounts. However, on\nfurther appeal by assessee, before

THE DY. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT vs. BHARATKUMAR ISHWARBHAI BHATIYA,, RAJKOT

ITA 49/RJT/2018[2013-14]Status: DisposedITAT Rajkot19 Jun 2025AY 2013-14

section 143(3) r.w.s. 263 of the Act and\nAssessing Officer made following addition:\n34\nH\nBHARATKUMAR ISHWARBHAI BHATIYA\nDHAMJIBHAI & KHIRAJMAL LEKHRAJBHAI THALVANI\ni.\nAddition an account of commission income of Rs. 8,61,446/-.\nii.\nAddition of peak credit in bank account of Rs. 46,50,353/-.\nOn appeal, before Ld. CIT(A), the assessee did not press ground

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

ITA 31/RJT/2019[2009-10]Status: DisposedITAT Rajkot19 Jun 2025AY 2009-10

section 143(3) read with section 263 of the Act and some of the\nassessment orders were passed by the Assessing Officer under section 153A r.w.s.\n143(3) of the Income Tax Act, 1961 (in short ‘the Act').The main ground of appeal by\nthe department (Revenue) is pertaining to assailing and deletion of 70% of additions\nmade on account

SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, RAJKOT

ITA 16/RJT/2019[2010-11]Status: DisposedITAT Rajkot19 Jun 2025AY 2010-11

u/s 263 of the Act, and directed the assessing officer to verify the source of cash deposited in the bank accounts, which have been left out, during the course of original assessment proceedings. Accordingly, assessing officer made addition of peak credit in individual bank accounts. However, on further appeal by assessee, before