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53 results for “reassessment u/s 147”+ Section 145(3)clear

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Key Topics

Section 14859Section 14754Addition to Income39Section 143(3)30Section 25027Section 145(3)10Survey u/s 133A10Section 1399Section 133A

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

ITA 32/RJT/2020[2012-13]Status: DisposedITAT Rajkot01 Mar 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita Nos. 31 & 32/Rjt/2020 िनधा"रणवष"/Asstt. Years:2011-12, 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष"

For Appellant: Shri Kalpesh Doshi, A.RFor Respondent: Shri B. D. Gupta, Sr. DR
Section 139Section 143(2)Section 143(3)Section 147Section 148

145 Taxman 12 wherein it was held as under: “Section 148 does not provide any methodology for computing the income on reassessment or assessment. On the contrary, it creates a legal fiction that such return shall be treated as one made under section 139. By the creation of such legal fiction all the procedures prescribed in and subsequent to section

Showing 1–20 of 53 · Page 1 of 3

9
Section 143(2)8
Reassessment6
Reopening of Assessment4

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

ITA 31/RJT/2020[2011-12]Status: DisposedITAT Rajkot01 Mar 2023AY 2011-12

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita Nos. 31 & 32/Rjt/2020 िनधा"रणवष"/Asstt. Years:2011-12, 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष"

For Appellant: Shri Kalpesh Doshi, A.RFor Respondent: Shri B. D. Gupta, Sr. DR
Section 139Section 143(2)Section 143(3)Section 147Section 148

145 Taxman 12 wherein it was held as under: “Section 148 does not provide any methodology for computing the income on reassessment or assessment. On the contrary, it creates a legal fiction that such return shall be treated as one made under section 139. By the creation of such legal fiction all the procedures prescribed in and subsequent to section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RJAKOT

In the result, appeal filed by the assessee in ITA No

ITA 286/RJT/2024[2014-15]Status: DisposedITAT Rajkot30 Jan 2026AY 2014-15

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

ITA 290/RJT/2022[2018-19]Status: DisposedITAT Rajkot30 Jan 2026AY 2018-19

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

ITA 288/RJT/2022[2013-14]Status: DisposedITAT Rajkot30 Jan 2026AY 2013-14

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

ITA 291/RJT/2022[2019-20]Status: DisposedITAT Rajkot30 Jan 2026AY 2019-20

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL - 1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

ITA 177/RJT/2024[2016-17]Status: DisposedITAT Rajkot30 Jan 2026AY 2016-17

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

ITA 176/RJT/2024[2014-15]Status: DisposedITAT Rajkot30 Jan 2026AY 2014-15

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

ITA 178/RJT/2024[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RAJKOT

In the result, appeal filed by the assessee in ITA No

ITA 287/RJT/2024[2016-17]Status: DisposedITAT Rajkot30 Jan 2026AY 2016-17

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

ITA 273/RJT/2022[2015-16]Status: DisposedITAT Rajkot30 Jan 2026AY 2015-16

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

ITA 275/RJT/2022[2019-20]Status: DisposedITAT Rajkot30 Jan 2026AY 2019-20

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

ITA 274/RJT/2022[2018-19]Status: DisposedITAT Rajkot30 Jan 2026AY 2018-19

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

ITA 3/RJT/2021[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

ITA 289/RJT/2022[2015-16]Status: DisposedITAT Rajkot30 Jan 2026AY 2015-16

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

ITA 13/RJT/2021[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

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

147 dated 17-03-2022. Regarding addition of Rs. 5,22,54,327/- the assessing officer in the reasons recorded on page 5 has mentioned that the said amount was cash received against sale of bitumen to various party or cash received against bill issued. However, at the time of making addition the same is shown as profit chargeable

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)

145(3) of the Act. 7. That, the Ld. AO has wrongly initiated penalty proceedings u/s 270A, 271A, 271B and 271F of the Act. 8. That, the Ld. AO has wrongly charged interest u/s 234A and 234B of the Act. 9. That, the findings of the Ld. AO are not justified and are bad-in-law. The appellant craves

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)

145(3) of the Act. 7. That, the Ld. AO has wrongly initiated penalty proceedings u/s 270A, 271A, 271B and 271F of the Act. 8. That, the Ld. AO has wrongly charged interest u/s 234A and 234B of the Act. 9. That, the findings of the Ld. AO are not justified and are bad-in-law. The appellant craves

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

ITA 723/RJT/2024[2016-17]Status: DisposedITAT Rajkot10 Jun 2025AY 2016-17

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

Section 145(3)Section 147Section 148

147 of the Act is incurably and defective. In para-3 of SCN, it is stated that the provision of Section 149(1)(b) has been followed by taking approval from the specified authority. However, as submitted above, there is no mention of asset or expenditure represented by the alleged-escaped income and hence, the notice issued u/s

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

ITA 545/RJT/2024[2017-18]Status: DisposedITAT Rajkot10 Jun 2025AY 2017-18

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

Section 145(3)Section 147Section 148

147 of the Act is incurably and defective. In para-3 of SCN, it is stated that the provision of Section 149(1)(b) has been followed by taking approval from the specified authority. However, as submitted above, there is no mention of asset or expenditure represented by the alleged-escaped income and hence, the notice issued u/s