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49 results for “reassessment u/s 147”+ Section 149clear

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Key Topics

Section 14895Section 14758Addition to Income30Section 25029Section 148A23Reopening of Assessment18Penalty17Section 142(1)14Section 69A

SHRI JAWAHIR RAVICHANDRA MEHTA,DUBAI(UAE) vs. THE DCIT, CIRCLE-2, RAJKOT, RAJKOT

In the result appeal of the assessee vide ITA/81/Rjt/2020 stands dismissed

ITA 81/RJT/2020[2005-06]Status: DisposedITAT Rajkot27 Dec 2021AY 2005-06

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Amarjit Singh, Accountant Memebr

Section 132Section 147Section 148Section 149Section 149(3)Section 4

section 149 is with effect from 01-07-2012 and its not retrospective in nature. Thus the time limit which has already in expired could not have been revived by subsequent amendment. For all these reasons and complying the ratio laid down above cited cases, we hold that notice issued u/s. 148 on 25-03-2013 for both the above

Showing 1–20 of 49 · Page 1 of 3

13
Section 271A11
Section 15111
Limitation/Time-bar9

THE ACIT-CENTRAL CIRCLE-2, RAJKOT vs. SHRI VICKY BALKRISHNA MEHTA, RAJKOT

The appeal of the Revenue is dismissed

ITA 130/RJT/2020[2004-05]Status: DisposedITAT Rajkot22 Feb 2023AY 2004-05

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2004-05 Assistant Commissioner Of Vs. Shri Vicky Balkrishna Mehta, Income-Tax, 7Th Floor, Mansrovar Central Circle-2, Apartment, Royal Park, Rajkot Kalawad Road, Rajkot Pan : Agqpm 6495 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 28.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 22.02.2023 आदेश/O R D E R Per Annapurna Gupta: This Appeal Is Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-13, Ahmedabad (Hereinafter Referred To As “Cit(A)”) Dated 22.01.2020 Passed U/S 250(6) Of The Income-Tax Act, 1961, (Hereinafter Referred To As “The Act”) For Assessment Year (Ay) 2004-05. 2. The Grounds Of Appeal Raised By The Revenue Read As Under:

For Appellant: Shri D.M. Rindani, ARFor Respondent: Shri Shramdeep Sinha, CIT-DR
Section 147Section 148Section 149Section 149(1)(c)Section 149(3)Section 250(6)

149(1)(c) and therefore, the Assessing Officer was justified in issuing notice u/s 148 for A.Y.2004-05. 3. On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in quashing the notice u/s 148 of the Act without appreciating that the facts found during the course of search proceedings showed that the members

KISHAN BEEJ,JAMNAGAR vs. ITO WARD 2(1), JAMNAGAR

In the result, appeal filed by the assessee is allowed

ITA 384/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Apr 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.384/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Kishan Beej Ito, Wared-2(1) बनाम Kashivishvanath Road Jamnagar – 361 001 Nr. P & T Office Vs. Jamnagar – 361 001 Pan : Aacfk 2114 P (अपीलाथ"/Appellant) (""यथ"/Respondent) :

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 115BSection 142(1)Section 147Section 148Section 234ASection 250Section 271ASection 69Section 69A

147 r.w.s. 144 of the Act, by determining total income at Rs.22,40,770/- and making addition of Rs. 21,92,000/- u/s 69A of the Act. The notice u/s 148 of the Act is challenged by the assessee on two ( grievances )counts, Viz: (i)Notice is barred by limitation and (ii) Procedure laid down u/s 148A is not followed

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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

reassessment proceedings should be quashed for assessment year 2015–16 and for assessment 2016–17. 36. On the other hand, the Ld. DR for the revenue submitted that there is no harm, to the assessee, if the assessing officer issued two different DIN number for the same Assessment Year. 37. The Ld. DR further pointed out that the information

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)

149 requires assessing officers to issue a notice of 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

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)

149 requires assessing officers to issue a notice of 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

SHIV EXTRUSION,JAMNAGAR vs. INCOME TAX OFFICER, JAMNAGAR

In the result, the appeal of the assessee is allowed

ITA 646/RJT/2025[2016-17]Status: DisposedITAT Rajkot12 Mar 2026AY 2016-17

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 646/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Shiv Extrusion Vs. Income Tax Officer Plot No.3978 Phase Iiiroad Income Tax Office, Ito Ward No.-R Dared, Jamnagar 2(10), Jamnagar, Income 361004, Gujarat, India, Jamnagar Tax Office, Shiv Smruti, Jamnagar, Jamnagar, Gujarat, 361008, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abkfs7199F (Appellant) (Respondent) Appellant By : Shri Ramesh M. Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 23/12/2025 Date Of Pronouncement : 12/03/2026

For Appellant: Shri Ramesh M. Patel, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. Sr. DR
Section 144BSection 147Section 148Section 149Section 149(1)(b)Section 151Section 151(1)Section 151ASection 250

u/s 147 read with section 144B of the I.T. Act. Shiv Extrusion vs. ITO 2. The Grounds of appeal raised by the assessee are as follows: - 1. 1. Jurisdictional Defects (Limitation and Threshold Failure) 1. Invalid Assumption of Jurisdiction due to Retrospective Failure of Monetary Tinreshold (Section 149(1)(b)): The NFAC erred in sustaining the reassessment