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21 results for “reassessment u/s 147”+ Section 153A(1)(b)clear

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Key Topics

Section 14726Section 14816Section 143(3)13Addition to Income10Deduction10Section 1329Section 153A9Section 2508Section 80I

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

u/s. 148 issued on 27-02-2015 for those years are void ab initio. Under the circumstances the submissions made on the merits of additions in the impugned assessment orders are not required to be adjudicated upon. The appeals for AY 1998-99 to 2004-05 are allowed.” 6. During the course of appellant proceeding before us the learned consul

Showing 1–20 of 21 · Page 1 of 2

7
Survey u/s 133A7
Section 133A6
Reopening of Assessment5

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)

b), which stated that the normal time limit for reopening assessment was four years, "but not more than six years, have elapsed from the end of the relevant assessment year unless the income chargeable to tax which has escaped assessment amounts to or is likely to amount to one lakh rupees or more for that year." 16. It has been

M/S. UNITED ENGINEERS, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, RAJKOT, RAJKOT

In the result, the above appeals of the assessee are partly allowed

ITA 305/RJT/2018[2012-13]Status: DisposedITAT Rajkot08 Jul 2021AY 2012-13

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Appellant: Shri P.C. Yadav, with Shri Dinesh Ruprelia, A.RsFor Respondent: Shri Om Prakash Singh, CIT, D.R
Section 153DSection 254Section 271(1)(C)Section 271(1)(c)Section 274

147 read with section 143(3) of the Act in the given facts and circumstances. 14. Coming to the 2nd fold of contention of the learned AR that the assessment framed under section 153C read with section 143(3) of the Act is bad in law and therefore no penalty proceedings can be initiated under section 271(1

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

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

THE ITO, WARD-1 (1) (3),, RAJKOT-GUJARAT vs. M/S SWAPNALOK DEVELOPERS, RAJKOT-GUJARAT

In the result, the appeal of the Revenue is dismissed

ITA 438/RJT/2015[2007-08]Status: DisposedITAT Rajkot22 Oct 2019AY 2007-08

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri Ranjit Singh, CIR-DRFor Respondent: Shri D.M. Rindani, AR
Section 143(3)Section 147Section 153ASection 40Section 80I

b) (v) of the I.T.Act. It was however, noticed that the assessee has not provided for the interest and remuneration as per the contents of the partnership deed. By not providing for interest and remuneration to the partner, the assessee was benefited for higher claim of deduction under section 80IB (10) of the I.T.Act as non-provision resulted in higher

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)

1. BHARATKUMAR ISHWARBHAI BHATIYA 2. DHAMJIBHAI & KHIRAJMAL LEKHRAJBHAI THALVANI i. Addition an account of commission income of Rs. 8,61,446/-. ii. Addition of peak credit in bank account of Rs. 46,50,353/-. On appeal, before Ld. CIT(A), the assessee did not press ground relating to commission income of Rs. 8,61,446/-, therefore, Ld. CIT(A) dismissed

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 785/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

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

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 133ASection 143(3)Section 147Section 148Section 250

b) of the Act and Page 3 of 28 ITA Nos. 785 to 787 & 765/Rjt/2024 Six Twenty Realty Pvt. Ltd. after obtaining necessary approval of the specified authority as defined u/s 151 of the Act. Notice u/s 148 of the Act along with order u/ s148A(d) of the Act was issued and served upon the assessee

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 767/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

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

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

B-702 in the project. In view of these facts, the seized document cannot be termed as a dumb document as it is highlighting the facts as admitted by the partner of the assessee-firm during the course of survey at its premise. Further, the argument that there is no reference of any name related to the assessee firm

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 770/RJT/2024[2022-23]Status: DisposedITAT Rajkot09 Mar 2026AY 2022-23

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

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

B-702 in the project. In view of these facts, the seized document cannot be termed as a dumb document as it is highlighting the facts as admitted by the partner of the assessee-firm during the course of survey at its premise. Further, the argument that there is no reference of any name related to the assessee firm

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 766/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Mar 2026AY 2017-18

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

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

B-702 in the project. In view of these facts, the seized document cannot be termed as a dumb document as it is highlighting the facts as admitted by the partner of the assessee-firm during the course of survey at its premise. Further, the argument that there is no reference of any name related to the assessee firm

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 768/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

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

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

B-702 in the project. In view of these facts, the seized document cannot be termed as a dumb document as it is highlighting the facts as admitted by the partner of the assessee-firm during the course of survey at its premise. Further, the argument that there is no reference of any name related to the assessee firm

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 769/RJT/2024[2021-22]Status: DisposedITAT Rajkot09 Mar 2026AY 2021-22

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

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

B-702 in the project. In view of these facts, the seized document cannot be termed as a dumb document as it is highlighting the facts as admitted by the partner of the assessee-firm during the course of survey at its premise. Further, the argument that there is no reference of any name related to the assessee firm

THE INCOME TAX OFFICER, WARD-1 (1) (3),, RAJKOT vs. M/S. TIRUPATI AGENCIES,, RAJKOT

Appeals are dismissed

ITA 365/RJT/2018[2011-12]Status: DisposedITAT Rajkot22 Feb 2023AY 2011-12

Bench: Smt.Annapurna Gupta & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 362 To 365/Rjt/2018 ("नधा"रण वष" / Assessment Years : 2008-09 To 2011-12) Income-Tax Officer M/S. Tirupati Agencies बनाम/ Ward-1(1)(3), Rajkot Prasang Commercial Vs. Complex, Nr. Chitralekha Apartment, 150 Ft. Ring Road, Rajkot "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacft0834H .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : Shri Shramdeep Sinha, Cit. D.R. ""यथ" क" ओर से / Shri Mehul Ranpura, A.R. Respondent By : सुनवाई क" तार"ख / Date Of 12/12/2022 Hearing घोषणा क" तार"ख /Date Of 22/02/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: All Four Appeals At The Instance Of The Revenue Are Directed Against The Orders All Dated 05.07.2018 Passed By The Passed By The Commissioner Of Income Tax (Appeals) – 1, Rajkot (The Cit(A)), Arising Out Of The Assessment Orders All Dated 29.03.2016 Passed By The Learned Ito, Ward 1(1)(3), Rajkot Under Section

For Appellant: Shri Shramdeep Sinha, CIT. D.R
Section 132Section 143(1)Section 147Section 153Section 153A

1) of the Act. Subsequently, a search under Section 132 of the Act was carried out at the premises of the assessee on 24.06.2010 and finally the assessment proceedings initiated thereon under Section 153A of the Act for A.Ys. 2005-06 to 2010-11 was completed on 25.10.2012. Fort the year under consideration, the relevant assessment has been completed determining

THE INCOME TAX OFFICER, WARD-1 (1) (3),, RAJKOT vs. M/S. TIRUPATI AGENCIES,, RAJKOT

Appeals are dismissed

ITA 362/RJT/2018[2008-09]Status: DisposedITAT Rajkot22 Feb 2023AY 2008-09

Bench: Smt.Annapurna Gupta & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 362 To 365/Rjt/2018 ("नधा"रण वष" / Assessment Years : 2008-09 To 2011-12) Income-Tax Officer M/S. Tirupati Agencies बनाम/ Ward-1(1)(3), Rajkot Prasang Commercial Vs. Complex, Nr. Chitralekha Apartment, 150 Ft. Ring Road, Rajkot "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacft0834H .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : Shri Shramdeep Sinha, Cit. D.R. ""यथ" क" ओर से / Shri Mehul Ranpura, A.R. Respondent By : सुनवाई क" तार"ख / Date Of 12/12/2022 Hearing घोषणा क" तार"ख /Date Of 22/02/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: All Four Appeals At The Instance Of The Revenue Are Directed Against The Orders All Dated 05.07.2018 Passed By The Passed By The Commissioner Of Income Tax (Appeals) – 1, Rajkot (The Cit(A)), Arising Out Of The Assessment Orders All Dated 29.03.2016 Passed By The Learned Ito, Ward 1(1)(3), Rajkot Under Section

For Appellant: Shri Shramdeep Sinha, CIT. D.R
Section 132Section 143(1)Section 147Section 153Section 153A

1) of the Act. Subsequently, a search under Section 132 of the Act was carried out at the premises of the assessee on 24.06.2010 and finally the assessment proceedings initiated thereon under Section 153A of the Act for A.Ys. 2005-06 to 2010-11 was completed on 25.10.2012. Fort the year under consideration, the relevant assessment has been completed determining

THE INCOME TAX OFFICER, WARD-1 (1) (3),, RAJKOT vs. M/S. TIRUPATI AGENCIES,, RAJKOT

Appeals are dismissed

ITA 363/RJT/2018[2009-10]Status: DisposedITAT Rajkot22 Feb 2023AY 2009-10

Bench: Smt.Annapurna Gupta & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 362 To 365/Rjt/2018 ("नधा"रण वष" / Assessment Years : 2008-09 To 2011-12) Income-Tax Officer M/S. Tirupati Agencies बनाम/ Ward-1(1)(3), Rajkot Prasang Commercial Vs. Complex, Nr. Chitralekha Apartment, 150 Ft. Ring Road, Rajkot "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacft0834H .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : Shri Shramdeep Sinha, Cit. D.R. ""यथ" क" ओर से / Shri Mehul Ranpura, A.R. Respondent By : सुनवाई क" तार"ख / Date Of 12/12/2022 Hearing घोषणा क" तार"ख /Date Of 22/02/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: All Four Appeals At The Instance Of The Revenue Are Directed Against The Orders All Dated 05.07.2018 Passed By The Passed By The Commissioner Of Income Tax (Appeals) – 1, Rajkot (The Cit(A)), Arising Out Of The Assessment Orders All Dated 29.03.2016 Passed By The Learned Ito, Ward 1(1)(3), Rajkot Under Section

For Appellant: Shri Shramdeep Sinha, CIT. D.R
Section 132Section 143(1)Section 147Section 153Section 153A

1) of the Act. Subsequently, a search under Section 132 of the Act was carried out at the premises of the assessee on 24.06.2010 and finally the assessment proceedings initiated thereon under Section 153A of the Act for A.Ys. 2005-06 to 2010-11 was completed on 25.10.2012. Fort the year under consideration, the relevant assessment has been completed determining

THE INCOME TAX OFFICER, WARD-1 (1) (3),, RAJKOT vs. M/S. TIRUPATI AGENCIES,, RAJKOT

Appeals are dismissed

ITA 364/RJT/2018[2010-11]Status: DisposedITAT Rajkot22 Feb 2023AY 2010-11

Bench: Smt.Annapurna Gupta & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 362 To 365/Rjt/2018 ("नधा"रण वष" / Assessment Years : 2008-09 To 2011-12) Income-Tax Officer M/S. Tirupati Agencies बनाम/ Ward-1(1)(3), Rajkot Prasang Commercial Vs. Complex, Nr. Chitralekha Apartment, 150 Ft. Ring Road, Rajkot "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacft0834H .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : Shri Shramdeep Sinha, Cit. D.R. ""यथ" क" ओर से / Shri Mehul Ranpura, A.R. Respondent By : सुनवाई क" तार"ख / Date Of 12/12/2022 Hearing घोषणा क" तार"ख /Date Of 22/02/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: All Four Appeals At The Instance Of The Revenue Are Directed Against The Orders All Dated 05.07.2018 Passed By The Passed By The Commissioner Of Income Tax (Appeals) – 1, Rajkot (The Cit(A)), Arising Out Of The Assessment Orders All Dated 29.03.2016 Passed By The Learned Ito, Ward 1(1)(3), Rajkot Under Section

For Appellant: Shri Shramdeep Sinha, CIT. D.R
Section 132Section 143(1)Section 147Section 153Section 153A

1) of the Act. Subsequently, a search under Section 132 of the Act was carried out at the premises of the assessee on 24.06.2010 and finally the assessment proceedings initiated thereon under Section 153A of the Act for A.Ys. 2005-06 to 2010-11 was completed on 25.10.2012. Fort the year under consideration, the relevant assessment has been completed determining

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 558/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

1,53,55,050 |\n| Net On-money receipts | 14,45,72,950 | |\n| Unaccounted payment for purchase of land | | (-)5,00,62,350 |\n| Unaccounted expenses | | (-)3,00,06,610 |\n| Total | 14,45,72,950 | |\n\nNet Surplus | | 6,45,03,990 |\nNet Surplus (%) | | 45% |\n\n17. As can be seen from this table, the net surplus