BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

28 results for “reassessment u/s 147”+ Transfer Pricingclear

Sorted by relevance

Delhi632Mumbai517Bangalore175Chennai141Jaipur126Hyderabad119Kolkata79Chandigarh63Ahmedabad63Indore41Rajkot28Pune27Raipur25Surat24Lucknow22Guwahati19Amritsar18Nagpur15Jodhpur12Cuttack11Dehradun8Agra7Patna5Karnataka5SC2Telangana2Visakhapatnam2Cochin1

Key Topics

Section 26355Section 14736Addition to Income18Section 14817Section 143(3)15Section 10(38)13Section 25013Penny Stock6Survey u/s 133A

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

ITA 104/RJT/2024[2013-14]Status: DisposedITAT Rajkot20 Jun 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

For Appellant: Shri Dhaval Shah, ARFor Respondent: Shri Sanjay Punglia, CIT. DR
Section 10(38)Section 147Section 263Section 69A

Reassessment Order subjected to revision is not erroneous or nor it is prejudicial to interest of the Revenue and hence, impugned Order dt. 05/01/2024 needs to be quashed, ITA No. 104/RJT/2024/AY.2013-14 Hansa Jitendra Haria vs. PCIT 3. The learned PCIT has erred in law and in fact in disregarding the specific inquiry on the shares GLOBAL SECUR undertaken

Showing 1–20 of 28 · Page 1 of 2

5
Section 133A4
Exemption4
Section 683

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

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

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

SHRI CHHAGANBHAI MULJIBHAI PATOLIYA,JETPUR vs. THE ITO WARD-1 (2) (3) RAJKOT, RAJKOT

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

ITA 477/RJT/2025[2012-13]Status: DisposedITAT Rajkot31 Oct 2025AY 2012-13

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.477/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) Chhaganbhai Muljibhai Patoliya, Vs The Ito Ward 1(2)(3), Radhe Park, Shreeji School, Aayakar Bhavan, Race Course, . Amarnagar Road, Rajkot (Gujarat) - 360001 Jetpur (Gujarat) - 360370 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ddrpp2365A (Appellant) (Respondent)

For Appellant: Written SubmissionFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 147Section 250Section 50Section 50C

reassessment proceedings u/s. 147 of the I.T. Act was initiated by issuing a notice u/s.148 to the assessee on 28.03.2019 after recording the reasons for reopening and with the prior approval of the Pr. Commissioner of Income Tax - I, Rajkot by invoking the provisions of Capital Gain including section 50C of the I.T. Act for the property transactions made

BHIKHALAL PRAHLADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX GANDHIDHAM CIRCLE, GANDHIDHAM

ITA 779/RJT/2024[2011-12]Status: DisposedITAT Rajkot21 Aug 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

price of the company Vax Housing Finance Corporation Limited is reproduced as under (downloaded from moneycontrol.com…..” ITA Nos.779&780/RJT/2024/AYs.2011-12&2016-17 Bhikhalal Prahladrai Agarwal-HUF 4. During the assessment proceedings, the assessing officer issued notice to the assessee to explain the above transactions with documentary evidences. However, the assessee has not submitted any reply before the assessing officer. Therefore

BHIKHALAL PRAHALADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE, GANDHIDHAM

ITA 780/RJT/2024[2016-17]Status: DisposedITAT Rajkot21 Aug 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

price of the company Vax Housing Finance Corporation Limited is reproduced as under (downloaded from moneycontrol.com…..” ITA Nos.779&780/RJT/2024/AYs.2011-12&2016-17 Bhikhalal Prahladrai Agarwal-HUF 4. During the assessment proceedings, the assessing officer issued notice to the assessee to explain the above transactions with documentary evidences. However, the assessee has not submitted any reply before the assessing officer. Therefore

MAYURBHAI JAYSUKHLAL SHAH,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal filed by the assessee, is allowed

ITA 319/RJT/2024[2013-14]Status: DisposedITAT Rajkot19 Nov 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 319/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Mayurbhai Jaysukhlal Shah Vs. Principal Commissioner Of 601, Cross Way, P.N. Marg, Income Tax, Jamnagar Jamnagar, Gujarat-361001 Office Of The Principal Commissioner Of Income Tax.Pcit, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afgps1754J (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 10(38)Section 143Section 147Section 263Section 68

reassessment under section 147 of the Act for the assessment year 2013-14, on the following grounds: “1. Ld. Principal CIT erred in law as well as on fact in assuming jurisdiction under 263 of the Act. 1 Mayurbhai Jaysukhlal Shah 2. Ld. Principal CIT erred in law as well as on fact in holding that Assessment order passed u/s

MANSUKHBHAI KANJIBHAI SAKARIYA,RAJKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT-1, RAJKOT

In the result, appeal filed by the assessee is allowed

ITA 318/RJT/2024[2016-17]Status: DisposedITAT Rajkot27 Aug 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.318/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Mansukhbhai Kanjibhai Sakariya The Pr.Commissioner Of बनाम At Khajuri Gundala Income Tax-1, Rajkot. Post Station: Vavdi Vs. Amarnagar, Khajuri Gundala. Pan : Aslps 7027 E (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Rajendra Singhal, Ld.Ar राज"वक"ओरसे/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

For Appellant: Shri Rajendra Singhal, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 144BSection 147Section 263

147 r.w.s. 144B of the MansukhbhaiKanjibhai Sakariya Vs. Pr.CIT 4 Income tax Act, 1961 on 28.03.2022, is erroneous and prejudicial to the interest of the revenue. 4.Considering above such facts, notice u/s 263 of the Income-tax Act, 1961, was issued by ld.PCIT, on 29.02.2023 and duly served upon the assessee.The ld. PCIT stated in the notice that assessee case

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

price with customer inclusive of all other add-on services provided by him) in various impounded documents/data as well as averments made by sales employee in his statement, estimation of unaccounted receipts at Rs. 30.22 crores as well as total receipts at Rs. 118.31 crores from entire project, i.e., 509 flats is strongly objected. 15. It is also submitted that

GLOBAL EXTRUSIONS PVT. LTD. ,JAMNAGAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

ITA 203/RJT/2024[2013-14]Status: DisposedITAT Rajkot09 Jun 2025AY 2013-14

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.203/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Global Extrusions Private Limited. Vs. Pcit Jamnagar, Ca Govind Sonecha Taranjali Building, “S&A House”, Near Golden City, Jamnagar 361008 80Ft Road, Khodiyar Colony, B/H Saru Section Police Headquarters, Jamnagar 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcm4319E (Appellant) (Respondent) Appellant By : Ms. Amoli Gusani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. (Cit)Dr Date Of Hearing : 19/03 /2025 Date Of Pronouncement : 09/06/2025

For Appellant: Ms. Amoli Gusani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. (CIT)DR
Section 139Section 142(1)Section 144BSection 147Section 147rSection 148Section 263

147 of the Act on the basis of the information received from the Investigation Wing that M/s Moral Alloy (P) Ltd is an accommodation entry provider and the assessee company is a beneficiary of such accommodation entity through M/s Ankit Metals in the form of non-genuine purchase and/or credits to the tune of Rs.1,07,50,000/- during

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

ITA 563/RJT/2024[2016-17]Status: DisposedITAT Rajkot11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

RK DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

ITA 556/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

R K DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

ITA 555/RJT/2024[2016-17]Status: DisposedITAT Rajkot11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

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

ITA 559/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already incurred the cost in order to acquire or process the inventory. Therefore, it is the realization of excess consideration over the cost incurred which should be assessed as profit or income, in other words, profit component embedded in the sales could be treated as income. Recently

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

ITA 557/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already incurred the cost in order to acquire or process the inventory. Therefore, it is the realization of excess consideration over the cost incurred which should be assessed as profit or income, in other words, profit component embedded in the sales could be treated as income. Recently

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

ITA 560/RJT/2024[2021-22]Status: DisposedITAT Rajkot11 Mar 2026AY 2021-22
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

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

price received by the seller of the units for which the seller has already incurred the cost in order to acquire or process the inventory. Therefore, it is the realization of excess consideration over the cost incurred which should be assessed as profit or income, in other words, profit component embedded in the sales could be treated as income. Recently

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

ITA 564/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently