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80 results for “reassessment”+ Section 148clear

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Key Topics

Section 148160Section 147107Addition to Income67Section 143(3)63Reassessment48Section 153D44Section 153A41Section 15131Limitation/Time-bar31Search & Seizure

M/S S.P ENTERPRISES,JAMSHEDPUR vs. DCIT, JAMSHEDPUR

In the result, appeals filed by the assessee are allowed and the

ITA 33/RAN/2016[2007-08]Status: DisposedITAT Ranchi30 May 2018AY 2007-08

Bench: Shri N.S Saini & Pavan Kumar Gadale

For Appellant: S/Shri S.K.Poddar/Devesh Poddar, ARsFor Respondent: Shri P.K.Mondal, JCIT
Section 139(5)Section 142(1)Section 143(2)Section 144Section 147Section 148

148. Thereafter, Assessing Officer without issuing notice under section 143(2) passed reassessment order under section 148. Later, a notice

Showing 1–20 of 80 · Page 1 of 4

27
Reopening of Assessment25
Section 25018

BADRINATH SALES PRIVATE LIMITED,ADITYAPUR, WEST SINGHBHUM vs. DCIT/ACIT CIRCLE 1 JSR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

ITA 414/RAN/2025[2011-12]Status: DisposedITAT Ranchi13 Feb 2026AY 2011-12
Section 131Section 133ASection 143(3)Section 145(3)Section 147Section 148Section 250

148", "Section 131", "Section 145(3)", "Section 143(3)", "Section 142(1)", "Section 144" ], "issues": "1. Whether the reassessment proceedings

INCOME TAX OFFICER, RANCHI, JHARKHAND vs. AMBA CARBONISATION PVT. LTD., RANCHI, JHARKHAND

In the result, the appeal of the revenue is dismissed

ITA 61/RAN/2024[2013-14]Status: DisposedITAT Ranchi06 Jan 2026AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.61/Ran/2024 Assessment Year: 2013-14 Ito, Ranchi………..…………….…….…...................................……….……Appellant Vs. Amba Carbonisation Pvt. Ltd ……....….…..….........……........……...…..…..Respondent 21, Ashok Bhawan, Kali Asthan Road, Ranchi, Jharkhand. [Pan: Aadca7460J] Appearances By: Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Appellant. Shri Devesh Poddar, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Revenue Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 15.01.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Is A Company Incorporated Under The Provisions Of The Companies Act & Is Engaged In The Business Of Manufacturing & Trading Of Special Smokeless Coal/Coke. The Assessee Also Derives Income By Way Of Interest On Bank Deposits. As Per Information Available With The Income-Tax Department, It Was Noticed That The Assessee’S Bank Accounts Reflected Substantial Cash Deposits, Which Were Allegedly Withdrawn Immediately Through Rtgs/Neft Transactions. It Was Further Observed That There Existed A Difference Between The Turnover Disclosed By The Assessee In The Return Of Income & The Total Credits Appearing In The Bank Accounts. On The Basis Of The Above Information, The Assessing Officer (Ao) Initiated Reassessment Proceedings By Issuing A Notice Under Section 148 Of The

Section 139Section 142(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 250Section 270ASection 273B

reassessment based on the material available on record and passed the assessment order dated 30.03.2022 under section 147 read with section 144B of the Act, making an addition of ₹13,64,83,677/- under section 69A of the Act, treating the same as unexplained money. A perusal of the assessment records reveals that two notices under section 148

OM PRAAKSH SINGH,RANCHI vs. DCIT, CIRCLE-1, RANCHI

In the result, appeal filed by the assessee is allowed

ITA 361/RAN/2018[2009-10]Status: DisposedITAT Ranchi10 Sept 2020AY 2009-10

Bench: Shri S.S, Godara, Jm & Dr. A.L. Saini, Am Om Prakash Singh Vs. Dcit, Circle-1, Ranchi Sankalp, East Jail Road, Ranchi- 834001. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Agkps0300D (अपीलाथ" /Appellant) .. (""थ" / Respondent)

For Appellant: Shri Manjit Verma, A/RFor Respondent: Shri A. K. Mohanti, JCIT, Sr. DR
Section 142(1)Section 143(3)Section 147Section 148Section 234CSection 263Section 37(1)

Section 147 of the I.T. Act, 1961. Notice u/s 148 is being issued.” Thus, it is abundantly clear that reassessment

M/S CHHAGANLAL AGARWAL,CHAIBASA vs. ITO,WARD-3(4), CHAIBASA

In the result, appeal of the assessee is allowed

ITA 319/RAN/2018[2010-11]Status: DisposedITAT Ranchi29 Aug 2019AY 2010-11

Bench: Shri Chandra Mohan Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.319/Ran/2018 (नििाारण वषा / Assessment Year :2010-2011) M/S Chhaganlal Agarwal, Vs. Ito Ward-3(4), Chaibasa Bari Bazar, Chaibasa-833201 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Aaffc 6053 J (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. निर्धाऩिती की ओर से /Assessee By : Shri Devesh Poddar, Advocate राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Addl.Cit(Dr)

For Appellant: Shri Devesh Poddar, AdvocateFor Respondent: Shri P.K.Mondal, Addl.CIT(DR)
Section 143(3)Section 147Section 234ASection 40

sections 148 to 153 , assess or reassess such income or recompute the loss or the depreciation allowance, as the case

MARS MERCANTILES PVT.LTD.,DHANBAD vs. ASSISTANT COMMISSIONE OF INCOME TAX, CENTRAL CIRCLE, DHANBAD, DHANBAD

In the result, appeal of the assessee is allowed

ITA 73/RAN/2022[2012-13]Status: DisposedITAT Ranchi05 Jun 2023AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Devesh Poddar, AdvocateFor Respondent: Shri Pranab Kr. Koley, Sr. DR
Section 143(3)Section 147Section 148Section 68

reassessment or recomputation, the Assessing Officer has to serve on the assessee a notice under sub-section (1) of section 148

MISRILALL JAIN & SONS,SINGHBHUM WEST vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result the appeal filed by the assessee is allowed

ITA 468/RAN/2024[2017-18]Status: DisposedITAT Ranchi21 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.468/Ran/2024 Assessment Year: 2017-18 Misrilall Jain & Sons….…………….…….…............................……….……Appellant M. D. House, Chaibasa Singhbhum West, Jharkhand – 833201. [Pan: Aabfm2851Q] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 21, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 30.07.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(3)Section 148Section 148ASection 250

reassessment proceedings on the ground that the notice issued under section 148A(b) of the Act was confined only to the alleged escapement of income amounting to ₹1,32,63,010. It is an undisputed fact that the said amount was duly disclosed by the assessee in the return of income filed in response to the notice under section 148

MAYUR RICE MILLS PRIVATE LIMITED,JHUMRITELAIYA vs. PCIT, RANCHI

In the result, the appeal of the assessee is allowed

ITA 33/RAN/2022[2012-13]Status: DisposedITAT Ranchi02 Nov 2022AY 2012-13

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Rajesh Kumar, Hon’Bleassessment Year: 2012-13 Mayur Rice Mills Private Limited Pr. Cit, Ranchi Gujhandi Road Vs Vill – Barwadih, Jhumritelaiya Pin - 825409 Pan : Aafcm5928H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.K. Pransukha, A/R Revenue By : Shri Sanjay Mukherjee, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 21/09/2022 घोषणा क" तारीख /Date Of Pronouncement : 02/11/2022 आदेश/O R D E R Per Shri Rajesh Kumar: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Learned Principal Commissioner Of Income Tax (Appeals) - Ranchi (Hereinafter ‘Ld. Pr. Cit’), Dated 30/03/2022, Passed Under Section 263 Of The Income Tax Act, 1961 (In Short “The Act”), For Assessment Year 2012-13. 2. The Sole Issue Raised In The Various Grounds Of Appeal Is Against The Invalid Exercise Of Jurisdiction U/S 263 Of The Act By The Ld. Pr. Cit As The Revisionary Proceedings Are Hopelessly Barred By Limitation.

For Appellant: Shri S.K. Pransukha, A/RFor Respondent: Shri Sanjay Mukherjee, CIT, D/R
Section 133(6)Section 143(3)Section 147Section 263Section 263(2)Section 56(2)(vii)

148(2). This, however, will not obviate the bar of limitation under section 263(2). The invocation of the jurisdiction under section 263(2) was barred by limitation”. 9. In the instant case before us also the issue on which the ld. PCIT proposed the revision of reassessment

HIRALAL AGENCIES PVT. LTD.,,RANCHI vs. DCIT, CIRCLE-1, RANCHI

Appeal of the assessee is allowed

ITA 288/RAN/2024[2011-12]Status: DisposedITAT Ranchi20 Nov 2025AY 2011-12

Bench: the Ld. CIT(A) where appeal of the assessee was dismissed sustaining the order of the AO.

Section 142(1)Section 143(3)Section 144Section 147Section 148Section 151(1)

Section 148 was issued on 11.08.2017 for reopening the completed assessment. During the reassessment proceedings, a certified copy of the reasons

SMITA,RANCHI vs. ITO WARD 3(4),, CHAIBASA

The appeal of the assessee is allowed

ITA 266/RAN/2025[2018-19]Status: DisposedITAT Ranchi06 Jan 2026AY 2018-19

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 144BSection 147Section 148Section 151

section 148 of the Act was issued on the ground that the assessee had sold a flat for a consideration of ₹30 lakhs, whereas the stamp duty value as per State valuation authority was ₹46.50 lakhs, resulting in alleged escapement of income chargeable to tax.The Assessing Officer completed reassessment

KROSS LIMITED,JAMSHEDPUR vs. PCIT, RANCHI, RANCHI

In the result, the appeal of the assessee is allowed

ITA 34/RAN/2022[12-13]Status: DisposedITAT Ranchi06 Jun 2023

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 133(6)Section 143(3)Section 147Section 148Section 263Section 263(2)Section 56(2)(vii)

148(2). This, however, will not obviate the bar of limitation under section 263(2). The invocation of the jurisdiction under section 263(2) was barred by limitation”. 9. In the instant case before us also the issue on which the ld. PCIT proposed the revision of reassessment

BISHNU TRANSPORT COMPANY,DHANBAD vs. DCIT/ACIT, CIRCLE-1,, DHANBAD

In the result, the appeal of the assessee is allowed

ITA 401/RAN/2024[2011-12]Status: DisposedITAT Ranchi06 Jan 2026AY 2011-12

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 143(3)Section 147Section 148Section 151Section 151oSection 68

reassessment proceedings on the ground that the approval obtained under section 151 of the Act for issuance of notice under section 148

KULDIP SINGH,RANCHI vs. DCIT/ACIT, CIRCLE-1, RANCHI

In the result, the appeal of the assessee is allowed

ITA 180/RAN/2025[14-15]Status: DisposedITAT Ranchi10 Feb 2026

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.180/Ran/2025 Assessment Year: 2014-15 Kuldip Singh…………………….……….……...................……….……Appellant The Avenue Vishnupuri Marg, Upper Burdwan Compound, Lalpur, Ranchi- 834001. [Pan: Agjps6921P] Vs. Dcit/Acit, Circle-1, Ranchi…...…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kailash Gautam, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2026 Date Of Pronouncing The Order : February 10, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 06.03.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

section 148 of the Act dated 22.11.2019 is barred by limitation. Consequently, the assessment framed pursuant thereto is void ab initio. Accordingly, we quash the reassessment

ROSHAN MAHESHWARI,JAMSHEDPUR vs. ITO,WARD-3(5), CHAIBASA

In the result, appeals filed by the assessee are allowed

ITA 117/RAN/2019[2009-10]Status: DisposedITAT Ranchi27 Aug 2019AY 2009-10

Bench: S/Shri Chandra Mohan Garg & Laxmi Prasad Sahu

For Appellant: Shri M.K.Choudhary, AdvFor Respondent: Shri P.K.Mondal, Addl. CIT(DR)
Section 143(2)Section 147Section 148Section 151Section 151(1)Section 234A

148 on 3.2.2016, which was not in accordance with the provisions of section 151(1) of the Act applicable at the relevant point of time, the issuance of notice u/s.148 of the Act is bad in law and consequently, the assessment order passed under section 147 r.w.s 143(3) is also bad in law and hence, same is cancelled. Therefore

MANISH AGARWAL,BALLYGUNGE vs. ACIT, CENTRAL CIRCLE-2, RANCHI

In the result, the appeal of the assessee is allowed

ITA 16/RAN/2024[2011-12]Status: DisposedITAT Ranchi06 Jan 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.16/Ran/2024 Assessment Year: 201-12 Manish Agarwal……….…………….…….…............................……….……Appellant 35A, Tirumala Apartment, Ballygunge Park, Kol- 700019. [Pan: Acdpa1176E] Vs. Acit, Central Circle-1, Ranchi......…..…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Sunit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 28.11.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That A Search & Seizure Operation Under Section 132 Of The Act Was Conducted In The Case Of The Assessee Group On 23.10.2019. Pursuant To The Said Search, The Assessing Officer (Ao) Issued A Notice Under Section 153A Of The Act Calling Upon The Assessee To File Its Return Of Income For Six Assessment Years Preceding The Year Of Search. In Response To The Notice Under Section 153A, The Assessee Filed Its Return Of Income For Assessment Year 2011–12, Declaring A Total Income Of ₹6,95,180/-. During The Course Of Assessment Proceedings, Several Statutory Notices Were Issued To The Assessee, Which

Section 132Section 139Section 143(3)Section 147Section 148Section 149Section 151Section 153Section 153ASection 153C

148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are I.T.A. No.16/Ran/2024 Manish Agarwal requisitioned under section 132-A after the 31st day of May, 2003, the Assessing Officer shall-- (a) issue notice to such person requiring

ABHISHEK GOURASARIA,JAMSHEDPUR vs. ACIT , JAMSHEDPUR

In the result, consequential assessment order also stands quashed

ITA 43/RAN/2023[2013-14]Status: DisposedITAT Ranchi06 Oct 2025AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayabhishek Gourasaria, A.C.I.T., 118, Flat No. 2B, Surabhi Apartment, K Jamshedpur Vs. Road, Bistupur, Jamshedpur-831001. Pan No. Adwpg 2149 R Appellant/ Assessee Respondent/ Revenue

Section 139Section 147Section 148Section 149Section 151Section 153Section 153ASection 153C

148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that, (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred

SARYU DEVI,RANCHI vs. ITO, WARD-1(1), RANCHI

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

ITA 251/RAN/2025[20-21]Status: DisposedITAT Ranchi22 Dec 2025

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.251/Ran/2025 Assessment Year: 2020-21 Saryu Devi…..………...…………….…….…............................……….……Appellant W/O Hira Nath Singh, Neori, Vikas, Sadar Ranchi, Jharkhand- 835217. [Pan: Geppd1201D] Vs. Ito, Ward-1(1), Ranchi…..….....…..…..….........……........……...…..…..Respondent Appearances By: Shri M. K. Choudhury, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : December 22, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 10.06.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Is An Individual Lady, Residing In A Village Area. She Had Not Filed Any Return Of Income For The Assessment Year 2021–22 As, According To Her, She Had No Taxable Income. The Assessee Was Not Registered On The Income-Tax E-Filing Portal During The Relevant Period. Her E-Filing Registration Was Done For The First Time On 09.03.2025. The Ao Received Information Through The Risk Management Strategy (Rms) That The Assessee Had Purchased Immovable Property For A Consideration Of ₹30,70,000. Based On This Information, Proceedings Under Section 147 Of The Act Were Initiated After Following

Section 142(1)Section 144Section 147Section 148Section 148ASection 151Section 250Section 69A

Section 148 of the act was served upon the assessee and without serving notice assumption of jurisdiction is bad in law as assessee was not registered on the income-tax portal at the relevant time; hence, service through electronic mode was impossible and no notice was served by email, by speed post, or by personal delivery. Therefore, the reassessment

SUBIR MANDAL,JAMSHEDPUR vs. ITO WARD 3(4), CHAIBASA, JAMSHEDPUR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 188/RAN/2025[2017-18]Status: DisposedITAT Ranchi22 Aug 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Ratnesh Nandan Sahayi.T.A. No. 188/Ran/2025 Assessment Year: 2017-2018 Subir Mandal,….…………………………………..Appellant 61, Parsudih, Pramathanagar, Jamshedpur-831001, Jharkhand [Pan:Anfpm1717N] -Vs.- Income Tax Officer,……………………………...Respondent Ward-3(4), Chaibasa, 47, Ch Area, Jamshedpur-831001, Jharkhand Appearances By: Shri Akshay Ringasia, A.R., Appeared On Behalf Of The Assessee Shri Khubchand T. Pandya, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 21, 2025 Date Of Pronouncing The Order: August 25, 2025 O R D E R

Section 142(1)Section 143(1)Section 148Section 56(2)(vii)

reassessment proceeding under section 148. However, notice u/s 148 and subsequent notices under section 142(1) could not be acted

M/S HEAVEN CONSTRUCTION AND ENGINEERING PVT. LTD.,,RANCHI vs. ITO,WARD-!(1), RANCHI

In the result, the appeal of the assessee is allowed

ITA 226/RAN/2018[2010-11]Status: DisposedITAT Ranchi09 Apr 2019AY 2010-11

Bench: Hon’Ble Shri S.S. Godara, Jm] I.T.A No. 226/Ran/2018 Assessment Year : 2010-11 M/S Heaven Construction & Engineering –Vs- Ito, Ward-1(1), Ranchi Pvt. Ltd. [Pan: Aabch 9922 N] (Appellant) (Respondent)

For Appellant: Shri Devesh Poddar, AdvocateFor Respondent: Shri Chandan Das, JCIT
Section 143(3)Section 144Section 147Section 148Section 282(2)Section 48

reassessment / reopening. I find in this backdrop of pleadings that the tribunal’s co-ordinate bench decision in I.T.A. Nos. 4 & 24/Ran/2015 M/s Premier Implements and Equipments Pvt. Ltd. vs. ITO decided on 28.02.2017 has quashed similar section 147 / 148

SRI AJAY KUMAR MURARKA,JAMSHEDPUR vs. ACIT,CIRCLE-1(1),, JAMSHEDPUR

In the result, appeal of the assessee is allowed

ITA 56/RAN/2019[2011-12]Status: DisposedITAT Ranchi13 Dec 2023AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal

For Appellant: Shri Akshay Ringasia, FCAFor Respondent: Shri Pranob Kumar Koley, Sr. DR
Section 10(38)Section 143(2)Section 147Section 148Section 234A

148 though delayed, has been taken into account, it is incumbent upon the Ld. AO to issue a notice u/s. 143(2) which otherwise vitiates the entire assessment proceedings. Requirement of issuing notice u/s. 143(2) cannot be dispensed with. Accordingly, the reassessment proceedings undertaken by the Ld. AO and the impugned reassessment order passed thereafter are liable