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11 results for “reassessment u/s 147”+ Section 11(1)(A)clear

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Key Topics

Section 14726Section 14823Section 143(3)15Addition to Income10Section 2638Reassessment8Section 1517Reopening of Assessment7Section 139

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)

1,94,84,010/-. Thereafter, the case of the assessee was reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 22.06.2019. Again re-assessment was framed vide order dt. 25/10/2019 passed u/s 143(3) r.w.s. 147 of the Act assessing the income at Rs. 2,04,11,530/-. Pertinent to state that the assessment

6
Section 143(2)5
Section 2504
Long Term Capital Gains4

SRI AJAY KUMAR MURARKA,JAMSHEDPUR vs. ACIT, JAMSHEDPUR

In the result, appeal of the assessee is allowed

ITA 202/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

reassessment proceeding u/s. 147. He pointed out that Ld. AO had issued first notice u/s. 142(1) on 12.07.2017, then on 14.08.2017. Again on 17.11.2017 Ld. AO issued a letter and thereafter on 13.12.2017, Ld. Counsel further submitted that in the notice issued by the Ld. AO u/s. 142(1), it was mentioned that in case of non-compliance, assessment

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

reassessment proceeding u/s. 147. He pointed out that Ld. AO had issued first notice u/s. 142(1) on 12.07.2017, then on 14.08.2017. Again on 17.11.2017 Ld. AO issued a letter and thereafter on 13.12.2017, Ld. Counsel further submitted that in the notice issued by the Ld. AO u/s. 142(1), it was mentioned that in case of non-compliance, assessment

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

11,000/-in cash as booking Amount for the purchase of 2 Abhishek Gourasaria Vs ACIT flat No. G-1 of 700 sq. ft. in the apartment Krishnakunj, Bistupur, Jamshedpur. As per the seized documents cash was deposited by "Sohanna" allegedly related the name to my Father Shri Sohan Lal Gaurisaria. The Assessing Officer erred in initiating the proceedings u/s

VISION & VISION PRIVATE LIMITED,JAMSHEDPUR vs. ACUT/ DCIT CIRCLE 1, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

ITA 183/RAN/2025[2018-19]Status: DisposedITAT Ranchi19 Nov 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.183/Ran/2025 Assessment Year: 2018-19 Vision & Vision Pvt. Ltd.…….……………............................……….……Appellant Block No.2, Ambika Tower, Main Road Shastri Nagar, Jamshedpur – 831005. [Pan: Aabcv5072B] Vs. Acit/Dcit, Circle-1, Jamshedpur ..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Ar, Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 12, 2025 Date Of Pronouncing The Order : November 19, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Principal Commissioner Of Income Tax (Pcit), Ranchi, Passed Under Section 263 Of The Income-Tax Act, 1961 (“The Act”) Dated 31.03.2025 For A.Y. 2018–19. The Assessee Challenges The Legality & Validity Of The Assumption Of Jurisdiction By The Pcit & The Consequent Revision Of The Reassessment Order Passed U/S 147 R.W.S. 144B Dated 27.03.2023. 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income For A.Y. 2018–19 Declaring Total Income Of ₹11,95,030. The Return Was Initially Processed U/S 143(1). Later, Based On Information Shared By The Ddit (Investigation), Kolkata, It Was Alleged That The Assessee Had Received An Accommodation Entry Of ₹1,18,61,425 From M/S Kuldeepak Enterprises During The Year. On This Basis, The Ao Reopened The

Section 142(1)Section 143(1)Section 147Section 148Section 263

section 263 of the Income-tax Act, 1961 (“the Act”) dated 31.03.2025 for A.Y. 2018–19. The assessee challenges the legality and validity of the assumption of jurisdiction by the PCIT and the consequent revision of the reassessment order passed u/s 147 r.w.s. 144B dated 27.03.2023. 2. Brief facts of the case are that the assessee filed return of income

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

1,21,499 on account of sundry receipts, and ₹46,089 on account of profit on sale of assets. 3. Aggrieved, the assessee preferred an appeal before the learned CIT(A). The learned CIT(A) rejected the grounds raised by the assessee and dismissed the appeal, sustaining the reassessment and additions made by the Assessing Officer. 4. Dissatisfied with

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)

u/s 143(2) r.w.s 147 dated 21.09.2020 do not allege any failure on the part of the assessee to disclose fully and truly all material facts at the time of original assessment. Therefore, the reopening is barred by the first proviso to section 147 of the Act and is void ab initio. Moreover, the reopening is also based

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, JAMSHEDPUR, JAMSHEDPUR vs. BENKO TRADERS PRIVATE LIMITED, KOLKATA

In the result, the appeal filed by the Revenue is dismissed

ITA 436/RAN/2024[2015]Status: DisposedITAT Ranchi17 Dec 2025

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.436/Ran/2024 Assessment Year: 2015-16 Acit, Cc, Jamshedpur…………….…….…............................……….……Appellant Vs. Benko Traders Pvt. Ltd....………...….…..….........……........……...…..…..Respondent 119, 4Th Floor, Block D, White House, Park Stree, Wb – 700016. [Pan: Aabcb1888R] Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 07, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-3, Patna For The Assessment Year 2015–16 Dated 25.09.2024 Passed U/S 250 Of The Income Tax Act (The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Under Section 139 Of The Act Declaring A Total Income As Nil. The Return Was Processed Under Section 143(1). Subsequently, The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Was Completed On 28.11.2017 Determining The Total Income At ₹9,88,28,406. Based On Information Received From The Investigation Wing, Mumbai, Relating To Alleged Use Of Stock Exchange Platform (Bse/Nse) For Generating Fictitious Long-Term/Short-Term Capital Gains Through Certain Scripts & Alleged Accommodation Entries, The Assessing Officer Recorded Reasons Under Section 147 Of The Act. A Notice Under Section 148 Was Issued The Assessee Filed Its Return Declaring The Same Income

Section 139Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69C

147 determining the total income at ₹2,26,89,300. 3. Aggrieved, the assessee preferred an appeal before the CIT(A), who deleted the additions observing as under: “Appellate findings: I have heard the rival submissions and perused the orders of the Ld.AO and the material available on record. In his written submission the Ld. AR stated that

KONDA KARABI,JAMSHEDPUR vs. DCIT, CIRCLE-1, JAMSHEDPUR

In the result, the grounds of appeal raised by the assessee are allowed for statistical for statistical purposes

ITA 4/RAN/2025[2018-19]Status: DisposedITAT Ranchi12 Nov 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahaykonda Karabi, D.C.I.T., G/15, Nargis, Ashiana Garden Sonari, Circle-1, Vs. Jamshedpur-831011 Jamshedpur. Pan No. Abwpk 3757 F Appellant/ Assessee Respondent/ Revenue

Section 143(3)Section 144BSection 147Section 148Section 148ASection 151Section 151A

147 rws 144B of the I. T. Act, 1961 as passed by department on 25.03.2023 is bad in law. The order as passed is void ab-initio, bad in law and fit to set aside. 5. For that the sanctioning authority has not applied his judicial mind before according sanction u/s 151. The approval has been granted for reopening

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

In the result the appeal filed by the assessee is allowed

ITA 467/RAN/2024[2014-15]Status: DisposedITAT Ranchi20 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.467/Ran/2024 Assessment Year: 2014-15 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 20, 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 09.10.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 139Section 143(3)Section 144Section 147Section 148Section 250

reassessment proceedings, the assessee remained largely non-compliant, and therefore, the Assessing Officer was left with no alternative but to complete the assessment ex parte under section 144 read with section 147 of the Act. The Assessing Officer determined the total income of the assessee at ₹7,34,14,430, making the following addition

SHAH BROTHERS,CHAIBASA vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result, Revenue's appeal stands allowed partly for statistical purpose

ITA 275/RAN/2023[2016-2017]Status: DisposedITAT Ranchi07 Jul 2025AY 2016-2017

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.275/Ran/2023 Assessment Year: 2016-17 Shah Brothers, Chaibasa……...................…...........................……….……Appellant Sadar Bazar, West Singhbhum, Jharkhand-833201. [Pan: Aazfs7498F] Vs. Acit, Central Circle-1, Ranchi..…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar & R. R. Mittal, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 26, 2025 Date Of Pronouncing The Order : July 07, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 28.11.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income U/S 139 Of The Act Declaring Total Income Of Rs.14,04,03,980/- For Assessment Year 2016-17. The Assessment Of The Assessee Was Completed U/S 143(3) Of The Act On 31.102.108 Accepting The Said Returned Income. Subsequently, Based On Information Received From Dcit, Cc-1(3), Mumbai, It Was Alleged That The Said Assessee Had Claimed A Bogus Contract Expenses Of Rs.2,69,14,526/- In Lieu Of The Bogus Work Order To M/S Pandhe Infracons Pvt. Ltd. During The F.Y 2015-16 Without Any Actual Work Had Been Performed. The Revenue Relied Upon Search Operation U/S 132 Of The Act Conducted On M/S

Section 132Section 132(4)Section 139Section 143(3)Section 147Section 148Section 150(1)Section 250Section 251

147 of the Act were initiated and notice u/s 148 was issued to the assessee and the assessee filed reply in response to the said notice. However, the Assessing Officer disallowed the said amount of Rs.2,69,14,526/- with a view that the same was a bogus transaction. 3. Dissatisfied with the above order, the assessee preferred an appeal