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15 results for “reassessment u/s 147”+ Section 143(3)clear

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Key Topics

Section 14744Section 14840Section 143(3)25Reassessment13Addition to Income12Reopening of Assessment11Section 2638Section 2507Section 143(2)

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)

u/s 143(3) r.w.s. 147 of the Act. Now the issue before us for adjudication is whether the revisionary jurisdiction exercised by the ld. PCIT under section 263 of the Act is 5 AY: 2012-13 Kross Limited barred by limitation or not. In our considered opinion ,the scope of powers of the AO in original assessment proceedings and reassessment

6
Section 1516
Section 685
Long Term Capital Gains4

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

3) is bad in law to the extent that no addition has been made in the order of assessment on basis of the reasons recorded for initiating proceeding u/s. 148.” 4. While taking the additional ground challenging the legality of the reassessment proceedings initiated u/s. 148 of the Act and the order passed u/s. 147 read with section 143

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

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

3 raised by the assessee by way of additional grounds are dismissed. 10. Now, we take up ground no. 4 of the additional grounds where assessee has challenged the assessment is null and void since no notice u/s. 143(2) was issued against return filed in response to notice u/s. 148. In this respect, ld. Counsel submitted that assessee

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

3 raised by the assessee by way of additional grounds are dismissed. 10. Now, we take up ground no. 4 of the additional grounds where assessee has challenged the assessment is null and void since no notice u/s. 143(2) was issued against return filed in response to notice u/s. 148. In this respect, ld. Counsel submitted that assessee

SUNIL KUMAR CHOUDHARY HUF,DABAGARDENS vs. ACIT, RANCHI

In the result, the appeal of the assessee is allowed

ITA 470/RAN/2024[2012-2013]Status: DisposedITAT Ranchi02 Jul 2025AY 2012-2013

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.470/Ran/2024 Assessment Year: 2012-13 Sunil Kumar Choudhary Huf...................…...........................……….……Appellant 30-15-138/20 Binoy Aka Complex, Opp. Bsnl Office, Andra Pradesh-530020. [Pan: Aabhs6048Q] Vs. Acit……………………..........…..….…..….........……........……...…..…..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 2Nd , 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 07.10.2024 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 Is Huf & Engaged In The Business Of Wholesaler, Transporter, Lease Rent. The Assessee Filed Return Of Income For The Assessment Year 2012-13 By Declaring Total Income Of Rs.16,72,850/-. The Case Of The Assessee Was Selected Under Cass Followed Notices Issued U/S 143(2) & 142(1) Of The Act & Assessment Was Completed U/S 143(3) On 25.03.2015 With Assessed Income Of Rs.16,89,850/-. Subsequently, The Case Of The Assessee Was Reopened U/S 147 By Issuing Notice U/S 148 Of The Act. The Assessee Sought Reasons Recorded For Reopening, However The Assessing Officer Rejected Such Request Stating That The Assessee Failed To File Return In

Section 143(2)Section 143(3)Section 144Section 147Section 148Section 250

3) had already completed on 25.03.05 after verification of document filed by the assessee, therefore, there was no occasion to make further reassessment u/s 148 of the Act. The ld. AR also stated that as per proviso to section 147 where assessment has been completed u/s 143

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)

147 read with Section 144 of the Act. 3. Dissatisfied with the order of Ld. AO preferred an appeal before the Ld. CIT(A) where appeal of the assessee was dismissed sustaining the order of the AO. 4. Aggrieved, assessee has, inter alia, challenged the validity of the reassessment on the ground that the notice under Section 148 dated

ABILITY SERVICES PRIVATE LIMITED,SAKCHI vs. ACIT, CIRCLE-1, JAMSHEDPUR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

ITA 20/RAN/2024[2014-15]Status: DisposedITAT Ranchi09 Jul 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.20/Ran/2024 Assessment Year: 2014-15 Ability Services Pvt. Ltd…….....................…...........................……….……Appellant 232 Kumhar Para, New Baradwari Sakchi, Jharkhand-831001. [Pan: Aacce1395H] Vs. Acit, Circle-1, Jamshedpur.....…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 02, 2025 Date Of Pronouncing The Order : July 09, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 18.12.2023 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 Is Engaged In The Business Of Contract & Transportation & Filed Its Return Of Income For The Assessment Year 2014-15 By Declaring Total Income Of Rs.81,52,900/-. The Case Of The Assessee Was Selected For Scrutiny & Assessment Was Framed On A Total Assessed Income Of Rs.84,49,220/-. Subsequnetly, Proceedings U/S 148 Were Initiated Vide Notice Dated 30.03.2021 & Assessment Was Completed On 20.03.2022 Wherein The Assessing Officer Made Addition Of Excess Depreciation Of Rs.36,64,657/- & Payment Of Epf/Esi Beyond The Due Date But Prior To Filing Of Return Of Rs.5,31,940/-

Section 143(3)Section 147Section 148Section 250

3) had already completed on 27.12.2016 after verification of document filed by the assessee, therefore, there was no occasion to make further reassessment u/s 148 of the Act. The ld. AR also stated that as per proviso to section 147 where assessment has been completed u/s 143

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

143(3) of the Act determining total income at ₹61,97,051. While completing the assessment, the Assessing Officer made addition of ₹30,00,000 under section 68 of the Act on account of unsecured loans, rejected the books of account and estimated profit at the rate of 8%, made further additions of ₹1,21,499 on account of sundry

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

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

143(3) read with section 147 and Section 144B of the Income Tax Act, 1961 (in short, the Act). 4. Aggrieved by the order of Assessing Officer, the assessee preferred appeal before the ld. CIT(A), who vide the impugned order, partly allowed the addition made by the Assessing Officer. 5. Further aggrieved by the order

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

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 and an assessment under section 143(3) was completed

NAVEEN SINGH,JAMSHEDPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, JAMSHEDPUR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

ITA 413/RAN/2024[2017-18]Status: DisposedITAT Ranchi06 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.413/Ran/2024 Assessment Year: 2017-18 Naveen Singh………...…………….…….…............................……….……Appellant M-9 Old, Adityapur Jamshedpur, Jharkhand- 831013. [Pan: Adkps4229A] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri P. S. Paul, Ca, 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 : January 06, 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 12.09.2024 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 Filed Its Return Of Income For Assessment Year 2017–18 Declaring A Total Income Of ₹43,99,340/- Under Section 139(1) Of The Act. The Return Was Processed Under Section 143(1) Accepting The Income As Declared. Subsequently, The Ao Issued A Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Sanction From The Competent Authority. The Assessee Did Not Respond To The Notice Under Section 148. Thereafter, Multiple Notices Under Section 142(1) Were Issued, Including Final Opportunity Notices, Which Were Duly Served But Remained Unanswered.

Section 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 56(2)(x)

143(1) accepting the income as declared. Subsequently, the AO issued a notice under section 148 of the Act after recording reasons and obtaining sanction from the competent authority. The assessee did not respond to the notice under section 148. Thereafter, multiple notices under section 142(1) were issued, including final opportunity notices, which were duly served but remained unanswered

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

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

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