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25 results for “reassessment u/s 147”+ Section 148(2)clear

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Key Topics

Section 14774Section 14861Section 143(3)42Addition to Income19Reassessment17Reopening of Assessment17Section 26314Section 15111Section 250

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)

148 is being issued.” Thus, it is abundantly clear that reassessment proceedings under section 147/143(3) of the Act has commenced by the AO after four years.We also note that as per reassessment order under section 147/143(3) of the Act the reassessment proceedings was claimed to be started by assessing officer on 24.12.2014 which is also beyond four years

Showing 1–20 of 25 · Page 1 of 2

8
Section 143(2)8
Section 1397
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

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 order dated 25.10.2019 passed u/s 143(3) r.w.s 147

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) of the Act that income has escaped Assessment Year: 2012-13 Mayur Rice Mills Private Limited 5 assessment Thereafter, the case of the assessee was reopened u/s 147 of the Act and the assessment was framed vide order dt. 15/11/2019 passed u/s 143(3) r.w.s. 147 of the Act. Pertinent to say that the assessment was reopened

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 proceedings initiated u/s. 148 of the Act and the order passed u/s. 147 read with section 143(3) of the Act, assessee has prayed that the legal ground goes to the root of the matter for which all the facts are already on record and it may be admitted for adjudication. Ld. Counsel placed reliance on the decision

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

148 was not issued to the Principal officer of the assessee company M/s Premier Implements and Equipments Pvt. Ltd. the said notice was not a valid notice in accordance with the section 282(2)(c ) of the Act and, therefore, the reassessment framed u/s 147

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

u/s 234A and 234B on the assessed income. Interest should be charged on the returned income following the decision of Hon'ble Jharkhand High Court. 5. For that other grounds in detail will be argued at the time of hearing. 2. Brief facts of the case are that the assessee is a partnership firm and derives income from salary & share

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

2. CIT v. India Terminal Connector System-Ltd. ITA No. 6430 of 2011. 3. Phool Chand Bajrang Lal V. Income-tax Officer (1993) 203 ITR 456 SC: 4. CIT V. Pradeep Kumar Gupta (2008) 303 ITR 95; Sec 153C read as under- "Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where

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

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

2) and 142(1) of the Act and 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

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)

148. Thereafter, multiple notices under section 142(1) were issued, including final opportunity notices, which were duly served but remained unanswered. I.T.A. No.413/Ran/2024 Naveen Singh Even notices served physically through notice server did not evoke any response. Accordingly, the AO completed the assessment under section 147 read with section 144, based on material available on record. The reasons recorded

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)

2. Background and facts of that case are that the assessee filed its return of income declaring a total income of ₹1,78,71,900/-. The case was selected for scrutiny, and assessment under Section 143(3) of the Act was completed on 07.03.2014, determining the total income at ₹1,90,18,590. Subsequently, the Assessing Officer noticed certain discrepancies

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

u/s 151 of the Act is hereunder: 6. On the other hand, the learned DR supported the orders of the lower authorities and submitted that approval under section 151of the Act was obtained. However, he could not controvert the assessee’s contention that the approval suffers from a fundamental infirmity, as it assessee. 7. We have heard the rival submissions

DR MABLE KATYARE ,HAZARIBAGH vs. ITO WARD-1(1), HAZARIBAGH

Appeals are allowed

ITA 287/RAN/2017[13-14]Status: DisposedITAT Ranchi08 Apr 2019

Bench: Shri S.S, Godaraassessment Year:2013-14 बनाम / Dr. Mable Katyare, H’Bagh Income Tax Officer, Pan: Afspk1459G Ward-1(1), H’Bagh V/S. अपीलाथ" /Appellant ""यथ" /Respondent .. अपीलाथ" क" ओर से/By Appellant Shri Devesh Poddar, Advocate ""यथ" क" ओर से/By Respondent Shri Chandan Das, Jcit-Dr सुनवाई क" तार"ख/Date Of Hearing 10-01-2019 घोषणा क" तार"ख/Date Of Pronouncement -04-2019 Assessment Year:2013-14 बनाम / Ramchandra Prasad Income Tax Officer, Pan: Afopp7929L Ward-1(1), H’Bagh V/S. अपीलाथ" /Appellant ""यथ" /Respondent .. अपीलाथ" क" ओर से/By Appellant Shri Devesh Poddar, Advocate ""यथ" क" ओर से/By Respondent Shri Chandan Das, Jcit-Dr सुनवाई क" तार"ख/Date Of Hearing 09-01-2019 घोषणा क" तार"ख/Date Of Pronouncement 8-04-2019

Section 132Section 143(3)Section 147Section 153C

sections 147/143(3) of the Act. 5. The ld. Counsel for the assessee has placed reliance on 'Sushil Gaur and Shelly Agarwal Vs. ITO', order dated 08.08.2017, passed by the SMC Bench of the Delhi (Trib.) in ITA 1500 & 1501/Del/2017. The ld. DR, per contra, relies on 'CIT vs. Sinhgad Technical Educational Society', judgment of the Hon'ble Supreme Court

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

148 of the Act. The ld. AR also stated that as per proviso to section 147 where assessment has been completed u/s 143(3), no action can be taken u/s 147 after four years unless there was any failure on the part of the assessee to disclose truly and fully all material facts necessary for the assessment

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

u/s. 234A and 234B, on the tax payable on the returned income, instead of tax payable on the returned income is unjustified. 9. For that, order grounds if any, would be urged at the time of hearing.’ 3. At the time of hearing, ld A.R. argued the legal issue that the assessment years involved in this case

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

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

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

2 | 4 ITA 04/Ran/2025 Konda Karabi Vs DCIT 4. For that the order u/s 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