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12 results for “reassessment u/s 147”+ Section 9clear

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Key Topics

Section 14731Section 14826Section 143(3)20Section 26311Addition to Income8Reassessment8Reopening of Assessment8Section 1517Section 10(38)

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)

reassessment proceedings was claimed to be started by assessing officer on 24.12.2014 which is also beyond four years. 8. It is a settled position of law that where an assessment under sub-section 3 of section 143 has been made for the relevant assessment year, then no action shall be taken under 5 Om Prakash Singh Assessment Year

4
Section 143(2)4
Section 263(2)4
Long Term Capital Gains3

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)

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)

u/s 133(6) of the Act . We note that this issue was not subject matter in the re-assessment proceedings nor it came to the notice of the AO during re-assessment proceedings which again culminated under section 143(3) read with section 147 of the Act vide order dated 15.11.2019. In our opinion, the limitation runs from

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)

reassessment on the ground that the notice under Section 148 dated 11.08.2017 was issued beyond four years from the end of the relevant assessment year (A.Y. 2011–12), even though the original assessment had been completed under Section 143(3). The reasons recorded for reopening do not allege any failure on the part of the assessee to disclose fully

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

9,88,128/- alleging the same to be the on-money paid by the assessee. It was submitted by the ld. AR that this assessment is the consequence of a search on M/s CDS Properties Pvt. Ltd.. It was a submission that this is evidence found in respect of a cash transaction recorded in a diary found and seized

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

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)

reassessment was not justified.” 7.3 Ld. AO simply based his belief on the alleged report supplied by the DIT(I&CI), Patna for assuming jurisdiction u/s. 148 of the Act without adducing on record any evidence in support thereof and without any independent application of mind on the issue. It is an inalienable principle of law that the reasons recorded

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

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

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

RAJENDER SHANGARI,JAMSHEDPUR vs. DCIT - CIRCLE 1, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

ITA 266/RAN/2023[2018-19]Status: DisposedITAT Ranchi15 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.266/Ran/2023 Assessment Year: 2018-19 Rajendra Shangari, Jamshedpur.................…...........................……….……Appellant Plot 9, Bhuiyadih, Agrico, Jamshedpur – 831009. [Pan: Alcps6310F] Vs. Dcit, Circle-1, Jamshedpur.....…..….…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Vinod Agarwal, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 09, 2025 Date Of Pronouncing The Order : July 15, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 16.11.2023 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 Is An Individual Who Is Engaged In Contractual Jobs To Tata Steel & State Government Wherein The Final Job Is Subject To Strict Scrutiny By Officials & Government Inspectors & Filed Return Of Income Declaring An Income Of Rs.2,58,20,920/- For The Assessment Year 2018-19. Subsequently, In The Case Of The Assessee, The Assessing Officer Invoked Section 148 Proceedings & Completed The Assessment U/S 147 R.W.S. 144B Of The Act By Adding An Amount Of Rs.38,46,188/- To The Income Of The Assessee Stating That The Alleged Sum Was Bogus Purchase. 3. Dissatisfied With The Above Order, The Assessee Preferred An Appeal Before The Ld. Cit(A) Against The Reassessment Order, Where The Ld. Cit(A)

Section 147Section 148Section 250

9, Bhuiyadih, Agrico, Jamshedpur – 831009. [PAN: ALCPS6310F] vs. DCIT, Circle-1, Jamshedpur.....…..….…..….........……........……...…..…..Respondent Appearances by: Shri Akshay Ringasia, AR, appeared on behalf of the appellant. Shri Vinod Agarwal, CIT-DR, appeared on behalf of the Respondent. Date of concluding the hearing : July 09, 2025 Date of pronouncing the order : July 15, 2025 ORDER Per Sonjoy Sarma, Judicial Member: The present