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6 results for “reassessment”+ Section 221(1)clear

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Key Topics

Section 26318Section 14714Section 14810Section 271(1)(c)10Section 143(3)5Addition to Income4Disallowance3Natural Justice3Section 254(1)2Section 250

BHAKTIKISHOREDAS DHARMTANYADASJI SWAMI,VAPI vs. INCOME TAX OFFICER, WARD-1, VAPI

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

ITA 292/SRT/2022[2011-12]Status: DisposedITAT Surat30 Aug 2023AY 2011-12

Bench: Shri Pawan Singh(Physical Hearing) Bhaktikishoredas I.T.O., Dharmtanyadasji Swami, Ward-1, Vs. Shri Swaminarayan Seva Trust, Vapi. Swaminarayan Gurukul, Gurukul Road, Chala, Vapi, Gujarat India-396191. Pan No. Bmgps 5746 G Appellant/ Assessee Respondent/ Revenue

Section 147Section 148Section 254(1)Section 69

1,31,500/-. The assessee requested for reasons recorded. The Assessing Officer recorded that the reasons recorded was provided to the assessee vide his letter dated 24/04/2018. 7. The assessee objected against reopening. The objection of assessee was recorded in para 2 of assessment order. In the objection, the assessee objected that case of A.Y. 2009-10 was also reopened

RAMBILASH RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WARD-2(2)(4), SURAT

2
Section 151(1)2
Penalty2

In the result, assessee's appeal is allowed

ITA 552/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12
Section 143(3)Section 147Section 148Section 254(1)Section 68

reassessment proceedings, if the twin\nconditions prescribed under Section 147 of the Act are satisfied.\n23. In fact, in three recent judgments; the Hon'ble Gujarat High Court has upheld\nthe reopening on similar facts. The case is squarely covered against the assessee by\nthese judgments which are:\n•\nYogendrakumar Gupta vs. ITO 366 ITR 186 (Guj)\n•\nPeass Industrial

MEENAXI GEMS PVT LTD,SURAT vs. INCOME TAX OFFICER, WD-1(1)(4), SURAT, SURAT

In the result, the appeal of the assessee in ITA No

ITA 612/SRT/2025[2007-08]Status: DisposedITAT Surat27 Nov 2025AY 2007-08

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.612 & 613/Srt/2025 Assessment Year: (2007-08) (Hybrid Hearing) Meenaxi Gems Pvt. Ltd., Vs. Ito, 5/1108-A, 1167/68-B, Santok Ward – 1(1)(4), Diamonds Office No.106, Gurjar Surat Faliya, Haripura, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcm4645B (Appellant) (Respondent) Appellant By Shri Prakash Jhunjhunwala, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 27/11/2025

Section 145(3)Section 147Section 148Section 151(1)Section 250Section 271(1)(c)Section 274

reassessment order passed u/s 147 is bad in law since had been issued in absence of fresh tangible material, without independent application of judicial mind and without having valid reason to believe of escapement of income; 3.0 On facts and circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition of entire alleged non-genuine

MEENAXI GEMS PVT LTD,SURAT vs. INCOME TAX OFFICER, WD-1(1)(4), SURAT, SURAT

In the result, the appeal of the assessee in ITA No

ITA 613/SRT/2025[2007-08]Status: DisposedITAT Surat27 Nov 2025AY 2007-08

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.612 & 613/Srt/2025 Assessment Year: (2007-08) (Hybrid Hearing) Meenaxi Gems Pvt. Ltd., Vs. Ito, 5/1108-A, 1167/68-B, Santok Ward – 1(1)(4), Diamonds Office No.106, Gurjar Surat Faliya, Haripura, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcm4645B (Appellant) (Respondent) Appellant By Shri Prakash Jhunjhunwala, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 27/11/2025

Section 145(3)Section 147Section 148Section 151(1)Section 250Section 271(1)(c)Section 274

reassessment order passed u/s 147 is bad in law since had been issued in absence of fresh tangible material, without independent application of judicial mind and without having valid reason to believe of escapement of income; 3.0 On facts and circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition of entire alleged non-genuine

WIND FINANCIAL SERVICES LLP,DAMAN & DIU vs. PCIT, VALSAD

In the result, the appeal of the assessee is allowed

ITA 501/SRT/2024[2014-15]Status: DisposedITAT Surat21 May 2025AY 2014-15

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.501 & 502/Srt/2024 (Ays: 2014-15 & 2015-16) (Hybrid Hearing) Wind Financial Services Llp, Vs. The Pcit, [Formerly Known Wind Financial Valsad Services Pvt. Ltd.] Shop No.102/A, 436 Sq Feet Built Up, Dabhel, Daman & Diu, Valsad – 396215 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfw6369H (Appellant) (Respondent) Appellant By Shri S. N. Divetia, Ar Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 12/03/2025 Date Of Pronouncement 21/05/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: These Appeals By The Assessee Emanate From The Orders Passed Under Section 263 Of The Income-Tax Act, 1961 (In Short, ‘The Act’) By The Learned Principal Commissioner Of Income Tax, Valsad [In Short, ‘Ld. Pcit’], Dated 16.03.2024 For Assessment Years (Ays) 2014-15 & 2015-16. Since Facts Of The Cases & The Grounds Taken Up In The Appeals Are Similar Except Variation In The Amount, These Appeals Were Heard Together & A Common Order Is Passed For The Sake Of Convenience & Brevity. Ita No. 501/Srt/2024 Is Taken As The ‘Lead Case’.

Section 142(1)Section 143(3)Section 147Section 148Section 263

section 263 of the Income-tax Act, 1961 (in short, ‘the Act’) by the learned Principal Commissioner of Income Tax, Valsad [in short, ‘ld. PCIT’], dated 16.03.2024 for assessment years (AYs) 2014-15 and 2015-16. Since facts of the cases and the grounds taken up in the appeals are similar except variation in the amount, these appeals were heard

WIND FINANCIAL SERVICES LLP,DAMAN & DIU vs. PCIT, VALSAD

In the result, the appeal of the assessee is allowed

ITA 502/SRT/2024[2015-16]Status: DisposedITAT Surat21 May 2025AY 2015-16

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.501 & 502/Srt/2024 (Ays: 2014-15 & 2015-16) (Hybrid Hearing) Wind Financial Services Llp, Vs. The Pcit, [Formerly Known Wind Financial Valsad Services Pvt. Ltd.] Shop No.102/A, 436 Sq Feet Built Up, Dabhel, Daman & Diu, Valsad – 396215 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfw6369H (Appellant) (Respondent) Appellant By Shri S. N. Divetia, Ar Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 12/03/2025 Date Of Pronouncement 21/05/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: These Appeals By The Assessee Emanate From The Orders Passed Under Section 263 Of The Income-Tax Act, 1961 (In Short, ‘The Act’) By The Learned Principal Commissioner Of Income Tax, Valsad [In Short, ‘Ld. Pcit’], Dated 16.03.2024 For Assessment Years (Ays) 2014-15 & 2015-16. Since Facts Of The Cases & The Grounds Taken Up In The Appeals Are Similar Except Variation In The Amount, These Appeals Were Heard Together & A Common Order Is Passed For The Sake Of Convenience & Brevity. Ita No. 501/Srt/2024 Is Taken As The ‘Lead Case’.

Section 142(1)Section 143(3)Section 147Section 148Section 263

section 263 of the Income-tax Act, 1961 (in short, ‘the Act’) by the learned Principal Commissioner of Income Tax, Valsad [in short, ‘ld. PCIT’], dated 16.03.2024 for assessment years (AYs) 2014-15 and 2015-16. Since facts of the cases and the grounds taken up in the appeals are similar except variation in the amount, these appeals were heard