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15 results for “reassessment u/s 147”+ Section 163clear

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Key Topics

Section 69A56Section 271(1)(c)32Addition to Income15Penalty11Section 25010Section 14810Section 1479Section 143(3)9Section 148A

SHRI SUDEEP MAHENDRABHAI SHAH,,SURAT vs. THE INCOME TAX OFFICER, WARD1(3)(5),, SURAT

In the result, the appeal of the assessee is partly allowed

ITA 2423/AHD/2016[2008-09]Status: DisposedITAT Surat28 May 2018AY 2008-09

Bench: Shri C.M.Garg & Shri O.P.Meena

Section 132(4)Section 143Section 147Section 148

reassessment under section 147 of the IT Act must fail.” Reliance is further placed in the case of Peass Industrial Engineering 12. (P) Ltd. v. DCIT [2016] 73 taxmann.com 185 (Gujarat) where information received from Investigation Wing, Ahmedabad was held to be sufficient material to constitute reason to believe for reopening of assessment even in the case where scrutiny assessment

VIKAS AGARWAL,SILVASSA vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

7
Section 2634
Bogus Purchases4
Reassessment4
ITA 191/SRT/2025[2016-17]Status: DisposedITAT Surat19 Aug 2025AY 2016-17

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 190/SRT/2025[2016-17]Status: DisposedITAT Surat19 Aug 2025AY 2016-17

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO,WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 193/SRT/2025[2017-18]Status: DisposedITAT Surat19 Aug 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA , SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 189/SRT/2025[2015-16]Status: DisposedITAT Surat19 Aug 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 188/SRT/2025[2015-16]Status: DisposedITAT Surat19 Aug 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 187/SRT/2025[2014-15]Status: DisposedITAT Surat19 Aug 2025AY 2014-15

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, SILVASSA WARD , SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 186/SRT/2025[2014-15]Status: DisposedITAT Surat19 Aug 2025AY 2014-15

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 192/SRT/2025[2017-18]Status: DisposedITAT Surat19 Aug 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIVEK KHABIA,SURAT vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, ground No. 3 is allowed and ground No

ITA 1072/SRT/2024[2018-19]Status: DisposedITAT Surat05 Mar 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 1072/Srt/2024 (Ay 2018-19) (Physical Court Hearing) Vivek Khabia Income Tax Officer, Ward- H.No.1187-90-91, 1089, Office 2(3)(4), Surat, Aaykar Bhavan, बनाम No.411, New Dtc Gheekanta Majura Gate, Surat-395 001 Vs Road, Nr. Bhavani Vad Temple, Haripura, Surat-395 003 [Pan : Avspk 5724 E] अपीलाथ"/Appellant ""थ" /Respondent

Section 133(6)Section 145(3)Section 147Section 148Section 148ASection 151ASection 254(1)Section 28

reassessment order passed u/s 147 in violation of Sec.148A(c) are bad in law. The appellant craves leave to add, amend, alter and/or withdraw the above ground of appeal at the time of hearing.” 3. Brief facts of the case are that assessee is an individual and engaged in the business of trading of rough, cut and polished diamond

AJAY KALISHCHANDRA BOHRA,DAMAN vs. PCIT, VALSAD

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

ITA 549/SRT/2024[2017-18]Status: DisposedITAT Surat03 Jan 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 549/Srt/2024 (Ay 2017-18) (Physical Court Hearing) Ajay Kalishchandra Bohra Principal Commissioner Of Income- 1, Plot No.22B, Daman Industrial Tax, Valsad, 301, 3Rd Floor, Palak बनाम Estate, Somnath Road, Dabhel, Arcade, Shantinagar, Tithal Road, Vs Daman-396 215 Valsad-396 001 [Pan : Ackpb 2567 R] अपीलाथ"/Appellant ""थ" /Respondent

Section 147Section 254(1)Section 263

147 r.w.s 144B as erroneous and prejudicial to the interest of revenue and passing order u/s 263, directing to pass fresh assessment order in the case. 2.Prayer Ajay K Bohra 2.1 The order u/s 263 passed by the PCIT may be kindly set aside. 2.2 Personal hearing may be granted. 2.3 Any other relief that your honours may deem

JAYVADAN RUGHNATHWALA,SURAT vs. ITO, WARD-1(2)(1), SURAT

ITA 923/SRT/2024[2018-19]Status: DisposedITAT Surat29 Aug 2025AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Bijayananda Pruseth Assessment Year 2018-19

For Appellant: Shri Rasesh Shah, A.RFor Respondent: Shri Ajay Uke, Sr.D.R
Section 115BSection 147Section 148Section 148ASection 69C

147 rws 144B of the Act may kindly be quashed and/or addition made by the assessing officer and confirmed by CIT(A) may please be deleted. 5. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal.” 3. Information was received from the Investigation Wing that

LEXUS SOFTMAC,SURAT vs. DCIT, CIRCLE1(1)(1), SURAT

In the result, assessee’s appeal ITA No

ITA 702/SRT/2024[2014-15]Status: DisposedITAT Surat25 Sept 2025AY 2014-15

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.702 & 703/Srt/2024 Ays: (2014-15 &2015-16) (Hybrid Hearing) Lexus Softmac, Deputy Commissioner Of F -3 To F-6, Gujarat Hira Bourse, Income-Tax, Circle 1(1)(1), बनाम/ Gems & Jewellery Park, Surat Room No.108, Vs. Ichchhapore, Aayakar Bhawan, Majura Surat - 394510 Gate, Opp. New Civil Hospital, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabfl 0495 P (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Deven K Kapadia, C.A. राज" की ओर से /Respondent By Shri Ajay Uke, Sr. Dr सुनवाई की तारीख/Date Of Hearing 19/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 25/09/2025

Section 143(3)Section 234ASection 250Section 271(1)(c)Section 69C

section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) both dated 20.05.2024 by the National Faceless Appeal Centre, Delhi/ Ld. Commissioner of Income Tax (Appeals) [in short, ‘CIT(A)’] for the assessment years (AYs) 2014-15 and 2015-16, which in turn arose out of separate assessment orders passed by the Assessing Officer (in short, ‘AO’) u/s

LEXUS SOFTMAC,SURAT vs. DCIT, CIRCLE 1(1)(1), SURAT

In the result, assessee’s appeal ITA No

ITA 703/SRT/2024[2015-16]Status: DisposedITAT Surat25 Sept 2025AY 2015-16

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.702 & 703/Srt/2024 Ays: (2014-15 &2015-16) (Hybrid Hearing) Lexus Softmac, Deputy Commissioner Of F -3 To F-6, Gujarat Hira Bourse, Income-Tax, Circle 1(1)(1), बनाम/ Gems & Jewellery Park, Surat Room No.108, Vs. Ichchhapore, Aayakar Bhawan, Majura Surat - 394510 Gate, Opp. New Civil Hospital, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabfl 0495 P (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Deven K Kapadia, C.A. राज" की ओर से /Respondent By Shri Ajay Uke, Sr. Dr सुनवाई की तारीख/Date Of Hearing 19/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 25/09/2025

Section 143(3)Section 234ASection 250Section 271(1)(c)Section 69C

section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) both dated 20.05.2024 by the National Faceless Appeal Centre, Delhi/ Ld. Commissioner of Income Tax (Appeals) [in short, ‘CIT(A)’] for the assessment years (AYs) 2014-15 and 2015-16, which in turn arose out of separate assessment orders passed by the Assessing Officer (in short, ‘AO’) u/s

SHRI GHANSHYAM DUNGARBHAI SUTARIYA,,SURAT vs. THE ACIT, CIRCLE-8,, SURAT

In the result, the appeal of the Assessee is dismissed

ITA 2971/AHD/2014[2009-10]Status: DisposedITAT Surat08 Aug 2019AY 2009-10

Bench: Shri H.S. Sidhu & Shri O.P. Meenaassessment Year: 2009-10 Ghanshyam Dungarbhai Sutaria, Vs. Acit, Circle-8, H.No. 1, 1St Floor, Sahaj Park Row Surat House, Hira Baug Circle, Vallabhacharya Road, Near Kailashdham Society, Ashwanikumar Road, Surat-395008 (Pan: Akkpp9318E) (Appellant) (Respondent)

Section 143(3)Section 251(1)Section 271(1)Section 271(1)(c)

u/s 271(1)(c) of the Act. The relevant case laws are as following: > PC Joseph & Bros (Kerala) 240 ITR 818 > Rakesh Suri (All) 331 ITR 458 > Sushma Devi Agarwal (ITAT-Kol-TM) 67 DTR 430 5.2 Also Where the omission is deliberate, he cannot get rid of merely by filing a revised return. The revised return being filed only