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28 results for “reassessment u/s 147”+ Section 69Cclear

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Key Topics

Section 69A56Section 14726Section 271(1)(c)24Addition to Income24Section 14818Section 69C13Section 25012Section 143(3)10Penalty8

M/S. PATEL AMBALAL HARGOVANDAS & CO.,,SURAT vs. THE DCIT, CENTRAL CIRCLE-2,, SURAT

In the results, appeal filed by Revenue (in IT(SS)A Nos

ITA 185/SRT/2022[2020-21]Status: DisposedITAT Surat26 May 2023AY 2020-21

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं/.It(Ss)A No.49/Srt/2022 Assessment Year: (2019-20) (Physical Hearing) The Acit, Central Circle-2, Vs. Rasikbhai Narottamdas Patel, Surat. Flat No.9-10, Mahavir Nagar Co.Op H.S. Ltd., Bldg-12, Nr. Gayatri Mandir, Udhna Magdalla Road, Surat – 395007. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Adgpp4550M (Appellant) (Respondent) आयकर अपील सं/.It(Ss)A No.86/Srt/2022 Assessment Year: (2015-16) The Dcit, Central Circle-2, Vs. Ashish Karamshibhai Koshiya, Surat. 40, Jivandeep Soceity, Singanpor Road, Katargam, Surat, Gujarat – 395004. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aojpk1118G (Appellant) (Respondent) आयकर अपील सं/.Ita No.185/Srt/2022 Assessment Year: (2020-21) M/S. Patel Ambalal Hargovandas Vs. The Dcit, Central Circle-2 & Co., Surat. 5/725, Haripura, Bhavaniwad, Opp. Dhobi Sheri, Surat – 395003. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aadfp2517N (Appellant) (Respondent) Appellant By Shri Ashok B. Koli, Cit(Dr) Shri Vartik Choksi, Shri Biren Shah & Shri Respondent By Nitin Gheewala, Ar Date Of Hearing 26/04/2023 Date Of Pronouncement 26/05/2023 आदेश /O R D E R Per Bench:

Section 132Section 143(3)Section 292CSection 69C

69C of the Act to the tune of Rs.1,79,99,000/-. 6. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the Ld. CIT(A), who has deleted the addition made by the Assessing Officer. The ld CIT(A) after considering the submissions of the IT(SS)A.49 & 86/SRT/2022 & ITA.185/SRT/2022 Ashish K. Koshiya

Showing 1–20 of 28 · Page 1 of 2

Section 687
Reassessment5
Reopening of Assessment3

INCOME TAX OFFICER, WARD 2(3)(7), SURAT vs. SHRI ANIL PUKHRAJ JAIN, SURAT

In the result the ground No

ITA 89/SRT/2017[2008-09]Status: DisposedITAT Surat23 Jan 2023AY 2008-09

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.89/Srt/2017 िनधा"रण वष"/Assessment Year: (2008-09) (Physical Court Hearing) Income Tax Officer, Ward-2(3)(7), Anil Pukhraj Jain, Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206-2Nd Floor, Tulsi Building, Bhavan, Adajan, Surat-395009 Vs. Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. (Appellant) (Respondent)/ "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q ""या"ेप सं Cross Objection No.10/Srt/2021 (A/O Ita No.89/Srt/2017) िनधा"रण वष"/Assessment Year: (2008-09) Anil Pukhraj Jain, Income Tax Officer, Ward-2(3)(7), Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206- 2Nd Floor, Tulsi Building, Vs. Bhavan, Adajan, Surat-395009 Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. Appellant/Co-Objector (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q िनधा"रती क" ओर से /Assessee By Shri Sapnesh R. Sheth, Ca राज"व क" ओर से /Respondent By Shri Ashok B. Koli, Cit-Dr सुनवाई क" तारीख/Date Of Hearing 23/12/2022 उ"ोषणा क" तारीख/Date Of Pronouncement 23/ 01/2023

Section 143(3)

reassessment proceedings under section 147/148 of the Act. During the assessment stage assessee did not file return of income in response to notice issued u/s 148 of the Act but he filed reply in the course of assessment proceedings stating to treat original return of income filed under section 139(1) of the Act, as the return of income field

INCOME TAX OFFICER, WARD-1(2)(1), SURAT, SURAT vs. DEEPESH VISHNU AGARWAL, SURAT

In the result, the appeal of the revenue is dismissed

ITA 833/SRT/2024[2017-18]Status: DisposedITAT Surat25 Nov 2025AY 2017-18
Section 144BSection 148Section 149

u/s 148 was issued beyond the permissible \"surviving period\" and without approval of the correct specified authority, rendering it void in law. The CIT(A)'s order quashing the reassessment proceedings was found to be without infirmity.", "result": "Dismissed", "sections": ["Section 148", "Section 148A", "Section 149", "Section 151", "Section 115BBE", "Section 69", "Section 69C", "Section 144B", "Section 147

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

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

SUNITA JAJOO,SURAT vs. ITO WARD 2(2)(4), SURAT

In the result, assessee’s appeal is allowed

ITA 882/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

u/s 147 of the Act, the submission and the various decisions of the ITA Nos.552 & 882/SRT/2024 (A.Y.11-12) Rambilash R Jajoo & Sunita Jajoo Courts including those relied upon by the ld Counsel for the assessee. Before we proceed to adjudicate the issue relating to validity of reassessment proceedings, we would like to examine the reasons recorded by the assessing officer, which

PISTABEN RAJMAL JAIN,SURAT vs. DCIT, CIRCLE 1(3), SURAT

In the result, both the appeals filed by the assessee are dismissed

ITA 703/SRT/2025[2014-15]Status: DisposedITAT Surat08 Apr 2026AY 2014-15

Bench: Dr. Brr Kumar, Hon’Ble & Ms. Suchitra Kambleita Nos. 635 & 703/Srt/2025 A. Y. 2013-14 & 2014-15

For Appellant: Shri Rasesh Shah, A.RFor Respondent: Shri Ajay Uke, Sr. D.R
Section 143(1)Section 147Section 148Section 251(1)(a)Section 68Section 69C

reassessment. 4. On the facts and circumstances of the case as well as law on the subject, the learned assessing officer has erred in making an addition of Rs. 44,645/- as unrecorded payment of commission u/s. 69C without any evidences and base purely on guess work. 5. On the facts and circumstances as well as law on the subject

PISTABEN RAJMAL JAIN,SURAT vs. DCIT, CIRCLE 1(3), SURAT

In the result, both the appeals filed by the assessee are dismissed

ITA 635/SRT/2025[2013-14]Status: DisposedITAT Surat08 Apr 2026AY 2013-14

Bench: Dr. Brr Kumar, Hon’Ble & Ms. Suchitra Kambleita Nos. 635 & 703/Srt/2025 A. Y. 2013-14 & 2014-15

For Appellant: Shri Rasesh Shah, A.RFor Respondent: Shri Ajay Uke, Sr. D.R
Section 143(1)Section 147Section 148Section 251(1)(a)Section 68Section 69C

reassessment. 4. On the facts and circumstances of the case as well as law on the subject, the learned assessing officer has erred in making an addition of Rs. 44,645/- as unrecorded payment of commission u/s. 69C without any evidences and base purely on guess work. 5. On the facts and circumstances as well as law on the subject

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 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 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,SILVASSA vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

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 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

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, 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 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

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

ITO, WARD-2(3)(2), SURAT, SURAT vs. KISHOR BHANUBHAI ASODARIA, SURAT

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 1245/SRT/2024[2015-16]Status: DisposedITAT Surat13 Aug 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

Section 10(38)Section 143Section 147Section 68Section 69

reassessment order passed under section 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2015-16. 2. Brief Facts of the case are the assessee is an individual filed his return of income for the asst. year 2015-16 declaring taxable income of Rs.3

YOGENDRAKUMAR RAMAVTAR AGARWAL,SURAT vs. ITO, WARD-1(2)(1), SURAT

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

ITA 882/SRT/2025[2009-10]Status: DisposedITAT Surat30 Oct 2025AY 2009-10

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Yogendrakumar Ramavtar Ito, Ward-1(2)(5), Agarwal, Surat Current Jurisdiction: 2053-Mahaveer Textile Market, Vs. Ito, Ward 1(2)(1), Ring Road, Textile Area, Aayakar Bhavan, Near Majura Surat-395002. Gate, Opp. New Civil Hospital, Surat-395001 Pan No. Aarpa 7623 C Appellant Respondent

For Respondent: Mr. Rasesh Shah, CA
Section 147Section 148Section 69Section 69C

69C of the I.T. Act 3. On the facts and circumstances of the case as well as 3. On the facts and circumstances of the case as well as 3. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) ha law on the subject, the learned CIT(A) has erred

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT vs. NARESHKUMAR B. AGARWAL, SURAT

ITA 164/SRT/2023[2020-21]Status: DisposedITAT Surat31 Oct 2025AY 2020-21
Section 147Section 250

u/s 69B towards purchase of land at block No.7 and 287\nKumbharia, (ii) Rs.5,94,15,000/- u/s 69A on account of on-money receipt of\nKuberji Crown and (iii) Rs.55,00,000/- u/s 69B for unaccounted payment for land\nat plot No. 224 at Kumbharia.\n44.1 Aggrieved by the order of AO, the assessee filed appeal before

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT vs. NARESHKUMAR B. AGARWAL, SURAT

ITA 163/SRT/2023[2013-14]Status: DisposedITAT Surat31 Oct 2025AY 2013-14
Section 147Section 250

u/s.\n132 of the Act in case of Kuberji Group on 06.02.2020. The residential premises\nof the assessee, Shri Naresh Bisheshwarlal Agrawal, was also covered during the\nsearch and seizure operation. Various incriminating documents were found and\nseized which indicated that the assessee had not disclosed his true and correct\nincome in the return of income. The assessee was issued