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80 results for “reassessment”+ Section 36(1)(iii)clear

Sorted by relevance

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Key Topics

Section 143(3)66Section 14860Section 14747Section 153A47Addition to Income42Condonation of Delay34Section 142(1)17Section 13214Unexplained Cash Credit

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 141/VIZ/2025[2009-10]Status: DisposedITAT Visakhapatnam13 May 2025AY 2009-10

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

36(1)(iii) of the Act. This issue is identical to that of the Revenue’s appeal in IT(SS)A No. 09/Viz/2025, AY 2012-13, which is adjudicated in the foregoing paragraphs of this order. Therefore, considering the similarity of the issue involved in all these appeals, our decision rendered in the Revenue’s appeal

Showing 1–20 of 80 · Page 1 of 4

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Section 143(2)11
Section 133A11
Search & Seizure11

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 143/VIZ/2025[2011-12]Status: DisposedITAT Visakhapatnam13 May 2025AY 2011-12

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

36(1)(iii) of the Act. This issue is identical to that of the Revenue’s appeal in IT(SS)A No. 09/Viz/2025, AY 2012-13, which is adjudicated in the foregoing paragraphs of this order. Therefore, considering the similarity of the issue involved in all these appeals, our decision rendered in the Revenue’s appeal

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 144/VIZ/2025[2012-13]Status: DisposedITAT Visakhapatnam13 May 2025AY 2012-13

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

36(1)(iii) of the Act. This issue is identical to that of the Revenue’s appeal in IT(SS)A No. 09/Viz/2025, AY 2012-13, which is adjudicated in the foregoing paragraphs of this order. Therefore, considering the similarity of the issue involved in all these appeals, our decision rendered in the Revenue’s appeal

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 140/VIZ/2025[2008-09]Status: DisposedITAT Visakhapatnam13 May 2025AY 2008-09

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

36(1)(iii) of the Act. This issue is identical to that of the Revenue’s appeal in IT(SS)A No. 09/Viz/2025, AY 2012-13, which is adjudicated in the foregoing paragraphs of this order. Therefore, considering the similarity of the issue involved in all these appeals, our decision rendered in the Revenue’s appeal

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 142/VIZ/2025[2010-11]Status: DisposedITAT Visakhapatnam13 May 2025AY 2010-11

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

36(1)(iii) of the Act. This issue is identical to that of the Revenue’s appeal in IT(SS)A No. 09/Viz/2025, AY 2012-13, which is adjudicated in the foregoing paragraphs of this order. Therefore, considering the similarity of the issue involved in all these appeals, our decision rendered in the Revenue’s appeal

GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, the appeal filed by the assessee in ITA

ITA 387/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133ASection 147Section 148Section 148ASection 151ASection 270ASection 271ASection 69

36,38,936/-. Also, the AO while culminating the assessment, initiated penalty proceedings, viz., (i) under section 270A of the Act for under- reporting of income, in consequence of misreporting of income, in respect of business income assessed at Rs.11,88,306/-; and (ii) penalty proceedings under section 271AAC of the Act in respect of addition towards unexplained investment made

GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, the appeal filed by the assessee in ITA

ITA 385/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133ASection 147Section 148Section 148ASection 151ASection 270ASection 271ASection 69

36,38,936/-. Also, the AO while culminating the assessment, initiated penalty proceedings, viz., (i) under section 270A of the Act for under- reporting of income, in consequence of misreporting of income, in respect of business income assessed at Rs.11,88,306/-; and (ii) penalty proceedings under section 271AAC of the Act in respect of addition towards unexplained investment made

GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, the appeal filed by the assessee in ITA

ITA 386/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133ASection 147Section 148Section 148ASection 151ASection 270ASection 271ASection 69

36,38,936/-. Also, the AO while culminating the assessment, initiated penalty proceedings, viz., (i) under section 270A of the Act for under- reporting of income, in consequence of misreporting of income, in respect of business income assessed at Rs.11,88,306/-; and (ii) penalty proceedings under section 271AAC of the Act in respect of addition towards unexplained investment made

VENKATA RAMANA GODA,VISAKHAPATNAM vs. ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 489/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2020-21

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.489/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Venkata Ramana Goda, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Circle-3(1), Pan: Abzpg3216A Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 17/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 08/03/2025. The 2 Venkata Ramana Goda Vs. Acit

For Appellant: Mrs. K. Hemalatha, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133(6)Section 147Section 148Section 151ASection 2(14)(iii)Section 234ASection 234BSection 250

iii) income or classes of income; or (iv) cases or classes of cases. The assessee in the present case before us, has not assailed the vesting of 21 Venkata Ramana Goda vs. ACIT jurisdiction with the DCIT/ACIT, Circle-3(1), Visakhapatnam, i.e., JAO based on either of the aforesaid four categories, but has rather challenged the lack of inherent jurisdiction

SATYANARAYANA KODURU,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-1, GUDIWADA

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 491/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.491/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Satyanarayana Koduru, Vs. Income Tax Officer, Krishna District. Ward-1, Pan:Altpk1048C Gudiwada. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 148ASection 250Section 69Section 69A

iii) income or classes of income; or (iv) cases or classes of cases. The assessee in the present case before us, has not assailed the vesting of jurisdiction with the ITO, Ward 1, Gudiwada, i.e., JAO based on either of the aforesaid four categories, but has rather challenged the lack of inherent jurisdiction with the Jurisdictional Assessing Officer (JAO), both

VIKRAM BRAHMENDRA SATYAJIT MULPURI,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-3(1), VIJAYAWADA

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 534/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2020-21

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.534/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Vikram Brahmendra Satyajit Vs. Income Tax Officer, Mulpuri, Ward-3(1), Krishna District. Vijayawada. Pan: Aonpm1893G (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm:

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 148ASection 250Section 69A

iii) 17 Vikram Brahmendra Satyajit Mulpuri vs. ITO income or classes of income; or (iv) cases or classes of cases. The assessee in the present case before us, has not assailed the vesting of jurisdiction with the ITO, Ward 3(1), Vijayawada, i.e., JAO based on either of the aforesaid four categories, but has rather challenged the lack of inherent

NO 368 KOLAKALURU PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LIMITED,GUNTUR vs. INCOME TAX OFFICER, WARD-1, TENALI

In the result, the appeal filed by the assessee society is allowed in terms of our aforesaid observations

ITA 456/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.456/Viz/2025 (िनधा"रण वष"/Assessment Year:2019-20) No.368 Kolakaluru Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-1, Credit Society Limited, Tenali. Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W Section 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 80PSection 80P(2)(a)Section 80P(2)(d)

iii) income or classes of income; or (iv) cases or classes of cases. The assessee society in the present case before us, has not assailed the 17 No.368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited vs. ITO vesting of jurisdiction with ITO, Ward 1, Tenali, i.e., JAO based on either of the aforesaid four categories, but has rather challenged

GO IRON MARKETING,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD 3(3), VISHAKAPATNAM

In the result, the appeal filed by the assessee firm is allowed in terms of our aforesaid observations

ITA 483/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.483/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Go Iron Marketing, Vs. Income Tax Officer, Visakhapatnam. Ward-3(3), Pan: Aanfg6474D Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca (Hybrid Hearing) राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of 03/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 26/07/2025 Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 01/02/2024 For The Assessment Year 2018-19. The 2 Go Iron Marketing Vs. Ito

For Appellant: Mrs. K. Hemalatha, CAFor Respondent: Shri Badicala Yadagiri, CIT-DR
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 151ASection 250

iii) income or classes of income; or (iv) cases or classes of cases. The assessee firm in the present case before us, has not assailed the vesting of jurisdiction with the ITO, Ward 3(3), Visakhapatnam, i.e., JAO based on either of the aforesaid four categories, but has rather challenged the lack of inherent jurisdiction with the Jurisdictional Assessing Officer

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM vs. DODDI ROOPA, VISAKHAPATNAM

In the result, the appeal filed by the revenue is dismissed in terms of our aforesaid observations

ITA 413/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2019-20

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.413/Viz/2024 (िनधा"रण वष"/Assessment Year: 2019-20) Deputy Commissioner Of Vs. Smt. Doddi Roopa, Income Tax, Visakhapatnam. Circle-3(1), Visakhapatnam. Pan: Atfpr7237N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 15/10/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement:

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Shri Badicala Yadagiri
Section 131Section 133(6)Section 147Section 148Section 148A

iii) income or classes of income; or (iv) cases or classes of cases. The assessee in the present case before us, has not assailed the vesting of jurisdiction with the DCIT/ACIT, Circle-3(1), Visakhapatnam, i.e., JAO based on either of the aforesaid four categories, but has rather challenged the lack of inherent jurisdiction with the Jurisdictional Assessing Officer

DEPUTY COMMISSIONER OF INCOME TAX (IT), VISAKHAPATNAM vs. SHRI APPARAO MUKKAMALA, USA

In the result, the appeal filed by the revenue is dismissed, while for the cross-objection filed by the assessee is allowed

ITA 354/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam30 Sept 2025AY 2016-17

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI BALAKRISHNAN. S, HON’BLE (Accountant Member)

Section 144C(3)Section 147Section 148Section 153CSection 69A

1) or where the return was furnished but no notice under Section 143(2) was served and the limitation had expired or where the assessment or reassessment was made. 19. As per Sub-section (3) the Section 153C shall not apply to the search or requisition made on or after 01.04.2021. 20. Section 153D provides that no order of assessment

VIZAG SEAPORT P.LTD,VISAKHAPATNAM vs. CIT(A) 14, MUMBAI

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 2478/MUM/2015[2007-08]Status: DisposedITAT Visakhapatnam23 Aug 2022AY 2007-08

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri PJ Pardiwalla, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 32

reassessment has to be based on fulfilment of certain pre-condition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of "change of opinion" as an in-built test to check abuse of power

DCIT 7(3), MUMBAI vs. VIZAG SEAPORT P.LTD, MUMBAI

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 2402/MUM/2014[2005-06]Status: DisposedITAT Visakhapatnam23 Aug 2022AY 2005-06

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri PJ Pardiwalla, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 32

reassessment has to be based on fulfilment of certain pre-condition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of "change of opinion" as an in-built test to check abuse of power

DCIT 7(3), MUMBAI vs. VIZAG SEAPORT P.LTD, MUMBAI

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 2401/MUM/2014[2009-10]Status: DisposedITAT Visakhapatnam23 Aug 2022AY 2009-10

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri PJ Pardiwalla, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 32

reassessment has to be based on fulfilment of certain pre-condition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of "change of opinion" as an in-built test to check abuse of power

DCIT 7(3), MUMBAI vs. VIZAG SEAPORT P.LTD, MUMBAI

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 2400/MUM/2014[2008-09]Status: DisposedITAT Visakhapatnam23 Aug 2022AY 2008-09

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri PJ Pardiwalla, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 32

reassessment has to be based on fulfilment of certain pre-condition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of "change of opinion" as an in-built test to check abuse of power

VIZAG SEAPORT P.LTD,VISAKHAPATNAM vs. CIT(A) 14, MUMBAI

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 2479/MUM/2015[2010-11]Status: DisposedITAT Visakhapatnam23 Aug 2022AY 2010-11

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri PJ Pardiwalla, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 32

reassessment has to be based on fulfilment of certain pre-condition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of "change of opinion" as an in-built test to check abuse of power