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24 results for “reassessment u/s 147”+ Section 54clear

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Key Topics

Section 14841Section 14729Addition to Income18Section 143(3)16Section 3514Survey u/s 133A10Section 699Section 548Section 68

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

reassessing the unabated assessment on the basis of material received from the other sources and can proceed under section 148. The decision does not support the contentions raised that Section 148 is rendered redundant if Section 153C is to be resorted to in the facts of the present case. 36. The Single Bench of this Court in the case

INCOME TAX OFFICER, INFINITY TOWERS, SANKARMATHAM ROAD vs. AMMAJI CHENNUPATI, RAJEEVNAGAR, KURMANNAPALEM

Showing 1–20 of 24 · Page 1 of 2

8
Unexplained Investment8
Section 148A7
Reopening of Assessment6

In the result, the appeal of the revenue is dismissed, while the additional ground of cross-objection of the assessee is allowed in terms of our aforesaid observations

ITA 441/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam09 Sept 2025AY 2017-18

Bench: Us:

Section 10(38)Section 147Section 148Section 148ASection 69

54,480. The A.O. further observed that the assessee had purchased the aforesaid shares out of the sale proceeds of equity shares of Steel Exchange India Ltd. of Rs. 1,33,39,080, which in turn were purchased by him for a value of Rs. 60,30,000/-. 6 ITA No.441/Viz/2024 & CO No.7/Viz/2025 Ammaji Chennupati 8. The A.O. observed that

THE INCOME TAX OFFICER, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 35/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2014-15

Bench: Us:

For Appellant: None
Section 131Section 147

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 37/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2017-18

Bench: Us:

For Appellant: None
Section 131Section 147

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 38/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2017-18

Bench: Us:

For Appellant: None
Section 131Section 147

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject

ACIT, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 34/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2013-14

Bench: Us:

For Appellant: None
Section 131Section 147

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject

ACIT, CIRCLE-1(1),, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 36/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2016-17

Bench: Us:

For Appellant: None
Section 131Section 147

reassessment proceedings initiated vide notice u/s 148 of the Act, dated 29.06.2021, had culminated into the assessment order passed by the A.O under Section 147 of the Act, dated 23.03.2023, therefore, it is the order passed by the Vedumutha Electricals India Private Limited. CIT(A), dated 29.11.2024 in Appeal No. CIT(A)-48, Mumbai /10553/2016-17 which alone for the subject

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

54,030/-, viz. (i). purchase consideration vide a registered document No.2888/2017, dated 21/06/2017: Rs. 13,03,000/-; (ii). registration expenses: Rs. 98,030/-; and (iii). payment towards execution of construction works: Rs. 3,53,000/-. 8. Apart from that, the AO observed that the assessee during the subject year had sold two immovable properties (stock-in-trade), i.e., (i) Flat

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

54,030/-, viz. (i). purchase consideration vide a registered document No.2888/2017, dated 21/06/2017: Rs. 13,03,000/-; (ii). registration expenses: Rs. 98,030/-; and (iii). payment towards execution of construction works: Rs. 3,53,000/-. 8. Apart from that, the AO observed that the assessee during the subject year had sold two immovable properties (stock-in-trade), i.e., (i) Flat

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

54,030/-, viz. (i). purchase consideration vide a registered document No.2888/2017, dated 21/06/2017: Rs. 13,03,000/-; (ii). registration expenses: Rs. 98,030/-; and (iii). payment towards execution of construction works: Rs. 3,53,000/-. 8. Apart from that, the AO observed that the assessee during the subject year had sold two immovable properties (stock-in-trade), i.e., (i) Flat

TADISETTI MURALI MOHAN,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR

In the result, appeal of the assessee is allowed

ITA 34/VIZ/2023[2015-16]Status: DisposedITAT Visakhapatnam23 May 2023AY 2015-16

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

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 133ASection 143(2)Section 143(3)Section 144Section 144(1)(b)Section 148Section 68Section 69

54,868/- as unexplained investment U/s. 68 of the Act. 5. Without prejudice to the above ground, the Assessing Officer and Ld. CIT (A) have not considered the fact that the reopening of the assessment is without recording reasons. 6. The Ld. CIT (A) would have observed that the reopening of the assessment is bad in law as the Assessing

TADISETTI MURALI MOHAN,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR

In the result, appeal of the assessee is allowed

ITA 33/VIZ/2023[2014-15]Status: DisposedITAT Visakhapatnam23 May 2023AY 2014-15

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

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 133ASection 143(2)Section 143(3)Section 144Section 144(1)(b)Section 148Section 68Section 69

54,868/- as unexplained investment U/s. 68 of the Act. 5. Without prejudice to the above ground, the Assessing Officer and Ld. CIT (A) have not considered the fact that the reopening of the assessment is without recording reasons. 6. The Ld. CIT (A) would have observed that the reopening of the assessment is bad in law as the Assessing

TADISETTI MURALI MOHAN,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR

In the result, appeal of the assessee is allowed

ITA 35/VIZ/2023[2016-17]Status: DisposedITAT Visakhapatnam23 May 2023AY 2016-17

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

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 133ASection 143(2)Section 143(3)Section 144Section 144(1)(b)Section 148Section 68Section 69

54,868/- as unexplained investment U/s. 68 of the Act. 5. Without prejudice to the above ground, the Assessing Officer and Ld. CIT (A) have not considered the fact that the reopening of the assessment is without recording reasons. 6. The Ld. CIT (A) would have observed that the reopening of the assessment is bad in law as the Assessing

TADISETTI MURALI MOHAN,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), GUNTUR

In the result, appeal of the assessee is allowed

ITA 32/VIZ/2023[2012-13]Status: DisposedITAT Visakhapatnam23 May 2023AY 2012-13

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

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 133ASection 143(2)Section 143(3)Section 144Section 144(1)(b)Section 148Section 68Section 69

54,868/- as unexplained investment U/s. 68 of the Act. 5. Without prejudice to the above ground, the Assessing Officer and Ld. CIT (A) have not considered the fact that the reopening of the assessment is without recording reasons. 6. The Ld. CIT (A) would have observed that the reopening of the assessment is bad in law as the Assessing

VIDYAVATHI MANTHRAVADI,UNITED KINGDOM vs. COMMISSIONER OF INCOME TAX(IT AND TP), HYDERABAD

In the result, appeal of the assessee is allowed for statistical purposes

ITA 295/VIZ/2023[2013-14]Status: DisposedITAT Visakhapatnam28 May 2024AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.292/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2013-14) Sivakama Sundar Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1372 N Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.295/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Vidyavathi Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1370 Q Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessees By : Ms. P. Chandini, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 27/03/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R Per S. Balakrishnan:

For Respondent: Dr. Satyasai Rath, CIT-DR
Section 143(3)Section 147Section 148Section 263Section 54Section 54E

147 of the Act as erroneous and prejudicial to the interests of the revenue for the following reasons. The Ld. CIT observed that the possession for the Flat No. 202 was during February, 2011 whereas the assessee sold the property in 12/12/2012 which is before the completion of three years from February, 2011 and thereby concluded that the assessee

SIVAKAMA SUNDAR MANTHRAVADI,UNITED KINGDOM vs. COMMISSIONER OF INCOME TAX(IT AND TP), HYDERABAD

In the result, appeal of the assessee is allowed for statistical purposes

ITA 292/VIZ/2023[2013-14]Status: DisposedITAT Visakhapatnam28 May 2024AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.292/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2013-14) Sivakama Sundar Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1372 N Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) आयकरअपीलसं./ I.T.A. No.295/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2013-14) Vidyavathi Manthravadi, Vs. Commissioner Of Income Tax United Kingdom. (It & Tp), Pan: Avspm 1370 Q Hyderabad. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessees By : Ms. P. Chandini, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 27/03/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R Per S. Balakrishnan:

For Respondent: Dr. Satyasai Rath, CIT-DR
Section 143(3)Section 147Section 148Section 263Section 54Section 54E

147 of the Act as erroneous and prejudicial to the interests of the revenue for the following reasons. The Ld. CIT observed that the possession for the Flat No. 202 was during February, 2011 whereas the assessee sold the property in 12/12/2012 which is before the completion of three years from February, 2011 and thereby concluded that the assessee

GVA INDUSTRIES PRIVATE LIMITED,CHHATTISGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

ITA 137/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam03 Dec 2025AY 2015-16
Section 142(1)Section 143(2)Section 147Section 148

147 of Income Tax Act, 1961 (in short 'Act') dated\n27.03.2022.\n4.\nBriefly stated the facts of the case are that, the assessee being a company,\nwhich is engaged in trading of steel bars, TMT etc., filed its return of income\nfor the A.Y. 2015-16 on 24.02.2016 declaring a total income of Rs.44,51,000/-.\nIt was noticed

DCIT, CENTRAL CIRCLE-1, VISAKHAPATNAM vs. GVA INDUSTRIES PVT. LTD., DHAMTARI

ITA 221/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam03 Dec 2025AY 2015-16
Section 142(1)Section 143(2)Section 147Section 148

147 of Income Tax Act, 1961 (in short 'Act') dated\n27.03.2022.\n4.\nBriefly stated the facts of the case are that, the assessee being a company,\nwhich is engaged in trading of steel bars, TMT etc., filed its return of income\nfor the A.Y. 2015-16 on 24.02.2016 declaring a total income of Rs.44,51,000/-.\nIt was noticed

ARRDY ENGINNERING INNOVATIONS (P) LTD,ROURKELA vs. THE ACIT, CIRCLE - 3(1), VISAKHAPATNAM., VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 432/VIZ/2012[2007-2008]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2007-2008

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

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 147Section 148Section 35Section 35(1)Section 35(1)(i)Section 35(1)(iv)Section 35(2)(ia)Section 40

reassessment proceedings U/s. 147 is not permissible merely on the basis of change of opinion because the AO for subsequent AY 2006-07 had taken a view that weighted deduction U/s. 35(2AB) cannot be allowed. 3. Even assuming (without admitting) that appellant was not eligible for weighted deduction U/s. 35(2AB) in respect of R&D expenditure towards field

ARRDY ENGINEERING INNOVATINS (P) LTD,ROURKELA vs. THE ACIT, CIRCLE - 3(1), VISAKHAPATNAM., VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 431/VIZ/2012[2005-06]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2005-06

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

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 147Section 148Section 35Section 35(1)Section 35(1)(i)Section 35(1)(iv)Section 35(2)(ia)Section 40

reassessment proceedings U/s. 147 is not permissible merely on the basis of change of opinion because the AO for subsequent AY 2006-07 had taken a view that weighted deduction U/s. 35(2AB) cannot be allowed. 3. Even assuming (without admitting) that appellant was not eligible for weighted deduction U/s. 35(2AB) in respect of R&D expenditure towards field