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16,589 results for “reassessment u/s 147”+ Addition to Incomeclear

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Mumbai4,165Delhi3,747Chennai976Kolkata908Ahmedabad892Bangalore839Jaipur803Pune658Hyderabad558Chandigarh363Surat330Indore276Raipur258Rajkot241Visakhapatnam229Amritsar219Cochin146Agra130Guwahati114Patna106Lucknow103Cuttack101Nagpur97Jodhpur56Dehradun53Allahabad52Telangana37Karnataka26Panaji24Ranchi23Jabalpur17Varanasi9Calcutta8Orissa6Kerala5SC5Gauhati3Rajasthan2Himachal Pradesh2Uttarakhand1Punjab & Haryana1

Key Topics

Section 148146Section 147120Section 143(3)95Addition to Income82Reassessment38Reopening of Assessment25Section 6824Section 25023Section 153A21Section 69

MAHESH KUMAR,DELHI vs. ITO,WARD-68(6), DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2650/DEL/2024[2012-13]Status: DisposedITAT Delhi06 Aug 2025AY 2012-13

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 10(38)Section 143(3)Section 147Section 148Section 68

147 has this effect that the Assessing Officer has to assess or reassess the income ("such income") which escaped assessment and which was the basis of the formation of belief and if he does so, he can also assess or reassess any other income which has escaped assessment and which comes to his notice during the course of the proceedings

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Section 15120
Natural Justice18

INCOME TAX OFFICER, WARD 3(1), DELHI, DELHI vs. ARTISTIC FINANCE PRIVATE LIMITED, DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2650/DEL/2023[2014-15]Status: DisposedITAT Delhi08 May 2025AY 2014-15

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 10(38)Section 143(3)Section 147Section 148Section 68

147 has this effect that the Assessing Officer has to assess or reassess the income ("such income") which escaped assessment and which was the basis of the formation of belief and if he does so, he can also assess or reassess any other income which has escaped assessment and which comes to his notice during the course of the proceedings

DCIT, CIRCLE-12(1), KOLKATA, KOLKATA vs. M/S DOTEX MERCHANDISE PVT. LTD., KOLKATA

In the result, appeal of the Revenue is dismissed and the cross objections are also dismissed as infructuous

ITA 1602/KOL/2016[2010-11]Status: DisposedITAT Kolkata03 May 2019AY 2010-11

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 133(6)Section 142(1)Section 143(1)Section 147Section 148Section 68

income if and only if the addition is first made by the AO with reference to the grounds or issue for which reason is recorded u/s 148(2) of the Act. Where however no addition is made in the order u/s 147 with reference to the reason recorded u/s 148 or where the addition made with reference to the reasons

H.K. ENTERPRISES,MUMBAI vs. DY CIT-CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 269/MUM/2021[2012-13]Status: DisposedITAT Mumbai24 Jan 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 153ASection 245D(1)Section 250Section 254

147. Thereafter, AO has not brought any evidence or made any inquiry that assessee has earned additional income of Rs.5 lakhs as brokerage income. In the instant case, after reopening the assessment order, the AO had not made any inquiry and not examined the material which was before him that how this income was declared by the assessee and addition

H.K. ENTERPRISES,MUMBAI vs. DY CIT CC - 2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 316/MUM/2021[2014-15]Status: DisposedITAT Mumbai24 Jan 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 153ASection 245D(1)Section 250Section 254

147. Thereafter, AO has not brought any evidence or made any inquiry that assessee has earned additional income of Rs.5 lakhs as brokerage income. In the instant case, after reopening the assessment order, the AO had not made any inquiry and not examined the material which was before him that how this income was declared by the assessee and addition

H.K. ENTERPRISES,MUMBAI vs. DY CIT - CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 317/MUM/2021[2015-16]Status: DisposedITAT Mumbai24 Jan 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 153ASection 245D(1)Section 250Section 254

147. Thereafter, AO has not brought any evidence or made any inquiry that assessee has earned additional income of Rs.5 lakhs as brokerage income. In the instant case, after reopening the assessment order, the AO had not made any inquiry and not examined the material which was before him that how this income was declared by the assessee and addition

H.K. ENTERPRISES,MUMBAI vs. DY CIT-CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 267/MUM/2021[2016-17]Status: DisposedITAT Mumbai24 Jan 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 153ASection 245D(1)Section 250Section 254

147. Thereafter, AO has not brought any evidence or made any inquiry that assessee has earned additional income of Rs.5 lakhs as brokerage income. In the instant case, after reopening the assessment order, the AO had not made any inquiry and not examined the material which was before him that how this income was declared by the assessee and addition

H.K. ENTERPRISES,MUMBAI vs. DY CIT-CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 268/MUM/2021[2013-14]Status: DisposedITAT Mumbai24 Jan 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 153ASection 245D(1)Section 250Section 254

147. Thereafter, AO has not brought any evidence or made any inquiry that assessee has earned additional income of Rs.5 lakhs as brokerage income. In the instant case, after reopening the assessment order, the AO had not made any inquiry and not examined the material which was before him that how this income was declared by the assessee and addition

H.K. ENTERPRISES,MUMBAI vs. DY CIT -CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 314/MUM/2021[2018-19]Status: DisposedITAT Mumbai24 Jan 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 153ASection 245D(1)Section 250Section 254

147. Thereafter, AO has not brought any evidence or made any inquiry that assessee has earned additional income of Rs.5 lakhs as brokerage income. In the instant case, after reopening the assessment order, the AO had not made any inquiry and not examined the material which was before him that how this income was declared by the assessee and addition

H.K.ENTERPRISES,MUMBAI vs. DCIT, CENTRAL CIRCLE-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

ITA 315/MUM/2021[2017-18]Status: DisposedITAT Mumbai24 Jan 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 153ASection 245D(1)Section 250Section 254

147. Thereafter, AO has not brought any evidence or made any inquiry that assessee has earned additional income of Rs.5 lakhs as brokerage income. In the instant case, after reopening the assessment order, the AO had not made any inquiry and not examined the material which was before him that how this income was declared by the assessee and addition

NSE IT LTD,MUMBAI vs. DCIT 8(2), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 5935/MUM/2014[2005-06]Status: DisposedITAT Mumbai28 Mar 2018AY 2005-06

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.5935/Mum/2014 (नििाारण वर्ा / Assessment Year: 2005-06) बिाम/ M/S. Nse. It Ltd, Dcit 8(2), Mumbai Trade Globe, Ground Floor, Andheri Kurla Road, V. Andheri (E), Mumbai 400059 स्थायी ऱेखा सं./ Pan : Aabcn0159P (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri. Sunil NahtaFor Respondent: Shri. T.A Khan(DR)
Section 143(3)Section 148Section 271(1)Section 271(1)(c)

addition made by the Id A.O to the total income as declared in return of income filed in response to notice u/s. 148 of the act and before receiving the reasons for reopening (ii) The conduct of the assessee was bonafide as it has suo-moto rectified the mistake in the return of income filed in response to notice u/s

DCIT, JAIPUR vs. VIMAL CHAND SURANA HUF, JAIPUR

In the result, the appeal of the revenue stands dismissed

ITA 437/JPR/2017[2007-08]Status: DisposedITAT Jaipur17 May 2018AY 2007-08
For Appellant: Shri S.R. Sharma &For Respondent: Shri Varinder Mehta (CIT) fu/kZkfjrh dh vksj ls@
Section 131Section 139(1)Section 143Section 143(3)Section 147Section 148Section 151Section 292C

addition is made only to safeguard the interest of the revenue. The Hon’ble Bombay High Court in CIT v. Jet Airways (I) Ltd. [2011] 331 ITR 236 (Bombay) held that if the Assessing officer does not assess the income for which reasons were recorded u/s 147 for reopening of assessment, he cannot assess any other Income u/s 147.This ratio

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(1), RAIPUR vs. MESERSS CHHATTISGARH STATEELECTRICITY BOARD, RAIPUR

ITA 31/RPR/2020[2006-07]Status: DisposedITAT Raipur25 Sept 2023AY 2006-07

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.31/Rpr/2020 "नधा"रण वष" / Assessment Year : 2006-07 The Deputy Commissioner Of Income Tax, Circle-4(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh State Electricity Board (Through Chhattisgarh State Power Holding Company Limited) Dangania Raipur Pan : Aabcc7876Q ……""यथ" / Respondent

For Appellant: S/shri Praveen Khandelwal & PraveenFor Respondent: Dr. Simran Bhullar, CIT-DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 80I

income vide application u/s 154 of the Act, thus, sustained the addition to the said extent. Regarding the other additions/disallowances assailed by the assessee and revenue, the Tribunal observed that as the same did not arise out of the reassessment proceedings, i.e., the order passed by the AO u/ss. 143(3) r.w.s 147

ACIT, CIR-1(2)(1), MUMBAI vs. M/S. CHERYL ADVISORY PVT LTD., MUMBAI

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

ITA 2063/MUM/2023[2013-14]Status: DisposedITAT Mumbai31 Jan 2024AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2013-14

For Appellant: Mr. Tanzil Padvekar, AdvFor Respondent: Mr. H.M. Bhatt, Sr. DR
Section 153C

u/s 147 of the Act on the ground of borrowed satisfaction. The assessee 147 of the Act on the ground of borrowed satisfaction. The assessee 147 of the Act on the ground of borrowed satisfaction. The assessee also challenged addition on merit. The Ld. CIT(A) in the impugned also challenged addition on merit

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

ITA 868/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Him.

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR a
Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

reassessment order passed u/ s 147 r.w.s. 143(3) is also illegal and void above said initio and is liable to be quashed.” In view of above facts and judicial pronouncements the completion of assessment u/s 144 of income tax act 1961 is ab-initio void. The assessment so framed may kindly be quashed. " Decision of the Learned

CORAL VENTURE PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX 12(1)(2), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 2483/MUM/2023[2010-2011]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-2011

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2010-11

For Appellant: Mr. Subhash Chhajed and Mr. Hitesh RathodFor Respondent: Mr. H.M. Bhatt, Sr. DR
Section 143(3)Section 147Section 148Section 151

income within th meaning of section 147 of the Act. Hence the entire Reassessment meaning of section 147 of the Act. Hence the entire Reassessment meaning of section 147 of the Act. Hence the entire Reassessment proceedings are liable to be annulled and quashed. proceedings are liable to be annulled and quashed. 6. On the facts and circumstances

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

ITA 63/BANG/2023[2013-14]Status: DisposedITAT Bangalore01 Sept 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

additional income, without any basis and evidences. • Without prejudice reassessment proceedings is void an bad in law. • Without prejudice to the above there was no reason to believe that assessee's income had escaped assessment. • Without prejudice to the above, the reasons recorded for reopening of assessment proceedings u/s 147

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

ITA 62/BANG/2023[2012-13]Status: DisposedITAT Bangalore01 Sept 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

additional income, without any basis and evidences. • Without prejudice reassessment proceedings is void an bad in law. • Without prejudice to the above there was no reason to believe that assessee's income had escaped assessment. • Without prejudice to the above, the reasons recorded for reopening of assessment proceedings u/s 147

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

ITA 65/BANG/2023[2015-16]Status: DisposedITAT Bangalore01 Sept 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

additional income, without any basis and evidences. • Without prejudice reassessment proceedings is void an bad in law. • Without prejudice to the above there was no reason to believe that assessee's income had escaped assessment. • Without prejudice to the above, the reasons recorded for reopening of assessment proceedings u/s 147

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

ITA 64/BANG/2023[2014-15]Status: DisposedITAT Bangalore01 Sept 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

additional income, without any basis and evidences. • Without prejudice reassessment proceedings is void an bad in law. • Without prejudice to the above there was no reason to believe that assessee's income had escaped assessment. • Without prejudice to the above, the reasons recorded for reopening of assessment proceedings u/s 147