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2,958 results for “reassessment u/s 147”+ Section 271(1)(c)clear

Sorted by relevance

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Key Topics

Section 250113Section 147102Section 14892Section 143(3)81Addition to Income71Section 271(1)(c)57Penalty42Reassessment33Section 153A26Section 68

R J CORPORATION,MUMBAI vs. INCOME TAX OFFICER, 42(1)(4), MUMBAI, MUMBAI

In the result, both the appeals of the assessee are allowed

ITA 7715/MUM/2025[2011-12]Status: DisposedITAT Mumbai11 Feb 2026AY 2011-12

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 133(6)Section 143(3)Section 145(3)Section 147Section 148Section 250Section 271(1)(c)Section 274

147 Total Alleged Bogus Rs. 1,34,45,643/- Rs. 38,64,574/- Purchases R. J. Corporation Profit Rate Applied 12.5% 12.5% Addition Made Rs. 16,80,705/- Rs. 4,83,072/- Assessed Income Rs. 18,81,540/- Rs. 8,25,020/- Penalty Order Date 15.03.2019 15.03.2019 Section of Penalty 271(1)(c) 271(1)(c) Penalty Levied

Showing 1–20 of 2,958 · Page 1 of 148

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25
Natural Justice23
Reopening of Assessment23

R J CORPORATION,MUMBAI vs. INCOME TAX OFFICER, 42(1)(4), MUMBAI, MUMBAI

In the result, both the appeals of the assessee are allowed

ITA 7714/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Feb 2026AY 2010-11

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 133(6)Section 143(3)Section 145(3)Section 147Section 148Section 250Section 271(1)(c)Section 274

147 Total Alleged Bogus Rs. 1,34,45,643/- Rs. 38,64,574/- Purchases R. J. Corporation Profit Rate Applied 12.5% 12.5% Addition Made Rs. 16,80,705/- Rs. 4,83,072/- Assessed Income Rs. 18,81,540/- Rs. 8,25,020/- Penalty Order Date 15.03.2019 15.03.2019 Section of Penalty 271(1)(c) 271(1)(c) Penalty Levied

VIJAYAWADA TOLLWAY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, the appeal filed by the assessee is

ITA 1468/HYD/2025[2012-13]Status: DisposedITAT Hyderabad06 Feb 2026AY 2012-13
For Appellant: Shri A.V. Raghuram, Advocate
Section 143(3)Section 147Section 271(1)(c)

271(1)(c) of the Act. 7. We have carefully considered the rival submissions and perused the material available on record. We have also gone through page no. 8 of the reassessment order dated 05.12.2019 passed by the Ld. AO under section 143(3) read with section 147 of the Act, the relevant portion of which is to the following

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

ITA 987/PUN/2025[2014-15]Status: DisposedITAT Pune27 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Subodh Ratnaparkhi, CAFor Respondent: Shri Amit Bobde, CIT
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 250

reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C Corollary being that after seizing of operational period of Section 153A to 153D. the cases being dealt thereunder were circumscribed in the scope of newly substituted Section 148." We are in complete agreement

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), BHOPOAL, BHOPAL vs. M/S RASHTRIYA TAKNIKI SHIKSHAK PRASHIKSHAN EVAM ANUNSANDHAN SANSTHAN, BHOPAL

Appeal is dismissed

ITA 509/IND/2025[2014-15]Status: DisposedITAT Indore22 Dec 2025AY 2014-15

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

Section 10Section 271(1)(c)Section 43(1)

reassessment was passed on the same day and the assessee then paid the tax due as well as the interest thereon. 10. Unfortunately for the assessee, the Assessing Officer thereafter initiated penalty proceedings under section 271(1)(c) of the Act. 11. After obtaining a response from the assessee, the Assessing Officer saddled the assessee with penalty

PRASAM RAKESH CHOUDHARY,GIRNAR SOCIETY, BAPURAO GALLI, ITWARI, NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, BHOPAL , BHOPAL

Appeal is dismissed

ITA 529/IND/2025[2018 -2019]Status: HeardITAT Indore22 Dec 2025

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

Section 10Section 271(1)(c)Section 43(1)

reassessment was passed on the same day and the assessee then paid the tax due as well as the interest thereon. 10. Unfortunately for the assessee, the Assessing Officer thereafter initiated penalty proceedings under section 271(1)(c) of the Act. 11. After obtaining a response from the assessee, the Assessing Officer saddled the assessee with penalty

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX), JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

ITA 861/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Dharam Singh Meena, JCIT-DR
Section 147Section 148ASection 234ASection 250Section 271(1)(c)Section 69Section 69A

reassessment or re-computation under section 147. Unless, the notice was served on the proper person in the manner prescribed under section 282, the service was insufficient and AO did not have jurisdiction to re-assess the escaped income. Thus, the service of notice under section 148 was no service in the eye of law and all subsequent proceedings including

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX.) JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

ITA 862/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Dharam Singh Meena, JCIT-DR
Section 147Section 148ASection 234ASection 250Section 271(1)(c)Section 69Section 69A

reassessment or re-computation under section 147. Unless, the notice was served on the proper person in the manner prescribed under section 282, the service was insufficient and AO did not have jurisdiction to re-assess the escaped income. Thus, the service of notice under section 148 was no service in the eye of law and all subsequent proceedings including

SHRI RAMCHAND LAXMANDAS BABANI,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 192/JPR/2025[2011-12]Status: DisposedITAT Jaipur21 Aug 2025AY 2011-12

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ ITA No. 192/JPR/2025 निर्धारणवर्ष / AssessmentYear : 2011-12 Shri Ramchand Laxmandas Babani P.No.2, Shiv Shankar Colony Janta Colony, Jaipur – 302 004 (Raj) बनाम Vs. The ITO Ward -6(4) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ANYPB 6571 A अपीलार्थी / Appellant निर्धारिती की ओरसे/Assesseeby : Shri Mohit Balani, Advocate (Thru" V.C.) राजस्व की ओरसे /Revenue by: Shri Gautam Sin

For Appellant: Shri Mohit Balani, Advocate (Thru” V.C.)For Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 271(1)(c)

u/s 271(1)(c) of the Act in the present case has been levied on the basis that the Appellant has not shown the long term capital gain while filing the "Original return of income". 4.3. The Appellant at this juncture, the Appellant would like to draw your attention towards the provisions of S.148 of the Act, which

RAKESH KUMAR JAIN,JAIPUR vs. DCIT,CIRCLE-2, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee is allowed

ITA 212/JPR/2025[2014-15]Status: DisposedITAT Jaipur23 Jul 2025AY 2014-15

Bench: Or At The Time Of Hearing Of The Appeal & / Or Modify Any Of The Above Grounds.

For Appellant: Shri C.L. Yadav, CA and Shri Vikas Yadav AdvocateFor Respondent: Shri Gautam Singh Choudhary
Section 250(6)Section 271(1)(c)

271(1)(c) Assessing Officer alleged that assessee had concealed its income, orders imposing penalty were invalid and liable to be cancelled. [In favor of assessee] 8 RAKESH KUMAR JAIN VS DCIT, CIRCLE-2, JAIPUR 8 In view of the above facts and judicial decisions, the penalty imposed by the AO and confirmed by the CIT(A) may kindly

INCOME TAX OFFICIER- 23(3)(1), MUMBAI, MUMBAI vs. TISYA JEWELS, MUMBAI

In the result, both the appeals of the Revenue are accordingly partly allowed

ITA 869/MUM/2025[2007-08]Status: DisposedITAT Mumbai27 Jun 2025AY 2007-08

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2007-08 & Assessment Year: 2012-13 Income Tax Officer- 23(3)(1), Tisya Jewels Mumbai G-2 Sagar Fortune, 184 525A, 5Th Floor, Piramal Chambers, Vs. Waterfield Road, Bandra West, Parel, Mumbai-400012 Mumbai- 400050 Pan No. Aadft 8056 G Appellant Respondent Assessee By : Mr. Nishit Gandhi A/W Ms. Aadnya Bhandari Revenue By : Mr. Hemanshu Joshi, Cit-Dr

For Appellant: Mr. Nishit Gandhi a/wFor Respondent: Mr. Hemanshu Joshi, CIT-DR
Section 271(1)(c)Section 298

reassessed the income of the assessee at Rs.15,90,000 by making addition towards 25% gross profit on alleged bogus purchase made from hawala dealers. Thereafter, the AO levied penalty under section 271(1)(c) of Rs.3,40,980 on the ground that the assessee has failed to offer any explanation with regard to the alleged bogus purchases made from

INCOME TAX OFFICER- 23(3)(1), MUMBAI, MUMBAI vs. TISYA JEWELS, MUMBAI

In the result, both the appeals of the Revenue are accordingly partly allowed

ITA 870/MUM/2025[2012-13]Status: DisposedITAT Mumbai27 Jun 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2007-08 & Assessment Year: 2012-13 Income Tax Officer- 23(3)(1), Tisya Jewels Mumbai G-2 Sagar Fortune, 184 525A, 5Th Floor, Piramal Chambers, Vs. Waterfield Road, Bandra West, Parel, Mumbai-400012 Mumbai- 400050 Pan No. Aadft 8056 G Appellant Respondent Assessee By : Mr. Nishit Gandhi A/W Ms. Aadnya Bhandari Revenue By : Mr. Hemanshu Joshi, Cit-Dr

For Appellant: Mr. Nishit Gandhi a/wFor Respondent: Mr. Hemanshu Joshi, CIT-DR
Section 271(1)(c)Section 298

reassessed the income of the assessee at Rs.15,90,000 by making addition towards 25% gross profit on alleged bogus purchase made from hawala dealers. Thereafter, the AO levied penalty under section 271(1)(c) of Rs.3,40,980 on the ground that the assessee has failed to offer any explanation with regard to the alleged bogus purchases made from

DIESH KUMAR GOYAL,KOTA vs. ITO, WARD-1(1), KOTA, KOTA

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

ITA 32/JPR/2025[2010-11]Status: DisposedITAT Jaipur22 May 2025AY 2010-11
For Appellant: Sh. Rajendra Sisodia, Adv
Section 143(3)Section 271(1)(c)Section 274Section 68Section 69

Reassessment – Service of notice – Primary email id – Notice\nissued on the secondary notice\nService of the notice is not valid\n147, 282, Rule 127, Art. 226]\nFailure to participate in the proceedings\nReassessment was quashed. [S. 144, 144B,\n1.4The ITAT, Pune Bench, in the case of York Transport Equipment (India) Pvt. Ltd.\nvs. ITO in ITA No.125/PUN/2024, has held that

MR. CHITTARANJAN TRIMBAK GAIKWAD,PUNE vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4, PUNE, PUNE

In the result, the appeal of the assessee is allowed

ITA 759/PUN/2024[2010-11]Status: DisposedITAT Pune10 Jan 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri B.C. MalakarFor Respondent: Shri Ramnath P. Murkunde
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 271(1)(c)

u/s. 271(1)(c) of the Act was attracted in the case of the assessee for such income declared in the Revised Return of Income and so also owing to the assessment order passed u/s.143(3) r.w.s. 147 of the Act on 22/01/2014 accepting such income declared in the Revised Return of Income filed. The penalty therefore so levied

PUMPKIN PICTURES PRIVATE LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -2, THANE

In the result, the appeal by the assessee is dismissed

ITA 4197/MUM/2024[2011-12]Status: DisposedITAT Mumbai17 Dec 2024AY 2011-12

Bench: Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Rajesh Bhosle, AdvFor Respondent: Shri Krishnakumar, Sr. AR
Section 139(1)Section 142(1)Section 147Section 148Section 250Section 271(1)(c)

147 of the Act were initiated on the basis that despite receiving substantial contract receipts and professional and technical fees, the assessee has not filed its return of income under section 139(1) of the Act. It is discernible from the record that even in response to the notice issued under section 148 of the Pumpkin Pictures Private Limited

AMIT KHEMKA,KOLKATA vs. ITO, WARD - 43(1), KOLKATA

In the result, the appeal is partly allowed

ITA 636/KOL/2024[2012-13]Status: DisposedITAT Kolkata20 Aug 2024AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

For Appellant: Shri Vikash Kumar Agarwal, FCAFor Respondent: Shri Manoj Kumar Pati, Addl. CIT, Sr. DR
Section 147Section 250Section 271BSection 68

147 Order, presumed the entire deposits as trading receipts and by applying 8% estimated margin derived the additional total income at Rs. 18,58,785/-. b) The assessee would like to state that such calculation is made on an ad-hoc basis and is construed to be an act on the basis of certain presumption, conjecture and surmise. The assessee

AMIT KHEMKA,KOLKATA vs. ITO, WARD - 43(1), KOLKATA

In the result, the appeal is partly allowed

ITA 635/KOL/2024[2012-13]Status: DisposedITAT Kolkata20 Aug 2024AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

For Appellant: Shri Vikash Kumar Agarwal, FCAFor Respondent: Shri Manoj Kumar Pati, Addl. CIT, Sr. DR
Section 147Section 250Section 271BSection 68

147 Order, presumed the entire deposits as trading receipts and by applying 8% estimated margin derived the additional total income at Rs. 18,58,785/-. b) The assessee would like to state that such calculation is made on an ad-hoc basis and is construed to be an act on the basis of certain presumption, conjecture and surmise. The assessee

NOVA PROMOTERS AND FINLEASE PVT. LTD.,DELHI vs. ITO, NEW DELHI

ITA 3173/DEL/2014[2000-01]Status: DisposedITAT Delhi06 Aug 2024AY 2000-01

Bench: Shri S.Rifaur Rahman & Ms.Madhumita Roynova Promoters & Vs. Ito, Ward 13(3) Finlease Pvt. Ltd. Ito Building, I.P. Estate 7, Kapil Vihar, Pitampura, Delhi – 34

For Appellant: NoneFor Respondent: Shri Anshul
Section 147Section 271(1)(c)Section 68

147 of the Act. It further appears that the assessee also paid commission of Rs.2,96,250/- to the said entry operator, details whereof are appearing in the order passed by the ld. AO. 5. During the course of reassessment proceedings in order to examine the genuineness and creditworthiness of the companies who had given entries to the assessee, summoned

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 215/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 28.03.2016. 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer on account of alleged unexplained investment of Rs. 5,13,883/- on account of unexplained investment block

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 218/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 28.03.2016. 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer on account of alleged unexplained investment of Rs. 5,13,883/- on account of unexplained investment block