Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Electronica Machine Tools Ltd. v. Dy. CIT (2022)96 ITR 20 (SN) (Pune) (Trib)

S. 147: Reassessment-Finding of Commissioner (Appeals) recorded in perfunctory manner-Order not sustainable-Matter restored to Commissioner (Appeals) for adjudication de novo on merits. [S. 148]

Dy. CIT v. Sunflag Iron And Steel Co. Ltd. (2022) 96 ITR 9 (SN.) (Nag) (Trib)

S. 147 : Reassessment-Change of opinion-Industrial undertakings-Sale of surplus power-Reassessment is not valid. [S. 80IA(4)(iv)]

ACIT v. AbirInfrastructure Pvt. Ltd. (2022)97 ITR 245 (Hyd.) (Trib)

S. 147 : Reassessment-With in four years-No failure of disclosure of facts-Reassessment order is bad in law. [S. 148]

Satyawan v. ITO (2022)97 ITR 16 (SN) (Delhi) (Trib)

S. 147 : Reassessment-Assessment reopened on certain specific grounds-No addition was made on which the reassessment notice was issued-Additions made on other grounds-Reassessment is bad in law. [S. 143(3)]

Sanjit Jitendranath Biswas v. ITO (2022)97 ITR 14 (SN) (Surat) (Trib)

S. 147: Reassessment-No new tangible material to reopen assessment-Reassessment quashed. [S. 148]

Bhupendra K. Pathak v. ITO (2022)97 ITR 28 (SN)/ 218 TTJ 11 / 216 DTR 283 (SMC) (Pune) (Trib)

S. 147: Reassessment Notice-Failure to issue notice-Reassessment void-Issue of notice prior to filing return of no avail. [S. 143(2) 148, 292BB]

Sanjit Jitendranath Biswas v. ITO (2022)97 ITR 14 (SN) (Surat) (Trib)

S. 147 : Reassessment-No new material-Cash credits-Income from undisclosed source-Assessee borrowed money from friends and relatives-No evidence to show the receipts as bogus-Reassessment was quashed. [S.68, 148]

Golden Central Foods Products P. Ltd. v. ITO(2022)100 ITR 49 (SN)(Delhi) (Trib)

S. 147 : Reassessment-Unsecured loans-Accommodation entries-In reasons recorded, name of assessee and person from whom bogus accommodation entry different-Name of party and Permanent Account Number in information received also different-Reassessment not valid-Addition as cash credit was deleted. [S. 68, 133(6), 148]

ITO v. Hassab Realty Pvt. Ltd. (2022) 99 ITR 315 (Pune) (Trib)

S. 147 : Reassessment-Not made any addition pertaining to three-folded reasons for reopening the assessment-Cash credits-Reassessment order is bad in law.[S. 68, 148, 254(1)]

Gopi Kishan Pandey v.ITO (2022) 99 ITR 203 (Trib) (Lucknow)(Trib)

S. 147 : Reassessment-Best Judgment Assessment-Natural justice-Notice issued u/s 143(2)-Assessee was out of station-Not attended-Order was passed under section 144-Matter remanded for re-adjudication. [S.50C, 143(2),144, 148]