JAGDISHPRASAD MAHESHWARI,NAGPUR vs. DCIT/ACIT CIRCLE-4, NAGPUR

ITA 748/NAG/2025Status: DisposedITAT Nagpur17 April 2026AY 2013-149 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that reassessment proceedings initiated beyond four years, based on existing records without any failure to disclose by the assessee, are invalid. The Assessing Officer lacked jurisdiction to reopen the assessment.

What were the facts?

The assessee's assessment for AY 2013-14 was completed under Section 143(3). Subsequently, reassessment proceedings were initiated beyond four years, based solely on information already available in the original assessment records. There was no mention of the assessee failing to disclose material facts.

What were the issues?

Whether reassessment proceedings initiated beyond four years are valid when based on existing assessment records without any failure to disclose by the assessee. Whether the Assessing Officer has jurisdiction to reopen a concluded assessment on the same material.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 148,Section 144B

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(8)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, NAGPUR ‘SMC’ BENCH, NAGPUR

Before: DR.MANISH BORAD

For Appellant: Shri Mahavir Atal
For Respondent: Shri Surjit Kumar Saha
Hearing: 10.03.2026Pronounced: 17.04.2026

The captioned appeal at the instance of assessee pertaining to A.Y. 2013-14 is directed against the order dated 10.11.2025 framed by National Faceless Appeal Centre, Delhi (NFAC) arising out of Assessment Order dated 23.03.2022 passed u/s.147 r.w.s.144 r.w.s.144B of the Income Tax Act, 1961 (in short ‘the Act’).

2.

I will take up the legal issue raised by the assessee challenging the validity of the assessment proceedings in light of the judgment of Hon’ble Bombay High Court in the case of Crystal Pride Developers Vs. ACIT (2025) 172 taxmann.com 463 (Bombay).

3.

At the outset, ld. Counsel for the assessee submitted that r

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →