JAT EDUCATION SOCIETY,ROHTAK vs. DCIT E CIRCLE 2, CHANDIGARH

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ITA 4157/DEL/2026Status: DisposedITAT Delhi16 September 2026AY 2019-203 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were not sustainable in law because the additions made in the assessment order did not align with the reasons recorded for reopening. Therefore, the reopening itself was quashed.

What were the facts?

The Assessing Officer initiated reassessment proceedings under Section 147/148 based on alleged financial transactions. However, the final assessment order made additions for surplus funds that were not part of the original reasons for reopening.

What were the issues?

Whether reassessment proceedings are valid when additions made in the assessment order are unrelated to the reasons recorded for reopening.

Which sections of the Income-tax Act were involved?

Section 144,Section 147,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: ‘F’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL

For Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Hearing: 20.08.2026Pronounced: 16.09.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘F’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.4157/Del/2026 Assessment Year: 2019-20 JAT Education Society, Vs. DCIT (Exemption), C.R. Polytechnic Campus, Circle-2, Delhi Road, Chandigarh Rohtak -124001 Haryana PAN: AAAJJ0176A (Appellant) (Respondent) Assessee by Sh. Ankit Kumar, Adv. Department by Ms. Harpreet Kaur Hansra, Sr. DR Date of hearing 20.08.2026 Date of pronouncement 16.09.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2019-20, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1086296907(1), dated 20.02.2026, involving proceedings under section 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

ITA No.4157/Del/2026

2.

Coming to the first and foremost legal issue herein, it emerges during the course of hearing that the learned assessing authority had set into motion section 148/147 proceedings on account of alleged financial transactions i.e. time deposits of Rs.2,00,00,000/- , cash deposits of Rs.19,94,850/-, payment received in respect of a contract of Rs.1,16,274/- and interest other than interest on securities of Rs.37,94,522/-, totaling to Rs.2,59,05,746/- in the assessee’s case whereas the impugned assessment framed on 21.03.2024 ended in making addition of Rs.6,20,97,141/- relating to surplus funds, which never formed part of the foregoing reopening reasons. 3. We hereby conclude in light of this clinching factual position and as per ATS Infrastructure Ltd. Vs. ACIT (2024) 166 taxman.com 61 (Delhi), Ranbaxy Laboratory CIT (2011) 335 ITR 136 (Del), PCIT v. Jakhotia Plastics (P.) Ltd. (2018) 94 taxmann.com 89 (Delhi), CIT Vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom.) and CIT(E) Vs. BP Poddar Foundations for Education (2023) 148 taxmann.com 125 (Cal) that the impugned reopening is not itself sustainable in law once the learned Assessing Officer has nowhere

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ITA No.4157/Del/2026

made any addition in the assessee’s hands going by the foregoing reason/information recorded herein. Quashed accordingly All other remaining pleadings between the parties on merits stand rendered academic. 4. This assessee’s appeal is allowed. Order pronounced in the open court on 16th September, 2026 Sd/- Sd/- (MANISH AGARWAL) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 16th September, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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