MEENA ASHOK SHAH,AMRELI vs. ADDITIONAL / JOINT / DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX/INCOME-TAX OFFICER, NATIONAL FACELESS ASSESSMENT CENTRE

ITA 656/RJT/2025Status: DisposedITAT Rajkot16 September 2026AY 2014-1533 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reopening of assessment beyond four years was invalid as the Revenue failed to establish the assessee's failure to disclose material facts. It also noted issues with the approval process for reopening.

What were the facts?

The assessee claimed exemption for long-term capital gains on sale of shares. The Assessing Officer reopened the assessment, treating the transactions as bogus, and added the gains to the total income. The assessee argued that the reopening was beyond four years and the original assessment had already examined the issue.

What were the issues?

Whether the reassessment proceedings initiated beyond four years are valid without establishing failure to disclose material facts, and whether the approval for reopening was validly obtained.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3),Section 10(38),Section 68,Section 151

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Kalpesh Doshi, Ld. AR
For Respondent: Shri Ravinder Sindhu, Ld. CIT(DR)
Hearing: 12/08/2026Pronounced: 16/09/2026

Per, Shri Sonjoy Sarma, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY) 2014-15, is directed against the order under section 250 of the Income-tax Act, 1961 [hereinafter referred to as ‘the Act’] passed by the National Faceless Appeal Centre [hereinafter referred to as ‘NFAC’], dated 06.08.2025, which in turn arises out of an order passed by assessing officer u/s. 147 r.w.s. 144 of the Act, date

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 →