ROYAL MAHANAGAR DEVELOPERS,BHUBANESWAR vs. DCIT, CIRCLE-1(1), BHUBANESWAR

ITA 69/CTK/2026Status: DisposedITAT Cuttack09 September 2026AY 2014-154 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reopening of the assessment was based on incorrect facts, rendering the entire reopening unsustainable. Consequently, the reopening was quashed.

What were the facts?

The Assessing Officer reopened the assessment based on the belief that the assessee had shown Work-in-Progress (WIP) of Rs. 23.72 lacs for AY 2014-15. However, it was later acknowledged that this figure related to AY 2015-16, and the actual WIP for AY 2014-15 was Rs. 507.08 lacs.

What were the issues?

Whether the reopening of assessment was valid when the reasons recorded were based on erroneous factual assumptions regarding the Work-in-Progress amount.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, CUTTACK BENCH CUTTACK

Before: SHRI GEORGE MATHAN & SHRI GOPALAN GURUSAMY

Hearing: 09/09/2026Pronounced: 09/09/2026

Per George Mathan, JM: This is an appeal filed by the assessee against the order of the CIT(A), NFAC [hereinafter referred to as the ‘CIT(A)’] in appeal no.CIT(A), Bhubaneswar-2/100065/2020-21 dated 25.11.2025 for the assessment year 2014-15. 2. Shri D. Parida & Chitrasen Parida, ARs appeared on behalf of the assessee and Shri Vijay Singh, Sr. D.R. represented on behalf of the revenue.

3.

It was submitted by the ld. AR that the reasons recorded for the purpose of reopening has been recorded by the Assessing Officer in

The order continues below.

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