RAJSRIYA AUTOMOTIVE INDUSTRIES PVT. LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-5(1), CHENNAI
In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the reassessment was bad in law as the AO reopened the concluded assessment without any fresh material. The AO had relied on existing material that was already considered during the original assessment.
What were the facts?
The assessee challenged the validity of reassessment proceedings, arguing that the Assessing Officer (AO) reopened the assessment based on existing material, not fresh evidence. The AO had added a difference in interest income to the total income.
What were the issues?
Whether the reassessment proceedings were validly initiated without fresh material evidence. Whether the AO had tangible material to reopen a concluded assessment.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Before: SHRI. M. BALGANESH & BEFORE SHRI S.S. VISWANETHRA RAVI
आयकर अपीलीय अिधकरण, ’सी’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI �ी ऐम. बालगनेश, लेखा सद एवं �ी एस.एस. िव$ने% रिव, �ाियक सद के सम& । BEFORE SHRI. M. BALGANESH, ACCOUNTANT MEMBER AND BEFORE SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER आयकर अपील सं./I.T.A. No. 2736/Chny/2025 िनधा(रण वष(/Assessment Year: 2012-13 Rajsriya Automotive Industries Private Vs. Deputy Commissioner of Limited, Income Tax, No.64/13, ABM Avenue, Boat Club Corporate Circle -5(1), Raja Annamalaipuram, Chennai. Chennai – 600 028. [PAN: AABCR-4226-K] (अपीलाथ+/Appellant) (,-थ+/Respondent) अपीलाथ+ की ओर से / Appellant by : Mr. N. Arjunraj, Advocate ,-थ+ की ओर से/Respondent by : Ms. Swarnalatha, Addl. CIT सुनवाई की तारीख/ Date of hearing : 25.06.2026 घोषणा की तारीख /Date of Pronouncement 03.08.2026 : आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:
This appeal filed by the assessee is directed against the order dated 08.09.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2012-13.
2 ITA No. 2736/Chny/2025
The ld.AR, Mr. N. Arjunraj, Advocate, submits that the assessee
raised ground nos. 2 to 5 challenging validity of re-assessment
proceedings and prayed to take up the same as preliminary issue. Upon
hearing both the parties and with their consent, we proceed to hear
ground nos. 2 to 5 as a preliminary issue.
The ld.AR, drew our attention to the page no. 155 of the paper
book and argued that the AO without having any new material evidence
reopened the assessment concluded u/s. 143(3) of the Income-tax Act,
1961 (herein after “the Act”) only on the ground on an examination of
existing material evidence which were furnished to AO during the course
of assessment proceedings. Further, he drew our attention to the para
no. A & B, wherein he vehemently argued that the AO proceeded to
reopen the concluded assessment only on existing material, but not on
bringing on record any fresh material evidence. He argued the
reassessment is bad under law as having being no tangible material in
the hands of AO to reopen the original assessment.
The ld.DR, Ms. Swarnalatha, Addl.CIT, relied on the order of the
ld.CIT(A).
3 ITA No. 2736/Chny/2025
Upon hearing both the parties, we note that on an examination of
the reassessment order dated 11.12.2019, which is at page no.155 of
the paper book, wherein it is observed by the AO with reference to
interest income that “ it is seen that in P&L Account, miscellaneous
income of Rs.2,87,25,578/- is credited and hence the difference of
Rs.31,16,280/- (Rs.41,03,328 – Rs.9,87,048) was added to the total
income. We find the opinion of the AO that the assessee offered only
sum of Rs.9,87,048/-, but however, not offered the above said difference
amount for taxation. We note that the original assessment dated
17.02.2015 is at page no. 29 of the paper book, wherein in response to
the notices issued by the AO u/s. 142(1) and 143(2) of the Act, the
assessee appeared and filed replies during the course of assessment
proceedings and thereby, having satisfied with the explanation offered
by the assessee the AO accepted the returned income. On perusal of
the re-assessment order, as rightly pointed by the ld.AR, there is no
fresh material available with the AO on issues on account of interest
income and disallowance of 14A as it clearly shows that the AO on the
basis of existing material re-opened the original assessment
order. Therefore, having no fresh material in the hands of AO in
order to reopen the already concluded assessment u/s. 143(2) of
4 ITA No. 2736/Chny/2025
the Act, the re-assessment is bad in law and therefore, the order of the ld.CIT(A) is not justified in confirming the view of the AO in reopening the assessment without having any tangible material. Thus, order of the ld. CIT(A) is set aside and ground nos. 2 to 5 raised by the assessee are allowed.
In view of our decision, in favour of the assessee in quashing reassessment order dated 11.12.2019 as bad in law, the remaining ground nos. 6 to 12 on merits becomes infructuous and are dismissed.
In the result, appeal filed by the assessee is partly allowed. Order pronounced on 03rd August, 2026 at Chennai.
Sd/- Sd/- (M. BALGANESH) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER
Chennai, Dated: 03.08.2026 JPV आदेश की ,ितिलिप अ3ेिषत/Copy to: 1. अपीलाथ+/Appellant, 2.,-थ+/ Respondent, 3. आयकर आयु4/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय ,ितिनिध/DR & 5. गाड( फाईल/GF.
PRASANNA Digitally signed by PRASANNA VANI JETTY VANI JETTY Date: 2026.08.06 10:06:17 +05'30'
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