SHANTI RICE MILLS,KARNAL vs. INCOME TAX OFFICER, KARNAL

ITA 8805/DEL/2025Status: DisposedITAT Delhi10 July 2026AY 2014-1510 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that reopening the assessment based on the same material already considered during the original assessment constitutes a mere change of opinion. Therefore, the notice issued under Section 148 and the consequent reassessment proceedings under Section 147 were quashed.

What were the facts?

The assessee's assessment was completed under Section 143(3). Later, the Assessing Officer (AO) reopened the assessment under Section 147, alleging undervaluation of closing stock based on existing records. The AO had previously attempted rectification under Section 154/155 on the same issue, which was not pursued.

What were the issues?

Whether reopening of assessment under Section 147 is valid when based solely on a change of opinion and existing material, without any fresh information.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3),Section 154,Section 155

AI-generated summary — verify with the full judgment below

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

For Appellant: Shri Vivek Chaurasia, CA
For Respondent: Shri Ajay Kumar Arora, Sr. DR
Hearing: 05/05/2026

PER MANISH AGARWAL, AM: This appeal is filed by the Assessee against the order of Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [Ld. CIT(A)] dated 10.11.2025 u/s 250 of the Income Tax Act, 1961 (“the Act” in short) arising out of the assessment order passed u/s 143(3) of the Act dated 29.11.2016 for Assessment Year 2014-15. 2. Brief facts of the case are that the assessee is a partnership firm engaged in the business of rice shelling (paddy milling) for last 30 years. The return of income was filed on 19.07.2014 declaring total income of Rs.1,01,620/-. The case was selected for scrutiny and assessment order passed u/s 143(3) dated 29.11.2016 wherein disallowance of Rs.1,07,620/- wa

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 →