ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, JAMSHEDPUR, JAMSHEDPUR vs. JAI PRAKSH SINGH , JAMSHEDPUR

ITA 5/RAN/2025Status: DisposedITAT Ranchi20 April 2026AY 2013-146 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reasons recorded for reopening did not mention any failure on the part of the assessee to disclose material facts. Since the original assessments were under Section 143(3) and reopening was beyond four years, the first proviso to Section 147 applied.

What were the facts?

The revenue appealed against the CIT(A)'s order quashing reassessments for AY 2013-14 and 2014-15. The CIT(A) found no fresh information for reopening. The revenue argued that differences in VAT/Service Tax, PF/ESIC, and Form 26AS warranted reopening.

What were the issues?

Whether the reopening of assessment beyond four years was valid without recording the assessee's failure to disclose material facts. Whether the reasons recorded for reopening were sufficient to justify the reassessment.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 36(1)(va),Section 2(24)(x)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: S/SHRI GEORGE MATHAN & RATNESH NANDAN SAHAY

For Appellant: Shri Sharvan Kumar Jha, AR
For Respondent: Shri Ashish Kumar Deharia, ld CIT DR
Hearing: 20/04/2026Pronounced: 20/04/2026

Per Bench Both the appeals filed by the revenue are directed against the separate orders of the ld CIT(A), Patna-3 both dated 28.10.2024 in Appeal No.CIT(A), Patna- 3/10817/2012-13 for the assessment year 2013-14 and in Appeal No.CIT(A), Patna-3/10733/2013-14 for the assessment year 2014-15. 2. Shri Sharvan Kumar Jha, ld AR appeared for the assessee and Shri Ashish Kumar Deharia, ld CIT DR appeared for the revenue.

3.

It was submitted by ld CIT DR that the ld CIT(A) has quashed the assessment for both the assessment years on the ground that there is no fresh

P a g e 1 | 6

ITA No. 5 & 9 /Ran/2025 Assessment Year : 2013-14 & 14-

The order continues below.

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