SARITA SHETTY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

ITA 2053/BANG/2025Status: DisposedITAT Bangalore24 August 2026AY 2015-167 pages
AI SummaryAllowed

What were the facts?

The assessee invested in convertible bonds which were later converted into equity shares. The Assessing Officer initiated reassessment proceedings, alleging that the fair market value of the shares was higher than the value at which they were allotted, leading to an addition under section 56(2)(vii)(c). The assessee argued that the reasons for reopening were not provided.

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid because the reasons for reopening the assessment were not furnished to the assessee, despite her request. Consequently, the reassessment order was quashed.

What were the issues?

Whether reassessment proceedings are invalid if the reasons for reopening are not provided to the assessee. Whether the addition under section 56(2)(vii)(c) is justified when the fair market value of shares is disputed.

Which sections of the Income-tax Act were involved?

Section 147,Section 56(2)(vii)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SOUNDARARAJAN K.

PER SHRI PRASHANT MAHARISHI, VICE PRESIDENT:

1.

This appeal is filed by Sarita Shetty (the assessee/appellant) for assessment year 2015–16 against the order dated 5 August 2025 passed by the National Faceless Appeal Centre (NFAC), Delhi [the learned CIT(A)], which partly allowed the assessee’s appeal against the reassessment o

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 48,773 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →