DISHA EDUCATION SOCIETY,RAIPUR vs. DCIT, EXEMPTION CIRCLE, RAIPUR, RAIPUR

ITA 468/RPR/2026Status: DisposedITAT Raipur31 August 2026AY 2012-1314 pages
AI SummaryAllowed

What did the Tribunal hold?

The tribunal held that reassessment proceedings initiated beyond four years without fulfilling the conditions of the first proviso to Section 147 are invalid. Since the AO did not prove any failure by the assessee to disclose material facts, the reassessment was quashed.

What were the facts?

The assessee's reassessment proceedings were initiated beyond the four-year period from the end of the assessment year. The Assessing Officer (AO) failed to demonstrate any failure on the part of the assessee to disclose material facts fully and truly.

What were the issues?

Whether reassessment proceedings initiated beyond four years are valid when the assessee has not failed to disclose material facts. Whether the AO's reasons for reopening were legally sustainable.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “DB”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY & SHRI AVDHESH KUMAR MISHRA

For Appellant: shri Praveen Khandelwal &
For Respondent: Shri Rituparna Namdeo, CIT-DR
Hearing: 07.07.2026Pronounced: 31.08.2026

PER PARTHA SARATHI CHAUDHURY, JM: The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC, Delhi dated 03.03.2026 for the assessment year 2012-13 as per the grounds of appeal on record.

2.

The contention in law as assailed by the Ld. Counsel for the assessee was that reassessment framed u/s.143(3) r.w.s. 147 of the Income Tax Act, 1961 (for short ‘the Act’) by the ACI

The order continues below.

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