CHHATTISGARH STATE INDUSTRIAL DEVELOPMENT CORPORATION LTD., RAIPUR,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR, RAIPUR

ITA 333/RPR/2025Status: DisposedITAT Raipur29 June 2026AY 2011-1229 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid because the AO's reasons for reopening did not match the additions made. The discrepancy between the income escaping assessment mentioned in the reasons and the actual additions made rendered the AO's satisfaction ambiguous and the notice under Section 148 void ab initio.

What were the facts?

The Assessing Officer (AO) issued reassessment notices based on reasons indicating certain incomes escaped assessment. However, during reassessment, the AO made additions on entirely different grounds and amounts than those specified in the reasons recorded. The assessee argued that this discrepancy vitiated the reassessment proceedings.

What were the issues?

Whether reassessment proceedings are valid when additions made by the AO differ significantly from the income escaping assessment stated in the reasons recorded for reopening.

Which sections of the Income-tax Act were involved?

Section 148,Section 147

AI-generated summary — verify with the full judgment below

आयकर अपील"य अ"धकरण "यायपीठ रायपुर म"। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER AND DR. DIPAK P. RIPOTE, ACCOUNTANT MEMBER आयकर अपील सं. / ITA Nos.333, 334 & 335/RPR/2025 "नधा"रण वष" / Assessment Years : 2011-12, 2012-13 & 2013-14 Chhattisgarh State Industrial Development Corporation Limited Udyog Bhawan, Ring Road-1, Telibandha, Raipur (C.G.)-492 006 PAN: AABCM6288N

........अपीलाथ" / Appellant बनाम / V/s. The Deputy Commissioner of Income Tax, Circle-1(1), Raipur (C.G.) ……""यथ" / Respondent

आयकर अपील सं. / ITA Nos.353, 354, 355 & 356/RPR/2025 "नधा"रण वष" / Assessment Years : 2011-12, 2012-13, 2013-14 & 2014-15 The Deputy Commissioner of Income Tax, Circle-1(1), Raipur (C.G.)

........अपीलाथ" / Appellant बनाम / V/s.

2 Chhattisgarh State Industrial Development Corporation Limited ITA Nos.333 to 335/RPR/2025 ITA Nos.353 to 356/RPR/2025 Chhattisgarh State Industrial Development Corporation Limited Ground Floor, LIC Campus, Pandri, Ravigram, S.O-Raipur (C.G.)-492 001 PAN: AABCM6288N

……""यथ" / Respondent

Assessee by : Shri R.B Doshi, CA Revenue by : Ms. Manisha Kinnu, CIT-DR

सुनवाई क" तार"ख / Date of Hearin

The order continues below.

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