DCIT-2(1)(1), MUMBAI vs. BANK OF BARODA, MUMBAI

ITA 4869/MUM/2025Status: DisposedITAT Mumbai12 February 2026AY 2016-17Bench: SHRI OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that reopening beyond four years from the end of the assessment year requires proof of the assessee's failure to disclose material facts, which was not established. Relying on Supreme Court decisions, it was held that an audit party's opinion alone is not sufficient for reopening.

What were the facts?

The Revenue reopened the assessment of Bank of Baroda for AY 2015-16 and 2016-17, primarily based on an audit objection. The assessee challenged the validity of this reopening before the CIT(A).

What were the issues?

Whether reopening of assessment beyond four years, based solely on an audit objection, is valid. Whether an audit party's opinion constitutes 'information' for reopening under Section 147.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 263,Section 115JB

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, “B” BENCH, MUMBAI

Before: SHRI OM PRAKASH KANT, AM

For Appellant: Shri C. Naresh, AR
For Respondent: Shri Vimal Kumar Meena, (CIT DR)
Hearing: 10.12.2025Pronounced: 12.02.2026

Per Bench:

These appeals are filed by the Revenue and the and cross objections by the assessee, challenging the order of the Learned Commissioner of Inc

The order continues below.

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