SAPNA NAINESH JATANIA,RAJKOT vs. INCOME TAX OFFICER, WARD 1(1), JAMNAGAR, JAMNAGAR
What did the Tribunal hold?
The Tribunal held that the reopening of assessment was bad in law as it was initiated for mere verification and not based on tangible material indicating escaped income. The reassessment proceedings were quashed.
What were the facts?
The assessee's appeals for AY 2011-12 and 2012-13 were filed with a delay of 55 days. The Assessing Officer had reopened the assessment based on information regarding penny stock transactions, leading to an addition of Rs. 8,60,444. The CIT(A) had remitted the issue back to the Assessing Officer.
What were the issues?
Whether the reassessment proceedings initiated by the Assessing Officer were valid and based on sufficient material, or if they were initiated merely for inquiry and verification.
Which sections of the Income-tax Act were involved?
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Cases cited in this judgment(2)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- PCIT v. Manzel Dinesh Kumar Shah25 citing101 Taxmann.com 259 · 2019 · SC
- PCIT v. Manzil Dinesh Kumar Shah24 citing95 Taxmann.com 46 · 2018 · HC
Income Tax Appellate Tribunal, “SMC”
Before: DR. ARJUN LAL SAINI
Per, Dr. Arjun Lal Saini AM:
Captioned two appeals filed by the assessee, pertaining to Assessment Year, 2011-12 and 2012-13, are directed against the separate orders passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 10/03/2025, which in turn arise out of separate assessment orders passed by the Assessing Officer, u/s 144 r.w.s. 147 of the Income Tax Act, 1961. ITA NO. 449 & 469/RJT/2025 Sapna Nainesh Jatania,
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More judgments on Section 147
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- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
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- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
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