ANNAKODIRAJ,TIRUNELVELI vs. ITO, WARD-1,, TIRUNELVELI

ITA 4121/CHNY/2025Status: DisposedITAT Chennai27 February 2026AY 2017-181 pages
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What did the Tribunal hold?

The Tribunal held that when the reasons for reopening of assessment do not form part of the additions made in the reassessment order, the Assessing Officer is precluded from making other additions. This is in line with judicial pronouncements from the Hon'ble Jurisdictional High Court and the Supreme Court.

What were the facts?

The assessee's appeal is against the order of the Commissioner of Income Tax (Appeals). The reassessment was initiated based on cash deposits and withdrawals, but the additions made in the assessment order were for estimated net profit and unaccounted milk purchase, which were not part of the original reasons for reopening.

What were the issues?

Whether additions made in the reassessment order are valid when they do not form part of the original reasons for reopening the assessment.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A(d),Section 144,Section 144B

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Income Tax Appellate Tribunal, ‘D’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & SHRI S.R. RAGHUNATHA

Hearing: 26.02.2026Pronounced: 27.02.2026

PER GEORGE GEORGE K: This appeal filed by the assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 09.10.2025 passed under section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2017-18. :- 2 -:

2.

The assessee has raised legal grounds. One of the legal ground raised is Ground No.4.1, which reads as under:-

The order continues below.

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