What is CIT v. Jet Airways (I) Ltd. authority for?

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

How many judgments cite CIT v. Jet Airways (I) Ltd.?

694 judgments on BharatTax cite CIT v. Jet Airways (I) Ltd. (331 ITR 236), spanning 2012 to 2026.

Which sections of the Income Tax Act does CIT v. Jet Airways (I) Ltd. come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 144B, Section 234B, Section 151.

CIT v. Jet Airways (I) Ltd. (331 ITR 236)

Darbari Industries, Mumbai vs. Assistant Commissioner of Income Tax - 41(1)(1), Mumbai

In the result, the appeal of the assessee is allowed on legal ground, and the reassessment order is quashed

ITA 205/MUM/2026[2019-20]Status: DisposedITAT Mumbai21 Apr 2026AY 2019-20

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokardarbari Industries Acit - 41(1)(1) 110, Champaklal 8Th Floor, Kautilya Udyog Bhavan, Sion Vs. Bhavan, C-41-43, Koliwada Road, Sion Avenue 3, Near Videsh (West), Mumbai – Bhavan, G-Block, Bkc, 400 022. Bandra Kurla Complex, Bandra East, Mumbai- 400 051 Pan/Gir No. Aaafd3277E (Applicant) (Respondent) Assessee By Shri Bhupendra Shah, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 16.04.2026 Date Of Pronouncement 21.04.2026

Section 115BSection 139(1)Section 142(1)Section 144BSection 147Section 148Section 148ASection 250Section 270ASection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER Darbari Industries ACIT - 41(1)(1) 110, Champaklal 8th Floor, Kautilya Udyog Bhavan, Sion Vs. Bhavan, C-41-43, Koliwada Road, Sion Avenue 3, Near Videsh (West), Mumbai – Bhavan, G-Block, BKC, 400 022. Bandra Kurla Complex, Bandra East, Mumbai- 400 051 PAN/GIR No. AAAFD3277E (Applicant) (Respondent) Assessee by Shri Bhupendra Shah, Ld. AR Revenue by Shri Annavaram Kosuri, Ld. DR Date of Hearing 16.04.2026 Date of Pronouncement 21.04.2026 आदेश / ORDER PER MAKARAND V…

Amrapar Seva Sahkari Mandli Ltd, Amrapar vs. The Principal Commissioner of Income Tax - 1, Rajkot

In the result, the appeal of the assessee is dismissed

ITA 324/RJT/2025[2018-19]Status: DisposedITAT Rajkot17 Apr 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 324/Rjt/2025 Assessment Year: (2018-19) Amrapar Seva Sahkari Mandali Ltd. Vs. The Principal Commissioner Of C/O., Sarda & Sarda, Sakar, 1St Floor, Income Tax – 1, Dr. Radha Krishna Road, Opp. Aayakar Bhavan, Race Course Rajkumar Collage, Rajkot - 360001 Ring Road, Rajkot – 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaaa0819N (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar : Shri Sanjay Punglia, Ld. Cit(Dr) Respondent By Date Of Hearing : 18/03/2026 : 17/04/2026 Date Of Pronouncement

For Appellant: Shri Vimal Desai, Ld. AR

Section 139(1)Section 147Section 148Section 263Section 80ASection 80PSection 80P(2)(d)

…आयकर अपील"य अ"धकरण, राजकोट "यायपीठ, राजकोट। In The Income Tax Appellate Tribunal, Rajkot Bench, Rajkot Before Dr. Arjun Lal Saini, Accountant Member And Dr. Dinesh Mohan Sinha, Judicial Member आयकरअपीलसं./ITA No. 324/Rjt/2025 Assessment Year: (2018-19) Amrapar Seva Sahkari Mandali Ltd. Vs. The Principal Commissioner of C/O., Sarda & Sarda, Sakar, 1st Floor, Income Tax – 1, Dr. Radha Krishna Road, Opp. Aayakar Bhavan, Race Course Rajkumar Collage, Rajkot - 360001 Ring Road, Rajkot – 360001 "ायीलेखासं./जीआइआरसं./PAN/GIR No.: AAAAA0819N (Appellant) (Respondent) Appellant by : Shri Vimal Desai, Ld. AR : Shri Sanjay P…

Ampi Finance Limited, Kolkata vs. I.T.O., Ward-4(3), Kolkata

Appeal of the assessee is allowed

ITA 2831/KOL/2025[2012-13]Status: DisposedITAT Kolkata05 Mar 2026AY 2012-13

Bench: the Bench that the re-opening of

Section 143(3)Section 144Section 147Section 148Section 148(2)Section 250Section 69C

…nce of the arguments relied upon the decision of Hon’ble Kolkata High Court in the case of CIT (Exemption) Vs. B.P. Poddar Foundation For Education reported in (2023) 148 taxmann.com 125 (Calcutta) and CIT-5, Mumbai Vs. Jet Airways (I) Ltd. reported in (2011) 331 ITR 236 (Bombay). The Ld. AR therefore, prayed that the addition made by the AO may kindly be deleted as without jurisdiction. 6. The Ld. DR on the other hand relied the orders of authorities below. 7. After hearing the rival contention and perusing the material available on record, we find that the reasons recorded by the AO u/s 148(2) of the Act whic…

Dayanand Anglo Vedik Higher Secondry School Prabandh Karini Sabha, Jhabrera Roorkee vs. ITO Ward 1(3)(4), Roorkee

Appeal is allowed

ITA 212/DDN/2025[2015-16]Status: DisposedITAT Dehradun27 Feb 2026AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Rajiv Sahni, CAFor Respondent: Sh. A. S. Rana, Sr. DR

Section 10Section 147Section 148

…ned assessing authority has nowhere made any addition qua the above sole reason of reopening. 6. That being the clinching case, we hereby quote Ranbaxy Laboratories Ltd. vs. Union of India (2011) 336 ITR 136 (Del.) and CIT vs. Jet Airways (India) Ltd. (2011) 331 ITR 236 (Bom.) to quash the impugned reopening for the above precise reason in very terms. 7. This assessee’s appeal is allowed. Order Pronounced in the Open Court on 27/02/2026. (Manish Agarwal) (Satbeer Singh Godara) Accountant Member Judicial Member Dated: 27/02/2026 *Subodh Kumar, Sr. PS*…

Ramesh Purshottam Modi, Mumbai vs. Income Tax Officer Circle 22(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6577/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Purshottam Ito Circle 22(1) Modi Income Tax 303, Modi House, Linking Vs. Department, Road, Khar West, Piramal Chamber, Mumbai-400 052 Dr. Ss Rao Marg, Parel, Mumbai 0 400 012 Pan/Gir No. Aahpm2793F (Applicant) (Respondent) Assessee By Shri Ashwani Kumar A/W Ms. Deepali Aggarwal, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 12.02.2026 Date Of Pronouncement 19.02.2026

Section 143(3)Section 144BSection 147Section 148Section 250Section 94(7)Section 94(8)

…lidity of reassessment proceedings and failure of jurisdiction under section 148, the learned Authorised Representative placed strong reliance upon the judicial precedents of the Hon’ble Bombay High Court in Commissioner of Income-tax v. Jet Airways (I) Ltd. (331 ITR 236) and the Hon’ble Delhi High Court in Ranbaxy Laboratories Ltd. v. Commissioner of Income-tax (336 ITR 136)where it was held that the Assessing Officer, upon forming a reason to believe and issuing notice under section 148, must assess or reassess “such income” which formed the basis of reopening, and only thereafter the course of proceedings. It…

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2542/KOL/2025[2015-16]Status: DisposedITAT Kolkata18 Feb 2026AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2541 & 2542/Kol/2025 Assessment Years: 2013-14 & 2015-16 Dcit, Cc-1(2), Kolkata…………..…....…………….……….……….……Appellant Vs. M/S Amluckie Investment Company Ltd.……………….....……...…..…..Respondent 2Nd Floor, 10 Princep Street, Kolkata-700072. [Pan: Aacca6749H] Appearances By: Shri Manoj Kr. Pati, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 12, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Filed By The Revenue Are Directed Against Separate Orders Both Dated 21.07.2025 Of The Cit(A)-20, Kolkata Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Years 2013–14 2015-16 Respectively. Since Both The Appeals Relate To The Same Assessee & Arisen From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Both The Appeal Filed By The Revenue With A Delay Of 35 Days & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

Section 131Section 143(2)Section 147Section 148Section 250

…to disallowance of loss of Rs.57,86,077/- claimed on purchase and sale of shares of Wagend Indra Ventures Ltd. The ld. AR relied on the following decisions: a. CIT (E) vs. B P Poddar Foundation for Education [2022] 448 ITR 695 (Cal SC) b. Jet Airways (I) Ltd. 331 ITR 236 (Bom) c. Ranbaxy Laboratories Ltd. 336 ITR 136 (Del) d. M/s Infinity Infotech Parks Ltd. (2014) 9 TMI 1142 8. Upon hearing the submissions of the respective parties and we have perused the reasons recorded for issuance of notice u/s 148 which is as under: 8.1 We have also gone through the reassessment order framed u/s 147 of the Act and find tha…

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2541/KOL/2025[2013-14]Status: DisposedITAT Kolkata18 Feb 2026AY 2013-14

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2541 & 2542/Kol/2025 Assessment Years: 2013-14 & 2015-16 Dcit, Cc-1(2), Kolkata…………..…....…………….……….……….……Appellant Vs. M/S Amluckie Investment Company Ltd.……………….....……...…..…..Respondent 2Nd Floor, 10 Princep Street, Kolkata-700072. [Pan: Aacca6749H] Appearances By: Shri Manoj Kr. Pati, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 12, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Filed By The Revenue Are Directed Against Separate Orders Both Dated 21.07.2025 Of The Cit(A)-20, Kolkata Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Years 2013–14 2015-16 Respectively. Since Both The Appeals Relate To The Same Assessee & Arisen From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Both The Appeal Filed By The Revenue With A Delay Of 35 Days & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

Section 131Section 143(2)Section 147Section 148Section 250

…to disallowance of loss of Rs.57,86,077/- claimed on purchase and sale of shares of Wagend Indra Ventures Ltd. The ld. AR relied on the following decisions: a. CIT (E) vs. B P Poddar Foundation for Education [2022] 448 ITR 695 (Cal SC) b. Jet Airways (I) Ltd. 331 ITR 236 (Bom) c. Ranbaxy Laboratories Ltd. 336 ITR 136 (Del) d. M/s Infinity Infotech Parks Ltd. (2014) 9 TMI 1142 8. Upon hearing the submissions of the respective parties and we have perused the reasons recorded for issuance of notice u/s 148 which is as under: 8.1 We have also gone through the reassessment order framed u/s 147 of the Act and find tha…

Pentokey Organy Organ (India) Limited, Mumbai vs. Deputy Comm. of Income Tax, Circle 1(2)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 2651/MUM/2025[2015-16]Status: DisposedITAT Mumbai13 Feb 2026AY 2015-16

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailpentokey Organy (India) Ltd. 45/47, Somaiya Bhavan, M.G. Road, Fort, Mumbai. ............... Appellant Pan: Aaacp6875D V/S Deputy Commissioner Of Income Tax, Circle - 1(2)(1), ……………… Respondent Room No.535, 5Th Floor, Aaykar Bhavan, Maharishi Karve Road, Mumbai- 400020 Assessee By : Shri K. Gopal, Adv. Shri Om Kandalkar Revenue By : Shri Virabhadra Mahajan, Sr. Dr

For Appellant: Shri K. Gopal, AdvFor Respondent: Shri Virabhadra Mahajan, Sr. DR

Section 115Section 143(3)Section 144BSection 147Section 148Section 234Section 250

…compute the book profit under section 115-JB of the Act, resulting in a demand on the assessee. 11. In this regard, it is pertinent to note the following finding of the Hon’ble Jurisdictional High Court in CIT v. Jet Airways (India) Ltd., reported in (2011) 331 ITR 236 (Bom): - 6 “16. ……..Section 147 has this effect that the Assessing Officer has to assess or reassess the income ("such income") which escaped assessment and which was the basis of the formation of belief and if he does so, he can also assess or reassess any other income which has escaped assessment and which, comes to his notice during the cours…

M/S Stance Consumer Electronics Private Limited, Delhi vs. Deputy Commissioner of Income Tax, CC-32, Delhi

In the result appeal of the assessee for AY 2017-18 in ITA No

ITA 2792/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.2791 & 2792/Del/2025 (Assessment Yearss 2016-17 & 2017-18)

Section 143(3)Section 147Section 148Section 250Section 68

…oceedings ceased to survive. Consequently, we answer the first part of question in affirmative in favour of revenue and the second part of the question against the revenue.” 10. The Hon’ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd. [2011] 331 ITR 236 (Bombay) has also expressed the same view. Thus, by respectfully following the aforesaid judgments of the Hon’ble Jurisdictional High Court and of the hon’ble Bombay High Court wherein it is held that the reassessment order passed by making additions beyond the reasons recorded is without jurisdiction when the Assessing Officer has not made any a…

M/S Stance Consumer Electronics Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, CC-32, Delhi

In the result appeal of the assessee for AY 2017-18 in ITA No

ITA 2791/DEL/2025[2016-17]Status: DisposedITAT Delhi13 Feb 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.2791 & 2792/Del/2025 (Assessment Yearss 2016-17 & 2017-18)

Section 143(3)Section 147Section 148Section 250Section 68

…oceedings ceased to survive. Consequently, we answer the first part of question in affirmative in favour of revenue and the second part of the question against the revenue.” 10. The Hon’ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd. [2011] 331 ITR 236 (Bombay) has also expressed the same view. Thus, by respectfully following the aforesaid judgments of the Hon’ble Jurisdictional High Court and of the hon’ble Bombay High Court wherein it is held that the reassessment order passed by making additions beyond the reasons recorded is without jurisdiction when the Assessing Officer has not made any a…

Vedant Bhatnagar, Delhi vs. Income Tax Officer Ward 49(1), Delhi

Appeal is allowed

ITA 394/DEL/2026[2011-12]Status: DisposedITAT Delhi11 Feb 2026AY 2011-12

Bench: Sh. Satbeer Singh Godaraita No. 394/Del/2026 : Asstt. Year: 2011-12 Vedant Bhatnagar, Vs Income Tax Officer, 57, Pratap Nagar, Hari Nagar, Ward-49(1), New Delhi-110064 New Delhi-110002 (Appellant) (Respondent) Pan No. Ajepb2530P Assessee By: Sh. Nitin Gulati, Adv. & Ms. Reena Gandhi, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 11.02.2026 Date Of Pronouncement: 11.02.2026 Order This Assessee’S Appeal For Assessment Year 2011-12 Arises Against The Addl./Jcit(A)-5, Mumbai’S Din & Order No. Itba/Apl/S/250/2025-26/1083074346(1) Dated 27.11.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Nitin Gulati, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No. 394/Del/2026 : Asstt. Year: 2011-12 Vedant Bhatnagar, Vs Income Tax Officer, 57, Pratap Nagar, Hari Nagar, Ward-49(1), New Delhi-110064 New Delhi-110002 (APPELLANT) (RESPONDENT) PAN No. AJEPB2530P Assessee by: Sh. Nitin Gulati, Adv. & Ms. Reena Gandhi, Adv. Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 11.02.2026 Date of Pronouncement: 11.02.2026 ORDER This assessee’s appeal for Assessment Year 2011-12 arises against the Addl./JCIT(A)-5, Mumbai’s DIN & order No. ITBA/APL/S/250/2025…

Shimla W/O Shri Kiran Singh, Uttarpradesh vs. Sandhaya Maurya ITO Ward-2 (2) (3), Ghaziabad

Appeal is allowed

ITA 7041/DEL/2025[2020-21]Status: DisposedITAT Delhi10 Feb 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 7041/Del/2025 : Asstt. Year: 2020-21 Shimla W/O Sh. Kiran Singh, Vs Income Tax Officer, Village-Kudiya Gadi, Dasna Dehat, Ward-2(2)(3), Dasna, Ghaziabad-201015 Ghaziabad-201002 (Appellant) (Respondent) Pan No. Mnrps2732P Assessee By: Sh. Sahil Sharma, Adv. & Sh. Sanjay Parashar, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/107983568(1) Dated 21.08.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Sahil Sharma, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR

Section 147Section 148ASection 56

…n based on the foregoing sole reason of reopening. This reopening found is not sustainable in law. This being the clinching case, I hereby quote Ranbaxy Laboratories Ltd. vs. Union of India (2011) 336 ITR 136 (Del.) and CIT vs. Jet Airways (India) Ltd. (2011) 331 ITR 236 (Bom.) to quash the impugned reopening for the above precise reason in very terms. 5. This assessee’s appeal is allowed. Order Pronounced in the Open Court on 10/02/2026. (Satbeer Singh Godara) Judicial Member Dated: 10/02/2026 *Subodh Kumar, Sr. PS*…

M/S Srigarv Buildcon Pvt Ltd, Delhi vs. ACIT Central Circle 32, Delhi

Appeal is allowed

ITA 190/DEL/2026[2020-21]Status: DisposedITAT Delhi09 Feb 2026AY 2020-21

Bench: SHRI SATBEER SINGH GODARA (Judicial Member)

Section 147Section 148

…ng received for M/s. White Line Apparels Pvt. Ltd. This clinching factual position has gone unrebutted from the Revenue side. 3. Faced with this situation, I hereby quote Ranbaxy Laboratory Vs. CIT (2011) 335 ITR 136 (Del); CIT Vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom.); Matchless Infrastructure Pvt. Ltd. Vs. ITO, 2025 (1) TMI 866 (ITAT – Delhi); DCIT Vs. Interlink Foods Pvt. Ltd, ITA Nos. 4669,4670 & 4671/Del/2024 (ITAT – Delhi); Dinesh Babu Saxena Vs. ITO, ITA No. 3874/Del/2025 (ITAT -Delhi) that such a reopening suffering from complete non- application of mind is not sustainable. Quashed in very terms…

Arpita Jena, Bhubaneswar vs. ITO, Ward 3(1), Bhubaneswar

In the result, the appeal of the assessee is allowed

ITA 585/CTK/2025[2016-17]Status: DisposedITAT Cuttack02 Feb 2026AY 2016-17

Bench: Shri George Mathan & Shri Laxmi Prasad Sahuआयकर अपील सं/Ita No.585/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2016-2017) Arpita Jena, Vs Ito, Ward-3(1), Bhubaneswar A-60, Palashpalli, Bhubaneswar-751020 Dist : Khurda, Odisha Pan No. : Anepj 7345 N (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Miss Sarmila Agarwal, Ca राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 02/02/2026 घोषणा की तारीख/Date Of Pronouncement : 02/02/2026

For Appellant: Miss Sarmila Agarwal, CAFor Respondent: Shri Vijay Singh, Sr. DR

Section 147Section 148

…of the reopening. It was submission that the addition has been made in respect of the source for the purchase of property. It was submission that the in view of the decision of the Hon’ble Supreme Court in the case of Jet Airways (I) Ltd., reported in (2011) 331 ITR 236 (Bom) and the decision of the Hon’ble Madras High Court in the case of Anand Cine Services (P) Ltd., reported in (2024) 8 NYPCTR 284 (Mad), wherein the Hon’ble Madras High Court has categorically held that section 147 of the Act enables the Assessing Officer to travel beyond the reasons for initiating reassessment proceedings provided such reasse…