CIT v. Jet Airways (I) Ltd.

331 ITR 236High Court2011#78 most cited

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.

694

judgments rely on this decision, according to BharatTax’s citation analysis of 383,853 Indian tax judgments — from 2012 to 2026.

Also referred to as

Jet Airways · Section 147 · Section 148 · reassessment jurisdiction · income escaping assessment · reason to believe · Explanation 3 · scope of reassessment · additions beyond initial reasons · invalid reassessment · 331 ITR 236

Also reported as

30 Taxmann.com 1239 CTR 183

Sections most often in play

Section 147Section 148Section 143(3)Section 144BSection 234BSection 151Section 271(1)(c)Section 145(3)

Issues it is cited on

section 2(40)section 148(2)reason to believeincome escaping assessmentescapement of incomelive linktangible materialrejection of books of accountreopening of assessmentinterest under section 234bsection 254(1)change of opinion

Judgments citing CIT v. Jet Airways (I) Ltd.

Kalpana Nitin Shah, Mumbai vs. Income Tax Officer 19(2)(2), Mumbai

ITA 7012/MUM/2025[2011-12]Status: DisposedITAT Mumbai09 Jan 2026AY 2011-12

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Harshad M. Karnik, Sr. DR
Section 143(3)Section 148Section 151Section 194Section 271(1)(c)

…basis for reopening assessment. Whereas the addition was made only on account of interest income reflecting in 26AS, without any addition on main issue of capital gain, the matter is covered by the decision of Hon’ble Mumbai High Court in case of Jet Airways, 331 ITR 236 (Bom.), according to which “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 course of the proceedings. Howev…

Devi Manubhai Shah, Mumbai vs. ITO - Circle 32(1), Mumbai

ITA 7005/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Jan 2026AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Piyush ChhajedFor Respondent: Shri Annavaran Kosuri
Section 143(1)Section 143(3)Section 147Section 54F

…ote that the Assessee had challenged the validity of the reassessment proceedings before the Learned CIT(A) and had placed reliance upon the judgment of the Hon’ble Bombay High Court in the case of Commissioner of Income-tax-5, Mumbai vs. Jet Airways (I) Ltd. 331 ITR 236 (Bombay)/[2011]. The Learned CIT(A) rejected ground number 4 raised by the Assessee challenging the validity of the reassessment proceedings observing as under: “Ground 4: Jurisdiction for Addition The Appellant argues that the addition of Rs. 83,43,016 by denying section 54F exemption is beyond the Assessing Officer‟s jurisdiction, as it was no…

Chintan Harshad Kanakia, Mumbai vs. ITO Ward 42(1)(1), Mumbai

In the result, ground No.3 of appeal is allowed

ITA 2822/MUM/2025[2015-16]Status: DisposedITAT Mumbai01 Jan 2026AY 2015-16

Bench: Shri Pawan Singhsmt Renu Jauhriassessment Year: 2015-16 (Hybrid Hearing) Chintan Harshad Kanakia, Ito Ward 42 (1)(1) Room No. 103, Sacovar Apt., Sagar Complex, 703, Kautilya Bhavan, Vs. Saibaba Nagar, Borivali (W), Bkc, Mumbai -400051 Mumbai Pan – Agnpk6023E

Section 10(38)Section 132Section 143(2)Section 148Section 148ASection 151ASection 234BSection 254(1)Section 271(1)(c)

…e information received, which was basis of reasons recorded. Thus, assessment order completed on different issue is bad in law as has been held in a series of decision including by decision of jurisdictional High Court in Jet Airways (I) Ltd. Vs. CIT (2011) 331 ITR 236 (Bomb.) wherein it was held that if after issuing notice under Section 148, the AO does not assess or re-assess such income for which he had formed reason to believe that it had ITA No. 2822 /Mum/2025 (AY 2015-16) Chintan Harshad Kanakia escaped assessment, it is not open to him to independently assess or re- assess any other income which came…

Mukesh Gupta, Kamala Nagar vs. Dlc-CC-(1)(13), Delhi

ITA 7427/DEL/2025[2023-24]Status: DisposedITAT Delhi23 Dec 2025AY 2023-24

Bench: Sh. Satbeer Singh Godaraita No. 7396/Del/2025 : Asstt. Year: 2020-21 Ita No. 7426/Del/2025 : Asstt. Year: 2021-22 Ita No. 7427/Del/2025 : Asstt. Year: 2023-24 Mukesh Gupta, Vs Acit, D-89, 3Rd Floor, Kamla Nagar, Central Circle-3, Jawahar Nagar, North Delhi, New Delhi-110055 New Delhi-110007 (Appellant) (Respondent) Pan No. Akopg1709J Assessee By: Sh. Govind Kumar, Ca Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order These Assessee’S Three Appeals Ita Nos. 7396, 7426 & 7427/Del/2025, For Assessment Years 2020-21, 2021-22 & 2023-24, Arise Against The Cit(A)-23, Delhi’S Din & Order Nos. Itba/Apl/S/250/2025-26/1081204873(1), 1081205368(1) & 1081205086(1) All Dated 26.09.2025, In Proceedings U/S 147/143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Govind Kumar, CAFor Respondent: Sh. Amit Shukla, Sr. DR
Section 147Section 148

…y addition qua the above sole reason of reopening involving the assessee’s sale consideration. 4. That 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. These assessee’s three appeals ITA Nos. 7396, 7426 & 7427/Del/2025 are allowed. A copy of this common order be placed in the respective case files. Order Pronounced in the Open Court on 23/12/2025. (Satbeer Singh Godara) Judicial Member Dated: 23/12/2025 *Subo…

Mukesh Gupta, Kamala Nagar vs. Dlc-CC-(1)(13), Delhi

ITA 7426/DEL/2025[2021-22]Status: DisposedITAT Delhi23 Dec 2025AY 2021-22

Bench: Sh. Satbeer Singh Godaraita No. 7396/Del/2025 : Asstt. Year: 2020-21 Ita No. 7426/Del/2025 : Asstt. Year: 2021-22 Ita No. 7427/Del/2025 : Asstt. Year: 2023-24 Mukesh Gupta, Vs Acit, D-89, 3Rd Floor, Kamla Nagar, Central Circle-3, Jawahar Nagar, North Delhi, New Delhi-110055 New Delhi-110007 (Appellant) (Respondent) Pan No. Akopg1709J Assessee By: Sh. Govind Kumar, Ca Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order These Assessee’S Three Appeals Ita Nos. 7396, 7426 & 7427/Del/2025, For Assessment Years 2020-21, 2021-22 & 2023-24, Arise Against The Cit(A)-23, Delhi’S Din & Order Nos. Itba/Apl/S/250/2025-26/1081204873(1), 1081205368(1) & 1081205086(1) All Dated 26.09.2025, In Proceedings U/S 147/143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Govind Kumar, CAFor Respondent: Sh. Amit Shukla, Sr. DR
Section 147Section 148

…y addition qua the above sole reason of reopening involving the assessee’s sale consideration. 4. That 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. These assessee’s three appeals ITA Nos. 7396, 7426 & 7427/Del/2025 are allowed. A copy of this common order be placed in the respective case files. Order Pronounced in the Open Court on 23/12/2025. (Satbeer Singh Godara) Judicial Member Dated: 23/12/2025 *Subo…

Mukesh Gupta, Kamla Nagar vs. AO, Central Circle

ITA 7396/DEL/2025[2020-21]Status: DisposedITAT Delhi23 Dec 2025AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 7396/Del/2025 : Asstt. Year: 2020-21 Ita No. 7426/Del/2025 : Asstt. Year: 2021-22 Ita No. 7427/Del/2025 : Asstt. Year: 2023-24 Mukesh Gupta, Vs Acit, D-89, 3Rd Floor, Kamla Nagar, Central Circle-3, Jawahar Nagar, North Delhi, New Delhi-110055 New Delhi-110007 (Appellant) (Respondent) Pan No. Akopg1709J Assessee By: Sh. Govind Kumar, Ca Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order These Assessee’S Three Appeals Ita Nos. 7396, 7426 & 7427/Del/2025, For Assessment Years 2020-21, 2021-22 & 2023-24, Arise Against The Cit(A)-23, Delhi’S Din & Order Nos. Itba/Apl/S/250/2025-26/1081204873(1), 1081205368(1) & 1081205086(1) All Dated 26.09.2025, In Proceedings U/S 147/143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Govind Kumar, CAFor Respondent: Sh. Amit Shukla, Sr. DR
Section 147Section 148

…y addition qua the above sole reason of reopening involving the assessee’s sale consideration. 4. That 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. These assessee’s three appeals ITA Nos. 7396, 7426 & 7427/Del/2025 are allowed. A copy of this common order be placed in the respective case files. Order Pronounced in the Open Court on 23/12/2025. (Satbeer Singh Godara) Judicial Member Dated: 23/12/2025 *Subo…

Indu Gupta, Delhi vs. ITO Ward 58(1), Delhi

Appeal is allowed

ITA 6875/DEL/2025[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Sh. Satbeer Singh Godaraita No. 6875/Del/2025 : Asstt. Year: 2015-16 Indu Gupta, Vs Income Tax Officer, Sinha & Sinha Law Chambers Llp Ward-58(1), 108-109, Parmesh Business Centre-1, New Delhi-110002 Plot No. 20, Community Centre, Karkardooma, Delhi-110092 (Appellant) (Respondent) Pan No. Aespg0965Q Assessee By: Sh. Prince Mohan Sinha, Adv. & Sh. Aniket Krishnatray, Adv. Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order This Assessee’S Appeal For Assessment Year 2015-16 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1076388993(1) Dated 22.05.2025, In Proceedings U/S 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Prince Mohan Sinha, Adv. &For Respondent: Sh. Amit Shukla, Sr. DR
Section 144Section 148

…addition qua the above sole reason of reopening involving other assessee’s sale consideration. 4. That 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 23/12/2025. (Satbeer Singh Godara) Judicial Member Dated: 23/12/2025 *Subodh Kumar, Sr. PS*…

Rajarshi Shahu Shikshan Sanstha Inam Dhamani, Sangli vs. ITO Exemption, Kolhapur

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

ITA 1126/PUN/2024[2017-18]Status: DisposedITAT Pune18 Dec 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

…over, and left at that at the point of framing the 147 order. On the contrary, a complete different taxation scheme is triggered. Such a process has been disapproved by the Honourable Bombay High Court vide decision in case of CIT v. Jet Airways (I) Pvt Ltd -331 ITR 236. Copy of the said decision is enclosed herewith and marked as Annexure-3. Courts have been disapproving attempts of I-T authorities to assessee/reassessee, (say), to change stand taken at the stage of 148 notice, and stand taken by AO at 147 order stage. Reliance is placed on the following decisions - a) Lark Chemicals P. Ltd. Vs ACIT 99 taxmann…

Rajarshi Shahu Shikshan Sanstha Inam Dhamani, Sangli vs. ITO Exemption, Kolhapur

In the result, all the appeals filed by the assessee are

ITA 1125/PUN/2024[2016-17]Status: DisposedITAT Pune18 Dec 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024

Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

…over, and left at that at the point of framing the 147 order. On the contrary, a complete different taxation scheme is triggered. Such a process has been disapproved by the Honourable Bombay High Court vide decision in case of CIT v. Jet Airways (I) Pvt Ltd -331 ITR 236. Copy of the said decision is enclosed herewith and marked as Annexure-3. Courts have been authorities I-T to disapproving attempts of assessee/reassessee, (say), to change stand taken at the stage of 148 notice, and stand taken by AO at 147 order stage. Reliance is placed on the following decisions - a) Lark Chemicals P. Ltd. Vs ACIT 99 taxmann.…

Rajarshi Shahu Shikshan Sanstha Inam Dhamani, Sangli vs. ITO Exemption, Kolhapur

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

ITA 1124/PUN/2024[2015-16]Status: DisposedITAT Pune18 Dec 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

…over, and left at that at the point of framing the 147 order. On the contrary, a complete different taxation scheme is triggered. Such a process has been disapproved by the Honourable Bombay High Court vide decision in case of CIT v. Jet Airways (I) Pvt Ltd -331 ITR 236. Copy of the said decision is enclosed herewith and marked as Annexure-3. Courts have been disapproving attempts of I-T authorities to assessee/reassessee, (say), to change stand taken at the stage of 148 notice, and stand taken by AO at 147 order stage. Reliance is placed on the following decisions - a) Lark Chemicals P. Ltd. Vs ACIT 99 taxmann…

Rajarshi Shahu Shikshan Sanstha Inam Dhamani, Sangli vs. ITO Exemption, Kolhapur

In the result, all the appeals filed by the assessee are

ITA 1123/PUN/2024[2014-15]Status: DisposedITAT Pune18 Dec 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024

Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

…over, and left at that at the point of framing the 147 order. On the contrary, a complete different taxation scheme is triggered. Such a process has been disapproved by the Honourable Bombay High Court vide decision in case of CIT v. Jet Airways (I) Pvt Ltd -331 ITR 236. Copy of the said decision is enclosed herewith and marked as Annexure-3. Courts have been authorities I-T to disapproving attempts of assessee/reassessee, (say), to change stand taken at the stage of 148 notice, and stand taken by AO at 147 order stage. Reliance is placed on the following decisions - a) Lark Chemicals P. Ltd. Vs ACIT 99 taxmann.…

Rajarshi Shahu Shikshan Sanstha Inam Dhamani, Sangli vs. ITO Exemption, Kolhapur

In the result, all the appeals filed by the assessee are

ITA 1122/PUN/2024[2013-14]Status: DisposedITAT Pune18 Dec 2025AY 2013-14

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024

Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

…over, and left at that at the point of framing the 147 order. On the contrary, a complete different taxation scheme is triggered. Such a process has been disapproved by the Honourable Bombay High Court vide decision in case of CIT v. Jet Airways (I) Pvt Ltd -331 ITR 236. Copy of the said decision is enclosed herewith and marked as Annexure-3. Courts have been I-T to authorities disapproving attempts of assessee/reassessee, (say), to change stand taken at the stage of 148 notice, and stand taken by AO at 147 order stage. Reliance is placed on the following decisions - a) Lark Chemicals P. Ltd. Vs ACIT 99 taxmann.…

Rajarshi Shahu Shikshan Sanstha Inam Dhamani, Sangli vs. ITO Exemption, Kolhapur

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

ITA 1121/PUN/2024[2012-13]Status: DisposedITAT Pune18 Dec 2025AY 2012-13

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

…over, and left at that at the point of framing the 147 order. On the contrary, a complete different taxation scheme is triggered. Such a process has been disapproved by the Honourable Bombay High Court vide decision in case of CIT v. Jet Airways (I) Pvt Ltd -331 ITR 236. Copy of the said decision is enclosed herewith and marked as Annexure-3. Courts have been disapproving attempts of I-T authorities to assessee/reassessee, (say), to change stand taken at the stage of 148 notice, and stand taken by AO at 147 order stage. Reliance is placed on the following decisions - a) Lark Chemicals P. Ltd. Vs ACIT 99 taxmann…

Gian Gupta, New Delhi vs. ACIT, Circle- 33(1), New Delhi

In the result, this appeal is allowed

ITA 1307/DEL/2024[2011-12]Status: DisposedITAT Delhi17 Dec 2025AY 2011-12

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.1307/Del/2024 िनधा"रणवष"/Assessment Year: 2011-12 बनाम Gian Gupta, Acit, Kh. No. 389/2/2-415, Vs. Circle 33(1), Civic Centre, Ford Service Centre, Nh-8, Rangpuri, Minto Road, New Delhi. New Delhi. Pan No.Aaapg7797G अपीलाथ" Appellant ""यथ"/Respondent

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

…India Ltd., reported in 320 ITR 561 (SC); and iii. The Ld. AO had travelled far beyond the scope of reasons recorded prior to issue of notice u/s 148 of the Act and in so doing he had violated the principles laid down in the case of Jet Airways reported in 331 ITR 236 (Bom.), Oriental Bank of commerce reported in 272 CTR 56 (Del), and the case of Ranbaxy Laboratories reported in 336 ITR 136 (Del). 5 2.1 Per contra, the Ld. DR relied on the orders of the authorities below. 3. We have carefully considered the rival submissions and have gone through the records before us. Right at the outset, it deserves to…

Gujarat Vaibhav Publications Pvt. Ltd., Ahmedabad vs. The ITO, Ward-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 1359/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)Section 37

…n can be made on other issues in absence of addition for the issues based on which the case was reopened. In this regard, he placed reliance on the following decisions:- a) CIT vs. Mohmed Juned Dadani – [2014] 355 ITR 172 (Guj) b) CIT vs Jet Airways – [2011] 331 ITR 236 (Bombay) c) Ranbaxy Laboratories Ltd. – [2011] 336 ITR 136 (Delhi) 8. The Ld. Sr. Counsel submitted that no addition was made in respect of bogus purchase of Rs.2,00,000/- from M/s. A.M. Enterprise as recorded in the reason and, therefore, the Assessing Officer was not correct in making addition in respect of purchases made from M/s. Vandana Raj…

Gujarat Vaibhav Publications Pvt. Ltd., Ahmedabad vs. The ITO, Ward-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 1358/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)Section 37

…n can be made on other issues in absence of addition for the issues based on which the case was reopened. In this regard, he placed reliance on the following decisions:- a) CIT vs. Mohmed Juned Dadani – [2014] 355 ITR 172 (Guj) b) CIT vs Jet Airways – [2011] 331 ITR 236 (Bombay) c) Ranbaxy Laboratories Ltd. – [2011] 336 ITR 136 (Delhi) 8. The Ld. Sr. Counsel submitted that no addition was made in respect of bogus purchase of Rs.2,00,000/- from M/s. A.M. Enterprise as recorded in the reason and, therefore, the Assessing Officer was not correct in making addition in respect of purchases made from M/s. Vandana Raj…

Omprakash, Bulandshahr vs. ITO, Bulandshahr

Appeal is allowed

ITA 3933/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Sh. Om Prakash, Vs. Income Tax Officer, S/O- Lallu Singh, Purana Bulandshahr, Chattha Patti Harnam Uttar Pradesh Singh Near Sattar Sunar Siyana, Bulandshahr, Uttar Pradesh Pan: Aaspo6327Q (Appellant) (Respondent) Assessee By None Department By Sh. Rajesh Tiwari, Sr. Dr

Section 147Section 148Section 40A(3)

…penditure payment disallowance of Rs.73,10,000/- which has been upheld in the lower appellate discussion. 3. That being the clinching factual position, we hereby quote Ranbaxy Laboratory Vs. CIT (2011) 335 ITR 136 (Del) and CIT Vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom.) holding that such a reopening wherein the learned Assessing Officer does not make any addition qua the sole reason therein; is not sustainable in law. The same stands quashed in very terms therefore. 2 | P a g e All other pleadings between the parties on merits stands rendered academic. 4. This assessee’s appeal is allowed. Order pronounc…

K.G.N.Enterprise, Veraval vs. Income Tax Officer, Veraval

In the result, appeal filed by the assessee is allowed

ITA 181/RJT/2025[2019-20]Status: DisposedITAT Rajkot09 Dec 2025AY 2019-20

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.181/Rjt/2025 िनधा"रण वष"/Assessment Year : 2019-20 K.G.N. Enterprise बनाम/ Income Tax Officer Al Iraki Bageraza Lucky Colony, Vs Ward – 4, Range 201, Junagarh, Ner Somnathtokish, Behind Amit Veraval Akela Clinic, Veraval, Gir Somnath, Gujarat - 362264 "ायीलेखासं./जीआइआरसं./Pan/Gir No.:Aatfk8798E (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri R. B. Shah, Ld. Ar राज"की ओर से / Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख /Date Of Hearing : 15/09/2025 घोषणा की तारीख /Date Of Pronouncement : 09/12/2025 आदेश/Order

For Appellant: Shri R. B. Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 139(1)Section 147Section 250

…ITA No. 181/Rjt/2025 K.G.N. Enterprise vs. ITO आयकरअपीलीयअिधकरण,राजकोट"ायपीठ,राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, “SMC” RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER आयकरअपील सं. /ITA No.181/RJT/2025 िनधा"रण वष"/Assessment Year : 2019-20 K.G.N. Enterprise बनाम/ Income Tax Officer Al Iraki Bageraza Lucky Colony, Vs Ward – 4, Range 201, Junagarh, Ner Somnathtokish, Behind Amit Veraval Akela Clinic, Veraval, Gir Somnath, Gujarat - 362264 "ायीलेखासं./जीआइआरसं./PAN/GIR No.:AATFK8798E (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee by : Shri R. B. Shah, Ld. AR राज"की ओर से…

Aqua Tech Solutions Private Limited, Pune vs. PCIT (Central)-3, Mumbai

In the result, the appeal of the assessee is allowed

ITA 3855/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Dec 2025AY 2018-19

Bench: Shri Saktijit Dey & Ms Padmavathy S, Acccountant Member

For Appellant: Ms. Simran Dhawan &For Respondent: Shri. Rajesh Kumar Yadav, CIT. DR
Section 143(3)Section 263Section 263(1)Section 801A(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, ACCCOUNTANT MEMBER I.T.A. No. 3855/Mum/2025 (Assessment Year: 2018-19) Aqua Tech Solutions Private PCIT (Central)-3, Mumbai 441, 4th Floor, Kautilya Bhavan, Limited Vinayak Shramik Co-op. Society, C-41 to C-43, G Block, Bandra Vs. Sr. No. 128/1B Paud Road, Kurla Complex, Bandra (East), Kothrud, Pune Mumbai- Mumbai- 400051 PAN: AAGCA3182L Appellant) : Respondent) Assessee by : Ms. Simran Dhawan & Shri. Ravi Ganatra Revenue by : Shri. Rajesh Kumar Yadav, CIT. DR Date of Hearing : 19.11.2025 Date of Pr…

Principal Commissioner of Income Tax 2 Kolkata vs. M/S Royal Touch Fablon Private Limited

The appeal is dismissed

ITAT/132/2025HC Calcutta03 Dec 2025

Bench: HON'BLE JUSTICE RAJARSHI BHARADWAJ,HON'BLE JUSTICE UDAY KUMAR

Section 143(2)Section 147Section 148Section 68

…decision of Hon'ble jurisdictional High Court in the case of M/s. Infinity Infotech Parks Ltd., wherein the Hon'ble Calcutta High Court has held by following the decision of Hon'ble Bombay High Court in the case of 5 CIT Vs. Jet Airways (I) Ltd. [2011] 331 ITR 236 and also Hon’ble Delhi High Court decision in the case of Ranbaxy Laboratories Vs. CIT 336 ITR 136 (Del.) that where the income the escapement of which was the foundation for recording of reasons to believe, is not assessed or reassessed in the order u/s. 147, then it is not mere opened to the AO to independently assess any other income, whi…