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.

Lokesh Kumar Khabya, Surat vs. DCIT Central Circle 5(2), Mumbai

ITA 5100/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Nov 2025AY 2016-17

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 148Section 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER& MS. PADMAVATHY S, ACCOUNTANT MEMBER ITA Nos. 5100 to 5106/MUM/2025 (AY: 2016-17 & 2018-19 to 2023-24) (Physical hearing) Lokesh Kumar Khabya DCIT Central Circle – 5(2), Mumbai 2nd Floor, Office No. 212, New DTC, Vs Room No. 427, Kautilya Bhawan, Hath Falia, Haripura, Surat. BKC, Bandra East, Gujarat – 395003. Mumbai – 400051. [PAN: CVDPK2854E] Appellant / Assessee Respondent / Revenue ITA Nos. 5198 to 5201/MUM/2025 (AY: 2020-21 to 2023-24) Sourabh Sethi DCIT Central Circle – 5(2), Mumbai M-15, Flox Chambers, Opera H…

Atharv Star India Private Limited, Thane vs. DCIT Central Circle 5(2), Mumbai

ITA 4805/MUM/2025[2021-22]Status: DisposedITAT Mumbai19 Nov 2025AY 2021-22

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 148Section 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER& MS. PADMAVATHY S, ACCOUNTANT MEMBER ITA Nos. 5100 to 5106/MUM/2025 (AY: 2016-17 & 2018-19 to 2023-24) (Physical hearing) Lokesh Kumar Khabya DCIT Central Circle – 5(2), Mumbai 2nd Floor, Office No. 212, New DTC, Vs Room No. 427, Kautilya Bhawan, Hath Falia, Haripura, Surat. BKC, Bandra East, Gujarat – 395003. Mumbai – 400051. [PAN: CVDPK2854E] Appellant / Assessee Respondent / Revenue ITA Nos. 5198 to 5201/MUM/2025 (AY: 2020-21 to 2023-24) Sourabh Sethi DCIT Central Circle – 5(2), Mumbai M-15, Flox Chambers, Opera H…

Atharv Star India Private Limited, Thane vs. DCIT Central Circle 5(2), Mumbai

ITA 4791/MUM/2025[2022-23]Status: DisposedITAT Mumbai19 Nov 2025AY 2022-23

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 148Section 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER& MS. PADMAVATHY S, ACCOUNTANT MEMBER ITA Nos. 5100 to 5106/MUM/2025 (AY: 2016-17 & 2018-19 to 2023-24) (Physical hearing) Lokesh Kumar Khabya DCIT Central Circle – 5(2), Mumbai 2nd Floor, Office No. 212, New DTC, Vs Room No. 427, Kautilya Bhawan, Hath Falia, Haripura, Surat. BKC, Bandra East, Gujarat – 395003. Mumbai – 400051. [PAN: CVDPK2854E] Appellant / Assessee Respondent / Revenue ITA Nos. 5198 to 5201/MUM/2025 (AY: 2020-21 to 2023-24) Sourabh Sethi DCIT Central Circle – 5(2), Mumbai M-15, Flox Chambers, Opera H…

Atharv Star India Private Limited, Thane vs. DCIT Central Circle 5(2), Mumbai

ITA 4790/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Nov 2025AY 2020-21

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 148Section 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER& MS. PADMAVATHY S, ACCOUNTANT MEMBER ITA Nos. 5100 to 5106/MUM/2025 (AY: 2016-17 & 2018-19 to 2023-24) (Physical hearing) Lokesh Kumar Khabya DCIT Central Circle – 5(2), Mumbai 2nd Floor, Office No. 212, New DTC, Vs Room No. 427, Kautilya Bhawan, Hath Falia, Haripura, Surat. BKC, Bandra East, Gujarat – 395003. Mumbai – 400051. [PAN: CVDPK2854E] Appellant / Assessee Respondent / Revenue ITA Nos. 5198 to 5201/MUM/2025 (AY: 2020-21 to 2023-24) Sourabh Sethi DCIT Central Circle – 5(2), Mumbai M-15, Flox Chambers, Opera H…

Amit Kumar, Jaipur vs. ITO Ward 4(2), Jaipur

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

ITA 1087/JPR/2025[2018-19]Status: DisposedITAT Jaipur10 Nov 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. C. L. Yadav, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 144Section 144BSection 147Section 148ASection 2

…case has not done so, therefore, such addition being bad in Law has to be deleted and the entire 147 proceedings should be quashed. Reliance is also placed upon the decision of the Hon'ble Bombay High Court in the case of CIT vs. Jet Airways India Ltd. [2011] 331 ITR 236 (Bom.) and various other decisions. 9 Amit Kumar vs. ITO 3.6 Reliance is finally placed on the decision of Jurisdictional High Court of Rajasthan in Commissioner of Income Tax vs. Shri Ram Singh (2008) 306 ITR 343 (Raj) The Court observed as under:- ".... it is only when, in proceedings under Section 147 the Assessing Officer, assesses or reas…

Maya Kumari, Jaipur vs. ITO Ward 2(2), Jaipur

In the result, appeal of the assessee is allowed

ITA 581/JPR/2025[2012-13]Status: DisposedITAT Jaipur03 Nov 2025AY 2012-13
For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh choudhary, Addl. CIT
Section 147Section 148Section 234ASection 250Section 69

…ourse of proceedings of assessment or reassessment of escaped income, and which he intends to take into account, he would be required to issue a fresh notice under s.148.- CIT vs. Jet Airways (I) Ltd. (2011) 239 CTR (Bom) 183 : (2011) 52 DTR (Bom) 71 : (2011) 331 ITR 236 (Bom) concurred with. The very basis of initiation of proceedings for which reasons to believe were recorded were income escaping assessment in respect of items of club fees, gifts and presents, etc., but the same having not been done, the AO proceeded to reduce the claim of deduction under ss.80HH and 80-I which as per above discussion was not p…

Digambar Ramchandra Sawant Bhosle, Thane vs. Income Tax Officer 1 (1), Thane

In the result, the appeal is allowed for statistical

ITA 1772/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Oct 2025AY 2019-20

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Dharmesh Shah/Ms. Mitali Parekh, ARSFor Respondent: Shri Annavaran Kosuri, (Sr.DR)
Section 144BSection 147Section 68

…f the escaped income for any reason, he is not empowered to make addition in respect of any other income noticed in the course of assessment proceedings. Reliance has been placed the case of Hon'ble Bombay High Court in the case of CIT v. Jet Airways (I) Ltd .331 ITR 236. 3.2 It is also contended that the notice u/s.148 of the Act as well as order u/s.148A(d) of the Act were issued by the ITO, Ward 1(1), Thane and not by the Faceless authorities under the National Faceless Assessment Center. Thereafter, the proceedings were conducted and the order was passed by the assessment unit, National Faceless Assessment Ce…

ACIT, New Delhi vs. Vrinda Farms Private Limited, New Delhi

In the result, the appeal of the Revenue as well as cross objections of the assessee are dismissed

ITA 4849/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Acit, Central Circle 4, Vs. Vrinda Farms Private Limited, New Delhi. 43, Community Centre, Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) Co Nos.13 & 19/Del/2025 (In Ita No.4849/Del/2024) (Assessment Year: 2016-17) Vrinda Farms Private Limited, Vs. Acit, Central Circle 4, 43, Community Centre, New Delhi. Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) (Appellant) (Respondent) Assessee By : Shri Biren Shah, Ca Revenue By : Shri Dheeraj Kumar Jain, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Order : 29.10.2025 Order Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short]

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Section 132(4)Section 133(6)Section 68

…any other addition. For this, he placed reliance on the judgement of Hon’ble Jurisdictional High Court in the case of Ranbaxy Laboratories Ltd. vs CIT [2011] reported in 336 ITR 136 (Delhi) and in the case of CIT-II vs Jet Airways (I) Ltd. reported in [2011] 331 ITR 236 (Bom.). Ld. AR thus requested that the re-assessment order making additions of INR 100,11,32,484/- on the issues which are not the subject matter of reopening and without making additions on the issue for which reasons for reopening the 11 CO Nos.13 & 19/Del/2025 assessment were recorded, is without jurisdiction and, therefore, the reassessment o…

Ram Khilari Meena, Dausa vs. ITO, Dausa

In the result, the appeal of the assessee is allowed

ITA 1292/JPR/2025[2019-20]Status: DisposedITAT Jaipur28 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Mukesh Khandelwal, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 139Section 147Section 148Section 148ASection 44A

…008] 306 ITR 343 (Raj.) – Relevant Para no. 29 and 32 at page no. 8 of compilation. 2. Soyala Gram Sewa Sahakari Samiti Ltd. Tonk (Rajasthan) v/s ITO, Tonk (Jaipur ITAT) (ITA No. 1116/JP/2024 vide order dated 08.01.2025) 3. CIT vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom)(HC) – Relevant para no. 16 and 17 at page no. 17 of compilation. 4. Ranbaxy Laboratories Ltd. - vs. CIT (2011) 336 ITR 136 (Delhi High Court) - Relevant para no. 21 at page no. 28 of compilation. 5. ITO v Bidbhanjan Investment & Trading CO (P ) Ltd ( 2011) 59 DTR 345 ( Mum) (Trib) – Relevant para no. 17 at page no. 35 of compilation. 6. Dy.…

Katrathal Gram Sewa Sahkari Samiti Limited, Katrathal vs. ITO Ward 1 Sikar, Sikar

The appeal is dismissed

ITA 1001/JPR/2025[2019-20]Status: DisposedITAT Jaipur27 Oct 2025AY 2019-20
For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 139(1)Section 143(2)Section 144BSection 147Section 147rSection 148Section 148ASection 151Section 234ASection 250

…e of proceedings of assessment or reassessment of escaped income, and which he intends to take into account, he would be required to issue a fresh notice under s.148.— CIT vs. Jet Airways (I) Ltd. (2011) 239 CTR (Bom) 183 : (2011) 52 DTR (Bom) 71 : (2011) 331 ITR 236 (Bom) concurred with. The very basis of initiation of proceedings for which reasons to believe were recorded were income escaping assessment in respect of items of club fees, gifts and presents, etc., but the same having not been done, the AO proceeded to reduce the claim of deduction under ss.80HH and 80-I which as per above discussion was…

Surbhit Impex Private Limited, Mumbai vs. Principal Commissioner of Income Tax -8, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2570/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Oct 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Prabhash Shankar

For Appellant: Shri K. Shivaram Sr. Adv.& Shri Shashi Bekkal, ARFor Respondent: Shri Vivek Perampurna, (CIT-DR)
Section 147Section 263Section 41(1)

…No. 2570/Mum/2025 A.Y. 2018-19 Surbhit Impex Private Limited fresh notice has to be issued if, at all, some other issues need to be examined. Reliance is placed on the decision of hon'ble Bombay High Court o in the case of CIT v. Jet Airways India Ltd (2011) 331 ITR 236 (Bom)(HC) and PCIT v. Shark Mines and Minerals (P.) Ltd. [2023] 151 taxmann.com 71 (Orissa)(HC)wherein it was held that revision powers cannot be extended to additions that could not have been made by the AO. It is also submitted that a sum of Rs.33,00,000/- was paid back. Further, a sum of Rs.33,00,000/- was no longer outstanding as the sum had…

Sunita Saini, Haryana vs. Income Tax Officer, Ward 1(4), Faridabad, Haryana

In the result, appeal of the Assessee is allowed

ITA 1877/DEL/2024[2016-17]Status: DisposedITAT Delhi27 Oct 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.1877/Del/2024 िनधा"रणवष"/Assessment Year:2016-17 बनाम Sunita Saini, Income Tax Officer, House No.743P, Sector-38, Vs. Ward 1(4), Gurugram, Haryana. Faridabad. Pan No.Awmps2317Q अपीलाथ" Appellant ""यथ"/Respondent

Section 10(38)Section 147Section 151Section 263

…sment proceedings are required to be quashed in view of the decision of the jurisdictional High Court in the case of Ranbaxy Laboratories Ltd. vs. CIT (336 ITR 136), the decision of the Hon’ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd. (331 ITR 236). 3. The Ld. Counsel for the assessee further submitted that in spite of the assessee vide letter dated 17.07.2021 has requested the AO to provide copy of reasons recorded for reopening but the same was provided in a letter form which is placed at pages 24 to 26 of the Paper Book. Ld. Counsel submits that providing of reasons in letter form an…

ITO 13(2)(1), Mumbai vs. Sumangal Commodities Pvt. Ltd, Mumbai

ITA 1302/MUM/2025[2011]Status: DisposedITAT Mumbai16 Oct 2025

Bench: Justice (Retd.) C.V. Bhadang & Shri Prabhash Shankar: A.Y. : 2010-11

For Appellant: Shri Swapnil ChoudharyFor Respondent: Shri Rahul Hakani
Section 132(4)Section 148Section 68

…n of Rs.1,30,90,000/- as unexplained cash credit. 5. In appeal, the learned CIT(A) has deleted the same. The learned CIT(A) has, inter alia, placed reliance on the decision of Bombay High Court in Commissioner of Income Tax-5, Mumbai vs Jet Airways (I) Ltd., 331 ITR 236 (Bombay) and the decision of this Tribunal in Torm Shipping India (P.) Ltd. vs Income Tax Officer, Mumbai (ITA Nos. 1272 & 1273/Mum/2013 dated 3 Sumangal Commodities Pvt. Ltd. 14.10.2016). The learned CIT(A) has held that the AO has failed to establish the live link between the information and the alleged escapement of income and that the impugn…

Iscon Copper Private Limitted, Surat vs. ITO, Ward-1(1)(3), Surat

In the result, the appeal filed by the assessee stands allowed

ITA 885/SRT/2025[2011-12]Status: HeardITAT Surat09 Oct 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 147Section 147(1)Section 250Section 68

…1 IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, SURAT BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER I.T.A. No. 885/SRT/2025 Assessment Year: 2011-12 Iscon Copper Pvt Ltd Vs ITO, Ward – 1(1)(3) U-27, Bhagwati Ashish 4th Floor, Aayakar Complex, Nr. Raghuveer Bhavan, Majura Gate, bunglow, City Light, Surat. Surat - 395007 PAN – AACCI3933M (Appellant) (Respondent) Assessee by Shri PM Jagasheth, CA Revenue by J.K. Chandnani, Sr. DR Date of Hearing 06.10.2025 Date of Pronouncement 09.10.2025 ORDER Per: SHRI. SANDEEP GOSAIN, J.M.: The present appeal has been filed by the ass…

Nitaben Girishbhai Patel, Ahmedabad vs. The ITO, Ward-3(3)(2), Ahmedabad

In the result, while upholding the validity of reopening, we set aside the ex parte order of the CIT(A) on merits and restore the matter to his file for fresh adjudication in accordance with law

ITA 1560/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad09 Oct 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Nitaben Girishbhai Patel The Ito, Ward-3(3)(2) 33/B, Swi Park, Private Plot Vejalpur Madhuvrund Society Ahmedabad. Ghatlodiya, Ahmedabad. Pan : Aappp 5738 F (Applicant) (Responent) : Shri Parimalsinh B. Parmar, Ar Assessee By : Shri B.P. Srivastava, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 06/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 09/10/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri B.P. Srivastava, Sr.DR
Section 144BSection 147Section 148Section 271ASection 69A

…addition ultimately made has no nexus with the reasons recorded, rendering the reassessment proceedings bad in law. Reliance was placed on various judicial pronouncements including the decision of the Hon’ble Bombay High Court in CIT v. Jet Airways (I) Ltd. (331 ITR 236) and the Hon’ble Gujarat High Court in CIT v. Mohmed Juned Dadani (355 ITR 172) to contend that when the Assessing Officer does not ultimately make any addition on the very ground which formed the basis of the reasons recorded for reopening, he cannot proceed to make additions on some other issues which did not form part of such recorded reasons.…

Pitti Holdings Private Limited, Hyderabad vs. ACIT., Central Circle-1(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 450/HYD/2025[2018-19]Status: DisposedITAT Hyderabad08 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

For Appellant: Shri A. Srinivas, C.AFor Respondent: Dr. Sachin Kumar, DR
Section 148Section 148A

…ade by the Assessing Officer by making the disallowances of expenditure are not sustainable in law and liable to be deleted. In support of his contention, he has relied upon the judgment of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways (I) Ltd. 331 ITR 236 (Bom). 7. On the other hand, the Ld. DR has submitted that the Assessing Officer has followed the procedure as prescribed u/s.148 and 148A of the Act. The Assessing Officer has 21 ITA.No.450/Hyd./2025 reproduced the details as received from the Investigation Wing as detected in search operation u/s.132 of the Act conducted in the case of M/s. Va…

Whole Sale Cloth Merchant Association, Kota vs. Deputy Commissioner of Income Tax Central Circle Kota, Kota

ITA 962/JPR/2024[2015-2016]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-2016
For Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 11Section 11(2)Section 143(3)Section 147Section 40

…to the notice of the Assessing Officer subsequently during the course of proceedings under section 147, even though reason for notice for 'such income' which may have escaped assessment, may not survive. 34. In the case of CIT v. Jet Airways (1) Ltd. [2011] 331 ITR 236/(2010) 195 Taxman 117 the Bombay High Court has held that "Explanation 3 does not and cannot override the necessity of fulfilling the conditions set out in the substantive part of section 147 An Explanation to a statutory provision is intended to explain its contents and cannot be construed to override or render the substance or core nugatory, Se…

Whole Sale Cloth Merchant Association, Kota vs. Deputy Commissioner of Income Tax Central Circle Kota, Kota

In the result, the appeal of the assessee is allowed in ITA No

ITA 961/JPR/2024[2014-2015]Status: DisposedITAT Jaipur24 Sept 2025AY 2014-2015
For Appellant: Shri Siddharth Ranka, Adv
Section 11Section 11(2)Section 143(3)Section 147Section 40

…to the notice of the Assessing Officer subsequently during the course of proceedings under section 147, even though reason for notice for 'such income' which may have escaped assessment, may not survive. 34. In the case of CIT v. Jet Airways (1) Ltd. [2011] 331 ITR 236/(2010) 195 Taxman 117 the Bombay High Court has held that "Explanation 3 does not and cannot override the necessity of fulfilling the conditions set out in the substantive part of section 147 An Explanation to a statutory provision is intended to explain its contents and cannot be construed to override or render the substance or core nugatory, Se…

DCIT., Circle-1(1), Hyderabad vs. B T T Industries Private Limited, Hyderabad

In the result, appeal ITA

ITA 513/HYD/2025[2017-18]Status: DisposedITAT Hyderabad24 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA Ch. Satya DinakarFor Respondent: MS U Mini Chandran, CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 14A

…lenged the validity of additions made by the Assessing Officer towards 6 ITA.Nos.511, 512 & 513/Hyd./2025 disallowance of loss in light of certain judicial precedents including decision of Hon’ble Bombay High Court in the case of Jet Airways (I) Ltd., [2011] 331 ITR 236 (Bom.) and argued that, addition made on an issue other than the one on which reopening was done would be invalid when no addition is made on the issues mentioned in the reasons recorded. The learned CIT(A) after considering the relevant submissions of the assessee and also the decision of Hon’ble Bombay High Court in the case of Jet Airways (I)…

DCIT., Circle-1(1), Hyderabad vs. B T T Industries Private Limited, Hyderabad

In the result, appeal ITA

ITA 512/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Sept 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA Ch. Satya DinakarFor Respondent: MS U Mini Chandran, CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 14A

…lenged the validity of additions made by the Assessing Officer towards 6 ITA.Nos.511, 512 & 513/Hyd./2025 disallowance of loss in light of certain judicial precedents including decision of Hon’ble Bombay High Court in the case of Jet Airways (I) Ltd., [2011] 331 ITR 236 (Bom.) and argued that, addition made on an issue other than the one on which reopening was done would be invalid when no addition is made on the issues mentioned in the reasons recorded. The learned CIT(A) after considering the relevant submissions of the assessee and also the decision of Hon’ble Bombay High Court in the case of Jet Airways (I)…