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.

Income Tax Officer - Ward-12(2)(1), Mumbai vs. Devraj Multitrade Private Limited, Mumbai

In the result, the appeals of the revenue are dismissed for AYs 2014-15,

ITA 3512/MUM/2023[2014-15]Status: DisposedITAT Mumbai27 Jun 2025AY 2014-15

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3513/Mum/2023 (नििाारण वर्ा / Assessment Year :2013-14) आयकर अपील सुं./Ita No. 3512/Mum/2023 (नििाारण वर्ा / Assessment Year :2014-15) आयकर अपील सुं./Ita No. 3511/Mum/2023 (नििाारण वर्ा / Assessment Year :2015-16) आयकर अपील सुं./Ita No. 3550/Mum/2023 (नििाारण वर्ा / Assessment Year :2016-17)

For Appellant: Shri Ketan VajaniFor Respondent: Smt. Sanyogita Nagpal
Section 144Section 250Section 68

…funds. However, AO is not justified in making the addition on separate issue when there is no addition made on the core issue on which case was reopened. Reliance is placed on the decision of the Hon'ble Bombay High Court, in the case of Jet Airways (1) Ltd, 331 ITR 236 wherein is has been held "Whether, however, if after issuing a notice under section 148, he accepts contention of assessee and holds that income, for which he had initially formed a reason to believe that it had escaped assessment, has, as a matter of fact, not escaped assessment, it is not open to him to independently assess some other income; i…

Income Tax Officer Ward-12(2)(1), Mumbai vs. Devraj Multitrade Private Limited, Mumbai

In the result, the appeals of the revenue are dismissed for AYs 2014-15,

ITA 3511/MUM/2023[2015-16]Status: DisposedITAT Mumbai27 Jun 2025AY 2015-16

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3513/Mum/2023 (नििाारण वर्ा / Assessment Year :2013-14) आयकर अपील सुं./Ita No. 3512/Mum/2023 (नििाारण वर्ा / Assessment Year :2014-15) आयकर अपील सुं./Ita No. 3511/Mum/2023 (नििाारण वर्ा / Assessment Year :2015-16) आयकर अपील सुं./Ita No. 3550/Mum/2023 (नििाारण वर्ा / Assessment Year :2016-17)

For Appellant: Shri Ketan VajaniFor Respondent: Smt. Sanyogita Nagpal
Section 144Section 250Section 68

…funds. However, AO is not justified in making the addition on separate issue when there is no addition made on the core issue on which case was reopened. Reliance is placed on the decision of the Hon'ble Bombay High Court, in the case of Jet Airways (1) Ltd, 331 ITR 236 wherein is has been held "Whether, however, if after issuing a notice under section 148, he accepts contention of assessee and holds that income, for which he had initially formed a reason to believe that it had escaped assessment, has, as a matter of fact, not escaped assessment, it is not open to him to independently assess some other income; i…

Neelam Janardhan Rachalwar, Chimur vs. ITO Ward-2, Chandrapur

In the result, Assessee’s appeal is allowed

ITA 276/NAG/2025[2016-2017]Status: DisposedITAT Nagpur25 Jun 2025AY 2016-2017

Bench: Shri Narender Kumar Choudhryneelam Janardhan Ito, Ward-2, Chandrapur Rachalwar, Sai Mandir Road, Tilak Ward, Chimur, Vs. Chandrapur, Maharashtra Pan: Adqpr 7539 E (Appellant) (Respondent)

For Appellant: Ms. Shikha Loya, Ld. CAFor Respondent: Shri Surjit Kumar Saha, Ld. Sr. D.R
Section 147Section 148Section 250Section 269SSection 271D

…hich ultimately resulted into making the addition under consideration, and therefore addition under consideration is liable to be deleted, specifically in view of judgment of Hon'ble Jurisdictional High Court in the case of CIT vs. Jet Airways (I) Ltd. [2011] 331 ITR 236 (Bom.) wherein the identical issue has been dealt with, by observing and holding as under: - “11. The rival submissions which have been urged on behalf of the revenue and the assessee can be dealt with, both as a matter of first principle, interpreting the section as it stands and on the basis of precedents on the subject. Interpreting the provi…

Narendra Prasad Rai, Delhi vs. The Income Tax Officer, Delhi

Appeal is allowed

ITA 1692/DEL/2025[2012-2013]Status: DisposedITAT Delhi25 Jun 2025AY 2012-2013

Bench: Sh. Satbeer Singh Godaraita No. 1692/Del/2025 : Asstt. Year : 2012-13 Narendra Prasad Rai, Vs Income Tax Officer, C-36/X-3, Dilshad Garden, Ward-70(5), New Delhi-110095 New Delhi-110002 (Appellant) (Respondent) Pan No. Acfpr9031H Assessee By: None Revenue By : Ms. Indu Bala Saini, Sr. Dr Date Of Hearing: 25.06.2025 Date Of Pronouncement: 25.06.2025 Order This Assessee’S Appeal For Assessment Year 2012-13, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1072338735(1) Dated 20.01.2025, In Proceedings U/S 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Ms. Indu Bala Saini, Sr. DR
Section 143(3)Section 148

…rned assessing authority has nowhere made any addition qua the above sole reason of reopening. 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 25/06/2025. (Satbeer Singh Godara) Judicial Member Dated: 25/06/2025 *Subodh Kumar, Sr. PS*…

Vikram Sharma, New Delhi vs. ITO Ward-28(5), Delhi

Appeal is allowed

ITA 1641/DEL/2025[2010-11]Status: DisposedITAT Delhi25 Jun 2025AY 2010-11

Bench: Sh. Satbeer Singh Godaraita No. 1641/Del/2025 : Asstt. Year : 2010-11 Vikram Sharma, Vs Income Tax Officer, D-29, Pocket-D, Sarita Vihar, Ward-28(5), Delhi-110076 New Delhi-110001 (Appellant) (Respondent) Pan No. Bgnps0126B Assessee By: Sh. R. K. Raman, Ca Revenue By : Ms. Indu Bala Saini, Sr. Dr Date Of Hearing: 25.06.2025 Date Of Pronouncement: 25.06.2025 Order This Assessee’S Appeal For Assessment Year 2010-11, Arises Against The Addl./Jcit(A)-1, Vadodara’S Din & Order No. Itba/Apl/S/250/2024-25/1071957173(1) Dated 07.01.2025, In Proceedings U/S 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. R. K. Raman, CAFor Respondent: Ms. Indu Bala Saini, Sr. DR
Section 144Section 148

…rned assessing authority has nowhere made any addition qua the above sole reason of reopening. 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 25/06/2025. (Satbeer Singh Godara) Judicial Member Dated: 25/06/2025 *Subodh Kumar, Sr. PS*…

Rama Shanker Pareek, Jaipur vs. Income Tax Officer, Ward No. 7(2), Jaipur

In the result, appeal of the assessee is allowed

ITA 253/JPR/2025[2010-11]Status: DisposedITAT Jaipur24 Jun 2025AY 2010-11
For Appellant: Shri Shrawan Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, Addl.CIT
Section 142(1)Section 147Section 148Section 234ASection 250Section 69CSection 80C

…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…

Rohit Bhadana, Faridabad vs. Income Tax Officer, National Faceless Assessment Centre

Appeal is allowed

ITA 1242/DEL/2025[2010-11]Status: DisposedITAT Delhi24 Jun 2025AY 2010-11

Bench: Sh. Satbeer Singh Godaraita No. 1242/Del/2025 : Asstt. Year : 2010-11 Rohit Bhadana, Vs Cit(A)/Nfac, H. No. 169, Sector-15A, Delhi Faridabad, Haryana-121002 (Appellant) (Respondent) Pan No. Avnpb0812F Assessee By: Sh. Ashok Goyal, Ca & Sh. Rana Gurtej Singh, Adv. Revenue By : Ms. Indu Bala Saini, Sr. Dr Date Of Hearing: 24.06.2025 Date Of Pronouncement: 24.06.2025 Order This Assessee’S Appeal For Assessment Year 2010-11, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1067611537(1) Dated 13.08.2024, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Ashok Goyal, CA &For Respondent: Ms. Indu Bala Saini, Sr. DR
Section 147Section 148

…rned assessing authority has nowhere made any addition qua the above sole reason of reopening. 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 24/06/2025. (Satbeer Singh Godara) Judicial Member Dated: 24/06/2025 *Subodh Kumar, Sr. PS*…

Dinesh Garg (HUF), Valsad vs. Asst. Commissioner of Income Tax, Central Circle-1, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 397/SRT/2024[2019-20]Status: DisposedITAT Surat19 Jun 2025AY 2019-20

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Dinesh Garg(HUF), Valsad vs. Asst. Commissioner of Income Tax, Central Circle-1, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 395/SRT/2024[2017-18]Status: DisposedITAT Surat19 Jun 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Lalit Garg (HUF), Mumbai vs. Asstt. Commissioner of Income Tax, Central Circle-1, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 394/SRT/2024[2016-17]Status: DisposedITAT Surat19 Jun 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Lalit Garg (HUF)Q, Mumbai vs. Income Tax Officer, Ward-5, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 393/SRT/2024[2012-13]Status: DisposedITAT Surat19 Jun 2025AY 2012-13

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Lalit Garg (HUF), Mumbai vs. Income Tax Officer, Ward-5, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 392/SRT/2024[2011-12]Status: DisposedITAT Surat19 Jun 2025AY 2011-12

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Assistant Commissioner of Income Tax, Vapi vs. Lalit Garg (HUF), Mumbai

Accordingly. These appeals are treated as partly allowed

ITA 868/SRT/2023[2012-13]Status: DisposedITAT Surat19 Jun 2025AY 2012-13

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Dinesh Garg (HUF), Vapi vs. Assistant Commissioner of Income Tax, Central Circle-1, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 681/SRT/2023[2016-17]Status: DisposedITAT Surat19 Jun 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Dinesh Garg (HUF), Vapi vs. Assistant Commissioner of Income Tax, Central Circle -1, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 680/SRT/2023[2015-16]Status: DisposedITAT Surat19 Jun 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Dinesh Garg (HUF), Vapi vs. Assistant Commissioner of Income Tax, Circle Central - 1L, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 679/SRT/2023[2014-15]Status: DisposedITAT Surat19 Jun 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Dinesh Garg (HUF), Vapi vs. Assistant Commissioner of Income Tax, Central Circle -1, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 678/SRT/2023[2013-14]Status: DisposedITAT Surat19 Jun 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Lalit Garg (HUF), Vapi vs. Assistant Commissioner of Income Tax, Central Circle -1, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 677/SRT/2023[2015-16]Status: DisposedITAT Surat19 Jun 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Lalit Garg (HUF), Vapi vs. Assistant Commissioner of Income Tax, Central Circle -1, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 676/SRT/2023[2014-15]Status: DisposedITAT Surat19 Jun 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…

Lalit Garg (HUF), Vapi vs. Assistant Commissioner of Income Tax, Central Circle - 1, Vapi

Accordingly. These appeals are treated as partly allowed

ITA 675/SRT/2023[2013-14]Status: DisposedITAT Surat19 Jun 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl. आयकर अपील सं/ िनधा"रण वष"/ Appeal(S) By :

For Respondent: Shri Ravi Kant Gupta, CIT (DR) with Shri Mukesh Jain, Sr.DR
Section 145(3)Section 147Section 148Section 40A(3)Section 690

…y the AO on the issues for which the assessment was re- opened stood already deleted by the CIT(A). The issue is squarely covered by the following case laws. i. Pr. CIT Vs. Lark Chemicals (P.) Ltd. (2018) 99 taxmann.com 312(SC) ii. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bombay) In view of above discussion, the impugned addition made by the CIT(A) is not sustainable and the same is accordingly ordered to be deleted. 14. So far as the validity on merits of the addition made by the CIT(A) is concerned, as discussed above the identical issue had cropped up in earlier assessment year 2010-11 as well as in subseque…