CIT v. Kelvinator of India Ltd.

256 ITR 1High Court2002#163 most cited

What is CIT v. Kelvinator of India Ltd. authority for?

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

427

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2026.

Also referred to as

CIT v. Kelvinator of India Ltd. · Kelvinator principle · section 147 · section 148 · reopening assessment · mere change of opinion · tangible material · income escaping assessment · sanction under section 151 · full and true disclosure

Also reported as

123 Taxmann 433108 Taxmann.com 176174 CTR 617

Sections most often in play

Section 143(3)Section 147Section 148Section 142(1)Section 153ASection 151Section 153DSection 250

Issues it is cited on

kelvinatorsection 114sanction under section 151mere change of opinionfirst proviso to section 147material facts necessary for assessmentfull and true disclosurewithin four yearssection 144achange of opinionlive linktangible material

Judgments citing CIT v. Kelvinator of India Ltd.

LASCO CHEMIE PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD-15(2), NEW DELHI, DELHI

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

ITA 3811/DEL/2025[2012-13]Status: DisposedITAT Delhi08 Apr 2026AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarlasco Chemie Private Vs. Income Tax Officer, Limited, Ward-15(2), Delhi 10489 Kalptaru, Sadar Thana Road Motia Khan, New Delhi 110055 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcl 3502 E Appellant .. Respondent

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 147Section 148Section 149Section 151Section 250

…, initiation of reassessment is merely a change of opinion and not sustainable [refer ACIT v. ICICI Securities Primary Dealership Ltd [2012] 348 ITR 299 (SC), CIT v. Kelvinator of India: [2010] 320 ITR 561 (SC)- affirming CIT v Kelvinator of India Ltd. (2002) 256 ITR 1 (Del) (FB)]. Re (e): Reassessment is barred by limitation in terms of section 149 of the Act 33. In this regard, it is respectfully submitted, that proceedings initiated under section 147 cannot be regarded as having been validly initiated unless P a g e | 17 Lasco Chemie (P) Ltd. (AY 2012-13) reasons recorded for initiating the proceedings are…

VIRCHOW PETROCHEMICAL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-8(1), HYDERABAD

ITA 1191/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Feb 2026AY 2015-16
For Appellant: Shri M.V. Prasad, CAFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 147Section 148Section 250

…Court of Bombay in the case of Asian Paints Ltd. Vs. DCIT (2008) 308 ITR 195 (Bom). The Hon'ble High Court, by drawing support from the landmark judgment of the “Full bench” of the Hon'ble High Court of Delhi in the case of CIT Vs. Kelvinator of India (2002) 256 ITR 1 (Del) [which thereafter had been approved by the Hon'ble Apex Court in CIT Vs. Kelvinator of India (2010) 320 ITR 561 (SC)] had observed that the department cannot take recourse to the provisions of Sec. 147 of the Act for the failure of the A.O to apply his mind in the original assessment proceedings to the material which according to him, is rele…

AMIBEN RAJESHKUMAR PUNATAR,RAJKOT vs. ITO, WARD-1(2)(1), RAJKOT, RAJKOT

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

ITA 24/RJT/2026[2015-16]Status: DisposedITAT Rajkot06 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.24/Rjt/2026 िनधा"रण वष"/Assessment Year : 2015-16 Amiben Rajeshkumar Punatar, बनाम/ Ito, Ashish, 41-New Jagnath Plot, Vs Ward – 1(2)(1), Rajkot – 360001(Gujarat) Rajkot "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahrpp4181F (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR
Section 10(38)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 250

…egarding escapement of income. Hence, I note that the initiation of reassessment proceedings was based on a mere change of opinion and for that reliance is placed on the decision of the Hon’ble Delhi High Court in the case of CIT vs. Kelvinator of India Ltd., 256 ITR 1 (Del.). Based, on these Page 6 of 8 ITA No. 24/Rjt/2026/AY 2015-16 Amiben Rajeshkumar Punatar facts and circumstances, I quash the reassessment order framed by the assessing officer under section 147 of the Act, dated 30.03.2022, and allow the appeal of the assessee. 12. As the reassessment itself is quashed, all other issues on merits of the ad…

ACIT, CENTRAL CIRCLE-19, DELHI, DELHI vs. YASMIN KAPOOR, DELHI

Appeals of the assessee are allowed

ITA 2221/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

…nishers (P) Ltd. – [2015] 374 ITR 595 (SC) and Mumbai ITAT decision in the case of Pratibha Pipes and Structural Ltd. in ITA No.3874/Mum/2015. She also relied on the decision of Hon'ble Delhi High Court in the case of CIT Vs. Kelvinator of India Ltd. – [2002] 256 ITR 1(Delhi). She also relied on the decision of Hon'ble Supreme Court in the case of Kunhayammed Vs. State of Kerala – [2000] 245 ITR 360(SC) and Khoday Distilleries Ltd. Vs. MahadeshwaraSahakaraSakkareKarkhane Ltd. – [2019] 104 taxmann.com 25(SC). 19. I noted that the case law cited by the learned CIT-DR of Spacewood Furnishers (P) Ltd. (supra) relates…

ACIT, CENTRAL CIRCLE-19, DELHI, DELHI vs. DEEPA TALWAR, DELHI

Appeals of the assessee are allowed

ITA 2203/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

…nishers (P) Ltd. – [2015] 374 ITR 595 (SC) and Mumbai ITAT decision in the case of Pratibha Pipes and Structural Ltd. in ITA No.3874/Mum/2015. She also relied on the decision of Hon'ble Delhi High Court in the case of CIT Vs. Kelvinator of India Ltd. – [2002] 256 ITR 1(Delhi). She also relied on the decision of Hon'ble Supreme Court in the case of Kunhayammed Vs. State of Kerala – [2000] 245 ITR 360(SC) and Khoday Distilleries Ltd. Vs. MahadeshwaraSahakaraSakkareKarkhane Ltd. – [2019] 104 taxmann.com 25(SC). 19. I noted that the case law cited by the learned CIT-DR of Spacewood Furnishers (P) Ltd. (supra) relates…

ANUJ NAGPAL,DELHI vs. ACIT, CENTRAL CIRCLE 14, DELHI

The appeals are allowed

ITA 524/DEL/2022[2014-15]Status: DisposedITAT Delhi28 Jan 2026AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Sh. AkashOjha, AdvFor Respondent: Ms. PoojaSwaroop, CIT, DR
Section 143(3)Section 153ASection 153D

…ce Act, 1872 but if it is established that all the relevant material were duly put up for perusal before the authority, then the sanction cannot be considered as vitiated. 15. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus, in the present case, the onus is on the corroboratory evidence. Thus, in the present…

ANUJ NAGPAL,DELHI vs. ACIT, CENTRAL CIRCLE -14, DELHI

ITA 523/DEL/2022[2013-14]Status: DisposedITAT Delhi28 Jan 2026AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Sh. AkashOjha, AdvFor Respondent: Ms. PoojaSwaroop, CIT, DR
Section 143(3)Section 153ASection 153D

…nce Act, 1872 but if it is established that all the relevant material were duly put up for perusal before the authority, then the sanction cannot be considered as vitiated. 15. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus, in the present case, the onus is on the corroboratory evidence. Thus, in the present…

ANUJ NAGPAL,DELHI vs. ACIT CENTRAL CIRCLE 14, DELHI

The appeals are allowed

ITA 467/DEL/2022[2012-13]Status: DisposedITAT Delhi28 Jan 2026AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Sh. AkashOjha, AdvFor Respondent: Ms. PoojaSwaroop, CIT, DR
Section 143(3)Section 153ASection 153D

…ce Act, 1872 but if it is established that all the relevant material were duly put up for perusal before the authority, then the sanction cannot be considered as vitiated. 15. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus, in the present case, the onus is on the corroboratory evidence. Thus, in the present…

ANU NAGPAL,DELHI vs. ACIT, CENTRAL CIRCLE 14, DELHI

The appeals are allowed

ITA 465/DEL/2022[2014-15]Status: DisposedITAT Delhi28 Jan 2026AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Sh. AkashOjha, AdvFor Respondent: Ms. PoojaSwaroop, CIT, DR
Section 143(3)Section 153ASection 153D

…ce Act, 1872 but if it is established that all the relevant material were duly put up for perusal before the authority, then the sanction cannot be considered as vitiated. 15. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus, in the present case, the onus is on the corroboratory evidence. Thus, in the present…

ANU NAGPAL,DELHI vs. ACIT,CENTRAL CIRCLE-14, DELHI

The appeals are allowed

ITA 463/DEL/2022[2012-13]Status: DisposedITAT Delhi28 Jan 2026AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Sh. AkashOjha, AdvFor Respondent: Ms. PoojaSwaroop, CIT, DR
Section 143(3)Section 153ASection 153D

…ce Act, 1872 but if it is established that all the relevant material were duly put up for perusal before the authority, then the sanction cannot be considered as vitiated. 15. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus, in the present case, the onus is on the corroboratory evidence. Thus, in the present…

ABHEEK NAGPAL,DELHI vs. ACIT, DELHI

ITA 457/DEL/2022[2016-17]Status: DisposedITAT Delhi28 Jan 2026AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Sh. AkashOjha, AdvFor Respondent: Ms. PoojaSwaroop, CIT, DR
Section 143(3)Section 153ASection 153D

…nce Act, 1872 but if it is established that all the relevant material were duly put up for perusal before the authority, then the sanction cannot be considered as vitiated. 15. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus, in the present case, the onus is on the corroboratory evidence. Thus, in the present…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI vs. PERIYASAMY ANBUNATHAN, KARUR

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

ITA 1596/CHNY/2025[2016-17]Status: DisposedITAT Chennai23 Jan 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.J.K. Reddy, CAFor Respondent: Ms.E. Pavuna Sundari, CIT
Section 131Section 132Section 132(4)Section 250

…dditions proposed in the draft order or other jurisdictional issues. Hence, the application of mind by approving authority must be ascertained in the limited context only. 16. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus; in the present case, the onus is on the assessee to rebut that the Addl. CIT while a…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. PERIYASAMY ANBUNATHAN, KARUR

In the result, all the appeals of the Revenue and the assessee are

ITA 1536/CHNY/2025[2017]Status: DisposedITAT Chennai23 Jan 2026
Section 131Section 132Section 132(4)Section 250

…additions proposed in the draft order or other jurisdictional issues. Hence, the application of mind by approving authority must be ascertained in the limited context only. 16. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus; in the present case, the onus is on the assessee to rebut that the Addl. CIT while a…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. PERIYASAMY ANBUNATHAN, KARUR

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

ITA 1529/CHNY/2025[2014-15]Status: DisposedITAT Chennai23 Jan 2026AY 2014-15

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.J.K. Reddy, CAFor Respondent: Ms.E. Pavuna Sundari, CIT
Section 131Section 132Section 132(4)Section 250

…dditions proposed in the draft order or other jurisdictional issues. Hence, the application of mind by approving authority must be ascertained in the limited context only. 16. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus; in the present case, the onus is on the assessee to rebut that the Addl. CIT while a…

PERIYASAMY ANBUNATHAN,KARUR vs. DCIT, CC-1(4), CHENNAI

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

ITA 1489/CHNY/2025[2016-17]Status: DisposedITAT Chennai23 Jan 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.J.K. Reddy, CAFor Respondent: Ms.E. Pavuna Sundari, CIT
Section 131Section 132Section 132(4)Section 250

…dditions proposed in the draft order or other jurisdictional issues. Hence, the application of mind by approving authority must be ascertained in the limited context only. 16. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus; in the present case, the onus is on the assessee to rebut that the Addl. CIT while a…

PERIASAMY ANBUNATHAN,KARUR vs. DCIT, CC-1(4), CHENNAI

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

ITA 1488/CHNY/2025[2015-16]Status: DisposedITAT Chennai23 Jan 2026AY 2015-16

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.J.K. Reddy, CAFor Respondent: Ms.E. Pavuna Sundari, CIT
Section 131Section 132Section 132(4)Section 250

…dditions proposed in the draft order or other jurisdictional issues. Hence, the application of mind by approving authority must be ascertained in the limited context only. 16. The Hon'ble Delhi High Court (Full Bench), in the case of Kelvinator of India Ltd. 123 Taxmann 433 (FB), on the basis of the statutory presumption under section 114(e) of the Indian Evidence Act, 1872, had drawn a presumption in the Income Tax matter that all official actions were performed regularly unless controverted by the corroboratory evidence. Thus; in the present case, the onus is on the assessee to rebut that the Addl. CIT while a…

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

ITA 1670/CHNY/2024[2018-19]Status: DisposedITAT Chennai21 Jan 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri G. Baskar, Advocate &For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

…आयकर अपीलीय अिधकरण, ’बी’ "ायपीठ, चे"ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी एस.एस. िव"ने" रिव, "ाियक सद" एवं "ी जगदीश, लेखा सद" के सम" । Before Shri S.S. Viswanethra Ravi, Judicial Member & Shri Jagadish, Accountant Member आयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [PAN: AAATC5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by : Shri G.…

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

ITA 1667/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

…आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘B' BENCH, CHENNAI श्री एस.एस. विश्वनेत्र रवि, न्यायिक सदस्य एवं श्री जगदीश, लेखा सदस्य के समक्ष । Before Shri S.S. Viswanethra Ravi, Judicial Member & Shri Jagadish, Accountant Member आयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [PAN: AAATC5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant by Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प…

VAMA INTERNATIONAL,MUMBAI vs. ACIT 22(3), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 5456/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Dec 2025AY 2012-13
For Appellant: \nShri Dharan Gandhi, ARFor Respondent: \nMs. Kavitha Kaushik, (Sr. DR)
Section 143(1)Section 147Section 148

…eassessment notice after four years. In this regard, reliance is also placed on the decision of the Full Bench of the Delhi High Court in the\nPage | 9\nITA No. 5456/Mum/2025\nΑ.Υ. 2012-13\nVama International\ncase of CIT vs Kelvinator of India Limited (2002) 256 ITR 1\n(Del)(FB) wherein it has been held that initiation of re-assessment\nproceedings on the basis of information in the Tax Audit Report is not\nacceptable since the same was submitted by the appellant along with the\nreturn of income. It was one thing to say that the AO had received\ninformation from an audit report which was not before him, but it w…

HYDRISE FOODS PRIVATE LIMITED,UTTAR PRADESH, INDIA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AGRA, AGRA, UTTAR PRADESH, INDIA

In the result, both the appeals of the assessee are allowed

ITA 87/AGR/2024[2018-19]Status: DisposedITAT Agra04 Dec 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing)

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT DR
Section 132(1)Section 143(3)Section 153ASection 153D

…nishers (P) Ltd. – [2015] 374 ITR 595 (SC) and Mumbai ITAT decision in the case of Pratibha Pipes and Structural Ltd. in ITA No.3874/Mum/2015. She also relied on the decision of Hon'ble Delhi High Court in the case of CIT Vs. Kelvinator of India Ltd. – [2002] 256 ITR 1(Delhi). She also relied on the decision of Hon'ble Supreme Court in the case of Kunhayammed Vs. State of Kerala – [2000] 245 ITR 360(SC) and Khoday Distilleries Ltd. v. Sri Mahadeshwara Sahakara Sakkare Karkhane Limited– [2019] 104 taxmann.com 25(SC). 19. I noted that the case law cited by the learned CIT-DR of Spacewood Furnishers (P) Ltd. (supra)…

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