CIT v. Kelvinator of India Ltd.

320 ITR 561Supreme Court of India2010#18 most cited

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

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

1,673

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2010 to 2026.

Also referred to as

CIT v. Kelvinator of India Ltd. · Kelvinator of India · Section 147 · Section 148 · reassessment proceedings · mere change of opinion · fresh tangible material · escapement of income · reason to believe · validity of reassessment

Also reported as

187 Taxmann 3122 SCC 723187 Taxmann.com 312

Sections most often in play

Section 147Section 143(3)Section 148Section 142(1)Section 151Section 143(2)Section 68Section 139
Read the full judgment

Issues it is cited on

kelvinatorfresh tangible materialmere change of opinionfirst proviso to section 147material facts necessary for assessmentfull and true disclosurechange of opinionbeyond four yearslive linktangible materialescapement of incomereason to believe

Judgments citing CIT v. Kelvinator of India Ltd.

Sudarshan Jeans Private Limited, Kolhapur vs. ITO, Ambala

The appeal stand allowed

ITA 1070/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh30 Dec 2025AY 2015-16

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Rohit Goel (CA) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 142(1)Section 143(3)Section 147Section 148Section 32(1)(iia)

…nformation which has come to the possession of Ld. AO subsequent to the culmination of regular assessment proceeding which would indicate that certain income escaped in the hands of the assessee. The Hon’ble Apex Court in the case of Kelvinator of India Ltd. (320 ITR 561) held that post 01- 04-1989, Ld. AO has power to reopen, provided there is 'tangible material' to come to a conclusion that there is escapement of income from assessment. The recorded reasons must have a live link with formation of belief. With effect from 1-4-1989, the condition to reopen the case is that Ld. AO must have reasons to believe tha…

Hardayal Milk Products Private Limited, Shikohabad vs. DCIT, Circle-2(2)(1), Firozabad

In the result, both the appeals filed by assessee are allowed

ITA 344/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68

…, reopening of assessment on the same issue without any tangible new material amounts to a change of opinion, which is impermissible under the law. Reliance is placed on the landmark decisions in the following cases : a) CIT v. Kelvinator of India Ltd. [2010] 320 ITR 561 (SC); b) PCIT v. Tupperware India Pvt. Ltd. [2020] 421 ITR 371 (Del HC) : In this case, The AO reopened the assessment based on information from the Investigation Wing regarding share capital received from alleged entry providers. Hon’ble Delhi High Court quashed the reassessment, holding that the issue of share capital had been examined during o…

Hardayal Milk Products Private Limited, Shikohabad vs. DCIT, Circle-2(2)(1), Firozabad

In the result, both the appeals filed by assessee are allowed

ITA 343/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68

…, reopening of assessment on the same issue without any tangible new material amounts to a change of opinion, which is impermissible under the law. Reliance is placed on the landmark decisions in the following cases : a) CIT v. Kelvinator of India Ltd. [2010] 320 ITR 561 (SC); b) PCIT v. Tupperware India Pvt. Ltd. [2020] 421 ITR 371 (Del HC) : In this case, The AO reopened the assessment based on information from the Investigation Wing regarding share capital received from alleged entry providers. Hon’ble Delhi High Court quashed the reassessment, holding that the issue of share capital had been examined during o…

DCIT, Central Circle-20, Delhi vs. Lotus Herbals Pvt. Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision of the Full Bench of the Delhi High Court in the case of Usha International Limited: 348 ITR 485 wherein the Court held that re-assessinent DCIT vs. Lotus Hearbals Pvt. Ltd. proceedings will be invalid in case an issue or query is raised but thereafter the assessing officer does not make any addition…

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision of the Full Bench of the Delhi High Court in the case of Usha International Limited: 348 ITR 485 wherein the Court held that re-assessinent DCIT vs. Lotus Hearbals Pvt. Ltd. proceedings will be invalid in case an issue or query is raised but thereafter the assessing officer does not make any addition…

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision of the Full Bench of the Delhi High Court in the case of Usha International Limited: 348 ITR 485 wherein the Court held that re-assessinent DCIT vs. Lotus Hearbals Pvt. Ltd. proceedings will be invalid in case an issue or query is raised but thereafter the assessing officer does not make any addition…

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision of the Full Bench of the Delhi High Court in the case of Usha International Limited: 348 ITR 485 wherein the Court held that re-assessinent DCIT vs. Lotus Hearbals Pvt. Ltd. proceedings will be invalid in case an issue or query is raised but thereafter the assessing officer does not make any addition…

DCIT, Central Circle-20, New Delhi vs. Lotus Herbals P.Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision of the Full Bench of the Delhi High Court in the case of Usha International Limited: 348 ITR 485 wherein the Court held that re-assessinent DCIT vs. Lotus Hearbals Pvt. Ltd. proceedings will be invalid in case an issue or query is raised but thereafter the assessing officer does not make any addition…

Deputy Commissioner of Income Tax, Central Circle-28, New Delhi vs. Jct Limited, New Delhi

In the result, the appeal for the revenue for the A

ITA 2146/DEL/2025[2013-14]Status: DisposedITAT Delhi19 Dec 2025AY 2013-14

Bench: Shri C.N. Prasad & Shri Naveen Chandra

Section 144BSection 147Section 254

…epted, 4 years cannot be held valid solely on the basis of change of opinion on without any new tangible material before AO. Reliance is placed on various judicial decisions on this issue. The Hon'ble Supreme Court in the case of CIT vs. Kelvinator India Ltd. 320 ITR 561 (SC), has held that for reopening of the assessment, the AO should have in its possession 'tangible material'. The term 'tangible material' has been understood and explained by various courts subsequently. There has been unanimity of the courts on this issue that in absence of fresh material indicating escaped income, the AO cannot assume jurisdi…

Deputy Commissioner of Income Tax, Central Circle-28, New Delhi, Delhi vs. Jct Limited, Delhi

In the result, the appeal for the revenue for the A

ITA 2145/DEL/2025[1999-00]Status: DisposedITAT Delhi19 Dec 2025AY 1999-00

Bench: Shri C.N. Prasad & Shri Naveen Chandra

Section 144BSection 147Section 254

…epted, 4 years cannot be held valid solely on the basis of change of opinion on without any new tangible material before AO. Reliance is placed on various judicial decisions on this issue. The Hon'ble Supreme Court in the case of CIT vs. Kelvinator India Ltd. 320 ITR 561 (SC), has held that for reopening of the assessment, the AO should have in its possession 'tangible material'. The term 'tangible material' has been understood and explained by various courts subsequently. There has been unanimity of the courts on this issue that in absence of fresh material indicating escaped income, the AO cannot assume jurisdi…

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

…in reopening the assessment u/s. 147 since there is no new/fresh tangible material other the one available before A.O. in original assessment and ergo the reopening is not validly done and in view of supreme Court decision in the case of Kelvinator India Ltd 320 ITR 561 and jurisdictional High Court decision in the case of Hindustan Lever Ltd (2004) 268 ITR 332 (Bombay), the reopening deserves to be quashed. 10. Appellant craves to leave, add / alter or amend any other grounds of appeal.” 4. Assessee has also raised following additional grounds of appeal : “11. Without prejudice to other Grounds of appeal, App…

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

…w in reopening the assessment u/s.147 since there is no new/fresh tangible material other the one available before A.O. in original assessment and ergo the reopening is not validly done and in view of supreme Court decision in the case of Kelvinator India Ltd 320 ITR 561 and jurisdictional High Court decision in the case of Hindustan Lever Ltd (2004) 268 ITR 332 (Bombay), the reopening deserves to be quashed. 10. Appellant craves to leave, add / alter or amend any other grounds of appeal.” Assessee has also raised following additional grounds of appeal: “11. Without prejudice to other Grounds of appeal, Appellant…

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

…in reopening the assessment u/s. 147 since there is no new/fresh tangible material other the one available before A.O. in original assessment and ergo the reopening is not validly done and in view of supreme Court decision in the case of Kelvinator India Ltd 320 ITR 561 and jurisdictional High Court decision in the case of Hindustan Lever Ltd (2004) 268 ITR 332 (Bombay), the reopening deserves to be quashed. 10. Appellant craves to leave, add / alter or amend any other grounds of appeal.” 4. Assessee has also raised following additional grounds of appeal : “11. Without prejudice to other Grounds of appeal, App…

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

…w in reopening the assessment u/s.147 since there is no new/fresh tangible material other the one available before A.O. in original assessment and ergo the reopening is not validly done and in view of supreme Court decision in the case of Kelvinator India Ltd 320 ITR 561 and jurisdictional High Court decision in the case of Hindustan Lever Ltd (2004) 268 ITR 332 (Bombay), the reopening deserves to be quashed. 10. Appellant craves to leave, add / alter or amend any other grounds of appeal.” Assessee has also raised following additional grounds of appeal: “11. Without prejudice to other Grounds of appeal, Appellant…

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

…w in reopening the assessment u/s.147 since there is no new/fresh tangible material other the one available before A.O. in original assessment and ergo the reopening is not validly done and in view of supreme Court decision in the case of Kelvinator India Ltd 320 ITR 561 and jurisdictional High Court decision in the case of Hindustan Lever Ltd (2004) 268 ITR 332 (Bombay), the reopening deserves to be quashed. 10. Appellant craves to leave, add / alter or amend any other grounds of appeal.” Assessee has also raised following additional grounds of appeal: 4 ITA Nos.1121 to 1126/PUN/2024 Rajarshi Shahu Shikshan Sans…

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

…in reopening the assessment u/s. 147 since there is no new/fresh tangible material other the one available before A.O. in original assessment and ergo the reopening is not validly done and in view of supreme Court decision in the case of Kelvinator India Ltd 320 ITR 561 and jurisdictional High Court decision in the case of Hindustan Lever Ltd (2004) 268 ITR 332 (Bombay), the reopening deserves to be quashed. 10. Appellant craves to leave, add / alter or amend any other grounds of appeal.” 4. Assessee has also raised following additional grounds of appeal : “11. Without prejudice to other Grounds of appeal, App…

Principal Commissioner Of Income Tax Central Kanpur vs. Rajan Rajesh Kumar

The Appeal stands dismissed without being admitted

ITA/12/2024HC Uttarakhand17 Dec 2025

Bench: This Court Being Aggrieved By The Judgment & Order Dated 08.02.2024, Whereby The Appellate Tribunal Was Pleased To Allow The Appeal Of The Respondent. 3.

For Appellant: Mr. Hari Mohan Bhatia, learned counsel
Section 133ASection 151

…2025:UHC:11294-DB 1 Reserved IN THE HIGH COURT OF UTTARAKHAND AT NAINITAL HON’BLE THE CHIEF JUSTICE SRI G. NARENDAR AND HON’BLE SRI JUSTICE SUBHASH UPADHYAY Date of Judgment:17.12.2025 Reserved on : 31.10.2025 INCOME TAX APPEAL No. 12 OF 2024 Principal Commissioner of Income Tax (Central), Kanpur. ….Appellant. Versus Rajan Rajesh Kumar …Respondent Counsel for the appellant : Mr. Hari Mohan Bhatia, learned counsel. Counsel for the respondent / caveator : Mr. Sivaraman, Mr. C.S. Rawat and Mr. Vivek Kumar, learned counsels for the respondent.…

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

…f the Act, as the notice u/s 148 of the Act was issued well beyond the four years period mandated therein; ii. The impugned proceedings represented a change of opinion, which was specifically disapproved in the case of Kelvinator of 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 i…

Income Tax Officer, Gurgaon vs. Anil Kumar, Gurgaon

In the result, the appeal of the revenue is dismissed and the CO of the 7

ITA 4013/DEL/2024[2014-15]Status: DisposedITAT Delhi15 Dec 2025AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganeshincome Tax Officer, Vs. Anil Kumar, Ward-1(1), J-10, South City-1, Gurgaon Gurgaon, Haryana (Appellant) (Respondent) Pan: Aampk9521G Co No. 88/Del/2024 (Ita No. 4013/Del/2024) (Assessment Year: 2014-15) Anil Kumar, Vs. Income Tax Officer, J-10, South City-1, Ward-1(1), Gurgaon, Haryana Gurgaon (Appellant) (Respondent) Pan: Aampk9521G

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 10(38)Section 115BSection 133ASection 143(3)Section 144Section 147Section 148Section 44ASection 69

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A”: NEW DELHI BEFORE SHRI C. N. PRASAD, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER Income Tax Officer, Vs. Anil Kumar, Ward-1(1), J-10, South City-1, Gurgaon Gurgaon, Haryana (Appellant) (Respondent) PAN: AAMPK9521G CO No. 88/Del/2024 (ITA No. 4013/Del/2024) (Assessment Year: 2014-15) Anil Kumar, Vs. Income Tax Officer, J-10, South City-1, Ward-1(1), Gurgaon, Haryana Gurgaon (Appellant) (Respondent) PAN: AAMPK9521G Assessee by : Dr. Rakesh Gupta, Adv Shri Somil Agarwal, Adv Revenue by: Shri Ajay Kumar Arora, Sr. DR Date of Hearing 24/09/2025 Date of pro…

Manoj Kumar Agarwal, Farukhabad vs. Assessing Officer, Farrukhabad

In the result, appeal of the assessee is allowed for AY 2017-18 and appeal of the assessee for AY 2015-16 is partly allowed

ITA 76/AGR/2025[2017-18]Status: DisposedITAT Agra12 Dec 2025AY 2017-18

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

For Appellant: Shri Swaran Singh, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 143(3)Section 147

…uch less to the ld AO to have live link for formation of belief that income of assessee had escaped assessment. Reliance in this regard is placed on the following decisions:- a. Decision of Hon‟ble Supreme Court in the case of Kelvinator of India reported in 320 ITR 561 (SC) on the aspect of requirement of tangible material for reopening and on change of opinion; b. Decision of Hon‟ble Punjab and Haryana High Court in the case of Vipin Khanna Vs. CIT on the aspect of reassessment not permissible for making fishing and roving enquiries; c. Decision of Hon‟ble Delhi High Court in the case of PCIT Vs. NC Cables L…