Likewise, in Tilak Raj Bedi v. Joint CIT

319 ITR 385High Court2009#3228 most cited

What is Likewise, in Tilak Raj Bedi v. Joint CIT authority for?

The power of reassessment can be validly exercised if satisfaction is reached through due procedure that income has escaped assessment. Such satisfaction may include a change of opinion, but it is distinct from a 'mere change of opinion' and cannot be assailed if based on relevant material.

37

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

Tilak Raj Bedi v. Joint CIT · 319 ITR 385 · section 147 · reassessment · escapement of income · change of opinion · mere change of opinion · reason to believe · tangible material · section 148 notice

Sections most often in play

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 115BBESection 132Section 132(1)(c)

Issues it is cited on

section 147(a)mere change of opinionchange of opinionreason to believetangible materialescapement of incomereopening of assessmentreassessment proceedingsincome-tax officernotice under section 148section 148section 142(1)

Judgments citing Likewise, in Tilak Raj Bedi v. Joint CIT

INCOME TAX OFFICER, WARD-4(2), JALANDHAR, , CIVIL LINES vs. SH. BARJESH SINGHAL, MODERN COLONY

In the result, the appeal filed by the revenue is allowed for statistical purpose

ITA 363/ASR/2024[2016-17]Status: DisposedITAT Amritsar13 Oct 2025AY 2016-17

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: None (Written submission)
Section 142(1)Section 143(3)Section 147Section 148Section 250

…disclosure of material facts by the assessee as contemplated in the pre amended Section 147 (a) of the Act the Act. (f) If satisfaction is arrived at on the basis of any relevant material, such satisfaction cannot be assailed. Tilak Raj Bedi vs JCIT (2009) 319 ITR 385-P&11- The power of reassessment can be validly exercised if satisfaction is arrived at after following due procedure that income had escaped assessment. Such satisfaction may involve change of opinion but was not at par with 'mere change of opinion'. If satisfaction is arrived at on the basis of any relevant material, such satisfaction cannot be…

NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 236/ASR/2023[2011-12]Status: DisposedITAT Amritsar26 Sept 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Y. K. Sud & Sh. P. K. Anand, CAs
Section 132Section 142(1)Section 143(3)Section 148Section 153cSection 250

…disclosure of material facts by the assessee as contemplated in the pre amended Section 147 (a) of the Act the Act. (2) If satisfaction is arrived at on the basis of any relevant material, such satisfaction cannot be assailed, Tilak raj bedi vs JCIT (2009) 319 ITR 385-P&H- The power of reassessment can be validly exercised if satisfaction is arrived at after following due procedure that income had escaped assessment. Such satisfaction may involve change of opinion but was not at par with 'mere change of opinion. If satisfaction is arrived at on the basis of any relevant material, such satisfaction cannot be as…

JAY KISHORE CHOUBEY,RAIRANGPUR vs. ACIT, CIRCLE-1, ASANSOL

In the result, appeal of the assessee stands allowed

ITA 2/CTK/2023[2010-11]Status: DisposedITAT Cuttack29 Nov 2023AY 2010-11

Bench: Before S/Shri George Mathan, Judicial & Girish Agrawalassessment Year : 2010-2011 2011 Jay Jay Kishore Kishore Choubey, Choubey, Vs. Acit, Circle Acit, Circle-1, Asansol. Rairangpur Bazar, Rairangpur, Rairangpur Bazar, Rairangpur, Mayurbhanj. Pan/Gir No. Pan/Gir No.Acmpc 1759 N (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.R.Mohanty P.R.Mohanty, Adv Revenue By : Shri Charan Das, Sr. Das, Sr. Dr Date Of Hearing : 29/11 11/2023 Date Of Pronouncement : 29/11 /11/2023 O R D E R Per Bench

For Appellant: Shri P.R.MohantyFor Respondent: Shri Charan Das, Sr
Section 147Section 148

…ere given for reopening. 11 It is also held that satisfaction arrived at by any relevant material after following due procedure, It cannot be assailed. it may involve change of opinion but not at par with mere change of opinion. (Tilak raj bedi vs JCIT (2009) 319 ITR 385-P&H) 12 (AIA firm vs cit (1991) 189 ITR 285(sc) -The expression 'information' In the context in which it occurs must, in our judgment, mean instruction or knowledge derived from an external source P a g e 11 | 15 Assessment Year : 2010-2011 concerning facts or particulars, or as to law relating to a matter bearing on the assessment... Jurisdict…

SH. FARUKH JEHAN ZEB ,SRINAGAR vs. INCOME TAX OFFICER, ANANT NAG

In the result, the appeal of the assessee is dismissed

ITA 444/ASR/2017[2008-09]Status: DisposedITAT Amritsar03 Aug 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Touseef Ahmad Khanday &For Respondent: Sh. S. M. Surendranath, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 68

…ns recorded by respondent No. 2 nor can it interfere with the notice simply because on an overall reappraisal of material, a different opinion may be formed.” 12. In another case the Hon’ble Jurisdictional High Court in the case of “Tilak Raj Bedi Vs. JCIT”, 319 ITR 385 (P&H) on the issue of reasons has observed as under: “The power of reassessment can be validly exercised if satisfaction is arrived at after following due procedure that income had escaped assessment. Such satisfaction may involve change of opinion but was not at par with "mere change of opinion". 13. In our view, it was obligatory on the part…

SHRIMATI AMARJIT KAUR W/O BUGAR SINGH,MANSA vs. INCOME TAX OFFICER WARD 1(4), MANSA

In the result, the appeal of the assessee is dismissed

ITA 1/ASR/2018[2009-10]Status: DisposedITAT Amritsar26 Jul 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 147Section 148Section 251(2)Section 49

…143(l)(a) of the Act the question of examination of the material by the Assessing Officer did not arise at that stage. Therefore, in case of intimation u/s 143(1), re-opening cannot be challenged on the ground of change of opinion. i) Tilak Raj Bedi Vs. JCIT 319 ITR 385 P&H The power of reassessment can be validly exercised if satisfaction is arrived at after following due procedure that income had escaped assessment. Such satisfaction may involve change of opinion but was not at par with "mere change of opinion". j) Pb. State Cooperative Agriculture Dev Bank Vs. CIT 207 CTR 352 P&H The notice for reassessment…

M/S BLUE CITY TOWNSHIP & COLONIZERS,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

ITA 90/ASR/2017[2009-10]Status: DisposedITAT Amritsar14 Jul 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 147Section 148Section 151Section 234ASection 69

…ITR 285 (SC), Raymond Woollen Mills Limited. Vs ITO 236 ITR 34 SC, Gurera Gas Cylinders Pvt. Ltd. vs CIT 258 ITR 170 P&H, Jawand Sons Vs. CIT 326 ITR 39 P&H, Sewak Ram Vs ITO 236 CTR 462 (P&H), Aditya and Co. Vs CIT 279 ITR 47 P&H, Tilak Raj Bedi Vs. JCIT 319 ITR 385 P&H, Pb. State Cooperative Agriculture Dev Bank Vs. CIT 207 CTR 352 P&H, Grover Nursing Home 248 ITR 493 P&H, Consolidated Photo & Finvest Ltd. Vs. ACIT 281 ITR 394 Del the principle is laid down that the Assessing Officer is expected to possess information which should make a prima facie belief of income having escaped assessment. Since, th…

SHRI BALJINDER SINGH ,BATHINDA vs. INCOME TAX OFFICER, WARD 2(1), BATHINDA

In the result, both the appeals are disposed off in the terms indicated as above

ITA 148/ASR/2018[2009-10]Status: DisposedITAT Amritsar24 Aug 2022AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. J. K. Gupta, AdvFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 148Section 69A

…43(l)(a) of the Act the question of examination of the material by the Assessing Officer did not arise at that stage. Therefore, in case of intimation u/s 143(1), re-opening cannot be challenged on the ground of change of opinion. h) Tilak Raj Bedi Vs. JCIT 319 ITR 385 P&H The power of reassessment can be validly exercised if satisfaction is arrived at after following due procedure that income had escaped assessment. Such satisfaction may involve change of opinion but was not at par with "mere change of opinion". i) Pb. State Cooperative Agriculture Dev Bank Vs. CIT 207 CTR 352 P&H The notice for reassessment…

SHRIMATI MANJIT KAUR,BATHINDA vs. INCOME TAX OFFICER, WARD 2 (1), BATHINDA

In the result, both the appeals are disposed off in the terms indicated as above

ITA 147/ASR/2018[2009-10]Status: DisposedITAT Amritsar24 Aug 2022AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. J. K. Gupta, AdvFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 148Section 69A

…43(l)(a) of the Act the question of examination of the material by the Assessing Officer did not arise at that stage. Therefore, in case of intimation u/s 143(1), re-opening cannot be challenged on the ground of change of opinion. h) Tilak Raj Bedi Vs. JCIT 319 ITR 385 P&H The power of reassessment can be validly exercised if satisfaction is arrived at after following due procedure that income had escaped assessment. Such satisfaction may involve change of opinion but was not at par with "mere change of opinion". i) Pb. State Cooperative Agriculture Dev Bank Vs. CIT 207 CTR 352 P&H The notice for reassessment…

SHRIMATI NEETIMA GOYAL,FEROZPUR CANTT. vs. INCOME TAX OFFICER,3(2), FEROZPUR

In the result, appeal of the assessee is allowed on legal ground

ITA 184/ASR/2018[2011-12]Status: DisposedITAT Amritsar03 Feb 2020AY 2011-12

Bench: Shri L.P. Sahu, Am & Shri Ravish Sood, Jm आयकर अऩीऱ सं./Ita No.184/Asr/2018 (ननधाारण वषा / Assessment Year :2011-2012) Neetima Goyal, Vs. Ito, Ward-3(2), Ferozepur Prop. Raghav Sales, G.T.Road, Ferozepur Cantt., Pin-152001 स्थायी ऱेखा सं./ Panno. : Aicpg 3586 H (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri I.P.Bansal, Advocate राजस्व की ओर से /Revenue By : Shri Charan Dass, Dr

For Appellant: Shri I.P.Bansal, AdvocateFor Respondent: Shri Charan Dass, DR
Section 143(2)Section 143(3)Section 147Section 148Section 151Section 151(2)Section 44A

…T 18 November, 2009(P&H) (4) It is also held that satisfaction arrived at by any relevant material after following due procedure, it cannot be assailed.it may involve change of opinion but not at par with mere change of opinion. (Tilak Raj Bedi vs JCIT (2009) 319 ITR 385-P&H) (4) It is well settled that audit objection on the on the point of fact can be a valid ground for reopening of assessment. (i) Usha International Ltd, vs Assessee on 9 March, 2015 (ITAT delhi ) -As this tangible material, in the shape of audit objection, came into existence after the completion of the original assessment and led to the initi…

ITO 13(3)(3), MUMBAI vs. VULVAN TRADERS P. LTD, MUMBAI

ITA 4137/MUM/2015[2008-09]Status: DisposedITAT Mumbai30 Jan 2019AY 2008-09

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Years: 2008-09 Income Tax Officer-13(3)(3), M/S Vulvan Traders, 805, Room No.227,02Nd Floor, A Wingh, Corporate Avenue, बनाम/ Aayakar Bhavan, Sonawala Raod, Vs. M. K. Road, Goregaon East, Mumbai-400020 Mumbai-400063 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No.Aaacv1603K Assessment Years: 2008-09 M/S Vulvan Traders, 805, Income Tax Officer-13(3)(3), A Wingh, Corporate Room No.227,02Nd Floor, बनाम/ Avenue, Sonawala Raod, Aayakar Bhavan, Vs. Goregaon East, M. K. Road, Mumbai-400063 Mumbai-400020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No.Aaacv1603K

Section 143(1)Section 147Section 148

…f reassessment on the ground of lack of notice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 2.16…

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2580/CHNY/2017[2014-15]Status: DisposedITAT Chennai06 Dec 2018AY 2014-15

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

…of reassessment on the ground of lack of notice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 5.1…

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2579/CHNY/2017[2013-14]Status: DisposedITAT Chennai06 Dec 2018AY 2013-14

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

…of reassessment on the ground of lack of notice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 5.1…

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2578/CHNY/2017[2010-11]Status: DisposedITAT Chennai06 Dec 2018AY 2010-11

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

…of reassessment on the ground of lack of notice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 5.1…

SOLO HARDWARE P. LTD,MUMBAI vs. ASST CIT CIR 5(3)(2), MUMBAI

The appeals of the assessee are dismissed

ITA 1486/MUM/2017[2011-12]Status: DisposedITAT Mumbai24 Oct 2018AY 2011-12

Bench: Shri Joginder Singh & Shri Ramit Kochar

Section 115JSection 139Section 142Section 142(1)Section 143Section 143(3)Section 147Section 148

…of reassessment on the ground of lack of notice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 2.1…

SNEHALATA AHNAND RANE,MUMBAI vs. INCOME TAX OFFICER-WARD 3(3), KALYAN

The appeals of the assessee are partly allowed

ITA 1787/MUM/2018[2011-12]Status: DisposedITAT Mumbai11 Oct 2018AY 2011-12

Bench: Shri Joginder Singh

Section 133(6)Section 139Section 142Section 143Section 143(3)Section 147Section 148Section 69C

…f reassessment on the ground of lack of notice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 2.1…

SNEHALATA AHNAND RANE,MUMBAI vs. INCOME TAX OFFICER-WARD 3(3), KALYAN

The appeals of the assessee are partly allowed

ITA 1786/MUM/2018[2010-11]Status: DisposedITAT Mumbai11 Oct 2018AY 2010-11

Bench: Shri Joginder Singh

Section 133(6)Section 139Section 142Section 143Section 143(3)Section 147Section 148Section 69C

…f reassessment on the ground of lack of notice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 2.1…

SNEHALATA AHNAND RANE,MUMBAI vs. INCOME TAX OFFICER-WARD 3(3), KALYAN

The appeals of the assessee are partly allowed

ITA 1785/MUM/2018[2009-10]Status: DisposedITAT Mumbai11 Oct 2018AY 2009-10

Bench: Shri Joginder Singh

Section 133(6)Section 139Section 142Section 143Section 143(3)Section 147Section 148Section 69C

…f reassessment on the ground of lack of notice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 2.1…

SHRI DINESHKUMAR C. DOSHI,MUMBAI vs. INCOME TAX OFFICER 19(1)(4), MUMBAI

The appeals of the assessee are dismissed

ITA 1730/MUM/2018[2011-12]Status: DisposedITAT Mumbai11 Oct 2018AY 2011-12

Bench: Shri Joginder Singh

Section 133(6)Section 139Section 142Section 143Section 147Section 148

…on the ground of lack of notice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of the reassessment orders. Likewise, in Tilak Raj Dinesh S. Jain Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 4.14…

ITO 6(3)(2), MUMBAI vs. JAYDEEP PROFILES P.LTD, MUMBAI

ITA 3236/MUM/2016[2009-10]Status: DisposedITAT Mumbai25 Sept 2018AY 2009-10

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2009-10 Income Tax Officer 6(3)(2), Jaydeep Profiles P. Ltd., R No.503, 5Th Floor, Aayakar 142/7 Lakdi Bunder Road, बनाम/ Bhavan, M.K.Road, Darukhana, Reay Road, Vs. Mumbai 400 020 Mumbai 400 086 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacj8998B Assessment Year: 2009-10 Jaydeep Profiles P. Ltd., Income Tax Officer 6(3)(2), 142/7 Lakdi Bunder Road, R No.503, 5Th Floor, Aayakar बनाम/ Darukhana, Reay Road, Bhavan, M.K.Road, Vs. Mumbai 400 086 Mumbai 400 020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aaacj8998B 2 & 2698/Mum/2016

Section 133(6)Section 139Section 142Section 143Section 147Section 148

…tice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of 19 & 2698/Mum/2016 Jaydeep Profiles P.Ltd the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 4.1…

JAYDEEP PROFILES PVT. LTD.,MUMBAI vs. ITO WD 6 (3)(2), MUMBAI

ITA 2698/MUM/2016[2009-10]Status: DisposedITAT Mumbai25 Sept 2018AY 2009-10

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2009-10 Income Tax Officer 6(3)(2), Jaydeep Profiles P. Ltd., R No.503, 5Th Floor, Aayakar 142/7 Lakdi Bunder Road, बनाम/ Bhavan, M.K.Road, Darukhana, Reay Road, Vs. Mumbai 400 020 Mumbai 400 086 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacj8998B Assessment Year: 2009-10 Jaydeep Profiles P. Ltd., Income Tax Officer 6(3)(2), 142/7 Lakdi Bunder Road, R No.503, 5Th Floor, Aayakar बनाम/ Darukhana, Reay Road, Bhavan, M.K.Road, Vs. Mumbai 400 086 Mumbai 400 020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aaacj8998B 2 & 2698/Mum/2016

Section 133(6)Section 139Section 142Section 143Section 147Section 148

…tice. Non-issuance of notice to some of the legal heirs of the late P was merely an irregularity and the same did not affect the validity of 19 & 2698/Mum/2016 Jaydeep Profiles P.Ltd the reassessment orders. Likewise, in Tilak Raj Bedi v. Joint CIT, (2009) 319 ITR 385 (P & H), wherein, facts coming to light in a subsequent assessment year could validly form the basis for initiating reassessment proceedings, in view of Explanation 2 to section 147. The action of the income tax authorities in reopening the assessment of the assessee and restricting the deduction under section 80-IB was held to be valid. 4.1…

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