Northern Exim (P) Ltd. v. DCIT

357 ITR 586High Court2013#2423 most cited

What is Northern Exim (P) Ltd. v. DCIT authority for?

The validity of reassessment proceedings under Section 147 is judged solely by the reasons recorded, which cannot be supplemented or improved upon by any subsequent material or order rejecting objections.

48

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

Northern Exim (P) Ltd. v. DCIT · Section 147 · Section 148 · reasons recorded · validity of reassessment · reopening assessment · income escaping assessment · reason to believe · subsequent material · supplementing reasons · order rejecting objections · Delhi High Court

Sections most often in play

Section 132Section 142(1)Section 143(3)Section 147Section 148Section 153ASection 153CSection 65B

Issues it is cited on

section 148(2)live linksection 246aincome escaping assessmentescapement of incomereason to believeincome-tax officerreassessment proceedingsnotice under section 148undisclosed incomesection 139condonation of delay

Judgments citing Northern Exim (P) Ltd. v. DCIT

SRI PREM PROPERTIES PRIVATE LIMITED,GURGAON vs. ACIT,CIRCLE-24(1), NEW DELHI, DELHI

In the result, appeal filed by the assessee is allowed

ITA 957/DEL/2024[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Sri Prem Properties Private Limited, Vs. Acit, Circle 24 (1), A – 99, Bajghera Chowk, Delhi. New Palam Vihar, Gurgaon – 122 017 (Haryana). (Pan :Aaacs2554E) (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate Shri Skasham Agarwal, Ca Shri Deepesh Garg, Advocate Revenue By : Ms. Kirti Sankratyayan, Cit Dr Date Of Hearing : 01.09.2025 Date Of Order : 24.10.2025 Order Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals)-23, New Delhi [For Short ‘Ld. Cit (A)]Dated 04.01.2024 For Assessment Year 2012-13. 2. Brief Facts Of The Case Are, Assessee Filed Its Original Return Of Income On 30.09.2012 Declaring An Income Of Rs.2,15,340/-. The Case Of The Assessee Was Selected For Scrutiny For The Year Under Consideration.

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Ms. Kirti Sankratyayan, CIT DR
Section 132Section 147Section 148

…34 of the paper book which are the reasons recorded. He further submitted that validity of reopening is to be judged with reference to Reason recorded alone and this regard, he relied on the following decisions :- (i) Northern Exim (P.) Ltd. vs. DCIT, (2013) 357 ITR 586(Del.) (ii) Shipra Srivastava &Anr. vs. ACIT, (2009) 319 ITR 221 (Del.) 7 Balkrishna Hiralal Wani vs. ITO, (2010) 321 ITR 519 (Bom.) Further he submitted that there is no material having any nexus much less live nexus based on which belief of escapement of income has been made. He further relied on the pages 102-108 of the paper book which is th…

SH. NIRBHAY TREHAN,JAMMU vs. DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, JAMMU

In the result, the appeals of the assessee bearing ITA Nos

ITA 184/ASR/2019[2013-14]Status: DisposedITAT Amritsar20 Mar 2023AY 2013-14

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

Section 139Section 144Section 147Section 148Section 2Section 250

…S letter No NMS/AAIPT2526L/1307825 issued vide No 211 dated 10.08.2016 to the assessee. The reasons recorded cannot be supplied subsequent to the recording of such reasons in the form of an order rejecting the objections (Northern Exim (P) Ltd. v. DCIT [2013] 357 ITR 586 (Del) referred) I.T.A. Nos. 182/Asr/2019 16 I.T.A. Nos. 183 & 184/Asr/2019 iv. It is submitted that Non-Filers Monitoring System (in short “NMS”), is a monitoring system of IT Department that identifies the people who are liable to file taxes (i.e. with annual income more than Rs 250,000/-), but have not filed the return. Surprisingly the NMS l…

SH. NIRBHAY TREHAN,JAMMU vs. DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, JAMMU

In the result, the appeals of the assessee bearing ITA Nos

ITA 183/ASR/2019[2010-11]Status: DisposedITAT Amritsar20 Mar 2023AY 2010-11

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

Section 139Section 144Section 147Section 148Section 2Section 250

…S letter No NMS/AAIPT2526L/1307825 issued vide No 211 dated 10.08.2016 to the assessee. The reasons recorded cannot be supplied subsequent to the recording of such reasons in the form of an order rejecting the objections (Northern Exim (P) Ltd. v. DCIT [2013] 357 ITR 586 (Del) referred) I.T.A. Nos. 182/Asr/2019 16 I.T.A. Nos. 183 & 184/Asr/2019 iv. It is submitted that Non-Filers Monitoring System (in short “NMS”), is a monitoring system of IT Department that identifies the people who are liable to file taxes (i.e. with annual income more than Rs 250,000/-), but have not filed the return. Surprisingly the NMS l…

SMT. BANI TREHAN,JAMMU vs. DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, JAMMU

In the result, the appeals of the assessee bearing ITA Nos

ITA 182/ASR/2019[2010-11]Status: DisposedITAT Amritsar20 Mar 2023AY 2010-11

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

Section 139Section 144Section 147Section 148Section 2Section 250

…S letter No NMS/AAIPT2526L/1307825 issued vide No 211 dated 10.08.2016 to the assessee. The reasons recorded cannot be supplied subsequent to the recording of such reasons in the form of an order rejecting the objections (Northern Exim (P) Ltd. v. DCIT [2013] 357 ITR 586 (Del) referred) I.T.A. Nos. 182/Asr/2019 16 I.T.A. Nos. 183 & 184/Asr/2019 iv. It is submitted that Non-Filers Monitoring System (in short “NMS”), is a monitoring system of IT Department that identifies the people who are liable to file taxes (i.e. with annual income more than Rs 250,000/-), but have not filed the return. Surprisingly the NMS l…

BALLELA SAI SREE ,NELLORE vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 9/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

KARTHIK RAGHUPATHI REDDY PADI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 83/HYD/2023[2019-20]Status: DisposedITAT Hyderabad28 Feb 2023AY 2019-20

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

KAUSHIK REDDY PADI ,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 82/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

KAUSHIK REDDY PADI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 81/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

SAINATH REDDY PADI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 80/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

BALLELA SAI SREE,NELLORE vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 8/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

SAINATH REDDY PADI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 79/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

RAJESH KUMAR SURANA,R R DIST vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 78/HYD/2023[2019-20]Status: DisposedITAT Hyderabad28 Feb 2023AY 2019-20

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

SARITHA AGARWAL,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 77/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

SARITHA AGARWAL,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 76/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

SARITHA AGARWAL ,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 75/HYD/2023[2016-17]Status: DisposedITAT Hyderabad28 Feb 2023AY 2016-17

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

ANDEM SANDHYA REDDY,RANGA REDDY vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 7/HYD/2023[2019-20]Status: DisposedITAT Hyderabad28 Feb 2023AY 2019-20

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

BORRA PRAVEENA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 6/HYD/2023[2019-20]Status: DisposedITAT Hyderabad28 Feb 2023AY 2019-20

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

ISANAKA MASTHAN REDDY,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 5/HYD/2023[2019-20]Status: DisposedITAT Hyderabad28 Feb 2023AY 2019-20

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

VAMSI KRISHNA REDDY GOTEKE,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 46/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

VAMSI KRISHNA REDDY GOTEKE,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 45/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…ng Officer. The reasons which are recorded cannot be supplemented by affidavits. The imposition of that requirement ensures against an arbitrary exercise of powers under section 148.” (Emphasis supplied) 4. In the case of Northern Exim (P) Ltd vs DCIT [2013] 357 ITR 586 (Delhi), the Hon’ble High court held that having regard to the entire scheme and purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorised to refer to any other reason even if it can be oth…

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