Parashuram Pottery Works Co. Ltd. v. ITO

106 ITR 1Supreme Court of India1977#138 most cited

What is Parashuram Pottery Works Co. Ltd. v. ITO authority for?

The principle of finality dictates that stale issues should not be reactivated, and lapse of time brings repose to judicial and quasi-judicial controversies. A Commissioner cannot substitute their judgment for the Assessing Officer's unless the assessment order is legally erroneous, not merely less elaborate, thus limiting revisionary powers under Section 263.

486

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 1991 to 2026.

Also referred to as

Parashuram Pottery Works Co. Ltd. v. ITO · Parashuram Pottery · Section 263 · erroneous order · revision power · substitution of Commissioner's judgment · finality of assessment · stale issues · judicial precedent · 106 ITR 1

Sections most often in play

Section 143(3)Section 147Section 148Section 263Section 142(1)Section 151Section 69CSection 68

Issues it is cited on

section 10(31a)section 100section 76section 142(2c)section 153b(1)(b)section 150(1)section 153b(1)rectification under section 154section 144basection 33(4)section 206csection 158bc

Judgments citing Parashuram Pottery Works Co. Ltd. v. ITO

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 494/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh24 Feb 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…ues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity [see Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. It was further observed as under:- "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income- tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him…

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 488/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…ues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity [see Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. It was further observed as under:- "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income- tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him…

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 290/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…ues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity [see Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. It was further observed as under:- "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income- tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him…

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 289/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…ues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity [see Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. It was further observed as under:- "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income- tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him…

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 288/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…ues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity [see Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. It was further observed as under:- "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income- tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him…

M/S GANESH DASS HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 287/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…ues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity [see Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. It was further observed as under:- "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income- tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him…

SH. ARVAIL SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 286/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…ues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity [see Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. It was further observed as under:- "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income- tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him…

MATA BALA SUNDRI RICE MILL,VILLAGE KANIPLA, DISTRICT YAMUNA NAGAR vs. INCOME TAX OFFICER-WARD-3, YAMUNA NAGAR, YAMUNAGAR

In the result, appeal of the assessee is allowed

ITA 906/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh20 Feb 2026AY 2013-14

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 906/Chd/2025 "नधा"रण वष" / Assessment Year: 2013-14 Mata Bala Sundri Rice Mill, The Ito, C/O Jagdamba Rice & General Mills, Vs Ward-3, Village-Kanipla, Po-Sarawan, Yamuna Nagar. Yamuna Nagar. "थायी लेखा सं./Pan No: Aatfm9813G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Dhruv Goel, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 12.02.2026 Date Of Pronouncement : 20.02.2026

For Appellant: Shri Dhruv Goel, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 143(3)Section 147Section 148

…e all material facts fully and truly. In support of his contention, he relied upon a large number of decisions, namely, Duli Chand Singhania Vs ACIT 269 ITR 192 (P&H) and NDTV Vs DCIT 424 ITR 607 (S.C.), Parashuram Pottery Works Co. Ltd. v. Income Tax Officer 106 ITR 1. 3. The ld. DR, on the other hand relied upon the orders of Revenue Authorities and submitted that AO got an information that assessee has not disclosed the sale of broken rice which was a bye-product during hulling the rice. Hence, AO has rightly reopened the assessment. 4. We have duly considered the rival contentions and gone through the record…

STUDDS ACCESSORIES LIMITED,FARIDABAD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, FARIDABAD, FARIDABAD

In the result, appeal filed by the assessee is allowed

ITA 3570/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

For Appellant: Sh. Vishal Kalkra, Adv &For Respondent: Sh. Avikal Manu, CIT DR
Section 14Section 143(3)Section 144BSection 263Section 80J

…i - Trib.) - Diamines & chemicals Ltd. vs. PCIT: [2022] ITA No. 1472/Ahd/2015 & h) It is also settled law that section 263 proceedings cannot be initiated with a view to start fishing and roving inquiries [refer Parashuram Pottery Works Co. Ltd. vs ITO [1977] 106 ITR 1 (SC), CIT vs. Gabriel India Ltd.: [1993] 203 ITR 108 (Bombay), Spectra Shares & Scrips (P.) Ltd. vs CIT: [2013] 354 ITR 35 (Andhra Pradesh), Narayan Tatu Rane vs ITO (supra)]. c) Moreover, it is pertinent to note that in the impugned order passed under section 263 of the Act, the PCIT has not rendered any specific or speaking finding on the allega…

ELECTRIC LAMP AND COMPONENT MANUFACTURERS ASSOCIATION OF INDIA,NEW DELHI vs. CIT EXEMPTION, DELHI

In the result, the appeal of the appellant society is allowed

ITA 4309/DEL/2025[-]Status: DisposedITAT Delhi21 Jan 2026

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalelectric Lamp & Component Cit (Exemption) Manufacturers Association Of Delhi. India, Vs. (Civic Centre Minto Road, C/O Kapil Goel, Adv. Delhi-110002). G-8/5 Sector-11, Opposite Sfs Apartment, Rohini, Delhi-110085. Pan-Aaate0234A (Appellant) (Respondent) Assessee By Dr. Kapil Goel, Adv. Department By Shri Jitender Singh, Cit-Dr Date Of Hearing 24/11/2025 Date Of Pronouncement 21/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Exemptions) Dated 30.06.2025 Passed U/S 12Ab(1)(B) Of The Income Tax Act, 1961 (‘The Act’ In Short) Rejecting The Registration Applied By The Assessee U/S 12A Of The Act For The Period From Assessment Years 2021-22 To 2025-26. 2. Brief Facts Of The Case Are That The Appellant Society Was Incorporated On 29.06.1970 & Registered U/S 12A Of The Act In Terms Of Registration Certificate Issued On 30.09.1986. Thereafter, Assessment For Assessment Years 2013-14 & Electric Lamp & Component Manufacturers Association Of India Vs. Ito 2015-16 Were Completed On 29.03.2016 & 11.12.2017 Respectively, Wherein Assessee Was Allowed Exemption U/S 12A Of The Act. The Assessee Was Granted Registration U/S 12Ab Of The Act For Assessment Year 2021-12 To 2023-24 Vide Order Dated 27.05.2021, Thereafter, Assessee Applied For Permanent Approval U/S 12A Which Was Rejected By Ld. Cit(E) Vide Order Dated 30.06.2025 & Further Cancel The Provisional Registration Granted From Assessment Year Onwards.

Section 12ASection 143(3)Section 2(15)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Electric Lamp and Component CIT (Exemption) Manufacturers Association of Delhi. India, Vs. (Civic Centre Minto Road, C/o Kapil Goel, Adv. Delhi-110002). G-8/5 Sector-11, Opposite SFS Apartment, Rohini, Delhi-110085. PAN-AAATE0234A (Appellant) (Respondent) Assessee by Dr. Kapil Goel, Adv. Department by Shri Jitender Singh, CIT-DR Date of Hearing 24/11/2025 Date of Pronouncement 21/01/2026 O R D E R PER MANISH AGARWAL, AM: The present appeal is filed by th…

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

ITA 2954/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

…A) will not confer power to assume jurisdiction to the AO to initiate reassessment proceeding. Even otherwise the apex court has also while dealing with the provision of section 147/148 of the Act in the case of Parashuram Pottery Works Co. Ltd. v. ITO [1977] 106 ITR 1 (SC) held that; "According to section 148 of the Act of 1961, before making the assessment, reassessment or recomputation under section 147, the Income-tax Officer shall serve on the assessee a notice containing all or any of the requirements which may be included in a notice under sub-section (2) of section 139; and the provisions of the Act shall…

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

ITA 2953/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

…A) will not confer power to assume jurisdiction to the AO to initiate reassessment proceeding. Even otherwise the apex court has also while dealing with the provision of section 147/148 of the Act in the case of Parashuram Pottery Works Co. Ltd. v. ITO [1977] 106 ITR 1 (SC) held that; "According to section 148 of the Act of 1961, before making the assessment, reassessment or recomputation under section 147, the Income-tax Officer shall serve on the assessee a notice containing all or any of the requirements which may be included in a notice under sub-section (2) of section 139; and the provisions of the Act shall…

INCOME TAX OFFICER(E) WARD- 2(4), NEW DELHI, CIVIC CENTRE NEW DELHI vs. PRAKASH SEWA TRUST, PASCHIM VIHAR

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 12ASection 143(3)

…ar and afterwards then to hold contrarily in sale year is simply not permissible. This is based on well accepted and acknowledged legal principle of "consistency" and "stare decisis". Refer hon'ble sc decisions in cases of Parsuram Pottery Works Co Ltd vs ITO 106 ITR 1; Radhasoami Satsang vs CIT 193 ITR 321; CIT vs Excel Industries Ltd 358 ITR 295 (three judge bench); Shasun Chemical & Drugs Lid vs CIT 388 ITR 1; Godrej & Boyce Manufacturing Company Ltd vs DCIT 394 ITR 449; PCIT vs Maruti Suzuki ltd 416 ITR 1). Nothing prevented revenue to hold in purchase year and later on that assessee trust has not bonafidely…

SHANTI RICE MILLS,KARNAL vs. PR.CIT , KARNAL

In the result, the appeal of the assessee is dismissed

ITA 1162/DEL/2020[2015-16]Status: DisposedITAT Delhi22 Dec 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(3)Section 263Section 263(1)

…ues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi- judicial controversies as it must in other spheres of human activity. (See Parashuram Pottery Works Co. Ltd. v. ITO (1977) 106 ITR 1 (SC) at page 10) From the aforesaid definitions it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, same cannot be branded as erroneous by the Commissioner simply because, according to him, the order should have been writt…

PIYUSH GARG,AHMEDABAD vs. DCIT, CC-1(2), AHMEDABAD

In the result, the appeal of the assessee is dismissed

ITA 1590/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2022-23

For Appellant: Shri Anurag Sinha, A.RFor Respondent: Shri Uday Kishanrao Kakne, Sr. D.R
Section 115BSection 132ASection 143(1)Section 143(3)Section 154Section 271A

…he rectification order passed under section 154 substituting penalty u/s 271AAC(1), whereas the very timing and circumstances of such rectification show clear prejudice and jurisdictional overreach. In the case of Parshuram Pottery Works Co. Ltd Vs CIT (1977) 106 ITR 1 (SC) The Hon'ble Supreme Court has held as under: "It has been said that the taxes are the price that we pay for civilization. If so, it is essential that those who are entrusted with the task of calculating and realising that I.T.A No. 1590/Ahd/2025 Piyush Garg, A.Y. 2022-23 price should familiarise themselves with the relevant provisions and bec…

MICROSOFT CORPORATION (INDIA) PRIVATE LIMITED,NEW DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI

In the result, appeal filed by the assessee is allowed

ITA 2933/DEL/2025[2019-20]Status: DisposedITAT Delhi26 Nov 2025AY 2019-20
Section 143(1)Section 143(3)Section 154Section 263

…issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi judicial controversies as it must in other spheres of human activity [Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. It was further observed as under: - "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KOLKATA, KOLKATA vs. BANDHAN FINANCIAL SERVICES LIMITED, KOLKATA

In the result, the appeal of the revenue is dismissed

ITA 1139/KOL/2025[2014-15]Status: DisposedITAT Kolkata11 Nov 2025AY 2014-15

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2014-15 Dcit, Circle-1(1), Kolkata..……………… ……………...……….……….……Appellant Vs. Bandhan Financial Services Ltd....………………………….......……...…..…..Respondent Dn 32 Salt Lake, Salt Lake City, Sech Bhawan, S.O Salt Lake, Kol-700091. [Pan: Aabcg0611R] Appearances By: Shri Manas Mondal, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Biswanath Paul, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : November 11, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 11.06.2024 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2014–15. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 56 Days. The Revenue Has Filed A Petition For Condonation Of The Delay. After Considering The Reasons Cited In The Petition For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 139Section 143(2)Section 143(3)Section 250Section 37(1)Section 40A(3)

…dhan Financial Services Ltd sustained for multiple years, it would not be at all appropriate to allow the position to be changed in a subsequent year." 5.2.14. Reliance is again placed in the case of 'Parashuram Pottery Works Ltd. v. Income Tax Officer [1977] 106 ITR 1 (SC)', where, the Hon'ble Supreme Court had held the following: "It appears from the record that in several assessment years, the Revenue accepted the order of the Tribunal in favour of the assessee and did not pursue the matter any further but in respect of some assessment years the matter was taken up in appeal before the Bombay High Court but wi…

VIVEK NATHURAM GAVHANE,PUNE vs. THE PR. COMMISSIONER OF INCOME TAX, CENTRAL, PUNE

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

ITA 849/PUN/2025[2020-21]Status: DisposedITAT Pune04 Nov 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.849/Pun/2025 Assessment Year : 2020-21

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 133ASection 143(2)Section 143(3)Section 263Section 32Section 69C

…vision u/s 263 cannot be exercised with a view to initiate a roving and fishing enquiry in the matters which we have already concluded. In this regard, the observation made by the Hon’ble Supreme Court in the case of Parashuram Pottery Works Co. Ltd. vs. ITO, 106 ITR 1 (SC) is reproduced hereunder :- “From the aforesaid definitions it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him, the order s…

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

In the result, the appeals of the revenue in ITA No

ITA 712/JPR/2025[2017-18]Status: DisposedITAT Jaipur14 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 139(1)Section 153ASection 153CSection 68Section 69C

…will not confer power to\nassume jurisdiction to the AO to initiate reassessment proceeding. Even otherwise\nthe apex court has also while dealing with the provision of section 147/148 of the\nAct in the case of Parashuram Pottery Works Co. Ltd Vs ITO [ 1977] 106 ITR 1\nheld that;\n\"According to section 148 of the Act of 1961, before making the assessment,\nreassessment or recomputation under section 147, the Income-tax Officer shall\nserve on the assessee a notice containing all or any of the requirements which\nmay be included in a notice under sub-section (2) of section 139; and the\nprovisions of the Act sha…

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

In the result, the appeals of the revenue in ITA No

ITA 710/JPR/2025[2014-15]Status: DisposedITAT Jaipur14 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 139(1)Section 153ASection 153CSection 68Section 69C

…will not confer power to\nassume jurisdiction to the AO to initiate reassessment proceeding. Even otherwise\nthe apex court has also while dealing with the provision of section 147/148 of the\nAct in the case of Parashuram Pottery Works Co. Ltd Vs ITO [ 1977] 106 ITR 1\nheld that;\n\n\"According to section 148 of the Act of 1961, before making the assessment,\nreassessment or recomputation under section 147, the Income-tax Officer shall\nserve on the assessee a notice containing all or any of the requirements which\nmay be included in a notice under sub-section (2) of section 139; and the\nprovisions of the Act s…

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