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“reopening of assessment”

ReassessmentSections 147-151Sections 147-1514,262 judgments

HIMANSHU DAKSHESHKUMAR KATWALA,KHAMBHAT ANAND vs. INCOME TAX OFFICER, WARD-1(3)(1), PETLAD

In the result, the appeal of the assessee is allowed

ITA 199/AHD/2026[2017-2018]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2017-2018

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Hardik J Raval & Vivek D Rao, ARsFor Respondent: Shri Girish Parihar, Sr. DR
Section 115BSection 132Section 143(3)Section 147Section 69A

section 271(1)(c), without making any change to the assessed income or addition. 7. With respect to the grounds relating to reopening of assessment under section 147 and addition of Rs. 29,81,262/- under section 69A of the Act, the Ld. CIT(Appeals) held that these issues pertained

DEPUTY COMMISSIONER OF INCOME TAX, GANDHINAGAR vs. GUJARAT STATE PETROLEUM CORPORATION LIMITED, GANDHINAGAR

ITA 1254/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

hereinafter referred to as ‘the Act’) relating to the Assessment Years 2014-15 and 2015-16 respectively. Since common issue of challenging the reopening of assessment, disallowance made u/s 14A r.w.r. 8D and u/s. 115JB of the Act are involved in both the assessment years, for the sake of convenience ... Generation of Power, etc. The details of Returns of Income filed, assessment completed u/s. 143(3), appeals filed before CIT(A) and thereafter reopening of assessments are as follows: A.Y. 2014-15 Date Particulars Remarks 29/11/2014 Original ROI filed (-) 24,24,28,198/- 28/12/2017 Assessment Order u/s 143(3) Disallowance

DEPUTY COMMISSIONER OF INCOME TAX, GANDHINAGAR vs. GUJARAT STATE PETROLEUM CORPORATION LIMITED, GANDHINAGAR

ITA 1249/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

hereinafter referred to as ‘the Act’) relating to the Assessment Years 2014-15 and 2015-16 respectively. Since common issue of challenging the reopening of assessment, disallowance made u/s 14A r.w.r. 8D and u/s. 115JB of the Act are involved in both the assessment years, for the sake of convenience ... Generation of Power, etc. The details of Returns of Income filed, assessment completed u/s. 143(3), appeals filed before CIT(A) and thereafter reopening of assessments are as follows: A.Y. 2014-15 Date Particulars Remarks 29/11/2014 Original ROI filed (-) 24,24,28,198/- 28/12/2017 Assessment Order u/s 143(3) Disallowance

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

ITA 1166/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

hereinafter referred to as ‘the Act’) relating to the Assessment Years 2014-15 and 2015-16 respectively. Since common issue of challenging the reopening of assessment, disallowance made u/s 14A r.w.r. 8D and u/s. 115JB of the Act are involved in both the assessment years, for the sake of convenience ... Generation of Power, etc. The details of Returns of Income filed, assessment completed u/s. 143(3), appeals filed before CIT(A) and thereafter reopening of assessments are as follows: A.Y. 2014-15 Date Particulars Remarks 29/11/2014 Original ROI filed (-) 24,24,28,198/- 28/12/2017 Assessment Order u/s 143(3) Disallowance

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

ITA 1165/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

hereinafter referred to as ‘the Act’) relating to the Assessment Years 2014-15 and 2015-16 respectively. Since common issue of challenging the reopening of assessment, disallowance made u/s 14A r.w.r. 8D and u/s. 115JB of the Act are involved in both the assessment years, for the sake of convenience ... Generation of Power, etc. The details of Returns of Income filed, assessment completed u/s. 143(3), appeals filed before CIT(A) and thereafter reopening of assessments are as follows: A.Y. 2014-15 Date Particulars Remarks 29/11/2014 Original ROI filed (-) 24,24,28,198/- 28/12/2017 Assessment Order u/s 143(3) Disallowance

NARAYAN BARTER PRIVATE LIMITED,KOLKATA vs. INCOME TAX OFFICER,WARD-6(1),KOLKATA, KOLKATA

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

ITA 2572/KOL/2025[2011-12]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 147Section 148Section 151Section 250Section 271(1)(c)Section 68

that the orders passed by the lower authorities are arbitrary, unjust and bad in law and on facts. 2. For that the reopening of assessment u/s 147 based on alleged issuance of notice u/s 148 dated 26.03.2018 is invalid and void ab initio, as no such notice was served upon ... during the FY 2010-11. Based on this information, the Ld. AO noted that income of the assessee had escaped assessment and he reopened the assessment u/s 147 of the Act. Notices u/s 143(2) and 142(1) of the Act were issued and a show cause notice dated

PRATIK RAVJIBHAI KACHAROLA,MORBI vs. ITO, WARD-1, MORBI, MORBI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 692/RJT/2025[2017-18]Status: DisposedITAT Rajkot13 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 692/Rjt/2025 Assessment Year: (2017-18) Pratik Ravjibhai Kacharola Vs. The Ito, Ward – 1 4-Anumpam Society, B/H. Aayakar Bhavan, Race Course Akshardham Apartment, Ring Road, Rajkot – 360001 Ravapar Road, Morbi - 363641 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bwrpk4078C (Appellant) (Respondent)

For Appellant: Shri Abhimanyu Singh Yadav, Ld. Sr. DRFor Respondent: 18/02/2026
Section 147Section 148Section 148ASection 68

challenging the initiation of proceedings u/s 147, although no specific issues have been raised as to for what reasons he considers that the reopening of assessment is bad in law. These grounds are, therefore, dismissed lacking in substance, evidence and facts. Ground No. 3 is against the addition made

SMT. SANTOSH BAMALWA,DIBRUGARH vs. ACIT, CIRCLE-1, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 348/GTY/2025[2011-12]Status: DisposedITAT Guwahati13 Mar 2026AY 2011-12

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumarsmt. Santosh Bamalwa Acit, Circle-1 C/O A.K. Varma, Ground Floor, Aayakar Bhawan, 2Nd Floor, Vs. Mahalaya Road, Dibrugarh- Milan Nagar, Dibrugarh-786003, 786001, Assam Assam (Appellant) (Respondent) Pan No. Aedpb9900P Assessee By : Shri S.K. Tulsiyan, Advocate Revenue By : Shri Santosh Kumar Karnani, Addl. Cit Date Of Hearing: 09/03/2026 Date Of Pronouncement: 13/03/2026 O R D E R

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Santosh Kumar Karnani, Addl
Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 68

Santosh Bamalwa Vs ACIT 10. Since we have allowed the appeal of the assessee on merit, the legal issue raised challenging the reopening of assessment is not adjudicated at this stage and is being left open to be decided later if the need arises for the same

POREDDY SAMBASIVA REDDY,KADIRI vs. ITO, WARD-1, HINDUPUR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1862/HYD/2025[2018-19]Status: DisposedITAT Hyderabad13 Mar 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1862/Hyd/2025 ("नधा"रणवष"/ Assessment Year: 2018-19) Poreddy Sambasiva Reddy, Vs. Income Tax Officer, Kadiri. Ward-1, Pan: Bibpr4972G Hindupur. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Nvv Gopalal Krishna, Ca Assessee Represented By राज"वका""त"न"ध"व/ : Dr. Sachin Kumar, Sr.Ar Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 09/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 13/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Poreddy Sambasiva Reddy, Kadiri (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 22/10/2025 For The Assessment Year (“A.Y.” 2018-19. Poreddy Sambasiva Reddy Vs. Ito 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 142(1)Section 144Section 147Section 148Section 250Section 69A

appellants real income OR capacity. The addition being based on presumption and not evidence deserves to be deleted in entirety. 7. Invalid Reopening of Assessment u/s 147 The reassessment initiated u/s 148 was bad in law and void ab initio since it was based solely on Insight Portal flagged information

GRANULES INDIA LIMITED,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is dismissed

ITA 1289/HYD/2025[2010-11]Status: DisposedITAT Hyderabad13 Mar 2026AY 2010-11

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआयकर अपील सं / Ita No.1289/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2010-11) Granules India Limited Vs. Dcit- Circle -2(1) 15Th Floor, Granules Tower Signature Tower, Botanical Garden Road Sy. No. 6(P) Of Kondaput Kondapur, Hyderabad – 500084 Sy. No. 37 Of Kothaguda Telangana Opp. Botanical Gardens Serilingampalluy, R.R. District Pan: Aaacg7369K Hyderabad-500084, Telangana (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

Section 10BSection 143(3)Section 148Section 154Section 271(1)(c)

learned Commissioner of Income-tax (Appeals)-12, Hyderabad erred by confirming the assessment order passed by the learned Assessing Officer who erroneously reopened the assessment based on information received by him from the audit party (RAP), which constitutes a mere change in opinion and not "new material" which is very ... legal grounds taken by the assessee challenging validity of the reopening of the assessment by holding that the arguments of the appellant that reopening of assessment is based on “change of opinion” without there being any fresh tangible material is incorrect and misconceived. Further, the argument of the assessee that

BISHNUPRIYA BIJAYCHANDRA MAHANTY,NAVI MUMBAI vs. INCOME TAX OFFICER, MUMBAI

In the result, appeal of the assessee is appeal of the assessee is allowed for statistical allowed for statistical purpose

ITA 4477/MUM/2025[2018-2019]Status: DisposedITAT Mumbai13 Mar 2026AY 2018-2019

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2018-19 Bishnupriya Bijaychandra Mahanty Ito, Ward 28(1)(1), Mumbai 204 Plot 13/A Wing Siddhivinayak It-Office, Vashi Railway Vs. Chs, Sector 6, Ghansoli, Navi Station Building, Mumbai 400701, Navi Mumbai- 400703 Authroised Person Add: 218, Ratna High Street, Naranpura, Ahmedabad- 380013 Pan No. Btdpm 7308 A Appellant Respondent

For Respondent: Mr. Pritesh L. Shah (Virtually
Section 1Section 148Section 148ASection 149Section 69

section 1 of section 149 of the viso to sub section 1 of section 149 of the Act which bars the reopening of assessment for which notice U/S Act which bars the reopening of assessment for which notice U/S Act which bars the reopening of assessment for which notice

BMR OVERSEAS LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(2), C.R. BUILDING DELHI 110002, DELHI

In the result the appeal of the assessee is allowed

ITA 6646/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Bmr Overseas Limited, Vs. Dcit, Circle 4(2), Zb-33/487, Plot No. 4 & 5, C.R. Building, Dilshad Garde New Delhi Industrial Area, Shahdara, Delhi – 110 095 [Pan No. Aafcb8509D) (Appellant) (Respondent)

Section 115BSection 143Section 147Section 148Section 151Section 156Section 157ASection 68

issuing a notice under Section 148. The purpose behind this procedural check is to save the assesses from harassment resulting from the mechanical reopening of assessments. 128 A table representing the prescription under the old and new regime is set out below: Regime Time limits Specified authority Section

NAMAH SHIVAYA MARKETING PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD 18(1), DELHI, DELHI

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

ITA 6011/DEL/2025[2008-09]Status: DisposedITAT Delhi13 Mar 2026AY 2008-09

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarnamah Shivaya Marketing Income Tax Officer, Private Limited, Ward-18 (1), 206, Hans Bhawan, 1 Bahadur Vs. Delhi-110002. Shah Zafar Marg, Delhi-110002 . Pan-Aabcn7435Q (Appellant) (Respondent) Assessee By Shri Suresh Kumar Gupta, Ca Department By Shri Manish Gupta, Sr. Dr Date Of Hearing 09.03.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 07.08.2025 Of The Learned Commissioner Of Income Tax (Appeals)-Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 28.11.2019 Of The Ld. Assessing Officer, Ward No.18(1), New Delhi [Hereinafter Referred As ‘The Ao’] U/S 143(3)/263 Of The Act For Assessment Year 2008-09. 2. Brief Facts Of The Case Are That Assessee Filed Return Declaring Total Income Of Rs.7,070/- On 09.07.2008. Assessment Order Dated 21.03.2016 Was Passed. Hon’Ble

Section 142(1)Section 143(3)Section 147Section 153CSection 250Section 68

order dated 17.12.2024 has held as under: “13. Both sides heard. The assessee has raised multiple arguments on jurisdictional Issue challenging validity of reopening of assessment. The assessment in the case of assessee was reopened consequent to search action carried out by the Department in the case of Surender Kumar

DCIT, CENTRAL CIRCLE-32, DELHI, DELHI vs. BSES YAMUNA POWER LIMITED, NEW DELHI

In the result, the appeal filed by the Revenue is dismissed

ITA 5474/DEL/2025[2009-10]Status: DisposedITAT Delhi13 Mar 2026AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumardcit, Bses Yamuna Power Limited, Central Circle-32, Room No.359, E2, Ara Centre, Delhi. Vs. Jhandewalan Extension, New Delhi-110055. [ Pan-Aabcc8569N (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Ms. Deepashree Rao, Adv. & Shri Shivam Gupta, Ca Department By Ms. Monika Singh, Cit-Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Revenue Is Against Order Dated 23.05.2025 Of The Learned Commissioner Of Income Tax (Appeals)-30, New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 20.12.2016 Of Ld. Assessing Officer/Dcit, Circle-5(1), New Delhi (Hereinafter Referred To As ‘The Ld. Ao’ ) U/S 147/143(3) Of The Act For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Original Return Of Income Was Filed By Assessee On 29.09.2009 U/S 139(1) Of The Act After Adjusting Brought Forward Losses Of Dcit Vs. Bses Yamuna Power Ltd.

Section 139(1)Section 143(3)Section 147Section 148Section 250

issuing notice u/s 148 of the Act. Ld. CIT(A) erred in not considering the fact that the case of the assessee was reopened for Assessment Year 2009-10 i.e. non-capitalisation of personnel costs has been confirmed by CIT(A) in assessment order passed ... period of 4 years and almost at the fag-end of the overall limitation period of 6 years. 6.1 In the reasons for reopening of assessment, the AO alleged that the income of the assessee escaped assessment, inter allia, on account of the following four issues viz.: a) Disallowance

VIKAS CHANDRAKANTBHAI SHAH,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

ITA 25/AHD/2026[2019-20]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Jignesh Parikh, ARFor Respondent: Shri C Dharani Nath, Sr. DR
Section 147Section 148Section 148ASection 151Section 68

examine the issues raised in the appeal on merits as well. In Ground Nos.1 and 2, the assessee challenged the validity of reopening of assessment and contended that the notice under section 148A(b) and order under section 148A(d) were issued without proper application of mind and that ... ought to have been provided a reasonable opportunity to present his case before the CIT(A), particularly when the issues involved relate to reopening of assessment as well as addition of substantial amount of ₹99,80,000/-. 10. Considering the totality of the facts and circumstances of the case

KASHI NATH SETH SARRAF PRIVATE LIMITED,HARDOI vs. DCIT, SITAPUR, SITAPUR

In the result, the appeal of the assessee stands allowed for\nstatistical purposes

ITA 86/LKW/2024[2012-13]Status: DisposedITAT Lucknow12 Mar 2026AY 2012-13
For Respondent: \nShri Akshay Agrawal, Advocate
Section 142(1)Section 143(3)Section 147Section 148Section 151Section 68

Copy//", "summary": { "facts": "The assessee received share application money of Rs.50,00,000/- from M/s. Sharma Hire Purchase Ltd. The Assessing Officer (AO) reopened the assessment under Section 147, making an addition of Rs.50,00,000/-. The CIT(A) dismissed the assessee's appeal.", "held": "The Tribunal held that ... reopening of assessment under Section 147 was invalid as it was beyond four years and there was no failure on the part of the assessee to disclose material facts. The addition was based on a change of opinion without proper application of mind by the AO.", "result": "Allowed", "sections

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 785/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 133ASection 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A) The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 559/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21
Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A) The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under Section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 558/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A) The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 557/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A) The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

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