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“reopening of assessment”

ReassessmentSections 147-151Sections 147-1514,262 judgments

The decision most relied on for reopening of assessment is GKN Driveshafts (India) Ltd. v. ITO (259 ITR 19), cited in 1,349 judgments on BharatTax.

Leading authorities on reopening of assessment

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

CIT v. Lovely Exports (P) Ltd.
216 CTR 195 · 2008 · Supreme Court
854
citing judgments

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

CIT v. Jet Airways (I) Ltd.
331 ITR 236 · 2011 · High Court
694
citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

CIT v. RRJ Securities Ltd.
380 ITR 612 · 2016 · High Court
689
citing judgments

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

Union of India v. Ashish Agarwal
444 ITR 1 · 2022 · Supreme Court
524
citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

PCIT v. Meenakshi Overseas Pvt. Ltd.
395 ITR 677 · 2017 · High Court
471
citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Judgments citing reopening of assessment

Income Tax Officer, Ayakar Bhavan vs. Sukaniya Properties Pvt Ltd, Mumbai

In the result, appeal of the assessee is allowed and that of the

ITA 3711/MUM/2024[2008-09]Status: HeardITAT Mumbai14 Feb 2025AY 2008-09

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Dharmesh Shah & Mitali Parekh, A/RsFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 147Section 148Section 150(1)Section 150(2)Section 250Section 68

loss/deprecation loss for the impugned assessment year. 3 आयकर अपीलीय अधिकरण INCOME TAX APPELLATE TRIBUNAL I.T.A. No. 3309/Mum/2024 I.T.A. No. 3711/Mum/2024 reasons for reopening the assessment were recorded and approval was sought from the Addl. Commissioner of Income-Tax, Central Range-3, Mumbai. The approval was granted as under:- FORM ... reply to the said question, the ld. AO had mentioned “As per Annexure”. The said annexure containing the reasons recorded for reopening the assessment is enclosed in page 7 of the paper book of the assessee which is reproduced herein for the sake of convenience:- ANNEXURE DCIT

M/S. Sukaniya Properties, Pvt. Ltd, Mumbai vs. DCIT, Central Circle -3(4), Mumbai

In the result, appeal of the assessee is allowed and that of the

ITA 3309/MUM/2024[2008-09]Status: HeardITAT Mumbai14 Feb 2025AY 2008-09

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Dharmesh Shah & Mitali Parekh, A/RsFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 147Section 148Section 150(1)Section 150(2)Section 250Section 68

file its return of income and proposing to assess/re-assess the income/re-compute the loss/deprecation loss for the impugned assessment year. 3 reasons for reopening the assessment were recorded and approval was sought from the Addl. Commissioner of Income-Tax, Central Range-3, Mumbai. The approval was granted as under:- FORM ... reply to the said question, the ld. AO had mentioned “As per Annexure”. The said annexure containing the reasons recorded for reopening the assessment is enclosed in page 7 of the paper book of the assessee which is reproduced herein for the sake of convenience:- ANNEXURE REASONS RECORDED FOR ISSUE

Magestic Premises Private Limited, Mumbai vs. ACIT CC-2, Thane

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

ITA 1540/MUM/2024[2012-13]Status: DisposedITAT Mumbai14 Feb 2025AY 2012-13

Bench: Shri Om Pakash Kant & Shri Sandeep Singh Karhailassessment Year : 2012-13

For Appellant: Shri Prateek JainFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 131Section 132(4)Section 133(6)Section 143(3)Section 147Section 148Section 153ASection 250Section 69ASection 69C

27/03/2019. In response to the notice, the assessee filed its return of income on 30/04/2019. After receipt of the reasons recorded for reopening the assessment, the assessee filed its detailed objections against the reassessment proceedings, which were disposed of. During the assessment proceedings, notice under section ... availed accommodation entry of unsecured loan from an entity controlled by Mr. Shripal Vora. 6. From the perusal of the reasons recorded for reopening the assessment, forming part of the paper book from pages 23-24, it is ostensible that the only basis for initiating the reassessment proceedings

Nirmal Kumar Agrawal, Jaipur vs. DCIT, Circle - 4, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1224/JPR/2024[2013-2014]Status: DisposedITAT Jaipur13 Feb 2025AY 2013-2014
For Appellant: Sh. Tarun Mittal, CAFor Respondent: Mrs. Swapnil Parihar, JCIT-DR
Section 133ASection 147Section 148Section 68Section 69C

facts and in the circumstances of the case and in law, ld. CIT(A) grossly erred in confirming the action ld.AO in reopening the assessment u/s 147 of the Income Tax Act, arbitrarily. 2.1 That, ld.CIT(A) has further erred in confirming the action ld.AO in reopening the assessment ... Since the said investment was made out of regular books of account thus there was no escapement of income at all and therefore reopening of assessment is not in accordance with law. 3. On the facts and in the circumstances of the case, the Ld.CIT(A) has grossly erred

M/S Mammon Concast (P) Ltd., Agra vs. ITO, Ward-2(1)2, Agra

ITA 77/AGR/2023[2012-13]Status: DisposedITAT Agra12 Feb 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwal

For Appellant: Sh. Anurag Sinha, AdvFor Respondent: Sh. Shalendra Shrivastava, Sr. DR

Page 1 ITA No.77/Agr./2023 M/s Mammon Concast P. Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL “DB” BENCH, AGRA BEFORE

Sonavati Devi, Sitamarhi vs. ITO, Ward- 2 (5), Sitamarhi

In the result, appeal of the assessee stands allowed

ITA 242/PAT/2024[2018-19]Status: DisposedITAT Patna12 Feb 2025AY 2018-19

Bench: Sri Sanjay Garg

Section 147Section 250

assessee has brought my attention to the impugned assessment order. A perusal of the impugned assessment would reveal that the Assessing Officer has reopened the assessment in this case u/s. 147 of the Act stating that the assessee has withdrawn an amount of Rs.1,70,47,000/- from her bank ... Withdrawal of her money from a bank account in no circumstances can be assumed to be a case of escapement of income. The reopening of assessment is not sustainable on this score alone. The reopening of the assessment is hereby quashed. The impugned addition is accordingly deleted

Sushila Choudhary, Jaipur vs. Income Tax Officer, NFAC, Delhi

ITA 638/JPR/2024[2013-14]Status: DisposedITAT Jaipur12 Feb 2025AY 2013-14
For Appellant: Shri Nikhilesh Katariya, C.AFor Respondent: Shri Dinesh Badgujar, Addl.CIT (Thr. V.C.)
Section 139(1)Section 144BSection 147Section 148Section 292BSection 69A

held that, if the AO for whatever reason has reason to believe that, income has escaped assessment it confers jurisdiction to reopen the assessment. The relevant portion of the above decision is reproduced as under: "16. Section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable ... other words if the Assessing Officer for whatever reason has reason to believe that income has escaped assessment it confers jurisdiction to reopen the assessment. It is however to be noted that both the conditions must be fulfilled if the case falls within the ambit of the proviso to section

Ratna Infrastructure Projects Private Limited, Hyderabad vs. ITO, Ward-3(3), Hyderabad

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

ITA 132/HYD/2023[2012-13]Status: DisposedITAT Hyderabad12 Feb 2025AY 2012-13

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2012-13 Ratna Infrastructure Projects Vs. The Income Tax Officer, Ward –3(3), Private Limited, Hyderabad. Hyderabad. Pan : Aadcr5836P. (Assessee) (Respondent) Assessee By: Shri Mohd. Afzal, Advocate. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 20.01.2025 Date Of Pronouncement: 12.02.2025

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri B. Balakrishna, CIT-DR
Section 143(3)Section 148Section 40A(3)

first issue that came up for our consideration from additional grounds of appeal filed by the assessee is the validity of reopening of assessment u/s 147 of the Act and the consequent assessment order passed by the Assessing Officer under section 143(3) r.w.s 147 of the Income ... called for specific information vide question no.16, 16 for which the assessee has furnished the complete details of expenditure. Therefore, the reopening of assessment on the very same issue based on subsequent information received from ADIT, Investigation, Kolkata, is a change of opinion. In this regard, he relied upon

ACIT, Circle-2(1), Hyderabad vs. Y S Jagan Mohan Reddy, Kadapa

In the result, cross objection filed by the assessee is

ITA 670/HYD/2022[2011-12]Status: DisposedITAT Hyderabad12 Feb 2025AY 2011-12

Bench: Shri Manjunatha G. & Shri K.Narasimha Chary

For Appellant: Shri C.A.Vijay Mehta, ARFor Respondent: Ms.M.Narmada, CIT-DR and
Section 132Section 56(1)(vii)

arrat arftciia aferaer, gacrare FIs IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad Before Shri Manjunatha G., Accountant

Sssp Consultant and Techno Services Private Limited, Mumbai vs. ACIT, Mumbai

In the result, both the appeals of the assessee are allowed

ITA 719/MUM/2024[2015-16]Status: DisposedITAT Mumbai12 Feb 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri B.R. Baskaran

For Appellant: Shri Naresh JainFor Respondent: Ms. Monika H. Pande
Section 133ASection 147Section 148

Commissioner of Income Tax (Appeals)-51, Mumbai [„Ld.CIT(A)‟]. In both the years, the assessee inter alia, is challenging the validity of reopening of assessment. 2. We heard the parties on the legal issue of validity of reopening of assessment. 3. The facts relating to the case are stated ... case of Shri Pushpendra Bansal Group on 05-09-2019. The assessee was also covered by the survey operation. Subsequent thereto, the AO reopened the assessment of both the years under consideration. The reasons recorded by the AO for reopening of the assessment of both the years are extracted below

Sssp Consultant and Techno Services Private Limited, Mumbai vs. ACIT, Mumbai

In the result, both the appeals of the assessee are allowed

ITA 717/MUM/2024[2014-15]Status: DisposedITAT Mumbai12 Feb 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri B.R. Baskaran

For Appellant: Shri Naresh JainFor Respondent: Ms. Monika H. Pande
Section 133ASection 147Section 148

Commissioner of Income Tax (Appeals)-51, Mumbai [„Ld.CIT(A)‟]. In both the years, the assessee inter alia, is challenging the validity of reopening of assessment. 2. We heard the parties on the legal issue of validity of reopening of assessment. 3. The facts relating to the case are stated ... case of Shri Pushpendra Bansal Group on 05-09-2019. The assessee was also covered by the survey operation. Subsequent thereto, the AO reopened the assessment of both the years under consideration. The reasons recorded by the AO for reopening of the assessment of both the years are extracted below

Rekha Chandrakant Padalkar, Kandivali (East) vs. Income Tax Officer 42(3)(2), Mumbai

Appeal is allowed

ITA 6554/MUM/2024[2017-18]Status: DisposedITAT Mumbai12 Feb 2025AY 2017-18

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am) Rekha Chandrakant Padalkar Ito 42(3)(2) 701/702 B Wing, Gokul Kautilya Bhavan Paradise, Thakur Complex Vs. Bandra Kurla Kandivali East, Mumbai Complex, Bandra 400 101. East, Mumbai-51. Pan : Awdpp8597Q Appellant Respondent

For Appellant: Shri Nihar Ranjan SamalFor Respondent: Shri Dinar Prakash Daptari
Section 147Section 148Section 148ASection 250Section 50CSection 54

entire assessment be treated as bad in law. The Appellant prays that the entire assessment be treated as bad in law. Validity of Reopening of assessment 2. The learned CIT(A) erred in law while upholding the reassessment u/s. 147 of the Act without following proper guidelines, procedures and directives

Samtel India Ltd., New Delhi vs. ACIT, Circle- 22(1), New Delhi

In the result appeal of the assessee is allowed

ITA 7101/DEL/2018[2007-08]Status: DisposedITAT Delhi12 Feb 2025AY 2007-08

Bench: Shri Vikas Awasthy & Shri Manish Agarwalasst. Cit, Samtel India Limited, Circle-22(1), 501, Copia Corporate Vs. New Delhi. Suites, District Centre Jasola, New Delhi-110025 Pan-Aaacs0390N (Appellant) (Respondent) Assessee By Shri D.C. Garg, Ca Department By Shri Sahil Kumar Bansal, Sr. Dr Date Of Hearing 04/02/2025 Date Of Pronouncement 12/02/2025 Order Per Manish Agarwal, Am: This Is Appeal Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals)-8, New Delhi (“The Cit(A)” For Short) In Appeal No.32/13-14 Dated 27/01/2015 For Assessment Year 2007-08. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. That The Learned Commissioner Of Income Tax (Appeals)-Viii, New Delhi, Has Erred In Law As Well As On Facts & In Circumstances Of The Case In Upholding Action Of The Assessing Officer In Reopening The Assessment Under Samtel India Ltd. Vs. Acit

Section 143(3)Section 147Section 148Section 154Section 250Section 37

erred in law as well as on facts and in circumstances of the case in upholding action of the Assessing Officer in reopening the assessment under Samtel India Ltd. vs. ACIT section 148 of the Income Tax Act, 1961 without appreciation of facts and by disregarding the verdicts ... appeal before us. 8. In first ground of appeal assessee has challenged the action of the ld. CIT(A) in upholding the reopening of assessment u/s 148 when all the material facts were available on records and were duly considered at the time of completing the assessment

Asst. Commissioner of Income Tax, Central Circle-3(1), Hyderabad vs. B.Ramalinga Raju, Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 57/HYD/2020[2002-03]Status: DisposedITAT Hyderabad11 Feb 2025AY 2002-03

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)

lapsed four years, since then, the approval of commissioner of income tax (central) may kindly be accorded so as enable the undersigned to reopen the assessments u/s. 148 of the IT Act, 1961 in respect of Sri B.Rama Raju." From the above, it is seen that the assessment was reopened ... gone through the judgment and order of the learned Tribunal. It appears that the learned Tribunal has found that the reasons recorded for reopening the assessment has no nexus with the income ultimately assessed under Section 147 of the Income Tax Act, 1961. The finding of the learned Tribunal

Asst. Commissioner of Income Tax, Central Circle-3(1), Hyderabad vs. B.Ramalinga Raju, Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 55/HYD/2020[2002-03]Status: DisposedITAT Hyderabad11 Feb 2025AY 2002-03

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)

lapsed four years, since then, the approval of commissioner of income tax (central) may kindly be accorded so as enable the undersigned to reopen the assessments u/s. 148 of the IT Act, 1961 in respect of Sri B.Rama Raju." From the above, it is seen that the assessment was reopened ... gone through the judgment and order of the learned Tribunal. It appears that the learned Tribunal has found that the reasons recorded for reopening the assessment has no nexus with the income ultimately assessed under Section 147 of the Income Tax Act, 1961. The finding of the learned Tribunal

Raghuvir Retailers Pvt. Ltd., Kolkata vs. PCIT-2, Kolkata

In the result, the appeal of the assessee is allowed

ITA 919/KOL/2024[2013-14]Status: DisposedITAT Kolkata11 Feb 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Pcit-2 Raghuvir Retailers Pvt. Ltd. Aaykar Bhavan P-7, Mandawa Shikhar, 151, Sarat Chowringhee Square, Kolkata- Bose Road, Kolkata-700026, Vs. 700069, West Bengal West Bengal (Respondent) (Appellant) Pan No. Aaecr8231M Assessee By : Shri S.M. Surana, Ar Revenue By : Shri Subhendu Datta, Dr Date Of Hearing: 19.12.2024 Date Of Pronouncement : 11.02.2024

For Appellant: Shri S.M. Surana, ARFor Respondent: Shri Subhendu Datta, DR
Section 147Section 148Section 263Section 69A

assuming validly the jurisdiction to pass an order of assessment u/s 147 of the Act. It is settled law that the AO can reopen the assessment only after fulfilling the conditions laid down in the said section (section 147 of the Act) namely reason to believe that income chargeable ... examine the legal issue. For doing that first of all we have to examine whether the AO in the present case, could have reopened the assessment of the assessee by issuance of notice u/s 148 of the Act (which ultimate resulted in AO order dated 29.12.2017). 10. Now for examining

Sockalingam (HUF), Madurai vs. ACIT, Cirrcle - 1, Madurai

In the result the appeal of the assessee is allowed

ITA 1849/CHNY/2024[2013-14]Status: DisposedITAT Chennai11 Feb 2025AY 2013-14

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1849/Chny/2024 िनधा"रणवष" / Assessment Year: 2013-14 Assistant Commissioner Of Sockalingam (Huf), V. Income Tax, Plot No.423, Kk Nagar East, Circle -1, 9Th Street, Madurai – 625 020. Madurai. [Pan: Aaxhs-5962-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. T. Vasudevan, Advocate ""यथ"क"ओरसे/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 06.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.02.2025 आदेश /O R D E R

For Appellant: Shri. T. Vasudevan, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT
Section 143(3)Section 147Section 148Section 148ASection 50(1)Section 50CSection 50C(2)Section 54F

consequent proceedings are untenable in law. 4. The CIT(A) NFAC further failed to appreciate that the condition precedent for the reopening of assessment under sec.147 beyond the 4 year period as per the Proviso to the section, is that escapement of income should arise out of the failure ... assessee to disclose fully and truly all material facts and in the absence of the same, the notice under Sec.148 for reopening the assessment is without jurisdiction. 5. The CIT(A) NFAC further failed to appreciate that TOLA and the SC decision in Ashish Agarwal case would not extend

Agrawal Iron Traders, Etawah vs. Income Tax Officer Ward 2(2)(5), Etawah

ITA 31/AGR/2024[2017-2018]Status: DisposedITAT Agra10 Feb 2025AY 2017-2018

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwal

For Appellant: Sh. Prathna Jalan, CAFor Respondent: Sh. Shalendra Shrivastava, Sr. DR

Page | 1] ITA No.30/agr./2024 Agrawal Iron Traders ITA No.30/agr./2024 Agrawal Iron Traders IN THE INCOME TAX APPELLATE TRIBUNAL

Rambilash Rajaram Jajoo, Surat vs. Income Tax Officer Ward-2(2)(4), Surat

ITA 552/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) Rambilash Rajaram Jajoo (Physical Court Hearing) 429-432, Golden Point, Falsawadi, Ring Road, Surat City, Surat-395 002 [Pan : Aampj 0040 K] अपीलार्थी/Appellant Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 प्रत्यर्थी / Respondent आयकर अपील सं./Ita No. 882/Srt/2024 (Ay 2011-12) Sunita Jajoo 429-432, Golden Point, Near Bsnl Office, Falsawadi, Ring Road, Surat-395 002 [Pan: Aampj 0040 K] बनाम Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 अपीलार्थी/Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से /Assessee By Ms. Richa Toshniwal. Ca राजस्व की ओर से /Revenue By Shri Minal Kamble, Sr. Dr सुनवाई की तारीख/Date Of Hearing 23.01.2025 उद्घोषणा की तारीख/Date Of Pronouncement 10.02.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. These Two Appeals By Separate Assessee Are Directed Against The Separate Orders Of Addl/Jcit(A)-7, Kolkata/National Faceless Appeal Centre, Delhi [For Short To As "Nfac/Ld.Cit(A)] Dated 21.03.2024 & 21.04.2023 For Same

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

disclose fully or truly material facts. In view of the above facts, I am satisfied that this is a fit case for reopening of assessment u/s.147 of the I. Act 1961. Place: Surat Date: 23.03.2018 (C. ABDULRAHIMAN) Income Tax Officer, Ward 2(2)(1), Surat 18. From the reasons recorded ... listed Penny stock companies. After getting such information, assessing officer has applied his mind and then framed the reasons for reopening the assessment, therefore it is not a borrowed satisfaction. The assessing officer has also mentioned in the reasons recorded the quantity of shares sold, name of the scrip

Deputy Commissioner of Income Tax Central Circle -1(2), Nagpur vs. Vidarbha Infotech Private Limited, Nagpur

In the result, appeal by the Revenue is dismissed

ITA 76/NAG/2024[2016-17]Status: DisposedITAT Nagpur10 Feb 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke
Section 133(6)Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 250Section 263Section 44ASection 69C

which are audited u/s 44AB of IT Act as well as under the provisions of Companies Act: The present appeal is against the reopening of assessment and the additions made in the assessment order passedu/s 147 of the Act on 25/12/2018. Facts of the case: Assessee filed return of income