“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

DCIT CC 8.2 Mumbai, Mumbai vs. Dhirubhai Hirachand Ambani, Mumbai

In the result all the appeals of the revenue are dismissed

ITA 4331/MUM/2024[2001-02]Status: DisposedITAT Mumbai09 Jan 2025AY 2001-02

Bench: Shri Amarjit Singh & Sunil Kumar Singh

For Appellant: Shri NimeshVoraFor Respondent: Smt. SanyogitaNagpal, (CIT, DR)

Section 143(1)(a)Section 147Section 148Section 250

brief is that original return of income declaring total income of Rs.517,40,430/- was filed on 30.07.2001. Subsequently, the case was reopened for assessment u/s 147 of the Act by issuance of notice u/s 148 of the Act on 23.03.2018. The reason recorded for reopening the case are reproduced ... notice are also satisfied in this case for AY 2001-02". 3. The assessing officer stated that the assessee filed objection to the reopening the assessment and the same has been rejected vide order dated 22.11.2018. Subsequently, a show cause notice u/s 142(1) of the Act was issued

DCIT CC 8.2 Mumbai, Mumbai vs. Dhirubhai Hirachand Ambani, Mumbai

ITA 4324/MUM/2024[2002 03]Status: DisposedITAT Mumbai09 Jan 2025

Bench: Shri Amarjit Singh & Sunil Kumar Singh, Juducial Member Ita Nos. 4324, 4331 & 4345 To 4348/Mum/2024 Assessment Years: 2001-02 To 2006-07

For Appellant: Shri NimeshVoraFor Respondent: Smt. SanyogitaNagpal, (CIT, DR)

Section 143(1)(a)Section 147Section 148Section 250

Assistant Commissioner of Income Tax Circle- 3(4) Mumbai, Mumbai vs. The Shipping Corporation of India Limited, Mumbai

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

ITA 1970/MUM/2024[2016-2017]Status: DisposedITAT Mumbai09 Jan 2025AY 2016-2017

Bench: Sunil Kumar Singh, Hon'Ble

For Appellant: Shri Nitesh Joshi & Neha Vikam, A/RsFor Respondent: Shri Dr. Kishor Dhule, CIT D/R

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

order dated 20th November, 2007. 11. In this case, the Assessing Officer, vide notice dated 13th March, 2003, sought to reopen the assessment by invoking the provisions of Section 11 of the said Act. At the reverse of this notice, the Assessing Office, had stated the reason for reopening. Accordingly ... APPELLATE TRIBUNAL I.T.A. No. 1752/Mum/2024 I.T.A. No. 1970/Mum/2024 this is a matter where the Assessing Officer failed to furnish the reasons for reopening of assessment whilst invoking the provisions of Section 11 of the said Act. 12. Hon'ble Supreme Court in GKN Driveshafts (India) Ltd. (supra) has, however, further

The Shipping Corporation of India, Mumbai vs. DCIT-3(4), Mumbai

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

ITA 1752/MUM/2024[2016-17]Status: DisposedITAT Mumbai09 Jan 2025AY 2016-17

Bench: Sunil Kumar Singh, Hon'Ble

For Appellant: Shri Nitesh Joshi & Neha Vikam, A/RsFor Respondent: Shri Dr. Kishor Dhule, CIT D/R

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

order dated 20th November, 2007. 11. In this case, the Assessing Officer, vide notice dated 13th March, 2003, sought to reopen the assessment by invoking the provisions of Section 11 of the said Act. At the reverse of this notice, the Assessing Office, had stated the reason for reopening. Accordingly ... TRIBUNAL I.T.A. No. 1752/Mum/2024 Ι.Τ.Α. No. 1970/Mum/2024 this is a matter where the Assessing Officer failed to furnish the reasons for reopening of assessment whilst invoking the provisions of Section 11 of the said Act. 12. Hon'ble Supreme Court in GKN Driveshafts (India) Ltd. (supra) has, however

Nildhara Ltd., Ahmedabad vs. The Income Tax Officer, Ward-3(1)(1), Ahmedabad

In the result, the Ground Nos

ITA 271/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad08 Jan 2025AY 2012-13

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri A. P. Singh, CIT DR

Section 131Section 133(1)Section 143(3)Section 147Section 68

assessee has raised the following grounds of appeal: “1. The Ld. AO has erred in law and on facts of the case reopening the assessment u/s. 147 of the Act. Under the facts and circumstances of the case, the action of reopening is without jurisdiction and in not permissible either ... against the aforesaid order passed by Ld. CIT(A). 6. With respect to Ground No. 1, in which the assessee has challenged the reopening of assessment under Section 147 of the Act, we observe that in the instant case, the assessment of the assessee was reopened on the basis

Income-Tax Officer, Ward-4(1)(1), Ahmedabad vs. Solace Capital Services Private Limited, Ahmedbad

The appeal of the Revenue is dismissed and the Cross Objection filed by the Assessee is also dismissed as infructuous

ITA 1438/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad08 Jan 2025AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri M. S. Chhajed, ARFor Respondent: Shri Rignesh Das, Sr.DR

Section 131Section 143(1)Section 143(3)Section 147Section 148Section 151Section 68

with additional grounds of appeal. The CIT(A) admitted the assessee’s additional grounds of appeal regarding the validity of the reopening of assessment, as they related to the jurisdiction of the AO and were legal in nature, going to the root of the assessment proceedings. The CIT(A) noted ... assessee filed cross objection with following grounds: 1. The order passed by the Ld. A.O. is against the law, equity and justice. 2. Reopening of assessment is bad and illegal as Ld. AO has assumed jurisdiction on the basis of reasons to suspect. 3. Reopening of assessment

Nishank Sakariya, Chennai vs. ACIT, CC-4(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 2343/CHNY/2024[2013-14]Status: DisposedITAT Chennai08 Jan 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.P.M.Kathir, AdvocateFor Respondent: Mr.Vinod D. Mudaliar, JCIT

Section 143(3)Section 148Section 14ASection 2(47)(v)

Rs.2,32,05,740/- after making addition of Rs.3,40,920/- u/s.14A of the Act. The AO in his reasons recorded for reopening the assessment for AY 2013-14, takes notes of certain events of subsequent assessment year i.e. AY 2014-15, wherein the assessee had admitted Long Term Capital ... Income Tax Act, 1961. 7. As per the settled position of law, when the jurisdiction of the Assessing Officer to reopen an assessment is challenged, the reasons recorded for re-opening of assessment has to be read on a standalone basis. Nothing can be added/nothing can be subtracted. However

Sumita Roy Chowdhury, Kolkata vs. I.T.O., Ward - 48(1), Kolkata

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 1272/KOL/2024[2009-2010]Status: DisposedITAT Kolkata08 Jan 2025AY 2009-2010

Bench: Shri Pradip Kumar Choubey & Shri Sanjay Awasthiassessment Year: 2015-16 M. A Financial Services Pvt. Ltd.……………………….……….……….……Appellant 2, Lal Bazaar Street, 1St Floor, Kol-700001.. [Pan: Aaccm0481E] Vs. Ito, Ward-4(1), Kolkata…….…………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Ar, Appeared On Behalf Of The Appellant. Shri Praveen Kishore, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 09, 2025 Date Of Pronouncing The Order : October 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. Brief Facts Of The Case Of The Assessee Are That The Assessee Filed Its Return Of Income For The A.Y 2015-16 U/S 139 Of The Act On 20.07.2015 Declaring Total Income Of Rs.9,647/-. The Said Return Was Processed U/S 143(1) Of The Act. Later On, Based On Information Received Through Itba Software Under The Head High Risk Transaction Case Notice U/S 148A(B) Of The Act Was Issued & Finally Notice U/S 148 Of The Act Was Issued On 13.07.2022. In Response, The Assessee Filed Return On 02.11.2021 Declaring Total Income Of Rs.9,647. Assessment Was Made Under Sec. 147 M. A Financial Services Pvt. Ltd Read With Section 144B Of The Act On 24.05.2023 Determining Total Income Of Rs.6,55,31,471/- Inter-Alia Making Following Addition:

Section 139Section 143(1)Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 250Section 69A

cases where income escaping assessment amounts to ₹50 lakhs or more, assessments can be reopened within ten years. The new regime prohibits reopening of assessments that were time-barred under the old regime. The provisions of section 149 of the new regime are as under: 149. (1) No notice under

Shri Vishal Mehta, Rajkot vs. The ITO Ward-2 (1) (2), Rajkot

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 77/RJT/2024[2015-16]Status: DisposedITAT Rajkot07 Jan 2025AY 2015-16

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &

Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

party, statement of deponent and their cross-examination. 3. Ld. CIT(A) has erred in law as well as on fact in upholding reopening of assessment u/s 147 of the IT Act. The appellant craves leave to amend, alter modify and/or raise additional ground of appeal.” 4. The facts ... assessee furnished the list of the persons, whose cash was remitted to assessee`s bank accounts, the revenue authorities, would have reopened the assessment of those persons whose cash was deposited in the assessee`s bank account. The ld. CIT( A) also failed to ascertain the source of the cash

Shri Vishal Mehta, Rajkot vs. The ITO Ward-2(1) (2) Rajkot, Rajkot

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 76/RJT/2024[2014-15]Status: DisposedITAT Rajkot07 Jan 2025AY 2014-15

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &

Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

Shri Vishal Mehta, Rajkot vs. The ITO Ward-2(1) (2), Rajkot

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 75/RJT/2024[2013-14]Status: DisposedITAT Rajkot07 Jan 2025AY 2013-14

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &

Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

Shri Vishal Mehta, Rajkot vs. The ITO Ward-2 (1) (2), Rajkot

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 74/RJT/2024[2012-13]Status: DisposedITAT Rajkot07 Jan 2025AY 2012-13

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &

Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

Pallav, Jamnagar vs. DCIT, Circle 2, Jamnagar

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

ITA 473/RJT/2024[2017-18]Status: DisposedITAT Rajkot07 Jan 2025AY 2017-18

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

For Appellant: Shri Chetan Agarwal & Shri Brijesh ParekhFor Respondent: Shri Sanjay Punglia, Ld. CIT. DR

Section 142(1)Section 143(2)Section 147Section 148Section 68

case and remand report of assessing officer. 2. Ld. CIT(A) erred in law as well as on fact in upholding reopening of assessment on insufficient, invalid, incorrect and vague reasons recorded for reopening.” 3. Succinctly, the factual panorama of the case is that assessee before us is a Firm ... confirmed the action of ITA No.473/RJT/2024 – A.Y.- 2017-18 Pallav vs. DCIT the assessing officer. The ld. CIT(A) noticed that reopening of assessment done by the assessing officer is valid and not only that commencement of reassessment proceedings was also valid, and in reassessment proceedings, it has only

DCIT It 3 3 2 Mumbai, Mumbai vs. Pramarica Aspf II Cyprus Holding Ltd, Ctprus

The appeal of the revenue is dismissed

ITA 3041/MUM/2024[2013-14]Status: DisposedITAT Mumbai07 Jan 2025AY 2013-14

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Ms. Hirali Desai/ Shri YogeshFor Respondent: Shri Krishna Kumar, Sr. DR

Section 115A(1)(a)Section 143(1)Section 144CSection 148

mere change of opinion. The CIT(A) allowed the contention in favour of the assessee stating that the AO is not justified in reopening the assessment when true and full disclosure of all material facts were disclosed by the assessee during the original reassessment proceedings itself. The CIT(A) also ... section 147 of the Act. 1.4. Erred in holding that there was no change of opinion by Ld AO in the second reopening of assessment. Pramarica ASPF II Cyprus Holding Ltd. 1.5. Erred in not appreciating that the Ld. AO had erred in short grating TDS credit amounting

DCIT It 332 Mumbai, Income Tax vs. Pramarica Aspf II Cyprus Holding Ltd, Cyprus

The appeal of the revenue is dismissed

ITA 3040/MUM/2024[2015-16]Status: DisposedITAT Mumbai07 Jan 2025AY 2015-16

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Ms. Hirali Desai/ Shri YogeshFor Respondent: Shri Krishna Kumar, Sr. DR

Section 115A(1)(a)Section 143(1)Section 144CSection 148

Nidhi Goyal, Haryana vs. DCIT, Hisar

In the result, the cross objection filed by the assessee in AY 2006-07 is allowed and the appeal filed by the Revenue in AY 2006-07 is dismissed

ITA 886/DEL/2024[2022-23]Status: DisposedITAT Delhi07 Jan 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shris.Rifaur Rahman

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Javed Akhtar, CIT DR

Section 143(3)Section 271(1)(c)Section 274

deserve to be dismissed.” He submitted that the ld. CIT (A) has decided the issue relying on various case laws holding that the reopening of assessment under section 147 of the Act and the issuance of notice u/s 148 of the Act cannot be sustained and accordingly held that ... basis of report of DDIT (Inv.). Therefore, we are inclined to accept the findings given by the ld. CIT (A) that reopening of assessment u/s 147 of the Act and the issuance of notice u/s 148 of the Act cannot be sustained. Accordingly, we uphold the order

Lalit Kapoor, Rohtak vs. CIT Appeal, Income-Tax Rohtak

In the result, appeal of the assesse is allowed for statistical purpose in the terms aforesaid

ITA 3927/DEL/2024[2017-18]Status: DisposedITAT Delhi07 Jan 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.3927/ िद"ी /2025 (िन.व. 2012-13) Sharad Panwar, B-527, Mig Dda Flats, East Of Loni Road, Shahdara, Delhi 110093 ...... अपीलाथ"/Appellant Pan: Bcrpp-9210-P बनाम Vs. Income Tax Officer, Ward-58(3), R. No. 317, D-Block, Vikas Bhawan, ..... "ितवादी/Respondent New Delhi 110002 Assessee By : None Department By: Ms. Harpreet Kaur Hansra, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 19/11/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 19/11/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 28.06.2024, For Assessment Year 2012-13 2. The Appeal Is Time Barred By 288 Days. The Assessee Has Filed An Application Supported By An Affidavit Citing Reasons Causing Delay In Filing Of Appeal. After Perusal Of The Same, We Are Satisfied That Delay In Filing Of Appeal Is Not Intentional, The Delay Has Been Caused For The Reasons Stated In Petition Which Appears To Be Bonafide. Thus

For Appellant: NoneFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 144Section 148Section 2(41)Section 56(2)(vi)Section 69A

account of unexplained cash deposits in the bank account of the assessee with HDFC Bank Ltd. In First Appellate proceedings, the assessee assailed reopening of assessment as well as addition on merits. The CIT(A) vide impugned order granted part relief to the assessee on merits and restricted the addition

Viswanadh Kandula, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

In the result, appeals of the assessee for the A

ITA 1085/HYD/2024[2018-19]Status: DisposedITAT Hyderabad07 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1084 To 1088 & 1027/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2014-15 To 2019-20) M/S Ace Tyres (P) Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/09/2025 घोषणा की तारीख/Pronouncement: 24/09/2025 आदेश/Order Per Vijay Pal Raothese Six Appeals By The Assessee Are Directed Against The Six Separate Orders Dated 29/05/2025, 30/05/2025, 04/06/2025, 096/06/2025, 17/06/2025 & 14/07/2025 Of The Learned Cit (A)-11, Hyderabad Arising From The Assessment Order Passed U/S 143(3) R.W.S. 147 Of The Act, Pursuant To The Search & Seizure Operations U/S 132 Of The Act, Dated 04/01/2023 In Case Of Exel Group Of Companies Including The Assessee For The A.Ys 2014-15 To 2019-20 Respectively. Since Common Issues Are Raised In These Group Of Six Appeals Arising From Same Facts & Search & Seizure Operation, Therefore, For The Sake Of Convenience, All Page 1 Of 78

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR

Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

Officer has recorded the Page 13 of 78 ITA Nos 1084 to 1088 and 1207 of 2025 ACE Tyres P Ltd reasons for reopening the assessment u/s 147 of the Act in pursuant to the search & seizure action u/s 132 of the Act carried in case of the assessee ... that where Joint Commissioner recorded satisfaction in mechanical manner and without application of mind to accord sanction for issuing notice under section 148, reopening of assessment was invalid." Page 67 of 78 ITA Nos 1084 to 1088 and 1207 of 2025 ACE Tyres P Ltd Apex Court in the aforesaid

Vijay Sadwal, Faridabad Haryana vs. ITO, Ward-2(5), Faridabad

In the result, appeal of Revenue in ITA No

ITA 3554/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandrathe Income-Tax Officer Vs. Shri Paras Jain Ward – 58(7) 164-B, Gali No. - 5 Delhi Azad Nagar, East Delhi

For Appellant: Shri Ajit Gandhi, CAFor Respondent: Ms. Harpreet Kaur Hansra Sr. DR

Section 147Section 148Section 148ASection 151ASection 69Section 69C

hand, the appellant has provided sufficient compliance during the course of assessment proceedings. What was the information in his possession that led to reopening of assessment was also not mentioned either in the order passed u/s 148A(d) or from the final assessment order passed

Yogesh Ashok Mundade, Mumbai vs. Income Tax Officer Ward, 11(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 5084/MUM/2024[2014-15]Status: DisposedITAT Mumbai06 Jan 2025AY 2014-15

Bench: Sandeep Singh Karhail, Hon’Ble

For Appellant: Shri Hitesh M. Shah, C.AFor Respondent: Shri Pushkaraj Bhangepatil, Sr. D/R

Section 147Section 148Section 148ASection 149Section 69A

| आयकर अपीलीय अिधकरण "ायपीठ, मुंबई | IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI SHRI NARENDRA KUMAR BILLAIYA, HON’BLE