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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

Technocraft Industries (India) Limited, Mumbai vs. Asst. CIT 11(3)(1), Mumbai

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

ITA 7422/MUM/2025[2013-14]Status: DisposedITAT Mumbai03 Feb 2026AY 2013-14

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokar

For Appellant: Shri Tarang Mehta, Adv. a/w Shri Akash GogariCAFor Respondent: Shri Ritesh Misra (CIT DR)
Section 143(3)Section 148Section 250Section 37

assessee’s case u/sec. 148 of the Act dated 12.03.2019. The assessee filed the return u/sec. 148 and asked the recorded reason for reopening of assessment. During the reassessment the Ld. AO noted that the assessee claimed expenses u/sec. 37 amount of Rs.2.5/-crore which was related

Cool Diamond Private Limited, Mumbai vs. Income Tax Officer - 12(1)(1), Mumbai

In the result, the Assessee’s appeal is allowed, subject to verification as directed above

ITA 5085/MUM/2025[2013-14]Status: DisposedITAT Mumbai03 Feb 2026AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Renu Jauhriassessment Year: 2013-14 Cool Diamond Private Ward Ito -12(1)(1), Limited, Room No. 129, Aayakar 2Nd Floor, Plot No. 97, Myco Bhawan, M K. Road, Vs. Industrial Area, Misc Industrial Mumbai – 400020. Area, Andheri East, Mumbai – 400093. Pan – Aadcc6707 (Appellant) (Respondent) Present For: Assessee By : Shri Vimal Punmiya, Ld. A.R. Revenue By : Shri Virabhadra S. Mahajan, Sr. D.R. Date Of Hearing : 02.12.2025 Date Of Pronouncement : 03.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 30.06.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2013-14. 2. In The Instant Case, An Information Was Received By The Ao From The Ddit (Inv.) Unit – 4 – Surat, With Regard To The Circular Transaction Of Rs.2,11,19,942/- By The Assessee With M/S. Seven Star Jewels Proprietary. On Perusing The Information, The Ao Observed That It Is Apparent That The Assessee Has Earned An Income To The Tune Of Rs.2,11,19,942/- But Has Not Included This 2 Cool Diamond Private Limited

For Appellant: Shri Vimal Punmiya, Ld. A.RFor Respondent: Shri Virabhadra S. Mahajan, SR. D.R
Section 147Section 148Section 250

Thereafter, the AO issued various show cause notices to the Assessee, inter alia, alleging: “5. As per the reasons for reopening of assessment in your case, it is observed that you have huge financial transaction with Seven Star Jewels Prop. Tarachand Paldecha amounting to Rs. 2,11,19,942/-. Please

ACIT, Circle 24(1) Mumbai, Mumbai vs. Nilkamal Crates & Containers, Mumbai

ITA 3763/MUM/2025[2016-17]Status: DisposedITAT Mumbai03 Feb 2026AY 2016-17

Bench: Hon’Ble Justice (Retd.) C.V. Bhadang & Shri Arun Khodpia, Am

For Appellant: Shri Prashant Ghumare, AdvFor Respondent: C.O. No. 146/Mum/2025 in I.T.A. No. 3763/Mum/2025
Section 132Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 151Section 35(1)(i)Section 35(1)(ii)

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 Sri krishna (P.) Ltd. v. ITO [1996] 87 Taxman 315/221 ITR 538 (SC) [1996] 9 SCC 534. A table representing the prescription under

Anirudh Daga, Mumbai vs. ITO 23(10(6), Mumbai

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

ITA 2176/MUM/2024[2012-13]Status: DisposedITAT Mumbai03 Feb 2026AY 2012-13

Bench: The Itat

Section 10(38)Section 143(3)Section 68

whether appeal is maintainable or not due to monetary limits. 4. The appellant filed additional grounds of appeal before the ITAT challenging the reopening of assessment by Ld.AO and argued that the reopening of assessment is invalid/bad in law. The Ld.DR had argued that the assessment was reopened after getting

Krishan Kumar Bansal, Delhi vs. CIT(A), Delhi

In the result, the appeal of the assessee is allowed

ITA 4076/DEL/2024[2017-18]Status: DisposedITAT Delhi03 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay[Assessment Year: 2017-18]

Section 143(3)Section 147Section 148Section 151Section 271ASection 69A

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 Whether Special Leave Petition filed against impugned order was to be dismissed Held, Yes (in favour of the Assessee)." 5. Per Contra

Kishorbhai Dattani, Jam Khambhalia vs. Income Tax Officer, Ward -1, Dwarka

In the result, the appeal of the assessee is allowed

ITA 555/RJT/2025[2017-18]Status: DisposedITAT Rajkot02 Feb 2026AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 555/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Kishorbhai Dattani Vs. Income Tax Office, Hospital C/O. Sarda & Sarda (Ca), Sakar 1St Road, Near Rajdhani Hotel, Floor, Dr. Radha-Krishnan Road, Dwarka, Gujarat 361335 Opp. Rajkumar College, Rajkot, Rajkot Gujarat 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakpd7272M (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 03 / 11 /2025 Date Of Pronouncement : 02/ 02 /2026

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. Sr. DR
Section 115BSection 144BSection 147Section 148Section 250Section 69A

assessee are as follows: - 1. The reassessment order u/s. 147 r.w.s. 144B of the Act is bad in law. 2. The reopening of assessment u/s. 147 of the Act is bad in law. 3. The learned Assessing Officer has erred in law as well as on facts in making ... were duly disposed of by the AO. In light of the above, I am of the view that the AO was justified in reopening the assessment based on the material available with him. Accordingly, Grounds No. 1 and 2 are dismissed. 6.2.5 I have carefully considered the assessment order

Avula Sudarsanam, Chennai vs. DCIT, Ncc-19(1), Chennai

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

ITA 3552/CHNY/2025[2015-16]Status: DisposedITAT Chennai02 Feb 2026AY 2015-16

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.3552/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 Avula Sudarsanam, Vs. The Deputy Commissioner Of Plot No. 1A, Flat No. S2, Amr Nalloli, Income Tax, Officers Colony, West Street, Non Corporate Circle 19(1), Adambakkam, Chennai 600 088. Chennai. [Pan:Etjps9434J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri H. Yeshwanthkumar, Ca ""थ" की ओर से/Respondent By : Shri Sbr Kumar Laghimsetti, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 21.01.2026 घोषणा की तारीख /Date Of Pronouncement 02.02.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.09.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2015-16. 2. At The Outset, The Ld. Ar Shri H. Yeshwanthkumar, Ca Submits That There Was No Compliance By The Assessee Before The Ld. Cit(A) & The Appeal Of The Assessee Was Dismissed Exparte Without

For Appellant: Shri H. Yeshwanthkumar, CAFor Respondent: Shri SBR Kumar Laghimsetti, Addl. CIT
Section 143(3)Section 148

exparte without 2 I.T.A. No.3552/Chny/25 discussing on merits of the case. He drew our attention to the legal ground raised before us regarding reopening of assessment without any new/fresh tangible material and submits that there was no failure on the part of the assessee in furnishing all details before

Aryan Share and Stock Brokers Limited, Chennai vs. ITO, Corporate Ward 1(1) Che, Chennai

In the result, appeal filed by the assessee is allowed

ITA 2756/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Feb 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Praveen Kumar BansalFor Respondent: Mr.Kumar Chandan, JCIT
Section 147Section 148Section 69A

Shares & Stock Broker :: 2 :: 2. The assessee is noted to have raised a legal issue, challenging the jurisdiction of Assessing Officer (AO) to reopen the assessment for AY 2017-18, without satisfying the condition precedent as stipulated u/s.147 of the Income Tax Act, 1961 (hereinafter referred ... assessee is a registered SEBI Stock-Broker company. The AO has issued notice u/s.148 of the Act on 18.03.2021 expressing his desire to reopen the assessment for AY 2017-18. Pursuant thereto, the assessee is noted to have filed the RoI reiterating the return filed originally. The AO is noted

Mystical Constructions Private Limited, Mumbai vs. DCIT Circle 5(2)(1), Mumbai

In the result, the appeal is Allowed

ITA 5222/MUM/2024[2011-12]Status: DisposedITAT Mumbai02 Feb 2026AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawalι.Τ.Α. No.5222/Mum/2024 A.Y: 2011-12 Mystical Pvt Ltd Constructions A 603, A1 Akbar Bldg, Pe Road, Momin Nagar, Jogeswari (W), Mumbai - 400102 Pan - Aaccn5191N (Appellant) Vs Dcit, Circle 5(2)(1) Aayakar Bhawan, Mumbai. (Respondent) Assessee By Ms. Simran Dhawan A/W Mr. Ravi Gantara Revenue By Shri Umashankar Prasad, Cit Dr Date Of Hearing 04.11.2025 Date Of Pronouncement 02.02.2026 Order Per: Shri. Sandeep Gosain, J.M.: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dt. 06.08.2025 Passed Under Section 250 Of The Income Tax Act, 1961 ('The Act'), By The National Faceless Appeal Centre (Nfac) / Cit(A) For The

Section 132Section 143(3)Section 147Section 148Section 153CSection 250Section 271(1)Section 274

Commissioner of Income Tax (Appeals) has erred in ignoring the fact that the Ld. Assessing Officer erred in reopening the assessment u/s 147 of the Income Tax Act, 1961 by issue of notice dated 31.03.2018 u/s 148 of the Act which is illegal, bad in law or otherwise void ... appellant asserts that the appropriate procedure should have followed provisions outlined u/s section 153C of the Act as the basis of information for reopening the assessment relied solely on seized material unearthed at a premises owned by an individual during the course of search proceedings

Deputy Commissioner of Income Tax, Central Circle-1, Rajkot vs. Classic Network Pvt. Ltd., Rajkot

In the result, appeal filed by the assessee in ITA No

ITA 287/RJT/2024[2016-17]Status: DisposedITAT Rajkot30 Jan 2026AY 2016-17

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

Deputy Commissioner of Income Tax, Central Circle-1, Rajkot vs. Classic Network Pvt. Ltd., Rjakot

In the result, appeal filed by the assessee in ITA No

ITA 286/RJT/2024[2014-15]Status: DisposedITAT Rajkot30 Jan 2026AY 2014-15

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

Classic Network Private Limited, Rajkot vs. Deputy Commissioner of Income Tax, Central -1, Rajkot

In the result, appeal filed by the assessee in ITA No

ITA 178/RJT/2024[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

Classic Network Private Limited, Rajkot vs. Deputy Commissioner of Income Tax, Central - 1, Rajkot

In the result, appeal filed by the assessee in ITA No

ITA 177/RJT/2024[2016-17]Status: DisposedITAT Rajkot30 Jan 2026AY 2016-17

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

Classic Network Private Limited, Rajkot vs. The Deputy Commissioner of Income Tax, Central -1 Rajkot, Rajkot

In the result, appeal filed by the assessee in ITA No

ITA 176/RJT/2024[2014-15]Status: DisposedITAT Rajkot30 Jan 2026AY 2014-15

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 291/RJT/2022[2019-20]Status: DisposedITAT Rajkot30 Jan 2026AY 2019-20

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 290/RJT/2022[2018-19]Status: DisposedITAT Rajkot30 Jan 2026AY 2018-19

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 289/RJT/2022[2015-16]Status: DisposedITAT Rajkot30 Jan 2026AY 2015-16

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 288/RJT/2022[2013-14]Status: DisposedITAT Rajkot30 Jan 2026AY 2013-14

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

The Deputy Commissioner of Income Tax, Central Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 275/RJT/2022[2019-20]Status: DisposedITAT Rajkot30 Jan 2026AY 2019-20

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment

The Deputy Commissioner of Income Tax, Central Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 274/RJT/2022[2018-19]Status: DisposedITAT Rajkot30 Jan 2026AY 2018-19

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

year 2014–15. (iii) Revenue’s appeal in ITA No.286/RJT/2024, for assessment year 2014–15. In these appeals, the assessee has challenged the reopening of assessment under section 147/148 of the Act, on the plea that in order to reopen the assessment under section 147/148 of the Act, the primary ... higher authorities under section 151 of the Act, is neither digitally signed nor manually signed, hance, assessing officer does not have jurisdiction to reopen the assessment under section 147/148 of the Act. In order to adjudicate, this technical ground of the assessee, for assessment years 2013–14 and for assessment