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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

ITO, Ward-6(1), Kolkata vs. M/S Daniel Commodities Pvt. Ltd., Kolkata

ITA 645/KOL/2020[2009-10]Status: DisposedITAT Kolkata07 May 2024AY 2009-10

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.645/Kol/2020 Assessment Year: 2009-10 Ito, Ward-6(1), Kolkata………..…….......................…...……………....Appellant Vs. M/S Daniel Commodities Pvt. Ltd…..........…..........................…..…..... Respondent 6, Lyons Range, Kolkata – 1. [Pan: Aaccd9344F] C.O. 4/Kol/2023 (A/O I.T.A. No.645/Kol/2020) Assessment Year: 2009-10 M/S Daniel Commodities Pvt. Ltd…………….....................…..…..... Cross-Objector 6, Lyons Range, Kolkata – 1. [Pan: Aaccd9344F] Vs Ito, Ward-6(1), Kolkata …………….......................…...……………....Respondent Appearances By: Shri Abhijit Kundu, Cit-Dr, Advocate, Appeared On Behalf Of The Department. Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Assessee. Date Of Concluding The Hearing : February 23, 2024 Date Of Pronouncing The Order : May 07, 2024

Section 143(1)Section 144Section 147Section 148Section 151Section 250Section 263

that due to oversight, an amount of Rs.35,645/- towards profit on share dealing was not considered as income. The Assessing Officer, thereafter, reopened the assessment by serving notice u/s 148 of the Act 09.12.2011 and assessed the income of the assessee by adding the amount of Rs.35,645/-. Thereafter ... assessment u/s 147 r.w.s. 148 of the Act was bad in law for want of jurisdiction to the Assessing Officer to reopen the assessment in the absence of approval of the competent authority u/s 151 of the Act, therefore, the subsequent order passed by the CIT, Kolkata

Harshal Suresh Karvir, Palghar vs. National Faceless Assessment Centre, Delhi

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

ITA 4478/MUM/2023[2013-14]Status: DisposedITAT Mumbai07 May 2024AY 2013-14

Bench: Shri Vikas Awasthy (Jm) & Shri Amarjit Singh (Am)

Section 144Section 147

further submitted that the assessment order has been framed at the back of assessee. The assessee did not receive any notice/intimation regarding reopening of assessment. Hence, the assessee could not participate in reassessment proceedings. 2 Harshal Suresh Karvir 3. Per contra, Shri Krishna Kumar representing the Department strongly supported ... read with section 144 of the Act. The ld. Counsel for assessee has contended that the assessee has not received any notice for reopening the assessment or any notice thereafter. Hence, the assessee was not even aware that the assessment for A.Y. 2013-14 has been reopened. Therefore, the assessee

Maheshwari Megaventures Limited, Hyderabad vs. ACIT, Circle-16(2), Hyd, Hyderabad

In the result, appeal of the assessee is allowed

ITA 1291/HYD/2016[2009-10]Status: HeardITAT Hyderabad03 May 2024AY 2009-10

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri K.C. Devdas, ARFor Respondent: Shri Kumar Pranav, CIT-DR
Section 143(3)Section 147Section 50C

appeal, learned CIT(A), by order dated 24/12/2012 deleted the said addition. 3. While the matters stood thus, learned Assessing Officer proposed to reopen the assessment under section 147 of the Act on the ground that the method of computation of income by the assessee was erroneous and the provisions ... Apart from this, the reasons recorded by the learned Assessing Officer further show that the issue requires verification through scrutiny proceedings by reopening the assessment also further shows that the basis for reopening is not the reason to believe, but it is only a reason to suspect as has been

Gillanders Arbuthnot and Co. Ltd, 2009-10 vs. ACIT, Cir-4(1), Kol, Kolkata

The appeal of the assessee is allowed

ITA 495/KOL/2023[2014-15]Status: DisposedITAT Kolkata03 May 2024AY 2014-15

Bench: Dr. Manish Borad & Shri Sonjoy Sarma

Section 115JSection 133(6)Section 143(3)Section 147Section 148

purposes. 4. Now we take up the ITA No. 493/KOL/2023 for A.Y. 2009-10. 5. The assessee has raised the legal ground challenging reopening of assessment under section 147 of the Act and on merit, has challenged the order of ld. CIT(Appeals) confirming the action of ld. Assessing Officer ... succeed. 7. Being aggrieved, the assessee now is in appeal before the Tribunal. 8. Ld. Counsel for the assessee vehemently submitted that reopening of assessment are bad in law and there is no application of mind by the ld. Assessing Officer before initiating the reassessment proceeding. As far as merits

Gillanders Arbuthnot and Co. Ltd, 2009-10 vs. ACIT, Cir-4(1), Kol, Kolkata

The appeal of the assessee is allowed

ITA 494/KOL/2023[2013-14]Status: DisposedITAT Kolkata03 May 2024AY 2013-14

Bench: Dr. Manish Borad & Shri Sonjoy Sarma

Section 115JSection 133(6)Section 143(3)Section 147Section 148

purposes. 4. Now we take up the ITA No. 493/KOL/2023 for A.Y. 2009-10. 5. The assessee has raised the legal ground challenging reopening of assessment under section 147 of the Act and on merit, has challenged the order of ld. CIT(Appeals) confirming the action of ld. Assessing Officer ... succeed. 7. Being aggrieved, the assessee now is in appeal before the Tribunal. 8. Ld. Counsel for the assessee vehemently submitted that reopening of assessment are bad in law and there is no application of mind by the ld. Assessing Officer before initiating the reassessment proceeding. As far as merits

Gillanders Arbuthnot and Co. Ltd, 2009-10 vs. ACIT, Cir-4(1), Kol, Kolkata

The appeal of the assessee is allowed

ITA 493/KOL/2023[2009-10]Status: DisposedITAT Kolkata03 May 2024AY 2009-10

Bench: Dr. Manish Borad & Shri Sonjoy Sarma

Section 115JSection 133(6)Section 143(3)Section 147Section 148

purposes. 4. Now we take up the ITA No. 493/KOL/2023 for A.Y. 2009-10. 5. The assessee has raised the legal ground challenging reopening of assessment under section 147 of the Act and on merit, has challenged the order of ld. CIT(Appeals) confirming the action of ld. Assessing Officer ... succeed. 7. Being aggrieved, the assessee now is in appeal before the Tribunal. 8. Ld. Counsel for the assessee vehemently submitted that reopening of assessment are bad in law and there is no application of mind by the ld. Assessing Officer before initiating the reassessment proceeding. As far as merits

Event Developers Pvt. Ltd., Kolkata vs. I.T.O., Ward - 5(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 574/KOL/2022[2010-2011]Status: DisposedITAT Kolkata03 May 2024AY 2010-2011

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 143(3)Section 147Section 148Section 148(2)

basis of vague reason recorded. 3. The only issue raised in these grounds is against the wrong reopening of assessment u/s 147 of the Act by issuing notice u/s 148 of the Act without satisfying the conditions for reopening the assessment. 4. Facts in brief are that the assessee filed ... referring to the said reasons recorded, submitted that the AO has not recorded proper reasons and his objective satisfaction to reopen the assessment of the assessee. The Ld. A.R, while referring to first para of the reason recorded ,argued that the AO has only stated that the dept. was having

Aishwarya Publications Private Ltd., Mumbai vs. ITO 1(1)(1), Mumbai

In the result, the appeal is dismissed

ITA 3650/MUM/2023[2010-11]Status: DisposedITAT Mumbai03 May 2024AY 2010-11

Bench: Shri Amit Shukla (Jm) & Smt. Renu Jauhri (Am) I.T.A. No. 3650/Mum/2023 (A.Y. 2010-11) M/S. Aishwarya Vs. Ito, Ward 1(1)(1) Publication Pvt. Ltd. Room No. 534/579A 3Rd Floor, Centre Point Aayakar Bhavan 18Th Road, Chembur M.K. Road Mumbai-400 070. Mumbai-400 020. Pan : Aaaca3569K (Appellant) (Respondent) Assessee By Shri S.G. Goyal & Shri Harsh S. Goyal Department By Shri Manoj Kumar Sinha Date Of Hearing 16.04.2024 Date Of Pronouncement 03.05.2024 O R D E R Per Renu Jauhri (Am) :-

Section 127Section 133(6)Section 143(2)Section 148Section 148(1)Section 151

notice. Subsequently the case was transferred to ITO Ward (1)(1) u/s.127 of the I.T Act on 17/10/2017. The assessee’s objection against reopening of assessment u/s.148 filed vide letter dated 03/10/2017 were disposed off by the AO on 31/10/2017. (iv) Since notice u/s.148 was issued after 4 years from ... profit and completed the assessment. 6 M/s. Aishwarya Publications Pvt Ltd (viii) In appeal the CIT(A), upheld the validity of reopening of assessment but reduced the net profit on disputed purchases from 30% to 12.5%. 5. Before us, the Ld. AR vehemently argued that the entire basis and procedure

Income Tax Officer, Mumbai vs. Svadeshi Enterprise(Hubli), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 2785/MUM/2023[2014-15]Status: HeardITAT Mumbai03 May 2024AY 2014-15

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Rahul Chaudhary, Hon'Bleincome Tax Officer V. Svadeshi Enterprise(Hubli) R.N. 234, 2Nd Floor 12/A Yusuf Building Kautilya Bhawan, Bkc Veer Nariman Road, Fort Mumbai, Maharashtra- 400051 Mumbai-400023 Pan: Aapfs0181B (Appellant) (Respondent) Assessee Represented By : Shri Vijay Mehta Shri Veerbhandra Mahajan Department Represented By :

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

failed to apply his mind to the relevant material in making the assessment order, he cannot take advantage of his own wrong and reopen the assessment by taking recourse to the provisions of s. 147. We find ourself in respectful agreement with the view taken by the Full Bench ... Delhi High Court in its judgment in the case of Kelvinator (supra) referred to above, has taken a clear view that reopening of assessment under s. 147 merely because there is a change of opinion cannot be allowed. In our opinion, therefore, in the present case also

Sejal Vora, New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee stands allowed for

ITA 584/DEL/2024[2013-14]Status: DisposedITAT Delhi03 May 2024AY 2013-14

Bench: Shri Shamim Yahya & Ms. Madhumita Roy[Assessment Year: 2013-14]

Section 147Section 69A

circumstances of the case the CIT(A) was not justified in sustaining the addition of Rs.10,64,550/- ignoring the fact that the reopening of assessment was bad in law since the reasons recorded by the assessing officer were never provided to the appellant during the assessment proceedings. 4. That

Associated Teckno Plastic Pvt. Ltd., New Delhi vs. ITO Ward - 3(3), New Delhi

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

ITA 179/DEL/2020[2010-11]Status: DisposedITAT Delhi03 May 2024AY 2010-11

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: NoneFor Respondent: Sh. Kanv Bali, Sr. DR
Section 142(1)Section 143(2)Section 144Section 147Section 148

assessee company appeared and filed letter dated 23.08.2017 alongwith power of attorney and requested for the reasons for reopening of assessment. The reasons were provided vide letter dated 23.08.2017 and the same were received by hand by the AR of the assessee company. Notice u/s 142(1) was also issued

Shalini Gupta, Kolkata vs. ITO, Ward-22(4), Kolkata.

In the result, the appeal of the assessee is allowed

ITA 178/KOL/2024[2012-13]Status: DisposedITAT Kolkata01 May 2024AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 178/Kol/2024 Assessment Year: 2012-2013 Shalini Gupta,……………………………..……….Appellant 245B, A.P.C. Road, Manicktala, Kolkata-700006 [Pan:Ahqpj8419D] -Vs.- Income Tax Officer,…………………………...…Respondent Ward-22(4), Kolkata, 169, A.J.C. Bose Road, Kolkata-700014 Appearances By: Shri G. Banerjee, A.R., Appeared On Behalf Of The Assessee Shri B.K. Singh, Jcit, Sr. D.R. Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : April 10, 2024 Date Of Pronouncing The Order : May 01, 2024 O R D E R

Section 143(1)Section 143(3)Section 147

appeal. However, her grievances revolve around two issues, namely – (a) the ld. Addl./JCIT(Appeals)-5, Mumbai has erred in upholding the reopening of assessment under section 147/148 of the Income Tax Act; (b) the ld. Addl./JCIT(Appeals)-5, Mumbai has erred in confirming the addition of Rs.15 ... Year 2010-11, which required verification as no details has been provided by the assessee in this regard. Thus ld. Assessing Officer has reopened the assessment. The assessee raised objection on this reopening. Such objection has been decided by the ld. Assessing Officer. The ld. Assessing Officer has passed

DCIT, Central Circle, Noida vs. Pgp Charitable Trust, Delhi

In the result, both the appeals of the revenue are dismissed

ITA 471/DEL/2019[2011-12]Status: DisposedITAT Delhi01 May 2024AY 2011-12

Bench: Shri Amit Shukla & Shri M. Balaganesh

Section 12ASection 132Section 153C

recorded on 08.01.2015, is subsequent to the search and cannot constitute the seized document found, as a result of search. Thus, the reopening of assessment u/s 153C of the Act on the basis of the statement of Shri Man Singh could not be justified in law. Thus, it is seen ... language of section 153C of the Act and various judicial pronouncement cited here-in-above, it is abundantly clear that in order to reopen the assessment of other person u/s. 153C of the Act for the assessment year earlier to the year of search, direct correlation must exist between existence

DCIT, Central Circle, Noida vs. Pgp Charitable Trust, Delhi

In the result, both the appeals of the revenue are dismissed

ITA 470/DEL/2019[2010-11]Status: DisposedITAT Delhi01 May 2024AY 2010-11

Bench: Shri Amit Shukla & Shri M. Balaganesh

Section 12ASection 132Section 153C

recorded on 08.01.2015, is subsequent to the search and cannot constitute the seized document found, as a result of search. Thus, the reopening of assessment u/s 153C of the Act on the basis of the statement of Shri Man Singh could not be justified in law. Thus, it is seen ... language of section 153C of the Act and various judicial pronouncement cited here-in-above, it is abundantly clear that in order to reopen the assessment of other person u/s. 153C of the Act for the assessment year earlier to the year of search, direct correlation must exist between existence

Muralidhar Mysore Sundaresh, Bangalore vs. Income Tax Office, Ward-4(3)(1), Bengaluru

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

ITA 436/BANG/2024[2017-18]Status: DisposedITAT Bangalore30 Apr 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2017-18

For Appellant: Shri Siddesh N. Gaddi, A.RFor Respondent: Shri Narendra Kumar Naik, D.R
Section 115BSection 147Section 148Section 151Section 156Section 234ASection 27Section 270A(9)Section 271ASection 69A

Learned AO has erred in law and on facts in not providing a copy of reasons recorded for reopening of assessment and sanction obtained under section 151 of the Act; 6. The Learned AO has erred in law and on facts in not considering the return filed under section

Mr. Zamirullah Subedarkhan Khan, Mumbai vs. ITO-Ward 20(3)(5), Mumbai

In the result, the appeal is partly allowed

ITA 4165/MUM/2023[2011-12]Status: DisposedITAT Mumbai30 Apr 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2011-12 Mr. Zamirullah Ito- Ward 20(3)(5), Subedarkhan Khan Room No. 205, B.P.T., Piramal Chamber, Plot No. 262, Lalbaug, Vs. Kolsa Bunder, Mumbai- 400012 Darukhana, Reay Road, Mumbai- 400010. Pan: Aabpk9505H (Appellant) (Respondent) Present For: Assessee By : None Revenue By : Shri Manoj Kumar Singh, Sr. A.R. Date Of Hearing : 25 .04 . 2024 Date Of Pronouncement : 30 .04 . 2024 O R D E R Per: Ratnesh Nandan Sahay: 1. This Appeal Has Been Filed By The Appellant Against The Order Of The Ld. Cit Appeal Passed U/S 250 Of The Income Tax Act, 1961 [The ‘Act’ In Short] Vide Order No. Itba/Nfac/S/250/2023-24/1056652408(1) Dated 29/9/2023 For The Assessment Year 2011-12. 2. The Facts Of The Case, In Brief, Are That The Assessee Had Filed Its Return Of Income Declaring The Total Income At Rs.14,08,440/- Which Was Processed

For Appellant: NoneFor Respondent: Shri Manoj Kumar Singh, Sr. A.R
Section 133(6)Section 143(1)Section 147Section 250Section 69C

filed appeal before the Ld. CIT Appeal who not only confirmed the addition made by the Ld. Assessing officer, but also upheld the reopening of assessment made u/s. 147 of the IT Act on the ground 3 Mr. Zamirullah Subedarkhan Khan that all statutory requirements for reopening of assessment were

Sama Jewellery Private Limited, Mumbai vs. DCIT-8(1)(1), Mumbai

In the result, the appeal is partly allowed

ITA 3988/MUM/2023[2011-12]Status: DisposedITAT Mumbai30 Apr 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahaysama Jewellery Private Dcit-8(1)(1) 6Th Floor, Limited, 313, Vasan Udyog Bhavan, Aayakar Bhawan, Off Senapati Bapat Marg, M.K. Road, Vs. Lower Parel, Mumbai 400020 Mumbai 400013. Pan No. Aaaat3419K (Appellant) (Respondent) Assessee By : Shri Himanshu Gandhi – Ca : Shri Prashant Mahajan – Sr. Ar Revenue By Date Of Hearing: 16.04.2024 Date Of Pronouncement : 30.04.2024 O R D E R Per: Ratnesh Nandan Sahay: 1. This Appeal Has Been Filed Against The Order Of The Ld. Cit Appeal Passed U/S 250 Of The Income Tax Act [The ‘Act’ In Short] Vide Din & Order No. Itba/ Nfac/S/250/2023-24/1056140099(1) Dated 15.9.2023 For The Assessment Year 2011-12. 2. The Facts Of The Case, In Brief, Are That The Appellant Is A Private Limited Company Engaged In The Business Of Manufacturing & Trading Of Jewelry. For The Assessment Year Under Consideration, The Appellant Filed Its Return Of Income Electronically On 28.09.2011 Declaring Total Income Of Rs.1,35,53,039/- Which Was Processed U/S. 143(1) Of The Income Tax Act Accepting The Returned Income. 3. In The Meantime, A Survey U/S. 133A Was Conducted In The Business Premises Of The Appellant On 04.2.2011 & Certain Discrepancy Was Sama Jewellery Private Limited; A. Y.2011-12

For Appellant: Shri Himanshu Gandhi – CA
Section 131Section 133(6)Section 133ASection 143(1)Section 143(3)Section 147Section 148Section 250

assessment made u/s 147 of the Act and the addition on account of bogus purchases. The Ld. CIT, Appeal upheld both the reopening of assessment and addition on the ground of bogus purchase. However, the Ld. CIT, Appeal restricted the addition of bogus purchases to Rs.23,42,153 being

Maya Milind Sirsath, Mumbai vs. Income Tax Officer 33(2)(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3562/MUM/2023[2012-13]Status: DisposedITAT Mumbai30 Apr 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 149(1)(b)Section 69A

required format given in para 3 of the circular no. 19 of 2019 dated 14/08/2019. 2. The learned Income Tax Officer erred in reopening the assessment u/s. 147 after a pg: 13 period of four years from the end of the relevant assessment year and issuing notice u/s. 148 without ... belief that income escaped is more than Rupees one lakh as required u/s. 149(1)(b) as per the reasons recorded for reopening the assessment. 2.1 We have heard rival submission of the parties on the issue of admissibility of the additional ground. As the additional ground raised being purely

Sudesh Devi, Ghaziabad vs. ITO, Ward- 2(3), Ghaziabad

In the result, appeal of assessee is dismissed

ITA 312/DEL/2018[2009-10]Status: HeardITAT Delhi26 Apr 2024AY 2009-10

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.311 और 312/िद"ी/2018 (िन.व. 2008-09 और 2009-10)

For Appellant: NoneFor Respondent: Shri Dharm Veer Singh, CIT(DR)
Section 40A(3)

made by ld. DR and have examined the orders of authorities below. The assessee in ground no. 1 & 2 of appeal has assailed reopening of assessment and in ground no. 3 & 4 of appeal has assailed disallowance of Rs. 1,12,27,857/- u/s. 40A(3) of the Income ... dismissed. 7. The assessee has assailed the order of CIT(A) by raising four grounds of appeal. Ground no. 1 & 2 are against reopening of assessment and in ground no. 3 & 4 of appeal, the assessee has challenged disallowance

Sudesh Devi, Ghaziabad vs. ITO, Ward- 2(3), Ghaziabad

In the result, appeal of assessee is dismissed

ITA 311/DEL/2018[2008-09]Status: HeardITAT Delhi26 Apr 2024AY 2008-09

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.311 और 312/िद"ी/2018 (िन.व. 2008-09 और 2009-10)

For Appellant: NoneFor Respondent: Shri Dharm Veer Singh, CIT(DR)
Section 40A(3)

made by ld. DR and have examined the orders of authorities below. The assessee in ground no. 1 & 2 of appeal has assailed reopening of assessment and in ground no. 3 & 4 of appeal has assailed disallowance of Rs. 1,12,27,857/- u/s. 40A(3) of the Income ... dismissed. 7. The assessee has assailed the order of CIT(A) by raising four grounds of appeal. Ground no. 1 & 2 are against reopening of assessment and in ground no. 3 & 4 of appeal, the assessee has challenged disallowance