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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

Shyama Shyam Infradevelopers Private Limited, Agra vs. ITO 2(1)(2), Agra

In the result, the appeal of the assessee is allowed

ITA 503/AGR/2025[2016-17]Status: DisposedITAT Agra23 Jan 2026AY 2016-17

Bench: Shri M. Balaganeshshyama Shyam Vs. Ito, Infradevelopers Pvt Ltd, Ward-2(1)(2), Khasra No. 961, Bhahistabad, Agra Sikandra, Agra (Appellant) (Respondent) Pan: Aatcs9899R Assessee By : Shri Gaurav Agarwal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 21/01/2026 O R D E R

For Appellant: Shri Gaurav Agarwal, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 147Section 148

entries recorded therein are correct warranting no addition on account of under reporting of gross receipts as mentioned in the reasons recorded for reopening the assessment. For the purpose of disallowance of expenditure incurred towards bricks and labour payments, the ld Assessing Officer concluded that books of accounts were ... very clear that no addition has been made by the ld Assessing Officer on the issue, which was subject matter of reopening of assessment. Accordingly, the very basis of assumption of jurisdiction u/s 147 of the Act for forming a belief that income of the assessee had escaped assessment fails

Gupta Builder and Developers, Mumbai vs. ACIT Central Circle 4(3), Mumbai

In the result, ground no. 3 of the assessee‟s appeal is allowed

ITA 70/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Jan 2026AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm M/S. Gupta Builders & Developers Asst. Commissioner Of Income 1201 & 1202, Bhumiraj Costarica, Tax, Central Circle 4(3), Mumbai Plot No. 1 & 2, Near Moraj Circle, Vs. Sector 18, Sanpada, Navi Mumbai – 400705. Pan/Gir No. Aajfg3066H (Appellant) : (Respondent)

For Respondent: Shri Asif Karmali SR DR
Section 143(3)Section 148Section 148ASection 151Section 250

also invalid since it has been granted mechanically. 8. BECAUSE, the impugned assessment order is bad in law since the reasons for reopening of assessment are recorded solely on "suspicion" without bringing on record any tangible material. 2 M/s. Gupta Builders and Developers 9. BECAUSE, the AO has erred ... reopening of assessment on the basis of "borrowed satisfaction" of information from survey party without any independent corroboratic. or application of mind and preliminary enquiries. 10. BECAUSE, there is no failure on the part of the Appellant to disclose material facts necessary for assessment. 11. BECAUSE, the AO failed

Inuus Infrastructure(P) Ltd., Haryana vs. DCIT, New Delhi

Appeal of the assessee is allowed

ITA 4617/DEL/2025[2015-16]Status: DisposedITAT Delhi23 Jan 2026AY 2015-16

Bench: Shri Anubhav Sharma

Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 151Section 151ASection 250

ITA No.4617/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER & SHRI

Yusufbhai Gafurbhai Shaikh, Surat vs. I.T.O Ward- 3(2)(6), Surat

In the result, the appeal of the assessee is allowed

ITA 494/SRT/2025[2010-11]Status: HeardITAT Surat22 Jan 2026AY 2010-11

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 133Section 133(6)Section 147Section 148Section 234Section 250

primary facts and paid due taxes. Once the Assessing Officer is in possession of complete facts prior to issuance of notice u/s 148, reopening of assessment lacks jurisdiction. In the present case, since no income chargeable to tax had escaped assessment, and the assessee had fully and truly disclosed ... material facts, the basic jurisdictional requirement u/s 147 of the Act fails. Therefore, we hold that the reopening of assessment is bad in law and liable to be quashed. 6. In view of the above discussion, we set aside the order of the Ld. CIT(A) and quash the reassessment

Deupty Commissioner of Income Tax, Mumbai vs. Anand Rathi Commodities Limited, Mumbai

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

ITA 5983/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jan 2026AY 2018-19

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar

Section 143(3)Section 147Section 148Section 148ASection 250Section 270ASection 36(1)(vii)Section 37(1)

prejudice to each other and assessee’s arguments in Department’s appeal: 1. “The Ld. CIT(A) ought to have appreciated that the reopening of assessment by issue of notice u/s. 148 of the Act was invalid and void ab initio. 2. The Ld. CIT(A) ought to have appreciated ... that the impugned reopening of assessment is on account of change of opinion and hence invalid and void ab initio. 6 ITA No. 5983/Mum/2025 & Co No.325/Mum/2025 Anand Rathi Commodities Limited 3. The respondent craves leave of Your Honour to add to, amend or alter the foregoing grounds of cross-objection

Badariprasad, Guna vs. Income Tax Officer Guna, Guna

In the result, appeal filed by the assessee is allowed

ITA 473/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshbadriprasad, Vs. Income Tax Officer, Heerabagh Colony, Guna, Guna, Gwalior Gwalior (Appellant) (Respondent) Pan: Arapr6314B

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment by Jurisdictional Assessment Officer(JAO) as against Faceless Assessment Officer (FAO) could be considered as valid. This goes to the root of the matter ... issued notice on the same day u/s.148 of the Act on 31.03.2022 [refer Page No.9 of the Paper Book], and pursuant to it, reopened the assessment for AY 2018-19 u/s.147 of the Act and thereafter passed the re/assessment order on 16.03.2023. The action of JAO issuing impugned notice dated

Haricharan Rathore, Ashok Nagar vs. Income Tax Officer, Ashok Nagar

In the result, appeal filed by the assessee is allowed

ITA 472/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshharicharan Rathore, Vs. Ito, 125, Path Kheda, Ashok Ashok Nagar, Nagar, Mp Mp (Appellant) (Respondent) Pan: Csqpr0999M Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment by Jurisdictional Assessment Officer(JAO) as against Faceless Assessment Officer (FAO) could be considered as valid. This goes to the root of the matter ... issued notice on the same day u/s.148 of the Act on 31.03.2022 [refer Page No.9 of the Paper Book], and pursuant to it, reopened the assessment for AY 2018-19 u/s.147 of the Act and thereafter passed the re/assessment order on 16.03.2023. The action of JAO issuing impugned notice dated

Ashok Sahu, Jhansi vs. Income Tax Officer, Ward 2(3)(1), Jhansi

In the result, appeal filed by the assessee is allowed

ITA 452/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment by Jurisdictional Assessment Officer(JAO) as against Faceless Assessment Officer (FAO) could be considered as valid. This goes to the root of the matter ... issued notice on the same day u/s.148 of the Act on 31.03.2022 [refer Page No.9 of the Paper Book], and pursuant to it, reopened the assessment for AY 2018-19 u/s.147 of the Act and thereafter passed the re/assessment order on 16.03.2023. The action of JAO issuing impugned notice dated

Vikas Chandra HUF, Aligarh vs. ITO Ward-4(1)(1), Aligarh

In the result, the appeal of the assessee is allowed

ITA 450/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshvikas Chandra Huf, Vs. Cit(Appeals), D-117, Ramesh Vihar, Nfac, Delhi Ramghar Road, Aligarh Up (Appellant) (Respondent) Pan: Aakjv9476N Assessee By : Shri Pankaj Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Pankaj Garg, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 139(1)Section 147Section 148Section 148ASection 151

assessee had also raised additional ground no. 3 stating that the approval granted u/s 151 of the Act by the competent authority for reopening the assessment is mechanical in nature. Since this additional ground goes to the root of the matter and facts relevant for its adjudication are already ... declaring total income of Rs. 34,590/-. Based on the information received from the investigation wing, the ld AO reopened the assessment of the assessee u/s 147 of the Act vide issuance of notice u/s 148 of the Act on 28.3.2024. The reasons recorded for reopening the assessment together with

Narayani Rathore, Shivpuri vs. Assessment Unit, Income Tax Department, Delhi

In the result, appeal filed by the assessee is allowed

ITA 444/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshnarayani Rathore, Vs. Assessment Unit, Peeroth Shivpuri, Income Tax Shivpuri, Mp Department, National Faceless Appeal Centre, Delhi (Appellant) (Respondent) Pan: Dhgpr1886H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment by Jurisdictional Assessment Officer(JAO) as against Faceless Assessment Officer (FAO) could be considered as valid. Narayani Rathore This goes to the root ... issued notice on the same day u/s.148 of the Act on 31.03.2022 [refer Page No.9 of the Paper Book], and pursuant to it, reopened the assessment for AY 2018-19 u/s.147 of the Act and thereafter passed the re/assessment order on 16.03.2023. The action of JAO issuing impugned notice dated

Sunita, Sahu vs. Assessment Unit, Income Tax Department, Delhi

In the result, appeal filed by the assessee is allowed

ITA 432/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment by Jurisdictional Assessment Officer(JAO) as against Faceless Assessment Officer (FAO) could be considered as valid. This goes to the root of the matter ... issued notice on the same day u/s.148 of the Act on 31.03.2022 [refer Page No.9 of the Paper Book], and pursuant to it, reopened the assessment for AY 2018-19 u/s.147 of the Act and thereafter passed the re/assessment order on 16.03.2023. The action of JAO issuing impugned notice dated

Sandhya Singh, Rohit Nagar, Bhopal vs. ITO 2(3) Bhopal, Aaykar Bhawan, Bhopal

In the result, the appeal is allowed for statistical purposes

ITA 584/IND/2025[2013-2014]Status: DisposedITAT Indore21 Jan 2026AY 2013-2014

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Adv. Sh. Gagan TiwariFor Respondent: Date of Hearing
Section 115BSection 143(1)Section 147Section 148Section 69A

record before the Assessing Officer and simply affirmed an ex parte assessment, which renders the appellate order unsustainable. On the issue of reopening of assessment, the learned Counsel submitted that the reassessment proceedings initiated under section 148 of the Act are invalid in law as there was no independent application

Bharat Kalwani, Indore vs. ITO-4(3), Indore

In the result, all the appeals filed by the assessee are allowed for statistical purposes, subject to the payment of costs as directed above

ITA 180/IND/2025[2016-17]Status: DisposedITAT Indore21 Jan 2026AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: CA Sh. S.N. AgrawalFor Respondent: Date of Hearing
Section 131Section 147Section 69A

order dated 27.03.2022, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals). Before the CIT(Appeals), the assessee challenged the reopening of assessment, the validity of the assessment framed without adequate opportunity, and the addition of ₹13,50,000/- under section 69A of the Act on account

Bharat Kalwani, Indore vs. ITO-4(3), Indore

In the result, all the appeals filed by the assessee are allowed for statistical purposes, subject to the payment of costs as directed above

ITA 179/IND/2025[2015-16]Status: DisposedITAT Indore21 Jan 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: CA Sh. S.N. AgrawalFor Respondent: Date of Hearing
Section 131Section 147Section 69A

order dated 27.03.2022, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals). Before the CIT(Appeals), the assessee challenged the reopening of assessment, the validity of the assessment framed without adequate opportunity, and the addition of ₹13,50,000/- under section 69A of the Act on account

Bharat Kalwani, Indore vs. ITO-4(3), Indore

In the result, all the appeals filed by the assessee are allowed for statistical purposes, subject to the payment of costs as directed above

ITA 178/IND/2025[2014-15]Status: DisposedITAT Indore21 Jan 2026AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: CA Sh. S.N. AgrawalFor Respondent: Date of Hearing
Section 131Section 147Section 69A

order dated 27.03.2022, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals). Before the CIT(Appeals), the assessee challenged the reopening of assessment, the validity of the assessment framed without adequate opportunity, and the addition of ₹13,50,000/- under section 69A of the Act on account

Vimal Alloys Private Limited, Mandi Gobindgarh, Punjab vs. Jao the Deputy Commissioner of Income Tax Circle, Patiala, Punjab

ITA 890/CHANDI/2025[2016-2017]Status: DisposedITAT Chandigarh21 Jan 2026AY 2016-2017

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Vipen Sethi, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(1)Section 147Section 148Section 151Section 69A

further contended that the Assessing Officer failed to provide the complete excel sheet and other underlying material relied upon for reopening and assessment. No opportunity of cross-examination of the third party was afforded to the assessee. Thus, the assessment suffers from gross violation of the principles of natural justice ... also submitted that the reopening of assessment was based on borrowed satisfaction, as the Assessing Officer merely acted on the information received from the Investigation Wing without any independent application of mind. The reasons recorded do not demonstrate any live nexus between the alleged material and escapement of income

Kataria Transworld, Ahmedabad vs. The Assistant Commissioner of Income Tax, Circle 3(1)(1), Ahmedabad.

In the result, the appeal filed by the Assessee is treated as allowed for statistical purpose

ITA 2245/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad21 Jan 2026AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T. R. Senthil Kumar (Judicial Member)

Section 144Section 147Section 148

appeal. I.T.A No. 2245/Ahd/2025 A.Y. 2015-16 Page No 3 Kataria Transworld vs. ACIT 5. The assessee also raised Legal ground on reopening of assessment apart from the merits of the case. Since the appellate order being an exparte order, we deem it fit to set-aside the matter ... file of Ld. CIT(A) to decide first the Legal ground raised by the assessee on reopening of assessment by giving one more opportunity of hearing to the assessee by sending Physical notice of hearing to the assessee and email id caviharsoni@gmail.com and Mobile No. 8980171867. Needless

Bilwa Infrastructure Limited, Hyderabad vs. ITO., Ward-1(1), Hyderabad

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

ITA 1362/HYD/2025[2018-19]Status: DisposedITAT Hyderabad21 Jan 2026AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 145Section 147Section 148Section 148ASection 151Section 151ASection 250

achieve the ultimate object of simplifying the tax administration, ease compliance and reduce litigation. 6.3 But prior to pre-Finance Act, 2021, while reopening an assessment, the procedure of giving the reasons for reopening and an opportunity to the assessee and the decision of the objectives were required ... with effect from 01.04.2023. In taxing statutes, intendment cannot be assumed unless specifically expressed in the provision enacted by the legislature. Therefore, the reopening of assessment without sanction/approval of the specified authority in accordance with Section 151 of the Act was bad in law. Consequently, reassessment order dated 16.01.2024 also

D.A.V. Educational Trust, Chennai vs. ITO, Exemption Ward-2, Chennai

In the result, the appeal of the assessee for AY 2017-18 is allowed

ITA 1670/CHNY/2024[2018-19]Status: DisposedITAT Chennai21 Jan 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri G. Baskar, Advocate &For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

liable to be quashed. 8. Further, thirdly, Shri Baskar submits that the reassessment is illegal for the reason that the Assessing Officer has reopened the assessment only on the basis of “change of opinion” to review his earlier order of scrutiny assessment. He drew our attention to page ... ground No. 2(2.1 to 2.5) and quash the reassessment. 9. The ld. DR Ms. Gouthami Manivasagam, JCIT submits that the argument of reopening of assessment, barred by limitation, is untenable. She submits that the first proviso to section 147 of the Act allows 7 I.T.A. Nos.1667 to 1670/Chny/24 reopening

D.A.V. Educational Trust, Chennai vs. ITO, Exemption Ward-2, Chennai

In the result, the appeals filed by the assessee for AY 2014-15,

ITA 1669/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadish

Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

liable to be quashed. 8. Further, thirdly, Shri Baskar submits that the reassessment is illegal for the reason that the Assessing Officer has reopened the assessment only on the basis of “change of opinion” to review his earlier order of scrutiny assessment. He drew our attention to page ... ground No. 2(2.1 to 2.5) and quash the reassessment. 9. The Id. DR Ms. Gouthami Manivasagam, JCIT submits that the argument of reopening of assessment, barred by limitation, is untenable. She submits that the first proviso to section 147 of the Act allows 7 LTA. Nos.1667 to 1670/Chiny/24 reopening