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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

Sanjib Sudhir Pradhan, Mumbai vs. Income Tax Officer, 15(1)(1), Mumbai

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

ITA 932/MUM/2022[2010-11]Status: DisposedITAT Mumbai24 Nov 2023AY 2010-11

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Mrs. Rituja Pawar Deswal a/wFor Respondent: Shri P.D. Chogule
Section 143(3)Section 147Section 250Section 68

notice issued under section 148 of the Act. In the reasons Sanjib Sudhir Pradhan ITA no.932/Mum./2022 ITA no.1503/Mum./2022 recorded for reopening the assessment, it was observed that the assessee is filing two separate returns of income on two different names and PANs. It was further observed that ... raised in assessee’s appeal is allowed. 18. Vide application dated 12/09/2022, the assessee sought admission of additional grounds of appeal challenging the reopening of assessment under Sanjib Sudhir Pradhan ITA no.932/Mum./2022 ITA no.1503/Mum./2022 section 147 of the Act. However, we find that on 17/03/2023 the learned

Globeop Holdings Company (Mauritius ) Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, International Tax-2(3)(2), Mumbai

ITA 2321/MUM/2022[2017-2018]Status: FixedITAT Mumbai24 Nov 2023AY 2017-2018

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2011-12

For Appellant: Shri Reepal Tralshawala, A.RFor Respondent: Shri H.M. Bhatt, D.R
Section 143(3)Section 147Section 69ASection 69C

copy of statement recorded of one person so called Shri Nikhil Vora is not furnished even though relied upon by AO for reopening of assessment as also for making addition and even though requested to submit the same time and again; c) cross-examination of Shri Nikhil Vora

Sanjib Sudhir Pradhan, Mumbai vs. ITO, 15(1)(1), Mumbai

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

ITA 1503/MUM/2022[2011-12]Status: DisposedITAT Mumbai24 Nov 2023AY 2011-12

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Mrs. Rituja Pawar Deswal a/wFor Respondent: Shri P.D. Chogule
Section 143(3)Section 147Section 250Section 68

notice issued under section 148 of the Act. In the reasons Sanjib Sudhir Pradhan ITA no.932/Mum./2022 ITA no.1503/Mum./2022 recorded for reopening the assessment, it was observed that the assessee is filing two separate returns of income on two different names and PANs. It was further observed that ... raised in assessee’s appeal is allowed. 18. Vide application dated 12/09/2022, the assessee sought admission of additional grounds of appeal challenging the reopening of assessment under Sanjib Sudhir Pradhan ITA no.932/Mum./2022 ITA no.1503/Mum./2022 section 147 of the Act. However, we find that on 17/03/2023 the learned

DCIT (Exemption)-2(1), Mumbai vs. Maharashtra State Road Transport Corporation, Mumbai

In the result, the appeal filed by the Revenue as well as cross objection filed by the assessee are dismissed

ITA 1766/MUM/2023[2013-14]Status: DisposedITAT Mumbai23 Nov 2023AY 2013-14

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 12ASection 143(2)Section 143(3)Section 148

also filed a revised return. The assessment was originally completed under section 143(3) of the Act on 30.3.2016. Subsequently the Assessing Officer reopened the assessment by issuing notice under section 148 of the Act on 5.3.2020. The assessee filed return of income in response to the above said notice ... Thereafter it asked for the reasons for reopening of assessment and the same was supplied by the Assessing Officer on 19.9.2021. The assessee filed objections to the reopening of assessment on 23.9.2021. However, the Assessing Officer disposed of the objection in the assessment order passed on 30.9.2021 i.e. the Assessing

M/S Ankur Power Projects Pvt. Ltd., Mumbai vs. ITO 15(1)(1), Mumbai

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

ITA 3291/MUM/2019[2011-12]Status: DisposedITAT Mumbai23 Nov 2023AY 2011-12

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 132Section 132(4)Section 143(1)Section 143(3)Section 148Section 68

tune of Rs. 64.11 crores during the financial year 2010-11. 3. Upon receiving the above said information, the Assessing Officer reopened the assessment of the year under consideration by issuing notice under section 148 of the Act on 22.3.2016. In the reopened assessment, the Assessing Officer assessed the share ... unexplained cash credit. Aggrieved the assessee has filed this appeal. 3 Ankur Power Projects Pvt Ltd 5. The assessee is contending that the reopening of assessment is bad in law. Besides the above, the assessee is also challenging the addition made u/s 68 of the Act. The Learned AR first

Sanjay Bhatia, Faridabad vs. ITO, Ward-2(3), Faridabad

In the result, the appeal of the assessee is partly allowed

ITA 1001/DEL/2020[2011-12]Status: DisposedITAT Delhi23 Nov 2023AY 2011-12

Bench: Shri Pradip Kumar Kedia

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri Om Prakash, Sr.DR
Section 143(3)Section 147Section 148Section 44A

time. Similarly, cash has been withdrawn to be utilized in trading I.T.A. No.1001/Del/2020 2 business and for personal needs. The Assessing Officer has reopened the assessment for Assessment Year 2011-12 in question for the reason that assessee has not filed the return of income despite cash deposits of Rs.30 ... aggregate in the bank account maintained with Axis Bank and Union Bank of India. The ld. counsel submitted that in pursuance of the reopening of assessment, the assessee filed return of income and declared an amount of Rs.1,59,650/-. The assessee has declared turnover of Rs.28

M/S. Vinayak Agro Industries, Rourkela vs. ITO Ward-4, Rourkela

In the result, both appeals of the assessee are partly allowed for statistical purposes

ITA 166/CTK/2023[2012-13]Status: DisposedITAT Cuttack22 Nov 2023AY 2012-13
For Appellant: Shri N.K.Rout, AdvocateFor Respondent: Shri S.C.Mohanty, Sr. DR
Section 143(3)Section 148

brought to tax the profit on the undisclosed turnover of Rs.3,41,31,829/- @3.30%. It was the submission that the reopening of assessment itself is invalid for both the assessment years insofar as the very information on the basis of which the reopening has been done, stood quashed ... judgment is set out below:- 'The Income-tax Officer can issue notice under section 148 of the Income-tax Act, 1961, proposing to reopen an assessment only where he has reason to believe that on account of either the omission or failure on the part of the assessee to file

M/S. Vinayak Agro Industries, Rourkela vs. ITO Ward-4, Rourkela

In the result, both appeals of the assessee are partly allowed for statistical purposes

ITA 107/CTK/2023[2009-10]Status: DisposedITAT Cuttack22 Nov 2023AY 2009-10
For Appellant: Shri N.K.Rout, AdvocateFor Respondent: Shri S.C.Mohanty, Sr. DR
Section 143(3)Section 148

brought to tax the profit on the undisclosed turnover of Rs.3,41,31,829/- @3.30%. It was the submission that the reopening of assessment itself is invalid for both the assessment years insofar as the very information on the basis of which the reopening has been done, stood quashed ... judgment is set out below:- 'The Income-tax Officer can issue notice under section 148 of the Income-tax Act, 1961, proposing to reopen an assessment only where he has reason to believe that on account of either the omission or failure on the part of the assessee to file

Parasuram Kesari, Visakhapatnam vs. Income Tax Officer, Ward-5(4), Visakhapatnam

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

ITA 189/VIZ/2023[2012-13]Status: DisposedITAT Visakhapatnam22 Nov 2023AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri C. Subrahmanyam, ARFor Respondent: Sri Madhukar Aves, Sr. AR
Section 142(1)Section 143(3)Section 147Section 148Section 40A(3)

illegal, arbitrary and without fulfillment of the conditions precedent for the issuance of the said notice. 3. Reopening of assessment without replying to the objections filed is not valid. 4. Reopening of assessment on the basis of change of opinion is bad in law. 5. Levy of interest U/s. 234B

ITO, Jaipur vs. Girraj Khandelwal HUF, Jaipur

In the result, appeal of the revenue is dismissed

ITA 465/JPR/2023[2011-12]Status: DisposedITAT Jaipur22 Nov 2023AY 2011-12

Bench: Or At The Time Of Hearing Of The Appeal.”

For Appellant: Sh. Vishnu Khandelwal (CA)For Respondent: Smt Monisha Chaudhary (Addl. CIT)
Section 143(2)Section 147Section 148Section 68

WRITTEN SUBMISSION: In the light of aforesaid facts my submission is as under: 1. The Ld. Assessing officer has erred in law on reopening the assessment based on information of DDIT (inv.) in respect of entering into transaction of shares of Swarnsarita Gems Ltd. It is respectfully submitted that assessing ... Therefore, the notice issued under section 148 is illegal and bad in law. 2. That the appellant has raised objection in respect of reopening of assessment vide letter dated 13.11.2018. However the learned assessing officer has made the assessment without disposing off the objections raised by the assessee

Adil Mohsin Magar, Pune vs. ITO Ward 41(1)(1), Mumbai (Previously ITO Ward 26(1)(1) Mumbai), Mumbai

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

ITA 2858/MUM/2023[2012-13]Status: DisposedITAT Mumbai21 Nov 2023AY 2012-13

Bench: Shri Pavan Kumar Gadaleadil Mohsin Magar, Vs. Ito-Ward 41(1)(1), Flat No. 3, 2Nd Floor, Kautilya Bhawan, G Prime Vihar Society, Block, Bkc Opp Slunke Vihar Bandra (E), Society, Pune-411040. Mumbai-400051. Maharashtra. Pan/Gir No. : Agkpm9307J Appellant .. Respondent

For Appellant: Ms. Mitali Parekh.ARFor Respondent: Shri S.G.Menon. Sr.Dr
Section 133(6)Section 144Section 69C

gross violation of principles of natural justice 3. The LdCIT(A) erred in law and in facts in not appreciating that the reopening of assessment was is bad in law. 4. The Ld. CIT(A) has erred in law and in facts in confirming the addition of alleged cash deposit

Cpi India I Limited, Mumbai vs. ACIT, Int.Tax. Circle-1(2)(1), Delhi

In the result, the appeal is partly allowed, as indicated

ITA 382/DEL/2023[2016-17]Status: DisposedITAT Delhi21 Nov 2023AY 2016-17

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2016-17 . Cpi India Ltd., Vs. Acit, C/O- Vasa Chauhan & International Taxation, Associates Off. No. 41, Circle -1(2)1), 3Rd Floor, High Life Premises, Delhi P.M. Road, Santacruz West, Mumbai Pan :Aadcc1505G (Appellant) (Respondent)

Section 112(1)(c)Section 144C(13)Section 147Section 148Section 48Section 48(1)

claiming loss, on the other hand, the remittance of Rs.160 crores was made to the assessee without deduction of tax. The Assessing Officer reopened the assessment under section 147 of the Act. In response to the notice issued under section 148 of the Act, the assessee filed its return ... addition made towards long-term capital gain as well as on the 4 | P a g e AY: 2016-17 validity of reopening of assessment under section 147 of the Act. However, learned DRP dismissed the objections of the assessee. 5. Before us, learned Senior Counsel appearing for the assessee

The Assistant Commissioner of Income Tax, Central Circle, Rajkot vs. Smt. Urmilaben Kishorbhai Viramgama, Rajkot

ITA 66/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

under orders issued on different dates and communicated to the different assesses. 3. Before the authorities below, different assessees challenged the reopening of assessment on very many counts out of which primarily on three different facts on which cases were reopened. The assessees whose names were appearing in the Memorandum ... authorities below inter alia on the ground of no reason of failure fully and truly in disclosing of material facts by her while reopening the assessment beyond the period of 4 years under Section 148 of the Act was mentioned. Relevant to mention that none of the documents were found

Maulesh D. Ukani, Rajkot-Gujarat vs. The Asstt. Commr. of Income Tax, Cir-1(1), Rajkot-Gujarat

ITA 46/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

under orders issued on different dates and communicated to the different assesses. 3. Before the authorities below, different assessees challenged the reopening of assessment on very many counts out of which primarily on three different facts on which cases were reopened. The assessees whose names were appearing in the Memorandum ... authorities below inter alia on the ground of no reason of failure fully and truly in disclosing of material facts by her while reopening the assessment beyond the period of 4 years under Section 148 of the Act was mentioned. Relevant to mention that none of the documents were found

The Asstt. Commr. of Income Tax, Cen. Cir-1, Rajkot-Gujarat vs. Maulesh D. Ukani, Rajkot-Gujarat

ITA 44/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

under orders issued on different dates and communicated to the different assesses. 3. Before the authorities below, different assessees challenged the reopening of assessment on very many counts out of which primarily on three different facts on which cases were reopened. The assessees whose names were appearing in the Memorandum ... authorities below inter alia on the ground of no reason of failure fully and truly in disclosing of material facts by her while reopening the assessment beyond the period of 4 years under Section 148 of the Act was mentioned. Relevant to mention that none of the documents were found

The Assistant Commissioner of Income Tax, Central Circle-1, Rajkot-Gujarat vs. Shri Kishorbhai V. Viramgama, Rajkot

ITA 42/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

under orders issued on different dates and communicated to the different assesses. 3. Before the authorities below, different assessees challenged the reopening of assessment on very many counts out of which primarily on three different facts on which cases were reopened. The assessees whose names were appearing in the Memorandum ... authorities below inter alia on the ground of no reason of failure fully and truly in disclosing of material facts by her while reopening the assessment beyond the period of 4 years under Section 148 of the Act was mentioned. Relevant to mention that none of the documents were found

The ACIT, Cen. Cir-1, Rajkot vs. Smt. Joliben Mahendrabhai Faldu, Rajkot

ITA 41/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

under orders issued on different dates and communicated to the different assesses. 3. Before the authorities below, different assessees challenged the reopening of assessment on very many counts out of which primarily on three different facts on which cases were reopened. The assessees whose names were appearing in the Memorandum ... authorities below inter alia on the ground of no reason of failure fully and truly in disclosing of material facts by her while reopening the assessment beyond the period of 4 years under Section 148 of the Act was mentioned. Relevant to mention that none of the documents were found

The ACIT, Central Circle-1, Rajkot vs. Shri Bhovan P. Rangani, Rajkot

ITA 37/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

under orders issued on different dates and communicated to the different assesses. 3. Before the authorities below, different assessees challenged the reopening of assessment on very many counts out of which primarily on three different facts on which cases were reopened. The assessees whose names were appearing in the Memorandum ... authorities below inter alia on the ground of no reason of failure fully and truly in disclosing of material facts by her while reopening the assessment beyond the period of 4 years under Section 148 of the Act was mentioned. Relevant to mention that none of the documents were found

The ACIT, Central Circle-1, Rajkot vs. Smt. Sonal Maulesh Ukani, Rajkot

ITA 36/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

under orders issued on different dates and communicated to the different assesses. 3. Before the authorities below, different assessees challenged the reopening of assessment on very many counts out of which primarily on three different facts on which cases were reopened. The assessees whose names were appearing in the Memorandum ... authorities below inter alia on the ground of no reason of failure fully and truly in disclosing of material facts by her while reopening the assessment beyond the period of 4 years under Section 148 of the Act was mentioned. Relevant to mention that none of the documents were found

Asstt. Commr. of Income Tax, Central Circle-1, Rajkot vs. Smitkumar P. Kaneria, Rajkot

ITA 35/RJT/2021[2012-13]Status: DisposedITAT Rajkot16 Nov 2023AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

under orders issued on different dates and communicated to the different assesses. 3. Before the authorities below, different assessees challenged the reopening of assessment on very many counts out of which primarily on three different facts on which cases were reopened. The assessees whose names were appearing in the Memorandum ... authorities below inter alia on the ground of no reason of failure fully and truly in disclosing of material facts by her while reopening the assessment beyond the period of 4 years under Section 148 of the Act was mentioned. Relevant to mention that none of the documents were found