“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

Jagdish R. Mookhey, Mumbai vs. ITO 11(2)_4, Mumbai

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

ITA 3152/MUM/2011[2005-06]Status: DisposedITAT Mumbai30 Oct 2023AY 2005-06

Bench: Us Is, Whether The ‘Reasons Recorded’ By The Ld. Ao U/S.148 Were Communicated To The Assessee During The Course Of Assessment Proceedings Or Not. Here In This Case, This Issue Was Adjudicated By The Tribunal Vide Order Dated 29/11/2013 Wherein, The Tribunal Has Held That, As Per The Order Sheet Entry Dated 08/12/2009, The Reasons For Reopening Was Given By Ld A.O Vide Letter Dated 18/12/2009 Alongwith Show-Cause Notice U/S.142(1). However, This Finding Of The Tribunal Was Challenged Before The Hon’Ble High Court Wherein The Hon’Ble High Court Has Set Aside This Issue To The Tribunal Vide Judgment & Order Dated 06/12/2016 In Income Tax Appeal No.965 Of 2014. For The Sake Of Ready Reference, The Entire Judgment Of The High Court Is Reproduced Hereunder:- 1. This Appeal Under Section 260A Of The Income Tax Act, 1961 (The Act") Challenges The Order Dated 29Th November 2013. Passed By The Income Tax Appellate Tribunal ("The Tribunal') The Impugned Order Is In Respect Of Assessment Year 2005-06

Section 142(1)Section 143(3)Section 148Section 260A

facts and in the circumstances of the case and in law, whether the Income Tax Appellate Tribunal was justified the reopening of assessment although the reasons recorded for appellant till the completion of the assessment? (2) On the facts and in the circumstances of the case and in law, whether ... Income Tax Appellate Tribunal was justified in reopening of assessment although there was no new tangible material evidence brought on record by the Respondent A.O? 3 Question No. 1. (a) It is case of the appellant that the reasons in support of the notice for reopening dated 19/1/2009 were

ITO 11(2)(4), Mumbai vs. Jagdish R. Mookhey, Mumbai

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

ITA 2956/MUM/2011[2005-06]Status: DisposedITAT Mumbai30 Oct 2023AY 2005-06

Section 142(1)Section 143(3)Section 148Section 260A

M/S Gupta Corporation Pvt Ltd, Nagpur vs. Assistant Commissioner of Income Tax Central Circle2(1), Nagpur

In the result, the appeal of assessee is dismissed

ITA 49/NAG/2018[2011-2012]Status: DisposedITAT Nagpur30 Oct 2023AY 2011-2012

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: N O N EFor Respondent: Shri Kailash G. Kanojiya

Section 131Section 133(6)Section 147Section 148Section 68

Kolkata according to which the appellant company was beneficiary of the accommodation entries. The AO accordingly had' a valid ground for reopening of assessment and issue notice u/s 148. There is no infirmity in the action of the AO. Accordingly Ground Nos. 1 and 2 are dismissed. 4.2 Ground

Deputy Commissioner of Income Tax 1(1), Bhilai, Durg vs. Bhilai Jaypee Cement Ltd., Bhilai, Durg

In the result, appeal filed by the revenue stands dismissed in terms of our aforesaid observations

ITA 241/RPR/2023[2015-16]Status: DisposedITAT Raipur30 Oct 2023AY 2015-16

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.241/Rpr/2023) (Assessment Year: 2015-16) Deputy Commissioner Of Income Tax 1(1), V Bhilai Jaypee Cement Ltd, Bhilai, Durg S Bsp Premises, Slag Yard Road (Opp Sector 4 Nmoh), Bhilai Pan: Aadcb1675Q (अपीलाथ" /Applicant) .. (""यथ" / Respondent) िनधा"रती क" ओर से /Assessee By : Shri. R.B. Doshi, Ca राज"व क" ओर से /Revenue By : Shri. Satya Prakash Sharma, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 25-10-2023 घोषणा क" तार"ख / Date Of : 30-10-2023 Pronouncement आदेश / O R D E R Per Arun Khodpia, Am:

For Appellant: Shri. R.B. Doshi, CAFor Respondent: Shri. Satya Prakash Sharma, Sr. DR

Section 143(3)Section 147Section 148Section 2(24)(x)Section 40A(2)(b)Section 68

scrutinized, any attempt on part of Assessing Officer to reexamine= the said claim, without any material would be based on change of opinion. Reopening of assessment was therefore clearly impermissible.: e) In PCIT v. Mahindra & Mahindra, Financial Services Ltd. (1TA NO. 288 of 2017 dt.021412019 (Born.) (HO): During the original ... scrutiny assessment, the Assessing Officer had examined the Assessee's- claim. of computer software expenses. Through the reopening process, Assessing Officer desired to re-exam in the same. Without there being. new tangible material available with him, the Tribunal correctly held that the same was impermissible. f) In YashomandirSahakariPatpedhi

Pramodbhai Balubhai Patel, Surat vs. Income Tax Officer Ward 3(1)(3), Surat

ITA 622/SRT/2023[2012-13]Status: DisposedITAT Surat30 Oct 2023AY 2012-13

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.622/Srt/2023 Assessment Year: (2012-13) (Physical Hearing) Pramodbhai Balubhai Patel, Vs. The Ito, D-204, Capital Status, Karan Park Ward- 3(1)(3), Road, Adajan, Surat – 395005. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adppp8613C (Assessee) (Respondent)

Section 143(3)Section 147Section 148Section 50CSection 54E

Kanad, Tal-Olpad, Dist-Surat. 5. Additional Ground:: Ld. CIT(A), NFAC has erred in law and on fact to upheld AO’s reopening of assessment u/s 147 and issue of notice u/s 148 of the act.” 3. In this appeal, the assessee has raised five grounds of appeals. Ground ... relate to merits of the addition and ground no.5 is legal ground, wherein the assessee has challenged the correctness of the reopening of assessment under section 147/148 of the Act. 4. The appeal filed by the assessee for assessment year 2012-13 is barred by limitation by thirty-one days

Mehul Prakash Mehta, Mumbai vs. ITO, W-27(1)(1), Mumbai

In the result, ground No.1(a) and (b) of the appeal are against reopening of assessment, in absence of any argument , are dismissed

ITA 944/MUM/2019[2009-10]Status: DisposedITAT Mumbai27 Oct 2023AY 2009-10

Bench: Shri. Prashant Maharishi, A Before Shri. Prashant Maharishi, Am & Shri Sandeep Singh Karhailshri Sandeep Singh Karhailit Assessment Year: Assessment Year: 2009-10 Mr. Mehul Prakash Mehta Mr. Mehul Prakash Mehta V. Ito, W-27(1)(1) 27(1)(1) 401/402, Mahalaxmi Apartment 401/402, Mahalaxmi Apartment Mumbai 16, Akash, 90 Feet Road Akash, 90 Feet Road Nath Panth Road, Ghatkopar (E) Nath Panth Road, Ghatkopar (E) Mumbai (Appellant) (Respondent) Pan No.Aghpm8335M Pan No. Shri V. D. Parmar, A.R. Assessee By: Shri Mahita Nair, D.R. Revenue By: 12.10.2023 Date Of Hearing Date Of Hearing : Date Of Pronouncement Pronouncement : 27.10.2023

For Appellant: Shri Mahita Nair, D.RFor Respondent: 12.10.2023

Section 1Section 143(3)Section 147Section 148

above decision of the Hon’ble Bombay High Court. 11. In the result, ground No.1(a) and (b) of the appeal are against reopening of assessment, in absence of any argument , are dismissed. 12. Ground No.1(c) of the appeal is partly allowed. 13. In the result, the appeal

Cricket South Africa (Npc), South Africa vs. ACIT, Circle 1(2)(1), International Taxation, New Delhi

In the result, appeal is allowed as indicated above

ITA 604/DEL/2023[2013-14]Status: DisposedITAT Delhi27 Oct 2023AY 2013-14

Bench: Shri Saktijit Dey, Vice- & Dr. B.R.R. Kumarassessment Year: 2013-14

For Appellant: Shri Percy Pardiwalla, Sr. Adv. &For Respondent: Shri Vizay B. Vasanta, CIT-DR

Section 144C(13)Section 147Section 148Section 194ESection 195

well as on merits. However, in ground no.1, assessee has challenged the validity of assumption of jurisdiction by the Assessing Officer to reopen the assessment under Section 147 of the Act. Since, the issue raised in ground no.1, is a legal and jurisdictional issue going to the root ... India. Whereas, assessee had not filed any return of income in India offering such income. Based on such information, the Assessing Officer reopened the assessment under Section 147 of the Act after recording reasons. In response to notice 3 - AY: 2013-14 issued under Section 148 of the Act, assessee

Assistant Commissioner of Income Tax, Circle1(1), Raipur vs. Akshay Lodha, Raipur

ITA 160/RPR/2022[2012-13]Status: DisposedITAT Raipur27 Oct 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 160/Rpr/2022 Co No.10/Rpr/2022 "नधा"रण वष" / Assessment Year : 2012-13 The Assistant Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Shri Akshay Lodha B-26, 27 Gate No.11, Pandri, Textile Market Pandri, Raipur (C.G.) Pan : Acipl3634P ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR

Section 147Section 250

Whether in law and on facts and the circumstances of the case, the Ld. CIT(A)/NFAC has erred in quashing the reopening of assessment order passed by the AO u/s 147 r.w.s 143(3) of the IT Act, 1961. 2. The order of the Id. CIT(A)/NFAC ... data of purchases could be linked in any way to the purchase transactions of the appellant. Thus, the appellant's claim that the reopening of assessment merely for fishing or roving enquiries not in accordance with settled law is found to be logical. 3. The facts on record, copy

The Income Tax Officer Ward, 2, Raigarh(Cg) vs. Shri Shri Bishambhar Dayal Agrawal, Jashpur (C.G.)

The appeal of the revenue is dismissed in terms of our aforesaid observations

ITA 223/BIL/2016[2010-11]Status: DisposedITAT Raipur27 Oct 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 223/Rpr/2016 "नधा"रण वष" / Assessment Year : 2010-11 The Income Tax Officer-2, Raigarh (C.G.)

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR

Section 143(3)Section 147Section 41(4)Section 69

only one condition has remained, viz., that where the AO has reason to believe that income has escaped assessment, confers jurisdiction to reopen the assessment. Therefore, post 1st April, 1989, power to reopen is much wider. However, one needs to give a schematic interpretation to the words "reason to believe ... condition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then, in the garb of reopening the assessment, review would take place. One must treat the concept of "change of opinion" as an in-built test to check abuse of power

Viral Lavjibhai Patel, Surat vs. Income Tax Officer, Ward-3(3)(5), Surat

In the result, assessee`s appeal is partly allowed in above terms

ITA 450/SRT/2023[2011-12]Status: DisposedITAT Surat26 Oct 2023AY 2011-12

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.450/Srt/2023 Assessment Year: (2011-12) (Physical Hearing) Viral Lavjibhai Patel, Vs. Income Tax Officer, A-18, Naginawadi Society, Ward-3(3)(5), Surat, Aaykar Sumul Dairy Road, Bhawan, Majura Gate, Opp. Surat – 395004. New Civil Hospital, Surat- 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Alvpp2897E (Appellant) (Respondent) Appellant By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 12/10/2023 Date Of Pronouncement 26/10/2023

Section 139Section 142(1)Section 143(3)Section 144Section 147Section 148Section 68

Assessing Officer was not having sufficient material to form the "reason to believe" at the time of re-opening of the assessment, therefore, reopening of assessment may be quashed. 10. On merit, ld Counsel submitted that assessee`s nature of business is cheque discounting business and in such business there ... information received from the assessee's bank is the basis for the formation of belief coupled with non-filing of return, hence reopening of assessment is valid. 12. On merit, ld DR for the Revenue argued that entire addition made by the Assessing Officer may be sustained. 13. We have

Saraswati Garewal, Bilaspur vs. Income Tax Officer, Ward 2(1), Bilaspur

In the result ground no. 1 of the assessee in terms of our aforesaid observations is allowed

ITA 166/RPR/2022[2014-15]Status: DisposedITAT Raipur25 Oct 2023AY 2014-15

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am Saraswati Garewal, V Income Tax Officer, Ward 2(1), C/O Shivbhajan, Vill: Pendridih, S Bilaspur Post: Hirri Mines, Bilaspur – 495222, (C.G.) Pan: Bizpg5287R (अपीलाथ" /Appellant) . (""यथ" / Respondent) . िनधा"रती क" ओर से /Assessee By Shri R.B. Doshi, Ca राज"व क" ओर से /Revenue By : Shri Satya Prakash Sharma, Sr. Dr सुनवाई क" तार"ख / Date Of : 13/10/2023 Hearing घोषणाक" तार"ख/Date : 25/10/2023 Of Pronouncement आदेश / O R D E R Per Arun Khodpia, Am:

For Respondent: Shri Satya Prakash Sharma, Sr. DR

Section 133(6)Section 142Section 142(1)Section 147Section 148Section 69A

facts. a) that the Ld. AO fail to provide reasons recorded for the reopening of assessment u/s 147. 5. In the context of aforesaid ground observations of the Ld. CIT(A) were also shown before us, wherein Ld. CIT has rejected the contention of the assessee stating that the assessee ... complete violation of the applicable principles of law by the Assessing Officer. The Assessing Officer was required to communicate the reasons for reopening the assessment which he has failed to do. The Assessing Officer despite the judgment of the 6 I.T.A. No.166/RPR/2022 Supreme Court in GKN Driveshafts (India

Himanshu Goyal, Dhamtari vs. Pr. CIT-1, Raipur

In the result legal grounds raised by the assessee under present appeal is allowed

ITA 144/RPR/2022[2012-13]Status: DisposedITAT Raipur25 Oct 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.144/Rpr/2022 (Assessment Years: 2012-2013) Himanshu Goyal, Vs Pr.Cit, Raipur-1, Raipur Nawagaon Road, Dhamtari, 793773, (C.G.) Pan No. :Agtpg1746Q (अपीलाथ" /Appellant) (""यथ" / Respondent) .. िनधा"रती क" ओर से /Assessee By : Shri Praveen Khandelwal & Praveen Goyal, Cas राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 09/10/2023 घोषणा क" तार"ख/Date Of Pronouncement : 25/10/2023 आदेश / O R D E R

For Appellant: Shri Praveen KhandelwalFor Respondent: Smt. Ila M. Parmar, CIT-DR

Section 143Section 263

trading in shares of M/s DLS Exports Pvt. Ltd., which were duly responded by the ld. AO. Before the ld. AO during the reopening of assessment proceedings, the assessee has also submitted that he had purchased 450 shares of Sarathi Dealers Pvt. Ltd., which was later on amalgamated with

Anirudh Keshav Dubey, Vapi vs. Income Tax Officer, Daman

In the result, ground No. 1 of the appeal is allowed for statistical purposes

ITA 564/SRT/2023[2011-12]Status: DisposedITAT Surat25 Oct 2023AY 2011-12

Bench: Shri Pawan Singh(Hybrid Hearing) Anirudh Keshav Dubey, I.T.O., Flat No. 602, Leela Tower, Near Daman Vs. Vatsav Park, Rofel College, Namdha Road, Vapi- 396191 (Gujarat) Pan No. Aejpd 7924 B Appellant/ Assessee Respondent/ Revenue

Section 144Section 147Section 148Section 194CSection 254(1)Section 69A

basis of information that the assessee has not filed any return of income and that there was cash deposit and contractual receipt. The reopening of assessment is not challenged by assessee before the 4 Anirudh Keshav Dubey Vs ITO Tribunal. The assessee has challenged only the addition of contractual receipt

Vivek Raghu Shetty, Mumbai vs. Asstt. Commissioner of Income Tax, Mumbaicircle-32(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 979/MUM/2022[2012-13]Status: DisposedITAT Mumbai24 Oct 2023AY 2012-13

Bench: Shri Kuldip Singh & Shri Amarjit Singhita Nos.975 To 978 & 979 To 981/Mum/2022 (A.Ys. 2008-09 To 2010-11 & 2012-13 To 2014-15)

For Appellant: AnujKisnadwalaFor Respondent: Ujjawal Kumar

Section 143(1)Section 147Section 148Section 68Section 69C

assessment was reopened u/s 147 of the Act by issuing of notice u/s 148 of the Act on 24.03.2015. The reason recorded for reopening the assessment is reproduced as under: “As per information available with this office from DGIT(Inv.) IX(2), Mumbai, Bhanwarlal Jain Group is a leading entry ... mentioned the correct fact of the case on the basis of which the assessment was reopened. Therefore, ld. Counsel contended that the reopening of assessment is bad in law and notice issued u/s 148 of the Act is not valid. In support of his contention the ld. Counsel has placed

Barcelona Mercantile Company Private Limited, Mumbai vs. Ward 12(1)(3), Mumbai

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

ITA 2346/MUM/2023[2011-12]Status: DisposedITAT Mumbai23 Oct 2023AY 2011-12

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Sanjay N. KapadiaaFor Respondent: Shri Ashok Kumar Ambastha

Section 143(3)Section 148Section 250Section 68

upholding the reopening of the assessment u/s 148 as valid. Barcelona Mercantile Company Pvt. Ltd. ITA no.2346/Mum./2023 The Appellant submits that the reopening of assessment u/s 148 be treated as bad in law and consequently the assessment order passed by the assessing officer u/s 143(3) r.w.s.147 vide order

Vivek Raghu Shetty, Mumbai vs. Asstt CIT, Circle-32(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 981/MUM/2022[2014-15]Status: DisposedITAT Mumbai23 Oct 2023AY 2014-15

Bench: Shri Kuldip Singh & Shri Amarjit Singhita Nos.975 To 978 & 979 To 981/Mum/2022 (A.Ys. 2008-09 To 2010-11 & 2012-13 To 2014-15)

For Appellant: AnujKisnadwalaFor Respondent: Ujjawal Kumar

Section 143(1)Section 147Section 148Section 68Section 69C

Vivek Raghu Shetty, Mumbai vs. Asstt. Commisssioner of Income Tax, Circle-32(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 980/MUM/2022[2013-14]Status: DisposedITAT Mumbai23 Oct 2023AY 2013-14

Bench: Shri Kuldip Singh & Shri Amarjit Singhita Nos.975 To 978 & 979 To 981/Mum/2022 (A.Ys. 2008-09 To 2010-11 & 2012-13 To 2014-15)

For Appellant: AnujKisnadwalaFor Respondent: Ujjawal Kumar

Section 143(1)Section 147Section 148Section 68Section 69C

Vivek Raghu Shetty, Mumbai vs. Asstt CIT, Circle-32(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 977/MUM/2022[2010-11]Status: DisposedITAT Mumbai23 Oct 2023AY 2010-11

Bench: Shri Kuldip Singh & Shri Amarjit Singhita Nos.975 To 978 & 979 To 981/Mum/2022 (A.Ys. 2008-09 To 2010-11 & 2012-13 To 2014-15)

For Appellant: AnujKisnadwalaFor Respondent: Ujjawal Kumar

Section 143(1)Section 147Section 148Section 68Section 69C

Vivek Raghu Shetty, Mumbai vs. Asstt CIT, Circle-32(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 976/MUM/2022[2009-10]Status: DisposedITAT Mumbai23 Oct 2023AY 2009-10

Bench: Shri Kuldip Singh & Shri Amarjit Singhita Nos.975 To 978 & 979 To 981/Mum/2022 (A.Ys. 2008-09 To 2010-11 & 2012-13 To 2014-15)

For Appellant: AnujKisnadwalaFor Respondent: Ujjawal Kumar

Section 143(1)Section 147Section 148Section 68Section 69C

Vivek Raghu Shetty, Mumbai vs. Asstt Commissioner of Income Tax, Circle-32(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 975/MUM/2022[2008-09]Status: DisposedITAT Mumbai23 Oct 2023AY 2008-09

Bench: Shri Kuldip Singh & Shri Amarjit Singhita Nos.975 To 978 & 979 To 981/Mum/2022 (A.Ys. 2008-09 To 2010-11 & 2012-13 To 2014-15)

For Appellant: AnujKisnadwalaFor Respondent: Ujjawal Kumar

Section 143(1)Section 147Section 148Section 68Section 69C