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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

Aditya Sharad Shah, Mumbai vs. CIT (A), NFAC., Delhi

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

ITA 1017/MUM/2023[2010-2011]Status: DisposedITAT Mumbai20 Jun 2023AY 2010-2011

Bench: Shri Pavan Kumar Gadaleaditya Sharad Shah, Cit(A) / Nfac 6 Madhu Parag, Mumbai-400002. बनाम/ 69 Swastik Society, Vs. Vileparle (W), Mumbai-400056. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Amyps1987N (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: NoneFor Respondent: Mr. Abhisek Kumar Singh.DR
Section 250Section 271(1)(c)

return of income filed earlier to be treated as compliance of notice u/s 148 of the Act. The assessee has filed objections to reopening of assessment and were disposed off. Further the A.O has issued notice u/s 143(2) and 142(1) of the Act . In compliance to the notices

Shri Gurkha Singh Alias Joginder Singh, Bathinda vs. Income Tax Offier Ward 1(1), Bathinda

In the result, the appeal of the assessee bearing ITA No

ITA 145/ASR/2018[2009-10]Status: DisposedITAT Amritsar20 Jun 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.145/Asr/2018 Assessment Year: 2009-10

Section 143(3)Section 148Section 250(6)Section 54BSection 64Section 69A

consider the orders of the revenue authorities. The assessee first agitated the additional ground in legal issue related to jurisdiction for reopening of assessment u/s 148 of the Act before ITAT. I.T.A. No.145/Asr/2018 6 Assessment Year: 2009-10 From verification of the record, we find that the assessee hadagitated

Mahalaxmi Ornaments House Pvt. Ltd., New Delhi vs. ITO, Ward-16(1), New Delhi

In the result, all three captioned appeals are allowed on legal grounds

ITA 2233/DEL/2022[2011-12]Status: DisposedITAT Delhi16 Jun 2023AY 2011-12

Bench: Shri Chandra Mohan Garg

For Appellant: Shri Raj Kumar Gupta, CAFor Respondent: Shri Om Prakash, Sr. DR

proceed to invoke provision of section 153C of the Act or he can initiate action u/s. 147/ 148 of the Act for reopening of assessment. He further submitted that in the present case the Assessing Officer invoked later recourse and initiated reassessment proceedings which cannot be alleged

Mahalaxmi Ornaments House Pvt. Ltd., New Delhi vs. ITO, Ward-16(1), New Delhi

In the result, all three captioned appeals are allowed on legal grounds

ITA 2232/DEL/2022[2010-11]Status: DisposedITAT Delhi16 Jun 2023AY 2010-11

Bench: Shri Chandra Mohan Garg

For Appellant: Shri Raj Kumar Gupta, CAFor Respondent: Shri Om Prakash, Sr. DR

proceed to invoke provision of section 153C of the Act or he can initiate action u/s. 147/ 148 of the Act for reopening of assessment. He further submitted that in the present case the Assessing Officer invoked later recourse and initiated reassessment proceedings which cannot be alleged

Mahalaxmi Ornaments House Pvt. Ltd., New Delhi vs. ITO, Ward-16(1), New Delhi

In the result, all three captioned appeals are allowed on legal grounds

ITA 2231/DEL/2022[2009-10]Status: DisposedITAT Delhi16 Jun 2023AY 2009-10

Bench: Shri Chandra Mohan Garg

For Appellant: Shri Raj Kumar Gupta, CAFor Respondent: Shri Om Prakash, Sr. DR

proceed to invoke provision of section 153C of the Act or he can initiate action u/s. 147/ 148 of the Act for reopening of assessment. He further submitted that in the present case the Assessing Officer invoked later recourse and initiated reassessment proceedings which cannot be alleged

Milky Way Consultants LLP, New Delhi vs. ITO Ward - 37(1), New Delhi

In the result, the appeal of the assessee is partly allowed on legal grounds

ITA 1946/DEL/2020[2011-12]Status: DisposedITAT Delhi16 Jun 2023AY 2011-12
For Appellant: Ms. Rano Jain, Adv. & Ms. Mansi Jain, AdvFor Respondent: Shri Sumit Kumar Verma, Sr. DR
Section 148

Officer to adjudicate the objections by passing a well reason orders. The ld. counsel submitted that at the time of recording reasons for reopening of assessment the Assessing Officer picked up amount of six entities amounting to Rs. 1,70,00,000/- whereas in fact, the assessee received unsecured loans ... jurisdictional High Court of Delhi in the case of PCIT vs. SNG Developers Ltd. 404 ITR 312 (Del.) that the reopening of assessment has to be held as bad in law. 4. Replying to the above, the ld. Senior DR strongly supported the orders of the authorities below and submitted

Magpie Marketing LLP, New Delhi vs. ITO Ward - 38(2), New Delhi

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

ITA 1943/DEL/2020[2011-12]Status: DisposedITAT Delhi16 Jun 2023AY 2011-12
For Appellant: Ms. Rano Jain, Adv. & Ms. Mansi Jain, AdvFor Respondent: Shri Sumit Kumar Verma, Sr. DR
Section 147Section 148

Officer to adjudicate the objections by passing a well reason orders. The ld. counsel submitted that at the time of recording reasons for reopening of assessment the Assessing Officer picked up amount of five entities totaling to Rs. 1,16,02,500/-. The ld. counsel submitted that at the time

Emm Aar Tourism Pvt Ltd, New Delhi vs. ITO Ward - 8(2), New Delhi

In the result, the appeal of the assessee partly allowed

ITA 5790/DEL/2019[2010-11]Status: DisposedITAT Delhi16 Jun 2023AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri M. Balaganeshassessment Year: 2010-11 Emm Aar Tourism P. Ltd. Ito Ward 8(2), New Delhi 10685, Jhandewalan Road, Nabi Karim, New Delhi 110055 Vs. Pan Aacce 1918 Q (Appellant) (Respondent) For Assessee : Shri Shikar Garg, Ca Shri Manoj Garg, Ca Revenue For : Shri Vipul Kashyap, Sr. Dr Date Of Hearing : 19.04.2023 Date Of Pronouncement : 16.06.2023 Order Per Chandra Mohan Garg, J.M. This Appeal Has Been Filed Against The Order Of Ld. Cit(A)-24 New Delhi Dated 11.04.2019 For Ay 2010-11. 2. The Sole Legal Ground Of Assessee Is As Follows:- 1. That On The Facts & Circumstances Of The Case, The Ld Cit(A) Erred In Confirming The Action Of Ld. Ao For Initiation Of Reassessment Proceedings U/S. 147/148 Of The Income Tax Act. 3. The Ld. Assessee Representative Submitted That For Ay 2010-11 The Assessee Submitted Return Of Income On 25.09.2010 Declaring Loss Of Rs. 46,894/- Which Was Processed U/S. 143(3) Of The Act. Drawing Our Attention Towards Pages 27 To 32 Of Assessee Paper Book The Ld. Ar Submitted That The Assessing Officer Received Information From The Investigation Wing Which Conducted Search & Seizure Operation On 18.11.2015 On Pradeep Kumar Jindal Group. He Further Elaborated That On Receipt Of Information The Assessing Officer Recorded Reasons For Initiated Of Reassessment Proceedings On 29.03.2017 & Obtained Approval Of Acit As Well As Pcit On The Very Same Date. The Ld. Ar Drawing Our Attention Towards Page 28 Of The Approval Note Submitted That The Ld. Acit While Granting Approval Noted “Yes, It Is A Fit Case” & The 1

For Appellant: Shri Shikar Garg, CA
Section 143(3)Section 147Section 148Section 151

First of all, ld. AR for the assessee drew our attention towards the sanction accorded by the ld. Principal CIT for reopening the assessment which is available at pages 14 & 15 of the paper book. On perusal of the sanction accorded by the ld. Principal CIT in the prescribed proforma ... what documents he had perused and what were the reasons for his being satisfied to accord the sanction to initiate the reopening of assessment u/ss 147/148 of the Act. 18. Even the AO has not applied his judicial mind independently while recording the reasons for initiating proceedings u/s 147/148

Smt. Manju Gupta, Kota vs. ITO, Ward-1, Bharatpur

In the result, appeal of the assessee is allowed

ITA 143/JPR/2023[2015-16]Status: DisposedITAT Jaipur14 Jun 2023AY 2015-16

Bench: Or During The Course Of Hearing.”

For Appellant: Shri Rajendra Agarwal (C.A.)For Respondent: Smt Monisha Chaudhary (Addl. CIT) a
Section 147Section 54F

appellant has filed written submissions along with documentary evidence and the same were perused. The appellant has contended that the reasons for reopening of assessment were came to the appellant's knowledge after completion of the entire re-assessment proceedings u/s 147 of the Act. However, in response ... justify her claim. In view of the above, it is clear that the appellant was fully aware of the reasons recorded for reopening of assessment u/s. 147 of the Act and made submissions accordingly. 4 Smt. Manju Gupta vs. ITO 7.5 Further, during the course of appellate proceedings, the appellant

Nuovo Pignone International Srl, Gurgaon vs. DCIT, Circle-2(2)(2), Delhi

In the result, appeal is allowed as indicated above

ITA 999/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Jun 2023AY 2018-19

Bench: Shri G.S. Pannu & Shri Saktijit Deyassessment Year: 2018-19 Nuovo Pignone International Versus Dcit, Circle 2(2)(2), Srl, 6Th Floor, Building No. 7A, International Taxation, Standard Chartered Building, New Delhi Dlf Cyber City, Phase-Iii, Gurgaon. Pan: Aabcg3212A (Appellant) (Respondent)

For Appellant: Sh. Sachit Jolly, Advocate &For Respondent: Sh. Virendra Singh, Sr. DR
Section 133ASection 143(3)Section 144C(13)

case of Blackstone Capital Partners (Singapore) VI FDI Three Pte. Ltd. (supra), Hon’ble jurisdictional High Court, while dealing with the issue of reopening of assessment based on information received from third party, observed, though such information can form basis for an examination/investigation by the Assessing Officer, but the decision ... reopen the assessment has to be of the Assessing Officer and not of the third party. The Assessing Officer cannot merely do a cut and paste job for reopening the assessment without independent application of mind or verification or investigation. The aforesaid ratio laid down by Hon’ble jurisdictional High

Jaquar and Company Private Limited, New Delhi vs. DCIT, Central Circle-19, Delhi

In the result, the appeal of the assessee in ITA No

ITA 1984/DEL/2022[2014-15]Status: DisposedITAT Delhi09 Jun 2023AY 2014-15

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Bhopal Singh, Sr. DR
Section 147Section 148Section 37(1)

have not been complied with. 2. That in any case and in any view of the matter, assumption of jurisdiction in reopening the assessment u/s 147, is bad in law and against the facts and circumstances of the case. 3. That having regard to the facts and circumstances ... weeks from the date of service of the order rejecting objections on the assessee. The above procedure is to be followed strictly for reopening of assessment.” 9. This judgment was followed by the co-ordinate bench in the case of Hirachand Kanuga in ITA No. 4261 and 4262/MUM/2012. The relevant

ACIT, Central Circle- 28, New Delhi vs. Solitaire World Pvt. Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 9627/DEL/2019[2011-12]Status: DisposedITAT Delhi09 Jun 2023AY 2011-12

Bench: Shri Narendra Kumar Billaiya & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.9627/Del/2019 िनधा"रणवष"/Assessment Year:2011-12 बनाम Acit Solitaire World Pvt. Ltd. Central Circle-28, Vs. 2678/1, Diamond Mall New Delhi. Gurudwara Road, Karol Bagh, New Delhi. Pan No. Aaocs1369R अपीलाथ" Appellant ""यथ"/Respondent

Section 143(1)Section 148Section 68

other hand, the Ld. Counsel for the assessee submits that in fact the objections filed by the assessee challenging the reopening of assessment were not disposed off by the Assessing Officer and therefore on this ground alone the assessment has to be quashed as bad in law. The Ld. Counsel

Ujjwal Microfinance Pvt Ltd, New Delhi vs. ITO Ward - 27(2), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 3877/DEL/2019[2011-12]Status: DisposedITAT Delhi09 Jun 2023AY 2011-12

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Rajendra Jha, Sr. DR
Section 142Section 144Section 147Section 148Section 151(1)

records carefully perused and relevant documentary evidences duly considered in light of Rule 18(6) of the ITAT Rules. 4. Reasons recorded for reopening the assessment read as under: “Reasons recorded in the case of M/S UJJWAL MICROFINANCE PVT. LTD.A.Y. 2011-12 for initiating proceedings u/s 147/148 of the Income ... whether the assessee has actually taken any accommodation entries amounting to Rs. 2.65 crores from White Collar Management Ltd., has, merely on suspicion, reopen the assessment proceedings. Whereas the facts remain that the assessee has not entered into any transaction of whatsoever nature with White Collar Management Ltd. during

Mesers S R Ingosts Private Limited, Raipur vs. Assistant Commissioner of Income Tax, Central Circle-1, Raipur

In the result Revised Ground no 4 of the assessee is partly allowed

ITA 4/RPR/2020[2011-12]Status: DisposedITAT Raipur09 Jun 2023AY 2011-12

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.04/Rpr/2020 (Assessment Year: 2011-2012) M/S S R Ingots Pvt. Ltd., Vs Acit, Cc-1, Raipur House No.16, Opp.Cg Gramin Bank, Choubey Colony, Raipur Pan No. :Aaics 5559 D (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Ajoy Kumar Singh & Smt. Surbhi Jain, Ars राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 12/04/2023 घोषणा क" तार"ख/Date Of Pronouncement : 09/06/2023 आदेश / O R D E R Per Arun Khodpia, Am :

For Appellant: Shri Ajoy Kumar Singh & Smt. Surbhi JainFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 132Section 147Section 148Section 153ASection 68

reopened by invoking provisions of section 148 was void ab initio and deserves to be quashed. 22. Ld CITDR, on this issue of reopening of assessment after witnessing the copies of documents instrumental in the process of recording of reasons for reopening as pressed into service

Navdeep Sharma, New Delhi vs. ITO(, Waqrd-71(1), New Delhi

In the result, appeal is dismissed

ITA 7067/DEL/2018[2010-11]Status: DisposedITAT Delhi08 Jun 2023AY 2010-11

Bench: Shri Saktijit Deyassessment Year: 2010-11

Section 139(1)Section 142(1)(iii)Section 147Section 148Section 151Section 151(2)Section 43(5)(d)Section 69A

assessment. Accordingly, after recording reasons and obtaining approval/sanction of the competent authority in terms of section 151 of the Act, 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 a return ... assessee to furnish supporting evidences for cash deposit after more than 3 years. Proceeding further, he submitted that while granting sanction for reopening of assessment, the competent authority has failed to apply his mind properly. In support of such contention, he relied upon the following decisions: 1. M/s. Chhugamal Rajpal

Rashi Steel and Power Limited, Bilaspur vs. ACIT, New Delhi

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

ITA 73/RPR/2021[2012-13]Status: DisposedITAT Raipur08 Jun 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./ Ita No. 73/Rpr/2021 (Assessment Year: 2012-13) M/S Rashi Steel & Power Ltd. Vs Acit Cf9, Rajeev Plaza, Bilaspur New Delhi Pan No. :Aaecr 6450 Q : Shri R.B.Doshi, Ca "नधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By : Shri Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 01/06/2023 घोषणा क" तार"ख/Date Of Pronouncement : 08/06/2023

For Respondent: Shri Ila M. Parmar, CIT-DR
Section 132Section 147Section 148Section 153ASection 2(22)(e)Section 250Section 271(1)Section 271(1)(b)Section 68Section 69

discussions with the banks FOR One time Settlement (OTS) to resolve the loan issues, the assessment proceedings were also commenced and culminated, the reopening of assessment was during the tenure of old management, however, the old management did not make any compliance, the new management could never come to know

Late Sh. Shekhar Dhariwal Through L/H Smt. Nikita Dhariwal, Dhariwal Bhawan, Shastri Market, Kota vs. ITO, Ward-2(2), Kota

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

ITA 51/JPR/2023[2014-15]Status: DisposedITAT Jaipur02 Jun 2023AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Monisha Choudhary, Addl.CIT
Section 147Section 148

Rupa Shyamsundar Dhumatkar Vs. ACIT (2020) 420 ITR 256 (Bom.) (HC) (Case laws compilation PB 31-32):-As per settled law, notice for reopening of assessment against a dead person is invalid. LATE SHRI SHEKHAR DHARIWAL THRU: L/H SMT NIKITA DHARIWAL VS ITO, WARD-2(2), KOTA Aemala Venkateswara ... have heard both the parties and perused the materials available on record. The case of the assessee was reopened for assessment proceedings u/s 147 of the Act. It is also noted by the Department as per PAN details, the assessee is individual and in this case no return of income

The ACIT Cent. Cir-6(4), Mumbai vs. Airmid Developers Ltd, Delhi

In the result, appeal filed by the Revenue/Department stands dismissed as infructuous

ITA 2381/MUM/2021[2012-13]Status: DisposedITAT Mumbai31 May 2023AY 2012-13

Bench: Shri Br Baskaran & Shri Narender Kumar Choudhrythe Acit, Cc-6(4), Vs Airmid Developers Ltd. Room No. 1925, 19Th M-62 & 63, 1St Floor, Floor, Connought Place, Air India Building, New Delhi-110001. Nariman Point, Pan: Aagca5601G Mumbai-400021. Appellant Respondent

For Appellant: Sh. K. Gopal, ARFor Respondent: Sh. Manoj Kumar Sinha, Sr. DR
Section 143(3)Section 147Section 148Section 250Section 36(1)(iii)Section 37

Commissioner qua additional ground is as under: “7. During the course of appellate proceedings, the appellant has raised an additional ground regarding the reopening of assessment The appellant has submitted that the Assessment Order u/s 143(3) was completed by the AO without taking any adverse view in respect ... considered by the AO while passing the original Assessment Order, therefore it is not a case of change of opinion and reopening of assessment is justifiable. Further, Ld. DR submitted that the original AO neither made any inquiry qua transaction between the assessee and its subsidiary company nor the Assessee

Vijayakumar Kanaiyalal Matta, Mumbai vs. ITO 26 (3)(4), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 53/MUM/2020[2014-15]Status: DisposedITAT Mumbai31 May 2023AY 2014-15

Bench: Shri Vikas Awasthy & Shri Amarjit Singhvk-Vk-La- 52@Eaqcbz@2020 ¼Fu-Oa- 2013&14½ Vk-Vk-La- 53@Eaqcbz@2020 ¼Fu-Oa- 2014&15½ Vijaykumar Kanaiyalal Matta 8/B/104, 10Th Floor, S. S. Nagar, Sion Koliwada, Sion Mumbai-400 037 ..... Vihykfkhz/Appellant Pan No. Aropm6060D Cuke Vs. Income Tax Officer – 26(3) (4) Room No.507, 5Th Floor, Pratyaksha Kar Bhawan, B. K. C. Bandra (E), ..... Izfroknh/Respondent Mumbai-400 051

For Appellant: Shri Tejveer Singh, AdvocateFor Respondent: Shri Abhishek Kumar Singh, Sr. AR
Section 131Section 147Section 148Section 69

assessee are decided in seriatim of assessment years. 4. The assessee in appeal has primarily raised two grounds. Ground no. 1, assailing reopening of assessment u/s 147 of the Act. Ground no. 2, against addition of unexplained investment u/s 69 of the Act. 5. Shri Tejveer Singh appearing on behalf ... submissions made by rival sides and have examined the orders of authorities below. The assessee in ground no. 1 of appeal has assailed reopening of assessment primarily on the ground that the reasons for reopening have not been recorded in a valid manner. We have examined the reasons for reopening

Vijayakumar Kanaiyalal Matta, Mumbai vs. ITO 26 (3)(4), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 52/MUM/2020[2013-14]Status: DisposedITAT Mumbai31 May 2023AY 2013-14

Bench: Shri Vikas Awasthy & Shri Amarjit Singhvk-Vk-La- 52@Eaqcbz@2020 ¼Fu-Oa- 2013&14½ Vk-Vk-La- 53@Eaqcbz@2020 ¼Fu-Oa- 2014&15½ Vijaykumar Kanaiyalal Matta 8/B/104, 10Th Floor, S. S. Nagar, Sion Koliwada, Sion Mumbai-400 037 ..... Vihykfkhz/Appellant Pan No. Aropm6060D Cuke Vs. Income Tax Officer – 26(3) (4) Room No.507, 5Th Floor, Pratyaksha Kar Bhawan, B. K. C. Bandra (E), ..... Izfroknh/Respondent Mumbai-400 051

For Appellant: Shri Tejveer Singh, AdvocateFor Respondent: Shri Abhishek Kumar Singh, Sr. AR
Section 131Section 147Section 148Section 69

assessee are decided in seriatim of assessment years. 4. The assessee in appeal has primarily raised two grounds. Ground no. 1, assailing reopening of assessment u/s 147 of the Act. Ground no. 2, against addition of unexplained investment u/s 69 of the Act. 5. Shri Tejveer Singh appearing on behalf ... submissions made by rival sides and have examined the orders of authorities below. The assessee in ground no. 1 of appeal has assailed reopening of assessment primarily on the ground that the reasons for reopening have not been recorded in a valid manner. We have examined the reasons for reopening