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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

Saravana Stores, Chennai vs. ACIT, C.C-1(2), Chennai

In the result, the appeal stands partly allowed in terms of our above order

ITA 488/CHNY/2021[2012-13]Status: DisposedITAT Chennai02 Nov 2022AY 2012-13

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T.Vasudevan (Advocate)- Ld. ARFor Respondent: Shri AR.V. Sreenivasan (Addl. CIT)-Ld. Sr. DR
Section 143(3)Section 147Section 148

appeal is contrary to law, erroneous and unsustainable on the facts of the case. JURISDICTION : 2. The CIT(A) erred in upholding the reopening of assessment by issue of notice dated 20.03.2019 under sec.148 of the Act. 3. The CIT(A) failed to appreciate that the reopening of assessment ... disclose material facts, ought to have applied the settled law that 'change of opinion' and also audit objection cannot be ground for reopening the assessment and hence is to be annulled. 6. The CIT(A) was not justified in confirming the reworking of closing stock value, considering

M/S N. G. Group, Mumbai vs. ITO, Ward-28(2)(, Navi Mumbai

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

ITA 503/MUM/2022[2009-10]Status: DisposedITAT Mumbai01 Nov 2022AY 2009-10

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am M/S N.G. Group The Income Tax Officer Plot No.8, Sector 11 3Rd Floor, 6Th Tower, Off Juinagar Railway Station, Vsrccl, Vashi Vs. Sanpada, Navi Mumbai–400703 Navi Mumbai –400709 (Respondent) (Appellant) Pan No. Aaffn9159E Assessee By : Ms. Ritika Agarwal, Ar Revenue By : Shri Chetan M. Kacha, Sr. Ar Date Of Hearing: 02.08.2022 Date Of Pronouncement: 01-11-2022

For Appellant: Ms. Ritika Agarwal, ARFor Respondent: Shri Chetan M. Kacha, SR. AR
Section 144Section 148Section 250Section 271(1)(c)Section 68

income of ₹79,49,960/-. 012. Assessee aggrieved with assessment order preferred the appeal before the learned CIT (A). The assessee challenged the reopening of assessment, which was dismissed. The assessee has also challenged the addition of ₹40 lacs of unsecured loans. The learned CIT (A) deleted the addition

Zarco Realities Pvt. Ltd., Lower Parel vs. Commissioner of Income Tax (Appeals) - 48, Churchgate

ITA 923/MUM/2022[2008-2009]Status: DisposedITAT Mumbai31 Oct 2022AY 2008-2009

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2008-09

For Appellant: NoneFor Respondent: Shri Satyapal Kumar, D.R
Section 143(3)Section 147Section 68

opening the assessment u/s. 147 of the Act and the Honourable CIT Appeal has erred in law and facts in confirming the Reopening of Assessment. 2. Appellant craves leave to add to, amend, alter and/or delete any of the forgoing grounds of appeal any time on or before the hearing ... Rs.320/- per share whereas since 23.01.2008 its share price was hovering around Rs.30/- per share. AO after recording the reasons reopened the assessment after initiating the proceedings under section 147/148 of the Act. Declining the contentions raised by the assessee AO proceeded to make the addition of Rs.3

The Dy CIT (It)-Circle-3(3)(2), Mumbai vs. Manish Vijay Mehta, Mumbai

In the result, appeals of the learned Assessing Officer and CO of the assessee for both the years are dismissed

ITA 494/MUM/2021[2006-07]Status: DisposedITAT Mumbai31 Oct 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Ajay Singh, ARFor Respondent: Shri Soumendu Kumar Dash, DR
Section 148

containing in ‘base note’ stating that same is confidential information and further that the learned Assessing Officer has fallen into grave error in reopening the assessment on the basis of the ‘base note’. It was further argued that the ‘base note’ does not mention any amount deposited during the relevant ... that of a Non resident and there is no dispute on the said facts. (Asst order pg 1). 6. Reasons recorded for reopening of assessment pg 123-124. 7. The AO had mentioned in the first paragraph of the assessment order itself that "Information was received by Government of India

The Dy CIT (It)-Circle-3(3)(2), Mumbai vs. Manish Vijay Mehta, Mumbai

In the result, appeals of the learned Assessing Officer and CO of the assessee for both the years are dismissed

ITA 493/MUM/2021[2007-08]Status: DisposedITAT Mumbai31 Oct 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Ajay Singh, ARFor Respondent: Shri Soumendu Kumar Dash, DR
Section 148

containing in ‘base note’ stating that same is confidential information and further that the learned Assessing Officer has fallen into grave error in reopening the assessment on the basis of the ‘base note’. It was further argued that the ‘base note’ does not mention any amount deposited during the relevant ... that of a Non resident and there is no dispute on the said facts. (Asst order pg 1). 6. Reasons recorded for reopening of assessment pg 123-124. 7. The AO had mentioned in the first paragraph of the assessment order itself that "Information was received by Government of India

The Dy CIT (It)-Circle-3(3)(2), Mumbai vs. Urvi Manish Mehra, Mumbai

In the result, appeals of the learned Assessing Officer and CO of the assessee for both the years are dismissed

ITA 492/MUM/2021[2007-08]Status: DisposedITAT Mumbai31 Oct 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Ajay Singh, ARFor Respondent: Shri Soumendu Kumar Dash, DR
Section 148

containing in ‘base note’ stating that same is confidential information and further that the learned Assessing Officer has fallen into grave error in reopening the assessment on the basis of the ‘base note’. It was further argued that the ‘base note’ does not mention any amount deposited during the relevant ... that of a Non resident and there is no dispute on the said facts. (Asst order pg 1). 6. Reasons recorded for reopening of assessment pg 123-124. 7. The AO had mentioned in the first paragraph of the assessment order itself that "Information was received by Government of India

The Dy CIT (It)-Circle-3(3)(2), Mumbai vs. Urvi Manish Mehta, Mumbai

In the result, appeals of the learned Assessing Officer and CO of the assessee for both the years are dismissed

ITA 491/MUM/2021[2006-07]Status: DisposedITAT Mumbai31 Oct 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Ajay Singh, ARFor Respondent: Shri Soumendu Kumar Dash, DR
Section 148

containing in ‘base note’ stating that same is confidential information and further that the learned Assessing Officer has fallen into grave error in reopening the assessment on the basis of the ‘base note’. It was further argued that the ‘base note’ does not mention any amount deposited during the relevant ... that of a Non resident and there is no dispute on the said facts. (Asst order pg 1). 6. Reasons recorded for reopening of assessment pg 123-124. 7. The AO had mentioned in the first paragraph of the assessment order itself that "Information was received by Government of India

Dy CIT, CC-3(3)(1), Mumbai vs. M/S Reliance Industries Holding P. Ltd., Mumbai

In the result, both the cross-objection are allowed, and both the appeals are dismissed as infructuous

ITA 126/MUM/2021[2010-11]Status: DisposedITAT Mumbai31 Oct 2022AY 2010-11
Section 92A(2)(j)

cases of reopened assessments, it is reopening of the assessment which isthe foundational aspect of the matter. Grievance against the reasons for reopening the assessment, which is not adjudicated by the learned CIT(A), has been raised by the assessee ... granted by the learned CIT(A) on other grounds. 3. The material facts of both cases are common, and the reasons recorded for reopening the assessment are also exactly the same. The reopening was done on the basis of inputs from the investigation wing about the outstanding put options

Dy CIT, CC-3(3)(1), Mumbai vs. M/S Reliance Industries Holding P. Ltd., Mumbai

In the result, both the cross-objection are allowed, and both the appeals are dismissed as infructuous

ITA 125/MUM/2021[2008-09]Status: DisposedITAT Mumbai31 Oct 2022AY 2008-09
Section 92A(2)(j)

cases of reopened assessments, it is reopening of the assessment which isthe foundational aspect of the matter. Grievance against the reasons for reopening the assessment, which is not adjudicated by the learned CIT(A), has been raised by the assessee ... granted by the learned CIT(A) on other grounds. 3. The material facts of both cases are common, and the reasons recorded for reopening the assessment are also exactly the same. The reopening was done on the basis of inputs from the investigation wing about the outstanding put options

M/S Radiance Exim Pvt Ltd., Mumbai vs. ITO 8 (1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6635/MUM/2019[2007-08]Status: DisposedITAT Mumbai31 Oct 2022AY 2007-08

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.6635/Mum/2019 (निर्धारण वर्ा / Assessment Year: 2007-08) M/S. Radiance Exim Pvt. बिधम/ Ito-8(1)(1) Ltd. Room No.621A, 6Th Floor, Vs. Shiv Chawl No.2, Shiv Aayakar Bhavan, M. K. Sagar Sejar Samiti, Tanaji Road, Mumbai-400020. Nagar, Kurar Village, Malad (E), Mumbai, Maharashtra, 400097. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aabcr4706L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Ashok Bansal Revenue By: Smt Mahita Nair (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 21/09/2022 घोषणा की तारीख /Date Of Pronouncement: 31/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-21, Mumbai Dated 31.07.2019 For The Assessment Year 2007-08. 2. At The Outset, The Ld. Ar Of The Assessee Has Challenged The Legality/Validity Of The Action Of Ao To Re-Open The Assessment Of Ay 2007-08 U/S 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”) By Issuance Of Notice U/S 148 Of The Act Dated 26.03.2014 & Consequent Passing Of Re-Assessment Order Vide Order Dated 20.03.2015, Which According To The Ld. Ar, Is Bad In Law For Several Reasons (Infra). According To The Ld. Ar, The Ao Did Not Had The Requisite Jurisdiction To Re-Open The Assessment U/S 147 Of The Act Because The Reasons Recorded By The Ao Dated 18.03.2014 (Refer Page

For Appellant: Shri Ashok BansalFor Respondent: Smt Mahita Nair (Sr. AR)
Section 142(1)Section 147Section 148

office of the DGIT(Inv.) which was based on search at the premises of Shri Praveen Kumar Jain group has resorted to reopen the assessment for AY. 2007-08, after issuing notice u/s 148 of the Act dated 26.03.2014. According to the Ld. AR, the fundamental jurisdictional requirement ... different ‘reasons recorded’ according to Ld AR shows non-application of mind and thus the AO did not had the requisite jurisdiction to reopen the assessment for AY. 2007-08. Moreover, according to the Ld. AR adverse information may trigger “reason to suspect”, (when he received information from DGIT

Solvex Interchem Pvt. Ltd., Mumbai vs. ACIT- 2 (3)(2), Mumbai

ITA 6973/MUM/2018[2010-11]Status: DisposedITAT Mumbai31 Oct 2022AY 2010-11

Bench: Shri Kuldip Singhassessment Year: 2010-11

For Appellant: Shri Himanshu Gandhi, A.RFor Respondent: Shri Azhar Zain Vayal Parambath, D.R
Section 143(3)Section 147Section 147BSection 147CSection 148Section 151(2)Section 68

recorded for initiating the reopening by the AO goes to prove that the same are very vague and ambiguous reasons, not sufficient to reopen the assessment. Firstly, information was received from DDIT(Inv.) that high value transactions by M/s. Solvex Interchem Pvt. Ltd. were found in the bank account ... Whether the Income Tax Appellate Tribunal was right in law in coming to the conclusion that when on the ground on which the reopening of assessment is based, no additions are made by the Assessing Officer in the order of assessment, he cannot make additions on some other grounds which

Ashwin S. Mehta, Mumbai vs. DCIT Cen Cir 4(1), Mumbai

In the result, both the appeals filed by the assessee for the A

ITA 2735/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Oct 2022AY 2013-14

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleashwin S. Mehta V. Dcit – Central Circle – 23 32, Madhuli, Dr. A.B. Road [Now Dcit, Cc-4(1)] Worli, Mumbai – 400018 4Th Floor, Aayakar Bhavan M.K. Road, Mumbai - 400020 Pan: Abapm2121M (Appellant) (Respondent)

Section 10(34)Section 142(1)Section 143(2)Section 148Section 14A

allow the ground raised by the assessee. Accordingly, ground raised by the assessee is allowed. 34. Coming to additional ground No.2, challenging reopening of assessment u/s. 147 as invalid and bad in law, Ld. AR submitted that this ground is not pressed, accordingly, the same is dismissed as not pressed

Ashwin S. Mehta, Mumbai vs. Asst CIT Cen Cir 4(1), Mumbai

In the result, both the appeals filed by the assessee for the A

ITA 2734/MUM/2017[2012-13]Status: DisposedITAT Mumbai28 Oct 2022AY 2012-13

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleashwin S. Mehta V. Dcit – Central Circle – 23 32, Madhuli, Dr. A.B. Road [Now Dcit, Cc-4(1)] Worli, Mumbai – 400018 4Th Floor, Aayakar Bhavan M.K. Road, Mumbai - 400020 Pan: Abapm2121M (Appellant) (Respondent)

Section 10(34)Section 142(1)Section 143(2)Section 148Section 14A

allow the ground raised by the assessee. Accordingly, ground raised by the assessee is allowed. 34. Coming to additional ground No.2, challenging reopening of assessment u/s. 147 as invalid and bad in law, Ld. AR submitted that this ground is not pressed, accordingly, the same is dismissed as not pressed

Ashwin S. Mehta, Mumbai vs. DCIT Cen Cir 23, Mumbai

In the result, both the appeals filed by the assessee for the A

ITA 422/MUM/2016[2011-12]Status: DisposedITAT Mumbai28 Oct 2022AY 2011-12

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleashwin S. Mehta V. Dcit – Central Circle – 23 32, Madhuli, Dr. A.B. Road [Now Dcit, Cc-4(1)] Worli, Mumbai – 400018 4Th Floor, Aayakar Bhavan M.K. Road, Mumbai - 400020 Pan: Abapm2121M (Appellant) (Respondent)

Section 10(34)Section 142(1)Section 143(2)Section 148Section 14A

allow the ground raised by the assessee. Accordingly, ground raised by the assessee is allowed. 34. Coming to additional ground No.2, challenging reopening of assessment u/s. 147 as invalid and bad in law, Ld. AR submitted that this ground is not pressed, accordingly, the same is dismissed as not pressed

Rajarathnam'S Jewels, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-1(1), Bangalore

In the result, appeal by the Assessee is dismissed

ITA 370/BANG/2022[2013-14]Status: DisposedITAT Bangalore28 Oct 2022AY 2013-14

Bench: Shri N. V. Vasudevan & Shri Laxmi Prasad Sahuassessment Year : 2013-14

For Appellant: Shri. H. Anil Kumar, CAFor Respondent: Shri. K. R. Narayana, Addl. CIT(DR)(ITAT), Bengaluru
Section 133ASection 143(3)

included either in the capital account or as a stock of the firm. The revenue authorities added the same in the assessment after reopening the assessment as the same was not considered in assessment for relevant assessment year. One of the substantial questions of law referred by the Tribunal ... Appellate Tribunal (ITAT) in ITA Nos.1344 to 1350/Bang/2017 for Assessment Years 2006-07 to 2012-13, by order dated 18.02.2021 held that reopening of assessment under section 148 of the Act was not valid and quashed the said assessments. It was contended that the Tribunal in the said order

Oopal Diamond, Mumbai vs. ACIT-19(2), Mumbai

In the result, appeal of the assessee for A

ITA 1501/MUM/2020[2013-14]Status: DisposedITAT Mumbai26 Oct 2022AY 2013-14
Section 143(3)

they are taken up together and disposed off by this common order for the sake of convenience. 2. The ground No.1 challenging the reopening of assessment was stated to be not pressed by the ld. AR at the time of hearing. The same is reckoned as a statement made from

Oopal Diamond, Mumbai vs. ACIT-19(2), Mumbai

In the result, appeal of the assessee for A

ITA 1500/MUM/2020[2011-12]Status: DisposedITAT Mumbai26 Oct 2022AY 2011-12
Section 143(3)

they are taken up together and disposed off by this common order for the sake of convenience. 2. The ground No.1 challenging the reopening of assessment was stated to be not pressed by the ld. AR at the time of hearing. The same is reckoned as a statement made from

Oopal Diamond, Mumbai vs. ACIT - 19(2), Mumbai

In the result, appeal of the assessee for A

ITA 1499/MUM/2020[20010-11]Status: DisposedITAT Mumbai26 Oct 2022
Section 143(3)

they are taken up together and disposed off by this common order for the sake of convenience. 2. The ground No.1 challenging the reopening of assessment was stated to be not pressed by the ld. AR at the time of hearing. The same is reckoned as a statement made from

Shri Bansilal S. Bhatti, Mumbai vs. ITO - 19(1)(2), Mumbai

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

ITA 298/MUM/2021[2011-12]Status: DisposedITAT Mumbai25 Oct 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am Income Tax Officer Shri Bansilal S. Bhatti Ward 19(1)(2) 155 Steel Apartment, 6Th 2Nd Floor, Matru Mandir Floor, Kumarwada, Vs. Grant Road, Mumbai-400 004 Tardeo Road, Mumbai (Appellant) (Respondent) Pan No. Aodpb5366B Assessee By : None Revenue By : Shri Ujjwal Chavan, Dr Date Of Hearing: 20.09.2022 Date Of Pronouncement: 25.10.2022

For Appellant: NoneFor Respondent: Shri Ujjwal Chavan, DR
Section 143(1)Section 143(3)Section 147Section 148Section 69C

addition made by the learned AO were confirmed. 08. Assessee is aggrieved and is in appeal before us. Assessee has not challenged the reopening of assessment but has challenged the addition on merits. Despite notice to the assessee on 6th occasions, none 09. appeared, therefore, the appeal of the assessee

Parthiban, Chennai vs. ITO Non Corporate Ward-7(2), Chennai

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

ITA 562/CHNY/2020[2014-15]Status: DisposedITAT Chennai21 Oct 2022AY 2014-15

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 562/Chny/2020 िनधा"रण वष"/Assessment Year:2014-15 Shri Parthiban, Vs. The Income Tax Officer, Plot No. 83-A, Door No. 9, Thiruvallur Non Corporate Ward 7(2), Street, Jagadhambigai Nagar, Chennai 600 034. Chennai 600 050. [Pan:Biipp0005R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Sitaraman, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 23.08.2022 घोषणा की तारीख /Date Of Pronouncement : 21.10.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 7, Chennai, Dated 17.01.2020 Relevant To The Assessment Year 2014-15. 2. Facts Are, In Brief, That The Assessee Has Filed His Return Of Income For The Assessment Year 2014-15 On 14.07.2014 Returning Nil Income & Agricultural Income Of ₹.43,00,530/-. The Case Was Selected Through Cass & The Assessment Was Completed Under 2

For Appellant: Shri G. Sitaraman, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 142(1)Section 143(2)Section 143(3)Section 148Section 2(1)(A)

No.562/Chny/20 section 143(3) of the Income Tax Act, 1961 [“Act” in short] dated 18.08.2016 accepting the income returned. Subsequently, the Assessing Officer reopened the assessment by issuing notice under section 148 of the Act dated 12.02.2019 for the following reasons: “During the period, you have an agricultural income ... making addition of ₹.41,04,312/- towards sale proceeds of standing crops treated as income from other sources. 3. The assessee challenged the reopening of assessment before the ld. CIT(A) and the ld. CIT(A) has held that reopening is valid. 4. On being aggrieved the assessee carried