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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

R K Dreamland, Rajkot vs. DCIT, CC-1, Rajkot

ITA 558/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A) The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

R K Dreamland, Rajkot vs. DCIT, CC-1, Rajkot

ITA 557/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A) The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

Chinmay Yogeshkumar Agrawal, HUF, Ahmedabad vs. The ITO, Ward-3(1)(1), Ahmedabad

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

ITA 2431/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad11 Mar 2026AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 132Section 144BSection 147Section 148Section 151Section 250Section 68

Rs.58,61,712/- as bogus cash credit of the assessee. The Ld. CIT(A) neither considered the grounds of appeal on the reopening of assessment as well as merits of the case. The assessee was never given any opportunity of hearing before deciding the appeal. Thus, Ld. Counsel requested

DCIT., Circle-2(1), Hydrabad vs. Kalptaru Investments Private Limited, Hyderabad

ITA 1077/HYD/2025[2013-14]Status: DisposedITAT Hyderabad11 Mar 2026AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.1077/Hyd/2025

For Appellant: Sri P Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 147Section 148

belief that the assessee had incurred commission of Rs.2,93,31,831 and in that view of the matter, the condition precedent for reopening the assessment having not been met, the assumption of jurisdiction u/s 148 ought to be held as bad in law. (iii) For that on the facts ... reopening to be void ab initio. (iv) For that on the facts and in the circumstances of the case, the reasons recorded for reopening the assessment was based on borrowed satisfaction and the AO did not objectively apply his own mind to the purported information received by him and therefore

Combine Diamonds Private Limited, Bandra Kurla Complex, Mumbai vs. Assistant Commissioner of Income Tax -5(1)(2), Mumbai

In the result, the appeal filed by the Assessee stands allowed

ITA 2480/MUM/2025[2009-10]Status: DisposedITAT Mumbai11 Mar 2026AY 2009-10

Bench: Shri Narender Kumar Choudhrya N D Shri Prabhash Shankara.Y: 2009-10 Combine Diamonds Vs. Acit-5(1)(2), Mumbai Private Limited Fw 6010B, 6Th Floor, Bharat Diamond Bourse, East Wing, Bandra Kurla Complex, Bandra East, Mumbai – 400051. Pan/Gir No. Aaacc9949H (Applicant) (Respondent) Assesseeby : Shri Rahul Sarda, Ca Revenue By : Shri Virabhadra Mahajan (Sr. Dr)

For Appellant: Shri Rahul Sarda, CAFor Respondent: Shri Virabhadra Mahajan (SR. DR)
Section 142(1)Section 143(3)Section 147Section 148Section 250

issuing notice dated 01.07.2016 u/s 142(1) of the Act. 5.1 However the AO thereaftervide letter dated 15.07.2016 issued/communicated/forwarded the reasons recorded for reopening of assessment u/s 147 of the Act, to the Assessee. And without waiting for the Assessee to file objectionsif any, to the reopening u/sec ... very same date. 6. The Assesseethereafter vide letter dated 06.09.2016 filed objectionsto the reopening of assessment proceedings, which were disposed of by the AO, vide letter dated 09.09.2016. Thereafter the AO issued statutory notices to the Assessee and ultimately vide assessment order dated 15.12.2016 u/s 143(3) r.w.s

Uma Kant Garg, Delhi vs. ACIT, Delhi

In the result, appeal of the assessee is allowed

ITA 7289/DEL/2025[2020-21]Status: DisposedITAT Delhi11 Mar 2026AY 2020-21

Bench: Shri Vikas Awasthyआअसं.7289/धिल्ली/2025 (नि.व. 2020-21) Uma Kant Garg, 36, Shera Mohalla, Garhi, Delhi 110065 ...... अपीलार्थी/Appellant Pan: Afxpg-6149-Q बिाम Vs. Income Tax Officer, Ward-62(1), ..... प्रनिवादी/Respondent Delhi 110002 अपीलार्थी द्वारा/Appellant By : Shri D C Garg, Chartered Accountant प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr (Through Vc) सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 11/03/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 24.09.2025, For Assessment Year 2020-21. 2. Shri D. C. Garg, Appearing On Behalf Of The Assessee Submits That The Assessee In Appeal Has Raised Legal Ground Assailing Validity Of Reopening Of Assessment. The Assessee In Grounds Of Appeal Has Also Challenged Addition On Merits. The Ld. Counsel Pointed That Reopening Of Assessment Is Bad In Law As The Notice Issued U/S 148 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) & The Approval Granted U/S 151 Of The Act By The Principal Commissioner Of Income-Tax (Pcit) Are Unsigned. To Substantiate His Contention, He Referred To Copy Of The 2 Notice Placed At Page 2 Of The Paper Book & The Approval Granted U/S 151 Of The Act Placed At Pages 3 & 4 Of The Paper Book. The Ld. Counsel Further Pointed That After The Issuance Of The Notice U/S 148 Of The Act, The Assessee Filed Return Of Income On 29.06.2024 Declaring Income Of Rs.10,23,800/-. Thereafter, The Assessing Officer (Ao) Issued Notice U/S 143(2) R.W.S. 147 Of The Act On 07.10.2024. The Said Notice Is At Pages 26 To 29 Of The Paper Book. In The Said Notice It Is Mentioned That:-

For Appellant: Shri D C Garg, Chartered AccountantFor Respondent: Shri Manoj Kumar, Sr. DR (Through VC)
Section 143(2)Section 148Section 151

Shri D. C. Garg, appearing on behalf of the assessee submits that the assessee in appeal has raised legal ground assailing validity of reopening of assessment. The assessee in grounds of appeal has also challenged addition on merits. The ld. Counsel pointed that reopening of assessment ... heard. The assessee has raised a legal ground i.e. ground no. 2 and ground no. 4 of appeal challenging validity of reopening of assessment as the notice issued u/s.148 of the Act and the approval u/s.151 of the Act is unsigned. A copy of the notice u/s.148

Sumitra Devi, Gurgaon vs. ITO, Ward 4(1), Gurgaon

ITA 2499/DEL/2025[2013-14]Status: DisposedITAT Delhi11 Mar 2026AY 2013-14

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. M.R. Sahu, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR
Section 144Section 147Section 148Section 148(1)

service on the assessee, that too, within the time frame envisaged under section 149 of the Act is necessary for a valid reopening of assessment. Reliance is placed on the following decisions wherein, it was held that mere issuance of notice u/s.148 is not enough for reassessment proceedings ... other hand, Ld. DR submitted that section 148(1) of the Act mandates only the issuance of notice for assuming jurisdiction to reopen an assessment. The statute consciously uses the expression “The Assessing Officer shall issue a notice

East Delhi Leasing P.Ltd, New Delhi vs. ITO, Ward-8(1), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 7917/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Mar 2026AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 147Section 148

assessee company on 15.10.2010 declaring Nil ITA No. 7917/Del/2019 income. No assessment was framed on the said return. The Id. AO sought to reopen the assessment for the Asst Year 2010-11 by recording the following reasons: - “Sir/Madam, Please refer to your letter dated 03-07-2017 filed in response ... part of the assessee to disclose fully and truly all material facts. Therefore, I am satisfied that it is a fit case for reopening the assessment u/s 147 and issuance of notice u/s 148 of the Act for the Financial Year 2009-10 relevant to Assessment Year 2010-11. Further

Shri Gandhi Maulana Azad Shramjivi Ashra, Kutch vs. Income Tax Officer, Exemption Ward 1, Rajkot

In the result, appeals of the assessee, are allowed

ITA 612/RJT/2025[2016-17]Status: DisposedITAT Rajkot10 Mar 2026AY 2016-17

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

assesse argued that there is 10 grounds of appeal as per the Form-36 out of 4 grounds of appeal on reopening of assessment order u/s. 147 of the Income Tax Act. The Ld. AR further submitted written submission before this Tribunal. Ground No. 2: (a) Reopening is based ... duly enclosed at page no. However, the Ld. AO has failed to consider the documents and has proceeded to reopen the assessment without proper inquiries and without perusing the documents available on record. The copy of financial statements of the trust is duly enclosed at page

Shri Gandhi Maulana Azad Shramjivi Ashra, Kutch vs. Income Tax Officer, Exemption Ward 1, Rajkot

In the result, appeals of the assessee, are allowed

ITA 611/RJT/2025[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

assesse argued that there is 10 grounds of appeal as per the Form-36 out of 4 grounds of appeal on reopening of assessment order u/s. 147 of the Income Tax Act. The Ld. AR further submitted written submission before this Tribunal. Ground No. 2: (a) Reopening is based ... duly enclosed at page no. However, the Ld. AO has failed to consider the documents and has proceeded to reopen the assessment without proper inquiries and without perusing the documents available on record. The copy of financial statements of the trust is duly enclosed at page

Deputy Commissioner of Income Tax, Yamunanagar vs. M/S the Ved Parkash Mukand Lal, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 833/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

inadvertent. This is not relevant, provided there is omission or failure on the part of the assessee. The latter confers jurisdiction to reopen an assessment. [Para 12]. Whether or not there was a failure or omission to disclose fully and truly material facts, is essentially a question of fact. Section ... incurred relatable to tax free income, there was omission and failure on its part to disclose fully and truly material facts and hence reopening of assessment was justified. 3.6 In the background of all these facts and judicial decisions, it was concluded by Ld. CIT(A) that

DCIT vs. M/S the Ved Parkash Mukand Lal, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 832/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

inadvertent. This is not relevant, provided there is omission or failure on the part of the assessee. The latter confers jurisdiction to reopen an assessment. [Para 12]. Whether or not there was a failure or omission to disclose fully and truly material facts, is essentially a question of fact. Section ... incurred relatable to tax free income, there was omission and failure on its part to disclose fully and truly material facts and hence reopening of assessment was justified. 3.6 In the background of all these facts and judicial decisions, it was concluded by Ld. CIT(A) that

The Ved Prakash Mukand Lal Educational Society, Yamunanagar vs. DCIT, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 825/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

inadvertent. This is not relevant, provided there is omission or failure on the part of the assessee. The latter confers jurisdiction to reopen an assessment. [Para 12]. Whether or not there was a failure or omission to disclose fully and truly material facts, is essentially a question of fact. Section ... incurred relatable to tax free income, there was omission and failure on its part to disclose fully and truly material facts and hence reopening of assessment was justified. 3.6 In the background of all these facts and judicial decisions, it was concluded by Ld. CIT(A) that

The Ved Prakash Mukand Lal Educational Society, Yamunanagar vs. DCIT, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 824/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

inadvertent. This is not relevant, provided there is omission or failure on the part of the assessee. The latter confers jurisdiction to reopen an assessment. [Para 12]. Whether or not there was a failure or omission to disclose fully and truly material facts, is essentially a question of fact. Section ... incurred relatable to tax free income, there was omission and failure on its part to disclose fully and truly material facts and hence reopening of assessment was justified. 3.6 In the background of all these facts and judicial decisions, it was concluded by Ld. CIT(A) that

Badamidevi Sardarmal Purohit, Mumbai vs. Income Tax Officer 19(1)(1), Parel

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

ITA 7398/MUM/2025[2015-16]Status: DisposedITAT Mumbai10 Mar 2026AY 2015-16

Bench: Shri Sandeep Gosain & Shri Jagadishassessment Year: 2015-16 Badamidevi Sardarmal Vs. Income Tax Officer 19(1)(1) Purohit Shop No.2, 3Rd Floor, Plot No.10 Dr Ss Rao Marg, Parel, Mumbai- 400012 Mistry Building, Padamji Road, Near Dream Land Cinema, Mumbai-400004 Pan: Akcpp0288R (Appellant) (Respondent) Assessee By Shri Vimal Punmiya Department By Shri Alok Singh (Cit-Dr) Date Of Hearing 09.03.2026 Date Of Pronouncement 10.03.2026

Section 143(3)Section 144BSection 147Section 148Section 68

basis of the said information, the Assessing Officer formed a belief that income chargeable to tax had escaped assessment and accordingly reopened the assessment under section 147 of the Act. In response to notice issued under section 148, the assessee filed return of income declaring the same income as originally ... from the impugned order it is evident that the issues raised by the assessee in the grounds of appeal, including the challenge to reopening of assessment and the addition made under section 68 of the Act, have not been adjudicated on merits. 8. It is well settled that the first

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 770/RJT/2024[2022-23]Status: DisposedITAT Rajkot09 Mar 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A). The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 769/RJT/2024[2021-22]Status: DisposedITAT Rajkot09 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A). The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 768/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A). The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 767/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A). The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 766/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

carried the matter in appeal before the learned CIT(A). The learned CIT(A) dismissed the technical grounds raised by the assessee, challenging reopening of assessment under section 147/148 of the Act. On merit, learned CIT(A), estimated the profit element on the “on money”, at the rate