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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

Lml Ltd, Mumbai vs. DCIT 3(2), Mumbai

ITA 3449/MUM/2013[2005-06]Status: DisposedITAT Mumbai13 Apr 2022AY 2005-06

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2001-02

For Appellant: NoneFor Respondent: Shri Salil Mishra (CIT-DR) &
Section 14ASection 35ASection 37Section 40A(9)Section 4O

manufacturing and sundry equipment. 4. In A.Y. 2005-06 & 2006-07 on the information received from Directorate of Enforcement, AO recorded reasons and reopened the assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act by noticing that the AO during ... Similarly, in A.Y. 2006-07 the AO on the basis of information received from Directorate of Enforcement recorded the reasons and initiated the reopening of assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act. The AO noticed that

Lml Ltd, Mumbai vs. ITO 3(2)(2), Mumbai

ITA 3008/MUM/2013[2004-05]Status: DisposedITAT Mumbai13 Apr 2022AY 2004-05

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2001-02

For Appellant: NoneFor Respondent: Shri Salil Mishra (CIT-DR) &
Section 14ASection 35ASection 37Section 40A(9)Section 4O

manufacturing and sundry equipment. 4. In A.Y. 2005-06 & 2006-07 on the information received from Directorate of Enforcement, AO recorded reasons and reopened the assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act by noticing that the AO during ... Similarly, in A.Y. 2006-07 the AO on the basis of information received from Directorate of Enforcement recorded the reasons and initiated the reopening of assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act. The AO noticed that

DCIT 3(2), Mumbai vs. Lml Ltd, Mumbai

ITA 2680/MUM/2013[2003-04]Status: DisposedITAT Mumbai13 Apr 2022AY 2003-04

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2001-02

For Appellant: NoneFor Respondent: Shri Salil Mishra (CIT-DR) &
Section 14ASection 35ASection 37Section 40A(9)Section 4O

manufacturing and sundry equipment. 4. In A.Y. 2005-06 & 2006-07 on the information received from Directorate of Enforcement, AO recorded reasons and reopened the assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act by noticing that the AO during ... Similarly, in A.Y. 2006-07 the AO on the basis of information received from Directorate of Enforcement recorded the reasons and initiated the reopening of assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act. The AO noticed that

DCIT 3(2), Mumbai vs. Lml Ltd, Mumbai

ITA 2679/MUM/2013[2002-03]Status: DisposedITAT Mumbai13 Apr 2022AY 2002-03

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2001-02

For Appellant: NoneFor Respondent: Shri Salil Mishra (CIT-DR) &
Section 14ASection 35ASection 37Section 40A(9)Section 4O

manufacturing and sundry equipment. 4. In A.Y. 2005-06 & 2006-07 on the information received from Directorate of Enforcement, AO recorded reasons and reopened the assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act by noticing that the AO during ... Similarly, in A.Y. 2006-07 the AO on the basis of information received from Directorate of Enforcement recorded the reasons and initiated the reopening of assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act. The AO noticed that

Lml Limited, Mumbai vs. Addl. CIT, Range - 3(2), Mumbai

ITA 2654/MUM/2013[2003-4]Status: DisposedITAT Mumbai13 Apr 2022

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2001-02

For Appellant: NoneFor Respondent: Shri Salil Mishra (CIT-DR) &
Section 14ASection 35ASection 37Section 40A(9)Section 4O

manufacturing and sundry equipment. 4. In A.Y. 2005-06 & 2006-07 on the information received from Directorate of Enforcement, AO recorded reasons and reopened the assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act by noticing that the AO during ... Similarly, in A.Y. 2006-07 the AO on the basis of information received from Directorate of Enforcement recorded the reasons and initiated the reopening of assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act. The AO noticed that

Lml Limited, Mumbai vs. Addl. CIT, Range - 3(2), Mumbai

ITA 2653/MUM/2013[2002-03]Status: DisposedITAT Mumbai13 Apr 2022AY 2002-03

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2001-02

For Appellant: NoneFor Respondent: Shri Salil Mishra (CIT-DR) &
Section 14ASection 35ASection 37Section 40A(9)Section 4O

manufacturing and sundry equipment. 4. In A.Y. 2005-06 & 2006-07 on the information received from Directorate of Enforcement, AO recorded reasons and reopened the assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act by noticing that the AO during ... Similarly, in A.Y. 2006-07 the AO on the basis of information received from Directorate of Enforcement recorded the reasons and initiated the reopening of assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act. The AO noticed that

Lml Ltd, Mumbai vs. Addl CIT RG 3(2), Mumbai

ITA 1894/MUM/2013[2001-02]Status: DisposedITAT Mumbai13 Apr 2022AY 2001-02

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2001-02

For Appellant: NoneFor Respondent: Shri Salil Mishra (CIT-DR) &
Section 14ASection 35ASection 37Section 40A(9)Section 4O

manufacturing and sundry equipment. 4. In A.Y. 2005-06 & 2006-07 on the information received from Directorate of Enforcement, AO recorded reasons and reopened the assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act by noticing that the AO during ... Similarly, in A.Y. 2006-07 the AO on the basis of information received from Directorate of Enforcement recorded the reasons and initiated the reopening of assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act. The AO noticed that

Addl CIT RG 3(2), Mumbai vs. Lml Ltd, Mumbai

ITA 7742/MUM/2012[2001-02]Status: DisposedITAT Mumbai13 Apr 2022AY 2001-02

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2001-02

For Appellant: NoneFor Respondent: Shri Salil Mishra (CIT-DR) &
Section 14ASection 35ASection 37Section 40A(9)Section 4O

manufacturing and sundry equipment. 4. In A.Y. 2005-06 & 2006-07 on the information received from Directorate of Enforcement, AO recorded reasons and reopened the assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act by noticing that the AO during ... Similarly, in A.Y. 2006-07 the AO on the basis of information received from Directorate of Enforcement recorded the reasons and initiated the reopening of assessment under section 147 of the Act by way of issuance of notice under section 148 of the Act. The AO noticed that

Lokesh Talanki, Bangalore vs. The Assistant Commissioner of Income Tax Circle-2(3)(1), Bangalore

In the result, appeals of the assessee are allowed

ITA 261/BANG/2019[2013-14]Status: DisposedITAT Bangalore13 Apr 2022AY 2013-14

Bench: Shri Beena Pillai & Ms. Padmavathy Sassessment Year : 2013-14

For Appellant: Shri Deepesh Waghale CAFor Respondent: Shri Shehnawaz Ul Rahaman Addln CIT
Section 142(1)Section 143(2)Section 143(3)Section 148Section 234BSection 54F

based on mere change of opinion. The assessing officer has not found any new evidence and he has not applied his mind in reopening the assessment b. The learned Commissioner appeals erred in acknowledging the fact that the assessing officer is not justified in reopening the file ... noticed that the residential property which the assessee owned along with the 3 others was bought by the assessee on 01.09.2004. The AO reopened the assessment of the year under consideration u/s.148 by notice dated 30.10.2017 to verify the claim of section 54F as the AO was of the opinion

Barkha Ramesh Merchant, Mumbai vs. ACIT 16(1), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 779/MUM/2020[2013-14]Status: DisposedITAT Mumbai12 Apr 2022AY 2013-14

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Blebarkha Ramesh Merchant V. Acit – 16(1) 110/111, Crescent Mansion Room No. 439 Gamdevi Lane, Gamdevi Aayakar Bhavan Mumbai-400007 M.K. Road Mumbai - 400020 Pan: Afnpm4225P (Appellant) (Respondent) Assessee By : Shri Chintan Patel Department By : Shri Dilipkumar Shah

For Appellant: Shri Chintan PatelFor Respondent: Shri Dilipkumar Shah
Section 10(38)Section 143(1)Section 148

dated 31.12.2017 in gross contravention of provisions of law as the Ld AO failed to provide necessary statements so relied upon for reopening of assessment and an opportunity to cross-examine the person(s) who had given adverse statements and thus reopening of assessment

Harbans B Thapar, Mumbai vs. ITO Ward 26(1)(5), Mumbai

In the result, appeal by assessee is allowed for statistical purpose in the terms aforesaid

ITA 1299/MUM/2020[2010-11]Status: DisposedITAT Mumbai08 Apr 2022AY 2010-11

Bench: Shri Pramod Kumar, Vice- & Shri Vikas Awasthyआअसं. 1299/मुं/2020 ("न. व .2010-11) Harbans B. Thapar, Anthony Road, Near Uttam Soc. Chembur, Mumbai 400 071 Pan: Aatpt-3454-C ...... अपीलाथ" /Appellant बनाम Vs. Income Tax Officer , Ward 26(1)(5), Kautilya Bhavan. G Block, Bandra Kurla Complex, Mumbai 400 051 ..... ""तवाद"/Respondent

For Appellant: Shri J.P.PurohitFor Respondent: Shri T. Sankar
Section 143(2)Section 144Section 147Section 148

Mumbai [in short 'the CIT(A)’] dated 13/02/2019 for the assessment year 2010-11. 2 2. The assessee in appeal has assailed reopening of assessment as well as addition on merits. The assessee has also raised a ground assailing that the additional evidences filed by the assessee were not accepted ... assessee on 30/03/2017. In response to the notice the assessee filed return of income and also asked for the reasons for reopening the assessment u/s. 147 of the Act. The reasons for reopening were allegedly not provided to the assessee. The Assessing Officer in the assessment order reproduced the reasons

M/S Atlanta Ltd, Mumbai vs. DCIT Ircle-9 (1)(2), Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 7427/MUM/2019[2013-14]Status: DisposedITAT Mumbai08 Apr 2022AY 2013-14

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Shri Mehul Jain
Section 133(6)Section 143(3)Section 147Section 37Section 68

Appeal in ITA.No. 7426/MUM/2019 for Assessment Year 2012-13 as a lead case. 3. Assessee has raised following grounds in its appeal: - 1. Reopening of Assessment u/s. 147 a) On the facts and circumstances of the case and in law, the learned CIT(A) erred in confirming the reopening beyond ... absence of failure on part of the appellant to disclose fully or truly all material facts necessary for its assessment, the reopening of assessment is bad in law and needs to be quashed. b) The learned CIT(A) erred in confirming the reopening of assessment

M/S Atlanta Ltd, Mumbai vs. DCIT Ircle-9 (1)(2), Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 7426/MUM/2019[2012-13]Status: DisposedITAT Mumbai08 Apr 2022AY 2012-13

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Shri Mehul Jain
Section 133(6)Section 143(3)Section 147Section 37Section 68

Appeal in ITA.No. 7426/MUM/2019 for Assessment Year 2012-13 as a lead case. 3. Assessee has raised following grounds in its appeal: - 1. Reopening of Assessment u/s. 147 a) On the facts and circumstances of the case and in law, the learned CIT(A) erred in confirming the reopening beyond ... absence of failure on part of the appellant to disclose fully or truly all material facts necessary for its assessment, the reopening of assessment is bad in law and needs to be quashed. b) The learned CIT(A) erred in confirming the reopening of assessment

Union Bank of India, Mumbai vs. Dy CIT Ltu-2, Mumbai

In the result, appeals filed by the assessee for assessment years 2009-10

ITA 1580/MUM/2020[UNION BANK OF INDIA]Status: DisposedITAT Mumbai07 Apr 2022

Bench: Shri Vijay Pal Rao & Shri Gagan Goyal

Section 14ASection 154Section 36(1)

allowed and the appeal of the revenue stands dismissed. 7. For the Assessment year 2011-12, the assessee has raised the following grounds:- Reopening of Assessment 1.1 The Ld. CIT(A) failed to appreciate that,AO reopened the assessment after a period of 4 years from ... after four years from the end of the assessment year. 8. The Ld.AR of the assessee has submitted that the Assessing Officer has reopened the assessment after the expiry of four years from the original assessment framed under section 143(3), therefore, the reopening is not valid

Assistant Commissioner of Income Tax Circle-1(3)(1), Bangalore vs. Shri B S Yediyurappa, Bangalore

In the result, Appeal of the Revenue is dismissed and CO filed by the assessee is dismissed, as not pressed

ITA 14/BANG/2019[2011-12]Status: DisposedITAT Bangalore07 Apr 2022AY 2011-12

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Asst.Commissioner Of Shri B.S. Yediyurappa, Income Tax, No.381, Davalgiri, Ii Main Circle - 1(3)(1) Vs. Vi Cross, Off 80 Ft Road, Bengaluru Rmv 2Nd Stage, Bengaluru Pan – Aaapy4922F Appellant Respondent

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Priyadarshini Mishra, Addl. CIT
Section 132Section 148

assessment were furnished as an Annexure. It is submitted that upon receipt of the reasons recorded, as aforesaid, the assessee filed objections for reopening the assessment vide letter dated 14.03.2016 filed on 15.03.2016. It is submitted that the assessee had contended that the re- opening of the assessments were unjustified ... appeal. 7. Against the assessment order the assessee carried appeal before the learned CIT(A). The learned CIT(A) observed with regard to reopening of assessment that the AO recorded reasons to believe based on information received consequent to search and seizure carried in the case of M/s. RNS Infrastructure

ITO Ward - 1(1), Kalyan vs. Shri Riten Kantilal Gada, Kalyan

In the result, the appeal filed by the revenue is hereby dismissed and cross objection filed by the assessee is hereby partly allowed

ITA 2017/MUM/2020[2010-11]Status: DisposedITAT Mumbai06 Apr 2022AY 2010-11

Bench: Shri Pramod Kumar, Vp & Amarjit Singh, Am आयकर अपील सं/ I.T.A. No.2017/Mum/2020 (निर्धारण वर्ा / Assessment Year: 2010-11) Ito, Ward -1(1) बिधम/ Shri Riten Kantilal Gada 1St Floor, Mohan Plaza, F. No.202, Green Acres, Vs. Wayale Nagar, Kalyan West- Anjur Phata, Near Oswal Saga, Kamatghar Road, 421301. Bhiwandi-421302. & Cross Objection No.148/Mum/2021 आयकर अपील सं/ I.T.A. No. 2017/Mum/2020 (निर्धारण वर्ा / Assessment Year: 2010-11) Shri Riten Kantilal Gada बिधम/ Ito, Ward -1(1) 1St Floor, Mohan Plaza, F. No.202, Green Acres, Vs. Anjur Phata, Near Oswal Wayale Nagar, Kalyan West- Saga, Kamatghar Road, 421301. Bhiwandi-421302. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Acmps3743C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Shri R.A. Dhyani (Sr. Ar) Assessee By: Shri Mayur J. Gosrani सुनवाई की तारीख / Date Of Hearing: 14/03/2022 घोषणा की तारीख /Date Of Pronouncement: 06/04/2022 आदेश / O R D E R Per Amarjit Singh, Jm: The Revenue As Well As Assessee Have Filed The Above Mentioned Appeal As Well As Cross-Objection Against The Order Dated 08.09.2020 Passed By The Commissioner Of Income Tax (Appeals)-02, Thane [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2010-11. C.O. No.148/Mum/2021 A.Y.2010-11

For Appellant: Shri Mayur J. GosraniFor Respondent: Shri R.A. Dhyani (Sr. AR)
Section 143Section 147

Further Ld. CIT(A) neither provided any documentary evidence on the basis of which AO established a reason to believe for reopening of assessment nor provided Cross Examination of the concern third party even after specifically requested by the appellant during the course of CIT(A) proceedings and also specifically

Rajendra Chaudhary HUF, Mumbai vs. ITO 21 (3)(1), Mumbai

In the result, ground No.6 of appeal is allowed

ITA 7687/MUM/2019[2009-10]Status: DisposedITAT Mumbai04 Apr 2022AY 2009-10

Bench: Shri Vikas Awasthyआअसं. 7687/मुं/2019 ("न.व 2009-10) Rajendra Chaudhary (Huf), Flat No.13, 366, Veer Savarkar Marg, 3Rd Floor, Ramkunj, Dhuruwadi, Prabhadevi, Mumbai 400 025. Pan: Aaehr-8352-N ...... अपीलाथ" /Appellant बनाम Vs. Income Tax Officer 21(3)(1), Room No.207, 2Nd Floor, Piramal Chambers, Lalbaug, Mumbai – 400 012 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Ashok Mehta ""तवाद" "वारा/Respondent By : Shri T. Shankar सुनवाई क" "त"थ/ Date Of Hearing : 07/01/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 04/04/2022

For Appellant: Shri Ashok MehtaFor Respondent: Shri T. Shankar
Section 133(6)Section 143(3)Section 147

appearing on behalf of the assessee submitted at the outset that the assessee is not pressing ground No.2 of the appeal, challenging 2 reopening of assessment u/s. 147 of the Income Tax act, 1961 ( in short ‘ the Act’). The ld. Authorized Representative for the assessee narrating the facts

ITO 10 (1)(3), Mumbai vs. Kailashnath Mercantile Pvt. Ltd., Mumbai

ITA 6451/MUM/2018[2009-10]Status: DisposedITAT Mumbai30 Mar 2022AY 2009-10
For Respondent: Shri Tejinder Pal Singh Anand (DR)
Section 139(1)Section 143(1)Section 143(3)Section 144ASection 147Section 148Section 68

evasive and does not address the objection of the appellant. As has been seen from the catena of judgments relied by the AR, reopening of assessment as per the provisions of the law requires that satisfaction should be that of the AO and not of the any other authority, apart ... issued shared at premium and such transactions has been directed to be examined by the Hon. CCIT, he is initiating the reassessment. While reopening the assessment it is sine qua non that assessing officer is satisfied that the income has escaped assessment and therefore the case is required

Sri Hanumanthiah, Bangalore vs. Income-Tax Officer, Bangalore

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

ITA 205/BANG/2017[2009-10]Status: DisposedITAT Bangalore30 Mar 2022AY 2009-10

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year: 2009-10

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 148Section 2(47)(v)Section 53A

Bengaluru and it relates to the assessment year 2009-10. In this appeal, the assessee has raised following issues:- a) Validity of reopening of assessment b) Validity of assessing long term capital gain upon entering Joint Development Agreement (JDA). Sri Hanumanthiah, Bangalore Page 2 of 12 At the time ... hearing, the Ld. A.R. did not press grounds relating to validity of reopening of assessment. Accordingly, those ground are dismissed as not pressed. 2. The facts relating to the case are stated in brief. The assessee is an individual. He filed his return of income for the year under consideration

Arvind Hanjarimal Jain, Mumbai vs. Asst CIT 31 (2), Mumbai

In the result, all the appeals filed by the assessee are allowed

ITA 270/MUM/2020[2012-13]Status: DisposedITAT Mumbai29 Mar 2022AY 2012-13

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

For Appellant: Shri Jain DixitFor Respondent: Shri Mehul Jain
Section 132Section 133(6)Section 139Section 143Section 143(2)Section 143(3)Section 148Section 154

same. 6. Aggrieved assessee preferred an appeal before the Ld.CIT(A) and filed detailed submissions wherein assessee has raised grounds of appeal objecting reopening of assessment u/s. 148 of the Act, addition made u/s.68 of the Act and disallowance of interest expenditure. 7. Ld.CIT(A) considered the submissions of grounds ... appeal raised by the assessee, Ld.CIT(A) rejected the objections raised by the assessee on reopening of assessment with the following observations: - “6.3.3 However, where the proceedings were originally completed u/s 143(1) of the Act, or where initial proceeding was completed u/s 143(3) of the Act and action