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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

Pinnacle Consrto and Ecohomes Pvt.Ltd, Pune vs. DCIT Circle-4, Pune

In the result, appeal filed by the assessee is allowed

ITA 2818/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2818/Pun/2025 निर्धारण वषा / Assessment Year : 2017-18 Pinnacle Contro & V Dcit, Ecohomes Pvt. Ltd., S Circle-4, Pune. Madhav Heritage, Tilak Road, Sadashiv Peth, Pune – 411030. Pan: Aaecp0400E Appellant/ Assessee Respondent /Revenue Assessee By Shri Suhas P. Bora Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18Dated 01.10.2025 Emanating From The Assessment Order Passed Under Section 147 Of The Act, Dated 27.08.2021. The Assessee Has Raised The Following Grounds Of Appeal : “1. Reassessment Bad In Law.

Section 143(3)Section 147Section 148Section 151Section 250Section 250(6)

same are bad in law, and void ab initio, as the reassessment order was passed without disposing of the appellant's objections to reopening of assessment and without passing a speaking order. 2. No fresh tangible material for reopening. The learned CIT(A) erred in confirming the reopening though ... cannot be sustained. As noted earlier, what we find is that there are no reasons to believe but only reasons to suspect. Hence, reopening of assessment is not satisfactory. 10. In the circumstances, the rule issued on 13th April 2016 is made absolute. The impugned notice dated 20thMarch

Sanjay Champalal Jaiswal, Nanded-Waghala vs. ITO, Ward-1, Nanded-Waghala

In the result, appeal of the assessee is partly allowed

ITA 2136/PUN/2025[2016-17]Status: DisposedITAT Pune08 Jan 2026AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2136/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Sanjay Champalal Jaiswal, V The Income Tax Officer, At Post, Hadsani, Mahur, S Ward-1, Nanded. Tq.Mahur, Nanded-Waghala, Maharashtra - 431721. Pan: Awlpj7783Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Govind Prasad Mandala (Through Virtual) Revenue By Shri Madhukar Anand – Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2016-17 Dated 18.07.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 29.03.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 147Section 148Section 149Section 250Section 69A

dated 29.03.2023. The Assessee has raised the following grounds of appeal : ITA No.2136/PUN/2025 [A] “1) The learned CIT (A) erred in upholding the reopening of assessment vide notice u/s. 148 of the Act dated 27/7/2022 Le. After expiry of three years from the end of the assessment year

Income Tax Officer, Pune vs. Sagar Construction Company, Pune

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

basis of information obtained that the assessee has taken unsecured loan of Rs.1.62 crores in cash through Shri Sachin Nahar, the Assessing Officer reopened the assessment by recording the following reasons, copy of which is placed at page 15 of the paper book: 3. The Assessing Officer accordingly issued notice ... response to which the assessee submitted its reply. The assessee also filed objections against the reopening of assessment u/s 147 on 16.02.2022. The Assessing Officer disposed of the objections on 07.03.2022 as per the directions of Hon’ble Supreme Court in the case of GKN Driveshafts (India

Apcotex Industries Limited, Raogarh vs. Income Tax Officer - Circle 15(1)(1), Mumbai

In the result, having regard to the foregoing discussion and

ITA 6022/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Jan 2026AY 2013-14

Bench: Shri Amit Shuk

Section 143(3)Section 144BSection 147Section 148Section 148ASection 24Section 250Section 32

grounds of appeal: 1. On the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeal) erred in upholding the reopening of assessment without appreciating that notice dated 28.07.2022 issued u/s 148 was time barred, being not within time limit provided u/s 149 of the income

Parvindar Indar Singh, Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

In the result, the appeal filed by the Assessee in ITA No

ITA 1002/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2013-14

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 147Section 14ASection 154

necessary for his assessment for the year under consideration thereby necessitating reopening u/s. 147 of the Act.” 2.1. The assessee objected to the reopening of assessment as there is no failure on the part of the assessee to make full and true disclosure and all necessary details were placed ... record in the original return and assessed to tax. Thus the reopening of assessment beyond four years period is not valid in law when there is no failure on the part of the assessee. Further, the reopening is merely based on change of opinion, which is not justified

Parvindar Indar Singh, Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

In the result, the appeal filed by the Assessee in ITA No

ITA 1001/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2013-14

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 147Section 14ASection 154

necessary for his assessment for the year under consideration thereby necessitating reopening u/s. 147 of the Act.” 2.1. The assessee objected to the reopening of assessment as there is no failure on the part of the assessee to make full and true disclosure and all necessary details were placed ... record in the original return and assessed to tax. Thus the reopening of assessment beyond four years period is not valid in law when there is no failure on the part of the assessee. Further, the reopening is merely based on change of opinion, which is not justified

West Bengal Electronics Industry Development Corporation Limited, Kolkata vs. DCIT/ACIT, Circle - 2(1), Kolkata

The appeal of the assessee is allowed

ITA 1591/KOL/2024[2013-2014]Status: DisposedITAT Kolkata07 Jan 2026AY 2013-2014
Section 143(3)Section 147Section 148Section 24(1)Section 250

condition has remained viz. that where the assessing officer has reason to believe that income has escaped a assessment, confers jurisdiction to reopen the assessment. Therefore, post-1-4-1989, power to reopen is much wider. However, one needs to give a schematic interpretation to the words "reason to believe ... precondition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then, in the garb of reopening the assessment, review would take place. 7. One must treat the concept of "change of opinion" as an in-built test to check abuse of power

West Bengal Electronics Industry Development Corporation Limited, Kolkata vs. D.C.I.T./A.C.I.T., Circle - 2(1), Kolkata

The appeal of the assessee is allowed

ITA 1590/KOL/2024[2012-2013]Status: DisposedITAT Kolkata07 Jan 2026AY 2012-2013
Section 143(3)Section 147Section 148Section 24(1)Section 250

condition has remained viz. that where the assessing officer has reason to believe that income has escaped a assessment, confers jurisdiction to reopen the assessment. Therefore, post-1-4-1989, power to reopen is much wider. However, one needs to give a schematic interpretation to the words "reason to believe ... precondition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then, in the garb of reopening the assessment, review would take place. 7. One must treat the concept of "change of opinion" as an in-built test to check abuse of power

All India Insurance Pensioners Association, Chennai vs. On Corp Ward 9(1) Che/, Chennai

In the result, appeal filed by the assessee is allowed

ITA 2879/CHNY/2025[2019-20]Status: DisposedITAT Chennai07 Jan 2026AY 2019-20

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.R.V. Veeramani, CAFor Respondent: Mr. K.Ilaiyaraja, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

issued notice u/s.148 of the Act on 31.03.2023 [a copy of which has been placed before us], and pursuant to it, reopened the assessment for AY 2019-20 u/s.147 of the Act and thereafter, the Assessment Unit Income Tax Department passed the re/assessment order on 24.02.2024 making certain additions ... Association :: 8 :: has been issued contrary to law and is against the ‘Rule of Law’; which impugned action of the JAO vitiates the reopening of assessment for AY 2019-20 by issuance of impugned notice dated 31.03.2023 u/s.148 of the Act and is therefore held to be illegal

Wellcare International Hospital and Research Institute Pvt. Ltd., Trichy vs. ITO, Ward-1(1), Trichy

In the result, appeal filed by the assessee is allowed

ITA 2867/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Jan 2026AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Ms. R. Sumedha, Advocate for Ms. G. Vardini KarthickFor Respondent: Mr. K.Ilaiyaraja, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

Trichy, had issued notice u/s.148 of the Act on 06.04.2022 [a copy of which has been placed before us], and pursuant to it, reopened the assessment for AY 2018-19 u/s.147 of the Act and thereafter, the Assessment Unit Income Tax Department passed the re/assessment order on 07.03.2024 making certain ... since it has been issued contrary to law and is against the ‘Rule of Law’; which impugned action of the JAO vitiates the reopening of assessment for AY 2018-19 by issuance of impugned notice dated 06.04.2022 u/s.148 of the Act and is therefore held to be illegal

Vijayakumar Balaji, Coimbatore vs. ITO, Ncw-3(1), Coimbatore

In the result, appeal filed by the assessee is allowed

ITA 2853/CHNY/2025[2020-21]Status: DisposedITAT Chennai07 Jan 2026AY 2020-21

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.S. Girish Kumar AdvocateFor Respondent: Mr. Shiva Srinivas, CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

copy of which has been placed before us], and ITA Nos.2853/Chny/2025 (AY 2020-21) Vijayakumar Balaji. :: 5 :: pursuant to it, reopened the assessment for AY 2020-21 u/s.147 of the Act and thereafter, the Assessment Unit Income Tax Department passed the re/assessment order on 22.01.2025 making certain additions. The action ... since it has been issued contrary to law and is against the ‘Rule of Law’; which impugned action of the JAO vitiates the reopening of assessment for AY 2020-21 by issuance of impugned notice dated 30.03.2024 u/s.148 of the Act and is therefore held to be illegal

Shanmugam Palanisamy, Keerambur vs. Income Tax Officer, Ward 2, Namakkal

In the result, appeal filed by the assessee is allowed

ITA 2701/CHNY/2025[2020-21]Status: DisposedITAT Chennai07 Jan 2026AY 2020-21

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.P.M.Kathir, AdvocateFor Respondent: Mr. K.Ilaiyaraja, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

Namakkal, had issued notice u/s.148 of the Act on 22.03.2024 [a copy of which has been placed before us], and pursuant to it, reopened the assessment for AY 2020-21 u/s.147 of the Act and thereafter, the Assessment Unit Income Tax Department passed the re/assessment order on 29.01.2025 making certain ... Palanisamy. :: 8 :: has been issued contrary to law and is against the ‘Rule of Law’; which impugned action of the JAO vitiates the reopening of assessment for AY 2020-21 by issuance of impugned notice dated 22.03.2024 u/s.148 of the Act and is therefore held to be illegal

M/S Jhs Svendgaard Laboratories Ltd., New Delhi vs. DCIT CC-31, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3454/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Jhs Svendgaard Vs. Dcit Laboratories Ltd. B1/E-23, Central Circle-31, New Mohan Cooperative Delhi Tuhglakabad, Badarpur, New Delhi New Delhi Pan: Aabcj5766G Appellant Respondent Assessee By Sh. Gaurav Jain, Adv & Sh. Tarun Chanana, Adv Revenue By Ms.Amisha S. Gupt, Cit (Dr) Date Of Hearing 09/10/2025 Date Of Pronouncement 07/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-30, New Delhi [‘Ld. Cit(A)’

Section 147Section 148Section 151ASection 37

with the Assessee’s transactions and the alleged escapement of income. Mere receipt of general or unverified information cannot, by itself, justify the reopening of assessment or sustain an addition. The "reason to believe" contemplated under Section 147 requires the AO to form an independent belief founded on relevant

ACIT Circle-28(1), New Delhi vs. Munjal Holdings, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 5834/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 250Section 68

ITA No.5834/Del/2024 ACIT Vs. Munjal Holdings THE INCOME TAX APPELLATE TRIBUNAL DELHI “E” BENCH: NEW DELHI BEFORE SHRI SUDHIR KUMAR

Global Emerging Markets India Limited, New Delhi vs. NFAC, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4050/DEL/2024[2013-2014]Status: DisposedITAT Delhi07 Jan 2026AY 2013-2014

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshglobal Emerging Markets Assessment Unit, India Limited, Income Tax Department, B-28, Pushpanjali Farms, Vs. Nfac. Bijwasan. Pan-Aaacg3233C (Appellant) (Respondent) Appellant By Ms. Prem Lata Bansal, Sr. Adv. & Shri Shivang Bansal, Adv. Respondent By Shri Rajesh Kumar Dhaneshta, Sr. Dr Date Of Hearing 03.12.2025 Date Of Pronouncement 07.01.2026

Section 139(1)Section 147Section 148Section 148ASection 149Section 149A

Respectfully following the said decision, we hold that the notice issued u/s 148 of the Act on 28.06.2022 is barred by limitation. Since, reopening of assessment has been quashed, the adjudication of the other grounds raised by the assessee becomes academic in nature and they are left open

Ajay Kumar Bajaj, Raipur vs. Income Tax Officer-4(1), Raipur

In the result, appeal of the assessee in ITA

ITA 596/RPR/2025[2017-18]Status: DisposedITAT Raipur06 Jan 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.596/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Ajay Kumar Bajaj 1, Adarsh Nagar, Mowa, Raipur-492 001 (C.G.) Pan: Akepb2140C

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 148Section 151

vide Ground of appeal 3. No.2 is that the Revenue has not provided the relevant information to the assessee, based on which, the reopening of assessment was done. 4. In this regard, the Ld. Counsel for the assessee demonstrates that vide letter dated 03.03.2022 for A.Y.2017-18, the department had provided ... There was no communication whatsoever given to the assessee to understand what are those information in possession of the Revenue, based on which, reopening of assessment has been done in the case of the assessee. In other words, the assessee contends that certain information were used by the Department

Shah Mahendrakumar Mafatlal (HUF), Mithkhali vs. Income Tax Officer, Ward 1(1)(3), Ahmedabad

In the result, the appeal of the assessee for A

ITA 1689/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad06 Jan 2026AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1688 & 1689/Ahd/2025 (िनधा"रण वष" / Assessment Years : 2014-15 & 2015-16) बनाम/ Shah Mahendrakumar Income Tax Officer Mafatlal Huf Ward-1(1)(3), Vs. 27D, Maharashtra Society, Ahmedabad Anmol Mithkhali Owners Asso Mithkhali, Ellisbridge, Ahmedabad, Gujarat - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaihs8263H (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Sulabh Padshah, Ar ""यथ" क" ओर से/Respondent By : Shri Yogesh Mishra, Sr. Dr 16/12/2025 Date Of Hearing Date Of Pronouncement 06/01/2026

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147

escapement of income or default on part of appellant at any stage of proceeding. On facts and circumstances of the case, the whole reopening of assessment is bad in law and void-ab-initio and thus the order passed by lower authorities deserves to be set a aside and order ... fictitious loan transactions and it has no nexus or relevance with Appellant's case. On facts and circumstances of the case, the entire reopening of assessment is completely illegal and unjustifiable and therefore the Assessment order passed u/s 147 rws 143(3) of the Act be quashed and set aside

Shah Mahendrakumar Mafatlal (HUF), Mithkhali vs. Income Tax Officer, Ward 1(1)(3), Ahmedabad

In the result, the appeal of the assessee for A

ITA 1688/AHD/2025[ 2014-15]Status: DisposedITAT Ahmedabad06 Jan 2026

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1688 & 1689/Ahd/2025 (िनधा"रण वष" / Assessment Years : 2014-15 & 2015-16) बनाम/ Shah Mahendrakumar Income Tax Officer Mafatlal Huf Ward-1(1)(3), Vs. 27D, Maharashtra Society, Ahmedabad Anmol Mithkhali Owners Asso Mithkhali, Ellisbridge, Ahmedabad, Gujarat - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaihs8263H (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Sulabh Padshah, Ar ""यथ" क" ओर से/Respondent By : Shri Yogesh Mishra, Sr. Dr 16/12/2025 Date Of Hearing Date Of Pronouncement 06/01/2026

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147

escapement of income or default on part of appellant at any stage of proceeding. On facts and circumstances of the case, the whole reopening of assessment is bad in law and void-ab-initio and thus the order passed by lower authorities deserves to be set a aside and order ... fictitious loan transactions and it has no nexus or relevance with Appellant's case. On facts and circumstances of the case, the entire reopening of assessment is completely illegal and unjustifiable and therefore the Assessment order passed u/s 147 rws 143(3) of the Act be quashed and set aside

Smt. Urmila Dhelia, Mumbai vs. Income Tax Officer Ward 23(3)(1), Mumbai

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

ITA 4259/MUM/2025[2011-12]Status: DisposedITAT Mumbai06 Jan 2026AY 2011-12

Bench: Shri Narender Kumar Choudhry

For Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 143Section 143(3)Section 147Section 2(24)Section 2(24)(vi)Section 234ASection 271(1)(c)

alongwith questionnaire were issued from time to time and served on the assessee. The reasons recorded by the AO for reopening of assessment are given as under:- "In this case, information is received from the office of ITO 23(2)(3), Mumbai that the assessee has received Rs.18

Naval Seth L/H Late Sh. Ghansham Dass Seth, Delhi vs. ACIT Circle-28(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 6210/DEL/2025[2016-17]Status: DisposedITAT Delhi06 Jan 2026AY 2016-17

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Ms. Mansi Jain, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 147Section 148Section 148ASection 151Section 250

save the assesses from 4 | P a g e Naval Seth vs ACIT Circle -28(1) harassment resulting from the mechanical reopening of assessments. 128 A table representing the prescription under the old and new regime is set out below: 74. The above table indicates that the specified authority