“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

ITO 19 1 5 Mumbai, Mumbai vs. Johratussharaf Syedna Mufaddal Saifuddin, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 9040/MUM/2025[AMRPS6217J]Status: DisposedITAT Mumbai09 Mar 2026

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2017-18 Ito – 19(1)(5) Vs. Johratussharf Syedna 502, Piramal Chembers Mufaddal Saifuddin Lalbaug, Mumbai – Saifee Mahal, Ag Bell 400012. Marg, Mumbai – 400006. Pan/Gir No. Amrps6217J (Applicant) (Respondent)

Section 147Section 148Section 148ASection 151Section 250

Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) failed to appreciate that reopening of assessment for A.Y. 2017-18 was squarely within time as per TOLA Notification No. 20/2021 & 38/2021 and CBDT Instruction No. 01/2022, where the requirement of fresh ... erred in quashing the reassessment order merely holding that there is no fresh tangible material to reopen the assessment, without appreciating the fact that the Ld. CIT(A) in its order for A.Y. 2018-19 in assessee’s own case, has accepted that the material found pertains

Primegold Steel and Power Limited, Club Road Punjabi Bagh Extension, Delhi vs. ACIT, Central Circle 26, Delhi

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

ITA 5257/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Mar 2026AY 2015-16

Bench: Shri Vimal Kumar & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16]

Section 147

dismissed the challenge of the assessee in the following manner. “…7. As regards, the legal grounds relating to reopening of assessment u/s 147 of the Act, I do not find any infirmity with the proceedings. The proceedings have been initiated by the AO as per the due process

Kamlesh Sharma, Raipur vs. DCIT, Circle-1(1), Raipur

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

ITA 70/RPR/2026[2020-21]Status: DisposedITAT Raipur06 Mar 2026AY 2020-21

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 70/Rpr/2026 (िनधा"रण वष" Assessment Year: 2020-21) Kamlesh Sharma, House No.109, Vs Deputy Commissioner Of Income Harihant Nagar, Sarona, Tax, Circle-1(1), Central Revenue Ring Road No.1, Raipur-492001, Cg Building, Civil Lines, Raipur-492001 Pan: Bppps4514C (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None (Adjournment Petition Filed) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2026 घोषणा की तारीख / Date Of : 06/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2020-21 Filed By The Assessee Is Directed Against The Order Dated 18.12.2025 Of The Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: None (Adjournment Petition filed)For Respondent: Dr. Priyanka Patel, Sr. DR

Section 10Section 139(1)Section 147Section 148Section 151ASection 249(3)Section 250Section 57Section 69

appeal by rejecting the delay condonation application by the Ld. CIT(A). The 2nd ground, a legal ground, challenges the validity of reopening of assessment. The 3rd ground is in respect of merit of the additions made in the assessment order. 2 Kamlesh Sharma vs. DCIT, Circle

Vinod Kumar Kailashchandra Verma, Raipur vs. Income Tax Officer, Ward-1(3), Raipur

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

ITA 69/RPR/2026[2015-16]Status: DisposedITAT Raipur06 Mar 2026AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 69/Rpr/2026 (िनधा"रण वष" Assessment Year: 2015-16) Vinod Kumar Khailashchandra Verma, Vs Income Tax Officer, Ward 3(1), House No.496/9, Avanti Vihar, Sector-2, Central Revenue Building, Telibandha, Raipur-492001 (C.G.) Civil Lines, Raipur, C.G. 492001 Pan: Aanpv5964B (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None. (Adjournment Petition Filed.) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2026 घोषणा की तारीख / Date Of : 06/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am:

For Appellant: None. (Adjournment petition filed.)For Respondent: Dr. Priyanka Patel, Sr. DR

Section 144Section 147Section 148Section 151Section 249(2)Section 249(3)Section 250Section 69A

appeal by rejecting the delay condonation application by the Ld. CIT(A). The 2nd & 3rd ground, legal grounds, challenge the validity of reopening of assessment. The 4th ground is in respect of merit of the additions made in the assessment order. 3. The relevant facts giving rise to this appeal

Income Tax Officer, Ward-3(1), Kolkata vs. A J Cast Alloys Private Limited, Howrah

ITA 1685/KOL/2024[2011-12]Status: DisposedITAT Kolkata06 Mar 2026AY 2011-12

Section 132(1)Section 133(6)Section 143(1)Section 147Section 148Section 250Section 69C

account of bogus purchases. The assessee has also filed petition under Rule 27 of the Income Tax Appellate Tribunal Rules, 1963 challenging the reopening of assessment u/s 147 of the Act on the ground raised in Rule 27 which is extracted below: “1. That on the facts ... circumstances of the case, the Leamed Assessing Officer has erred in law and on facts in reopening the assessment on the basis of reasons recorded in a vague, scanty, and non-specific manner, without mentioning the exact nature and complete details of the alleged transactions which were alleged

Suresh Kumar Poddar, Kolkata vs. I.T.O., Ward - 63(4), Kolkata

In the result, appeal of the assessee is allowed

ITA 1542/KOL/2024[2011-2012]Status: DisposedITAT Kolkata06 Mar 2026AY 2011-2012

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 111ASection 132Section 132(1)Section 139(1)Section 144Section 147Section 148Section 153CSection 250Section 250o

PCIT (2022) 147 taxmann.com 362 (Karnataka). 7. After hearing the rival contention and perusing the material available on record, we find that undisputedly reopening of assessment was made on the basis of information revealed during the course of search on third party i.e. of Shri Shirish Chandrakant Shah during ... After hearing the rival contentions and perusing the materials available on rec- ord, we find that undisputedly, the source of information for reopening of assess- 5 Suresh Kumar Poddar ment of the assessee u/s 147 of the Act was the material seized by the investiga- tion wing during the course

Mrs. Surekha Legal Representative of Late Shri. Devaraj, Bengaluru vs. Income Tax Officer, Ward-7(2)(5), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 2419/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19 Mrs. Surekha (Legal Representative Of Late Shri Devaraj, Since Dead) No.112, 1St Main, Ramarao Layout Vs. Ito Bsk 3Rd Phase, 3Rd Stage Ward 7(2)(5) Bengaluru 560 085 Bengaluru Pan No :Asvps2939R Appellant Respondent Appellant By : Sri Balachandran, A.R. Respondent By : Sri N. Balusamy, D.R. Date Of Hearing : 17.02.2026 Date Of Pronouncement : 06.03.2026

For Appellant: Sri Balachandran, A.RFor Respondent: Sri N. Balusamy, D.R

Section 143(2)Section 250

have heard both counsel and perused the papers and proceedings. 10. The facts are not in dispute. The impugned notice for reopening the assessment was issued on a dead person. There are several judgments of different High Courts holding that the notice issued on a dead person or reopening

Deputy Commssioner of Income Tax (Central Circle) -3(3), Mumbai vs. M/S. Welspun Enterprises Limited, Mumbai

In the result, the appeal is dismissed

ITA 1823/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Mar 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Arun Khodpiady. Cit (Central Circle)-3(3) M/S. Welspun Enterprises Limited 4Th Floor, Welspun House, Room No. 404, Kautilya Bhavan, Bkc, Mumbai-400 051 Senapati Bapat Marg, Lower Parel, Vs. Delisle Road, S.O., Mumbai-400 013 Pan/Gir No. Aabcm 4107 C (Appellant) : (Respondent) Appellant By : Shri Harsh Kapadia & Shri Ajay Nagpal Respondent By : Shri Arun Kanti Datta – Cit Dr Date Of Hearing : 28.01.2026 Date Of Pronouncement : 06.03.2026 O R D E R Per Saktijit Dey: Captioned Appeal By The Department, Arises Out Of Order Dated 17.01.2025 Of Learned Commissioner Of Income Tax (Appeals), Mumbai, Pertaining To A.Y. 2015-16. 2. In Ground No. 1, The Department Has Challenged The Deletion Of Addition Of Rs.23,47,354/-, Being Addition Made By The Assessing Officer (A.O. For Short) On Account Of Alleged Non-Genuine Expenses.

For Appellant: Shri Harsh Kapadia &For Respondent: Shri Arun Kanti Datta – CIT DR

Section 115JSection 132Section 153ASection 37(1)

assessment. The Hon'ble Apex Court has further held that in case of unabated/completed assessment, the only recourse available to the A.O. is reopening of assessment u/s. 147 of the Act. Thus, keeping in view the ratio laid down by the Hon'ble Supreme Court, as above

Deepak Mahadeo Bhoir, Mumbai vs. Income Tax Officer Ward, 42(1)(2), Mumbai

In the result, the appeal is allowed as indicated above

ITA 3597/MUM/2024[2013-14]Status: DisposedITAT Mumbai06 Mar 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardeepak Mahadeo Bhoir, Income Tax Officer, C/O Bharat Kumar, 317, Ward 42(1)(2), Prasad Chamber, Opera House, Vs. Mumbai - 400051 Mumbai – 400 004 (Appellant) : (Respondent) Pan No. Ajupb 7841H Appellant By : Shri Bharat Kumar, Ca Respondent By : Shri Annavaran Kosuri, Sr.- Dr (Appellant) (Respondent) Date Of Hearing : 12.02.2026 Date Of Pronouncement : 06.03.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Challenging The Order Dated 26.06.2024 Passed By National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year (A.Y.) 2013-14. 2. Before We Proceed To Decide The Substantive Issue Arising For Consideration, It Is Necessary To Provide A Brief Factual Background. This Appeal Was Earlier Disposed Of By The Coordinate Bench Vide Order Dated 12.12.2024. Subsequently, Assessee Filed A Miscellaneous Application Seeking Rectification/Recall Of The Appellate Order On The Ground That While Deciding The Appeal, The Bench Had Failed To Decide Ground No. 2.A & 2.B. While Deciding The Miscellaneous Application, The Bench Having Found Merit In The Submissions Of Assessee, Recalled The Order For The Limited Purpose Of Deciding Ground No. 2.A & 2.B Raised In The Memorandum Of Appeal. This Is How The Appeal Came Up For Hearing Before Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Annavaran Kosuri, Sr.- DR

Section 147Section 148Section 148ASection 149

hearing before us. 2 Deepak Mahadeo Bhoir vs. ITO 3. In Ground No.2a and 2.b, the assessee has challenged the validity of reopening of assessment under section (u/s.) 147 of the Income Tax Act, 1961 (in short the ‘Act’) as also the assessment order passed in pursuance thereof ... barred by limitation, hence void ab initio. 4. Before us, learned counsel submitted that the outer limit for reopening of assessment under the old regime was a period of six years, which for the assessment year under dispute expired on 31.03.2020. Whereas, he submitted, the Assessing Officer (AO) issued

Chandrani Commotrade Pvt. Ltd., Kolkata vs. I.T.O., Ward - 13(1), Kolkata

Appeal of the assessee is allowed

ITA 665/KOL/2025[2012-2013]Status: DisposedITAT Kolkata05 Mar 2026AY 2012-2013

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 139(1)Section 143(2)Section 147Section 148Section 148(2)Section 151Section 250

issue raised in Ground No. 3 is against the order of Ld. CIT(A) confirming reopening of assessment when the approval u/s 151 of the Act was mechanical in nature. 2 Chandrani Commotrade Pvt. Ltd. 3. The facts in brief are that the assessee filed return of income

Ampi Finance Limited, Kolkata vs. I.T.O., Ward-4(3), Kolkata

Appeal of the assessee is allowed

ITA 2831/KOL/2025[2012-13]Status: DisposedITAT Kolkata05 Mar 2026AY 2012-13

Bench: the Bench that the re-opening of

Section 143(3)Section 144Section 147Section 148Section 148(2)Section 250Section 69C

issues as under: (i) The appellate order was assailed by the assessee on the ground that the CIT(A) has upheld the invalid reopening of assessment u/s 147 of the Act. (ii) The appellate order passed by the Ld. CIT(A) is wrong as it has upheld the assessment order

Gopal Anil Kumar, Bangalore vs. DCIT, Central Circle-1(3), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 862/BANG/2025[2018-19]Status: DisposedITAT Bangalore05 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Ms. Pooja Maru, A.RFor Respondent: Sri Balusamy N., D.R

Section 132Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 37Section 44ASection 68

assessment proceedings. The sanction u/s 151 was considered equivalent to approval by the Higher Authority of the action of the AO in reopening the assessment. However, the language of the provision does not confine the duty of the sanctioning authority to merely approve the proposed action ... reopening the assessment but puts some more burdens before granting such sanction/approval. The use of the word "satisfied" cast greater duty on such authority. The sanctioning authority has to satisfy himself that necessary prerequisite of section 147 of the Act that there is an escapement of income stood fulfilled; however

Jaikishin Omprakash Pahuja, Ghatkopar, Mumbai vs. ITO Ward 2(2), Kalyan, Mumbai

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

ITA 8893/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Mar 2026AY 2016-17

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokar

Section 115BSection 142(1)Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69

raised following grounds of appeal: 1. In the facts and circumstances of the case and in law, the AO erred in reopening of assessment under section 148 a. Only on the basis of presumption and surmise b. Only on the basis of the information flagged in the system (INSIGHT

Rekhaben Sharadkumar Mehta, Mumbai vs. Ward 42(1)(4), Mumbai

In the result, Grounds No

ITA 8318/MUM/2025[2012-13]Status: DisposedITAT Mumbai05 Mar 2026AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Bijayananda Prusethrekhaben Sharadkumar Vs Ito Ward 42(1)(4) Mehta Room No.733, Kautilya Bhawan, 211 Tiwari Bhawan, S Modi Bkc, Mumbai 400051 Road, Kandivali West, Mumbai-400067 Pan:Ahppm8680G Appellant Respondent

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Bhagirath Ramawat (SR DR)

Section 143(3)Section 147Section 151Section 250Section 69BSection 92A

Bombay High Court in the case of HDFC Bank Ltd và ACIT [2022] 136 taxmann.com 69 (Bom HC). (b) The sanction granted for reopening the assessment u/s. 151 of the Act by Ld. Principal CIT- 33, MUMBAI, is mechanical devoid of any material/ evidence against the assessee and without appreciating ... information that assessee made the total transaction amount of Rs.91,20,342/-. Accordingly, the Ld. AO noted the reasons for reopening the assessment u/sec. 147 of the Act. The 3 Rekhaben Sharadkumar Mehta reasons for reopening of the assessment recorded reason is duly reproduced as below: “REASONS FOR REOPENING

Sachinkumar Subrai Kanse, Mumbai vs. Income Tax Officer 42(3)(3), Mumbai

ITA 8140/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Mar 2026AY 2016-17

Bench: Shri Anikesh Banerjee, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Sanjeev Bhagat, Sr. DR

Section 147Section 148Section 149(1)(b)Section 234ASection 271(1)(c)

required to be quashed. 3. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming reopening of assessment without considering the fact that the proceedings for AY 2016-17 are time barred as per section 149(1)(b) of Income

Sachinkumar Subrai Kanse, Thane vs. Income Tax Officer 42(3)(3), Mumbai

ITA 8139/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Mar 2026AY 2016-17

Bench: Shri Anikesh Banerjee, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Sanjeev Bhagat, Sr. DR

Section 147Section 148Section 149(1)(b)Section 234ASection 271(1)(c)

Srinivasa Rao Sirivuri Proprietor, Vizianagaram vs. Income Tax Officer, Vizianagaram

In the result, appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 459/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam04 Mar 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 44ASection 69A

amended Section 149 of the Act, the impugned notice is beyond the period of six years from the Assessment Year 2017-18. The reopening of assessment proceedings have also been challenged on the ground that during pendency of the proceedings under Section 154 of the Act on the same issue ... dated 26.03.2024. It is submitted that the instant notice was issued prior to the expiry of six years period for reopening the assessment proceedings under the un-amended Section 149 of the Act for the Assessment Year 2017-18. The order under Section 148A(d) of the Act was passed

ITO, Ward-1(1), Kolkata vs. A P Trading and Finance Company Limited, Kolkata

In the result, the appeal of the revenue stands dismissed and the cross-objection of the assessee stands allowed

ITA 2801/KOL/2025[2016-17]Status: HeardITAT Kolkata02 Mar 2026AY 2016-17

Bench: Shri George Mathan & Shri Laxmi Prasad Sahuassessment Year: 2016-17 Ito, Ward-1(1), Kolkata A P Trading & Finance Company Limited Vs P-39, Princep Street, Kol – 700069. (Pan: Aadca8815B) (Appellant) (Respondent)

For Appellant: Shri Narendra Kedia, AdvocateFor Respondent: Shri Soumitra Ghosh, Sr. DR

Section 148Section 148ASection 151

same lines. 8. Considering the facts and circumstances of the case and also the above decisions, we are inclined to quash the reopening of assessment as well as the assessment order passed the ld. AO. .In the result, the appeal of the assessee is allowed

Rjkumar Valecha L/H of Late Shri Ghanshyam Das Valecha, Jabalpur vs. DCIT Circle 2(1), Jabapur

ITA 176/JAB/2024[2012-13]Status: DisposedITAT Jabalpur27 Feb 2026AY 2012-13

Bench: Shri Kul Bharat & Shri, Anadee Nath Misshraassessment Year: 2012-13 Rajkumar Valecha L/H Of Late V. Dcit Circle-2(1) Shri Ghanshyam Das Valecha Annexue Building Napier S-736/1-4 Mahavir Complex, Town-482001. Russal Chowk-482001. Pan:Abjpv5609E (Appellant) (Respondent) Appellant By: Shri G. N. Purohit, Sr. Advocate Respondent By: Shri Rahul Padha, Jc-2 Date Of Hearing: 11 02 2026 Date Of Pronouncement: 27 02 2026 O R D E R

For Appellant: Shri G. N. Purohit, Sr. AdvocateFor Respondent: Shri Rahul Padha, JC-2

Section 143(1)Section 144BSection 147Section 148Section 153(2)Section 50

income filed by the assessee. The reopening is illegal. 7. The service of notice u/s 148 on 01.04.2019 is barred by limitation for reopening of assessment. The notice u/s 148 and subsequent proceedings should be quashed in toto. 8. The appellant craves permission to raise any other ground or grounds

Mummalaneni Raghavan, Guntur vs. Income Tax Officer, Guntur

In the result, both the appeals of the assessee are allowed

ITA 628/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2016-17

Bench: Itat, Stating That The Reopening Of Assessment U/S 147 Of The Act Was Based Merely On System Generated Information, Which Is Invalid & Without Any Tangible Material. In The Grounds Of Appeal, It Was Mentioned That The Assessment U/S 147 Is Beyond Time Limit Prescribed & Hence, The

Section 144Section 144BSection 147Section 194ASection 56

dated 22.03.2024 and 20.09.2024 respectively, pertaining to the assessment year 2016-17. 2. The appellant filed an appeal before ITAT, stating that the reopening of assessment u/s 147 of the Act was based merely on system generated information, which is invalid and without any tangible material. In the grounds ... passed by the Ld.CIT(A). ITA No.627 & 628/Viz/2025 Mummalaneni Raghavan 8. Heard both sides. Even though the “Grounds of Appeal” mentions that the reopening of assessment is invalid, no reasons were mentioned as to why the reopening is invalid. The Ld.AR of appellant also did not argue on this point