“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

Guiness Finance & Leasing Pvt. Ltd., Kolkata vs. ITO, Ward 6(2), Kolkata

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

ITA 1633/KOL/2025[2015-2016]Status: DisposedITAT Kolkata13 Nov 2025AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Guiness Finance & Leasing Pvt. Ltd..….……………….……….……….……Appellant 3Rd Floor, Baid Property, 10, Canning Street, Burra Bazar, Kol-1.. [Pan: Aabck1388B] Vs. Ito, Ward-6(2), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri Miraj D Shah, Ar, Appeared On Behalf Of The Appellant. Shri Sandeep Lakra, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Brief Facts Of The Case Of The Assessee Are That The Assessee 2. Company Filed Its Return Of Income For The A.Y 2015-16 On 30.09.2015 Declaring Total Income Of Rs.Nil. The Said Return Was Selected For Scrutiny On The Reason That The Assessee Is The Beneficiary Of Credit Of Rs.1,28,38,232/- From Penny Stock Company M/S Steel Exchange Ltd. Notices U/S 143(2) & 142(1) Of The Act Were Issued & Thereafter, The Case Of The Assessee Reopened By Issuing Notice U/S 148 Of The Act On 14.07.2022. The Assessing Officer Passed An Ex Parte Order U/S 147 Guiness Finance & Leasing Pvt. Ltd R.W.S. 144B Of The Act On 29.05.2023 Adding Rs.1,28,38,391/- To The Total Income Of The Assessee.

Section 143(2)Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 250

cases where income escaping assessment amounts to ₹50 lakhs or more, assessments can be reopened within ten years. The new regime prohibits reopening of assessments that were time-barred under the old regime. The provisions of section 149 of the new regime are as under: 8 Guiness Finance & Leasing

Income Tax Officer Ward 22 Kalyan, Kalyan vs. Rahul Ratanlal Harchwani, Ulhasnagar

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

ITA 4315/MUM/2025[2014-15]Status: DisposedITAT Mumbai13 Nov 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 148Section 148ASection 149Section 250Section 3

reproduced herein below: 6.1 The appellant argues that as per the pre-amended provisions of section 149, the six year period for reopening of assessment ended on 31.03.2021. The notice u/s 148 was issued on 08.04.2021 after the limitation period ended. Notice u/s 148 could not be issued

Rahul Ratanlal Harchwani, Mumbai vs. Income Tax Officer Ward 2, Kalyan

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

ITA 3349/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Nov 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 148Section 148ASection 149Section 250Section 3

Rahul Ratanlal Harchwani, Mumbai vs. Income Tax Officer Ward -2, Mumbai

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

ITA 3348/MUM/2025[2014-15]Status: DisposedITAT Mumbai13 Nov 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 148Section 148ASection 149Section 250Section 3

Arjun Oil Traders, Surat vs. ACIT, Navsari Circle, Navsari

ITA 147/SRT/2024[2011-12]Status: DisposedITAT Surat12 Nov 2025AY 2011-12

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.147/Srt/2024

Section 143(3)Section 145ASection 147Section 148Section 250

Aggrieved by the order of CIT(A), assessee filed present appeal before the Tribunal. The Ld. AR of the assessee submitted that reopening of assessment in the case of assessee is bad in law. The assessee was earlier subjected to scrutiny and assessed u/s.143(3) of the Act. During assessment ... account earlier and found the system of accounting proper and in consonance with the Income tax provisions, there was no point in reopening the assessment. 6.1 Regarding the issue of following ‘exclusive’or‘inclusive’method of accounting, the Ld. AR stated that as per Accounting Standard - 2 prescribed

Wheatons Design Private Limited, Jaipur vs. ACIT / DCIT, Circle -6, Jaipur

In the result, appeal of the assessee is allowed

ITA 781/JPR/2025[2014-15]Status: DisposedITAT Jaipur12 Nov 2025AY 2014-15

Bench: The Due Date Of Hearing.”

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita rinesh, JCIT-DR a

Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

facts necessary for assessment. In fact the AO after considering the details furnished has accepted the income declared by the assessee. Hence the reopening of assessment is illegal & bad in law. Reliance in this connection is placed on the following cases:- Durr India (P) Ltd. Vs. ACIT ... assessment for AY 2012-13. Such failure is an essential jurisdictional parameter that must be fulfilled before any notice can be issued for reopening the assessment proceedings after the expiry of four years from the end of the relevant assessment year. In the absence of any such allegation

Lekhraj Jasraj Jain, Mumbai vs. DCIT 19(1), Mumbai

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

ITA 4937/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Nov 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2014-15

For Respondent: Mr. Suchek Anchaliay &

Section 147Section 68Section 69C

page 8 thereof, containing the reasons 33. He specifically referred to page 8 thereof, containing the reasons recorded by the Assessing Officer for reopening the assessment, recorded by the Assessing Officer for reopening the assessment, recorded by the Assessing Officer for reopening the assessment, which, for the sake of which ... filed proceeded on incorrect assumptions that no return had been filed proceeded on incorrect assumptions that no return had been filed and had reopened the assessment based merely on suspicion and had reopened the assessment based merely o and had reopened the assessment based merely o arising from information received

Anand Ashok Chandavarkar, Mumbai vs. Income Tax Officer Ward 31 1 1 Mumbai, Mumbai

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

ITA 3808/MUM/2024[2012-13]Status: DisposedITAT Mumbai12 Nov 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankaranand Ashok Chandavarkar V/S. Income Tax Officer, Ward – C/O S.S. Tumkar, 202, Shreeji बनाम 31(1)(1), Room No. 203, 2Nd Darshan Chsl, Hanuman Floor, Kautilya Bhavan, C-41 Road, Ville Parle East, To C-43, G-Block, Bandra Mumbai – 400 057, Kurla Complex, Bandra Maharashtra (East), Mumbai – 400 051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Ablpc0382R Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Jitendra Singh & Ms. Shivali MhatreFor Respondent: Shri Bhagirath Ramawat (Sr. DR)

Section 144Section 147Section 148Section 69A

same is illegal, arbitrary and perverse on the following amongst other grounds which are urged without prejudice to one another. 2. Reopening of assessment without serving the notice under section 148 of the Act is bad in law The Ld. CIT(A) fell in error of law in upholding ... action of the action of the Ld. AO in reopening the assessment of the Appellant without serving any valid notice issued under section 148 of the Act The Appellant, therefore, prays that impugned order passed by the Ld.CIT(A) upholding the reassessment order passed without serving a valid notice under

Lal Chand Meena, Jaipur vs. ITO WD 5(2), Jaipur

ITA 1074/JPR/2025[2013-14]Status: DisposedITAT Jaipur11 Nov 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Anoop Bhatia, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT

Section 143(1)Section 147Section 148Section 2Section 50CSection 54F

dates on which the case was posted. 4.3 Ground No. 1 :- Vide this ground, the appellant has questioned the legal validity of the reopening of assessment on the ground that the appellant's case was reopened for the first time on 21.08.2015 and order ... said claim was legally questionable and hence, the appellant had failed to disclose the material facts truly and hence, it is held that reopening of assessment was legally valid. 4.4 Ground Nos. 2, 3 & 4:- The appellant has claimed that the deeming of provision of section 50C has a limited

Tika Ram Education Society, Sonipat, Haryana vs. DCIT/ACIT(E)(C-2), Chandigarh

In the result, the appeal of the Assessee is allowed

ITA 1140/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1140/Chd/2024 "नधा"रण वष" / Assessment Year : 2015-16 Tika Ram Educational The Dcit/ Acit, बनाम Society, C-2, Crz Senior Secondary School, Chandigarh Vs. West Ram Nagar, Sonepat 131001 "थायी लेखा सं./Pan No. Aabtt1486A अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Dhruv Goel, Ca राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 12-8-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 11.11.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 22.10.2204 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi For A.Y. 2015-16. 2. Grounds Of Appeal Are As Under:

For Appellant: Sh. Dhruv Goel, CAFor Respondent: Dr. Ranjit Kaur, Addl. Addl. CIT, Sr. DR

Section 10Section 12ASection 143(2)Section 144Section 148

Educational Society, Sonepat 1. That learned CITA (NFAC) has erred in law and facts in confirming the action of learned AO for reopening of assessment u/s 148 2. That the learned CITA (NFAC) has erred in law and facts in confirming the additions in Assessment order which is completed ... judicial discipline, CBDT Circular, amendment to Income Tax Act as well as not providing the tangible material relied while recording the reasons for reopening of assessment by AO 3 1140-c-2024 – Tika Ram Educational Society, Sonepat 7. The appellant craves leave to add to or amend the aforesaid grounds

Shri Rushabhdev Swetambar Murtipujak Jain Sangh, Ahmedabad vs. The ITO, Ward-2 (Exemption), Ahmedabad

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

ITA 136/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad11 Nov 2025AY 2012-13

Bench: Shri T.R. Senthil Kumar&Shri Makarand V. Mahadeokar

For Appellant: Shri Jaimin Shah, A.RFor Respondent: Shri R P Rastogi, CITDR

Section 12ASection 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

section 147, the assessee preferred an appeal before the learned CIT(A). The assessee raised multiple legal and factual grounds, contending that the reopening of assessment under section 147 was invalid and that the addition of Rs. 75,41,227/- made by the Assessing Officer was wholly unjustified. 6. Before ... bank Shri Rushabhdev Swetambar Murtipujak Jain Sanghvs.ITO(E) Asst.Year –2012-13 - 8– deposits had been reported. It was therefore contended that the reopening of assessment on the basis of the PAN reflected in the departmental information system could not be treated as invalid or without jurisdiction. 14. We have carefully

Kakoli Debanshi, Birbhum vs. ITO, Ward 3(1), Suri

In the result, the appeal of the assessee is allowed

ITA 1664/KOL/2025[2015-2016]Status: DisposedITAT Kolkata11 Nov 2025AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm**

Section 142(1)Section 144Section 147Section 148

case of Ibibo Group Pvt. Ltd. Vs. ACIT in WP(C) No. 17639/2022 order dated 13.12.2024 wherein it has been held that reopening of assessment for 2015-16 is not permissible in the extended period as per TOLA on and from 01.04.2021. The said decision has been followed ... supra). We note that the Hon'ble Delhi High Court in the case of Ibibo Group Pvt. Ltd. (supra) held that the reopening of assessment for Ay 2015-16 is not permissible in the extended period as per TOLA on and from 01.04.2021. We also note that Hon'ble Rajasthan

M/S. R S Vinimay Pvt. Ltd., Kolkata vs. ITO, Circle 11(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1513/KOL/2025[1513]Status: DisposedITAT Kolkata11 Nov 2025

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm M/S R.S. Vinimay Pvt. Ltd. Ito, Circle 11(3), 3A, National Library Avenue, Aaykar Bhawan, P-7, Alipore, Kolkata-700027 Chowringhee Square, Vs. West Bengal Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aadcr0739H Assessee By : Shri Giridhar Dhelia, Ar Revenue By : Shri Bonnie Deb Barma, Dr Date Of Hearing: 29.10.2025 Date Of Pronouncement: 11.11.2025

For Appellant: Shri Giridhar Dhelia, ARFor Respondent: Shri Bonnie Deb Barma, DR

Section 143(1)Section 147Section 148

Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 20.06.2025 for the AY 2016-17. 02. The assessee has challenged the reopening of assessment u/s 147 of the Act, based on the reasons recorded which are invalid and nullity in the eyes of law. 03. The brief facts ... learned Authorized Representative submitted that the assessee’s broker was never named in the investigation wing report and therefore very basis of reopening of assessment is wrong and deserves to be quashed. 04. The learned DR on the other hand relied on the order of the authorities below. 05. After

Monotech Systems Ltd., Chennai vs. DCIT, Corp. Circle-4(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1021/CHNY/2025[2017]Status: DisposedITAT Chennai11 Nov 2025

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. J. Prabhakar, F.C.AFor Respondent: Ms. R. Anitha, Addl. C.I.T

Section 147Section 234BSection 36Section 37(1)Section 45

impugned year, on the following grounds: “1. The National Faceless Appeal Centre (NFAC) is not justified in upholding the validity of reopening of assessment on the premise that explanation 1 to Section 147 is applicable to the facts of the case. 2. The First Appellate Authority (NFAC) is not justified ... certain disallowances/additions to the total income as declared by the assessee. 10. Further, the ld.AR drew our attention to the reasons recorded for reopening the assessment at page 27 – 28 of the paper book and submitted that the issue relating to the assessee’s claim of bad debts written

M/S. Ambattur Developers Pvt. Ltd., Chennai vs. ITO, Corporate Ward-1(1), Chennai

ITA 2601/CHNY/2024[2015-16]Status: DisposedITAT Chennai11 Nov 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2601/Chny/2024 निर्धारण वर्ष / Assessment Year: 2015-16 M/S. Ambattur Developers Private Limited, (Amalgamated With Ambattur Hotels Private Limited) No. 86/E2, Industrial Estate, Ambattur, Chennai - 600 058. Tamil Nadu. [Pan: Aaeca-7490-D] (अपीलार्थी/Appellant) Income Tax Officer, Vs. Corporate Ward- 1(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By : Shri. R. Vijayaraghavan, Advocate : Shri. Bipin, C.N., Cit सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 09.09.2025 : 11.11.2025 आदेश /Order Per S.R.Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Nfac, Delhi, (In Short Ld.Cit(A)) For The Assessment Year 2015-16, Vide Order Dated 12.08.2024. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Respondent: Shri. R. Vijayaraghavan, Advocate

Section 50CSection 56(2)(vii)

series of measures to deter the generation and use of unaccounted money. To this end, I propose— • Compulsory reporting of assets held abroad. • Reopening of assessments up to 16 years in relation to assets held abroad. • Tax collection at source on cash purchase of bullion/jewellery exceeding ₹2 lakh

Income Tax Officer 17(1)(1), Mumbai vs. Ashok Amritlal Nayak, Mumbai

In the result, appeal of the revenue is dismissed and the C

ITA 3484/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Surendra Mohan, Sr. DRFor Respondent: Shri Rahul Hakani, AR

Section 115BSection 143(1)Section 148Section 151ASection 250Section 68

dated 03.03.2025.” Grounds of CO Reopening is bad in law 1. The learned CIT(A) failed to appreciate that the reopening of assessment u/s 148 is bad in law. 3 ITA No. 3484 and CO No. 169/Mum/2025 Ashok Amritlal Nayak 2. The learned CIT(A) failed to appreciate that

Pushkar Vishwas, Bulandshahr vs. Income Tax Officer Ward 3(3), Bulandshahr

In the result, the Assessee’s appeal is allowed in the aforesaid manner

ITA 5661/DEL/2025[2011-12]Status: DisposedITAT Delhi11 Nov 2025AY 2011-12

Bench: Shri Mahavir Singha.Yr. : 2011-12 Pushkar Vishwas, Vs. Income Tax Officer, C/O Ca Vaibhav Goel, Ward 3(3), Bulandshahr, 75, Navyug Market, Uttar Pradesh 1St Floor, Ghaziabad Uttar Pradesh (Pan: Aezpv4597E) (Appellant) (Respondent)

For Appellant: Shri Vaibhav Goel, CAFor Respondent: Shri Manoj Kumar, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 151

which is the Form for recording the reasons for initiating proceedings u/s. 148 and for obtaining approval of the Pr. CIT, Ghaziabad for reopening of assessment, in column 7 of the said Form the AO has stated that the provisions applicable for reopening of assessment is section ... Counsel for the assessee submits that the AO has quoted the non-existent provisions for reopening the assessment which shows that there is complete non-existent provision for reopening the assessment which shows that there is complete non application of mind. It is also noted that the provisions of section

Khurshid Ahmad Dar, Jammu and Kashmir, India vs. ITO Ward, Udhampur

In the result, the appeal of the assessee is allowed

ITA 236/ASR/2025[2017-18]Status: DisposedITAT Amritsar10 Nov 2025AY 2017-18

Bench: Dr. Mitha Lalmeena, Hon'Ble & Shri Udayan Das Gupta, Hon'Blekhurshid Ahmad Dar Vs. Ito, Ward, Nully Poshwari Turkawangam, Udhampur Shopia, 192305, Jammu & Kashmir, India.Pin 192305. Pan No. Awmpd5664K Assessee By Shri Rohit Kapoor, Adv. & Shri V.S. Aggarwal, Itp. Revenue By Mrs. Roshanta Kumari Meena, Cit Dr. Date Of Hearing 23.09.2025. Date Of Pronouncement To. [1 .2025. Order Dr. Mitha Lal Meena, A.M.:

Section 144Section 147Section 148Section 148ASection 151Section 151(1)Section 250Section 250(6)Section 282Section 69A

there was a regime change with respect to law of limitation coming into effect from 1-4-2021, which curtailed time limit for reopening of assessment from 6 years to 3 years, revenue, with a view to avail limitation prescribed under unamended section 149, generated reassessment notices under section

Anju Meel, Jaipur vs. I.T.O. Ward 3(4), Jaipur

In the result, the appeal is partly allowed

ITA 741/JPR/2025[A.Y. 2008-09]Status: DisposedITAT Jaipur10 Nov 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. G. M. Mehta, CAFor Respondent: Sh. Gautam Singh Chaudhary, Addl. CIT

Section 142(1)Section 143(3)Section 147Section 148Section 151Section 292B

grounds of appeal, and submission filed by the appellant carefully. I find from the assessment order the objection raised by the appellant against reopening of assessment and issue of notice u/s 148 was disposed by the AO by passing speaking order on 25/02/2016 and the same was served

DCIT Central Circle-28, New Delhi, Delhi vs. Microtek Leasing & Finance Pvt. Ltd., Delhi

ITA 4188/DEL/2025[2012-13]Status: DisposedITAT Delhi10 Nov 2025AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. S. S. Nagar, CAFor Respondent: Sh. Jitender Singh, CIT-DR

Section 132(1)Section 143(3)Section 153Section 153C

principles enunciated by us and which explain how the period of six and ten AYs' is liable to be computed, the reopening of assessments pertaining to AYs’ 2010-11, 2011-12, 2012-13 and 2013- 14 would clearly fall beyond the ambit of ten AYs’ as provided under Section I53C