“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

Nuvama Wealth Management Limited, Mumbai vs. DCIT, Pratishtha Bhavan, Mumbai

In the result, the appeal of the assessee stands allowed

ITA 2559/MUM/2024[AY 2018-19]Status: DisposedITAT Mumbai31 Oct 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144BSection 263Section 37(1)

section 263 empowers the revisional authority only where there is an absence of enquiry or verification. It does not authorise the reopening of assessments on grounds of alleged inadequacy of enquiry. In the present case, the exhaustive and documented enquiries made by the Assessing Officer leave no scope for such

Kirti Karsandas Nayak, Umbergaon vs. ITO Ward-5, Vapi

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

ITA 659/SRT/2025[2011-12]Status: DisposedITAT Surat30 Oct 2025AY 2011-12

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2011-2012 Kirti Karsandas Nayak, Ito Ward-5, Plot No. 244/28, Gidc, Fortune Square, Chala Road, Umbergaon-396171. Vs. Vapi-396191. Pan No. Abbpn 3355 M Appellant Respondent

For Respondent: Mr. Parin Shah, CA

Section 148Section 271(1)(c)

confirmed by NFAC is invalid, bad in law and required to be quashed. 2. Ld. NFAC erred in law and on facts in reopening of assessment u/s 148 of the Act. 3. Ld. NFAC erred in law and on facts in confirming addition of Rs. 879390 as short term capital

Dhaval Indravadan Gandhi, Surat vs. ITO, Ward 2, Bardoli

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

ITA 601/SRT/2025[2012-13]Status: DisposedITAT Surat30 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-2013 Shri Dhaval Indravadan Gandhi, Ito Ward-2, At & Post Areth, Tal Mandvi, Aayakar Bhavan, Janta Nagar Surat-394160. Vs. Society, Bardoli-394601. Pan No. Ajjpg 4246 J Appellant Respondent

For Appellant: Ms. Namita Patel, Sr. DRFor Respondent: Mr. Shaunak K. Zaveri, CA

Section 143(3)

grossly erred in confirming the action of the AO in justified and grossly erred in confirming the action of the AO in reopening of assessment was not justified because instead of reopening of assessment was not justified because instead of reopening of assessment was not justified because instead

Dy. Commissioner of Income Tax, Jaipur vs. Hem Chand Jain, Jaipur

In the result, appeal of the Revenue is dismissed and Cross Objection of the assessee is allowed

ITA 670/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT &

Section 147Section 148Section 148ASection 151Section 250

case a notice u/s 148 of the Act was issued on 25.07.2022 after obtaining the prior approval from Pr. CIT-15, Delhi for reopening of assessment for the AY 2016-17. As per the provisions of section 151(2) for reopening an assessment by issue of a notice ... with the prior approval of Pr. 9 ITA No.670/JPR/2025 & CO No. 24/JPR/2025 Hem Chand Jain, Jaipur CIT for reopening an assessment for the AY 2016-17 beyond a period of three years from the end of the relevant assessment year is bad in law. While holding so the Tribunal observed

Amit Suresh Agrawal, Satara vs. ITO Ward-2, Satara

In the result, appeal of the assessee is partly allowed

ITA 2225/PUN/2025[2016-17]Status: DisposedITAT Pune30 Oct 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2225/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Amit Suresh Agrawal, V The Income Tax Officer, Amit Trading Co, Plot No.35, S Ward-2, Satara. Satara – 415002. Maharashtra. Pan: Abgpa2925D Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Kulkarni – Advocate Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This 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 02.04.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 Dated 10.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 147Section 148Section 149(1)(b)Section 151Section 151ASection 153ASection 153CSection 250Section 271(1)(c)Section 68

144B of the Income Tax Act, 1961 dated 10.05.2023. The Assessee has raised the following grounds of appeal : ITA No.2225/PUN/2025 [A] ―1. The reopening of assessment for Assessment Year 2016-17, alleging escapement of income of 43,22,430/-, is erroneous and unsustainable. The impugned notice issued under Section

Income Tax Officer, Ward-7(2)(3), Bengaluru vs. Mohammed Farooq Kanana, Bengaluru

In the result, appeal filed by the Revenue is dismissed

ITA 1509/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Oct 2025AY 2020-21

Bench: Shri.Laxmi Prasad Sahu & Shri.Soundararajan Kassessment Year : 2020-21 Ito, Vs. Mr. Mohammed Farooq Kanana, 6 9Th Cross, H Siddaiah Road, Ward – 7(2)(3), Bangalore. Bangalore – 560 027, Karnataka. Pan : Abvpm 1212 A Appellant Respondent Assessee By : Shri. Thirumala Naidu, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 27.10.2025 Date Of Pronouncement : 30.10.2025

For Appellant: Shri. Thirumala Naidu, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 147Section 250

unusually heavy workload. This led to an inadvertent delay in finalizing and filing the appeal/submission. 3.Handling of Reopened Assessment Cases: The reopening of assessments under section 147, especially post amendments and due to stricter judicial scrutiny, entails considerable procedural diligence. It involves reassessing cases based on fresh information or audit

Kajal Batra, Delhi vs. ACIT, Circle-52(1), Delhi

In the result, the appeal of the assessee stands dismissed as above

ITA 2419/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 151Section 68Section 69A

statement of facts before the Appellate Authority.” 5. Before us, the Ld. Authorized Representative (‘AR’) vehemently argued the case by contending that the reopening of assessment was not justified because the Ld. AO had not applied his mind at the time of reopening the 9 Kajal Batra assessment. According ... reasons recorded by the Ld. AO for reopening the assessment as mentioned on page No. 2 and 3 of the assessment order read as under: "I have independently examined the facts of the case as per the information and ITD/ITBA data available with the department and in my view

Baani Landbase Private Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, appeal of the Assessee is allowed

ITA 5944/DEL/2024[2015-16]Status: DisposedITAT Delhi30 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No.5944/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Baani Landbase Pvt Ltd., Dcit, Corporate One, Ground Floor, Vs. Circle-4(2), Plot No.5, District Center, Jasola, Central Revenue Building, Delhi. I.P. Estate, Delhi. Pan No.Aadcb0237E अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 148Section 154Section 156Section 292B

issued on 30.06.2021 which is placed at page 33 of the PB along with the approval and reasons recorded for reopening the assessment which are placed at pages 34 to 36. Ld. Counsel referring to page 35 of the Paper Book which are the reasons recorded for reopening of assessment ... submitted that the AO proposed to reopen the assessment on the ground that a sum of Rs.3,56,75,993/- has escaped assessment. Ld. Counsel submitted that the basis for coming to such conclusion was stated in the reasons that the assessee company has created a provision of Rs.9.25 crores

Atul Vrajlal Karia, Rajkot vs. Ac / Dc (Int.Txn), Rajkot

In the result, appeal filed by the assessee is allowed in above terms

ITA 133/RJT/2025[2012-13]Status: DisposedITAT Rajkot29 Oct 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.133/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2012-13 Atul Vrajlal Karia Ac/Dc (Int. Txn), बनाम C/O. D.S. Karia & Co. Ca, 203, Rajkot Cosmo Complex, Mahila College Vs. Chowk, Kalawad Road, Rajkot Pan : Adwpk6568J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

For Appellant: Shri Kalpesh Doshi, ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR

Section 127Section 147Section 148Section 151Section 153CSection 250Section 282Section 69

dismissed the appeal on technical grounds without appreciating the merit of the case. 2. That, the Ld. CIT(A) has wrongly confirmed the reopening of assessing u/s 147 of the Income Tax Act, 1961 on account of following counts: (a) The notice u/s 148 is issued beyond the time limit ... prescribed under the Act. (b) The reasons recorded for reopening the assessment is based on incorrect facts. (c) The reopening is made without "reason to believe", there is no live link between reasons recorded for reopening and formation of belief. (d) The reopening of assessment is bad-in-law since

Kalpanaben Vadilal Shah, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

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

ITA 928/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2017-18

For Appellant: Shri Jaimin Shah, AR

Section 147Section 148Section 153CSection 1ISection 210Section 234ASection 250Section 270ASection 68

corelate the said general information with the assessment records of the assessee. 6.1. As noted above, the Assessing Officer, in this case, has reopened the assessment solely on the basis of the information available on the insight portal of the department without verifying the veracity and truthfulness of such information ... forced in any other manner. Under the relevant provisions of section 147 & section 148 of the Income Tax Act, for assuming jurisdiction to reopen an assessment by the Assessing Officer, there is a condition precedent that the Assessing Officer must have reasons to believe that the income of the assessee

Satish Vishnu Thombare, Income Tax Officer, Ward-1, Ahmednagar vs. Varsha Prafulla Zende, Ahmednagar

In the result, the appeal of the Revenue is dismissed

ITA 1656/PUN/2024[2010-11]Status: DisposedITAT Pune29 Oct 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

For Appellant: Miss Shivani Shah (Virtual)For Respondent: Shri Akhilesh Srivastva

Section 132(1)Section 147Section 148Section 151Section 68

Appellant had never paid commission or claimed expenses of the same in her books of accounts. Therefore, the basis on which the AO reopened the assessment is factually incorrect. The appellant also contended that the reasons recorded form the backbone of the reassessment proceedings and when the same are proved ... Investments Ltd. and Another Vs. Settlement Commission and Others”, 264 ITR 571. 11. In view of the above discussion, we annul the reopening of assessment u/s.147 of the Act.” In this case, it was held that the reasons for which reopening was made have been proved to be wrong, then

Mahesh Narsing Choudhary, Navi Mumbai vs. ITO Ward 28(2)(1), Navi Mumbai

ITA 4769/MUM/2025[2019-2020]Status: DisposedITAT Mumbai29 Oct 2025AY 2019-2020

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Khushiram JadhwaniFor Respondent: Shri Paresh Deshpande

Section 144BSection 147Section 148Section 148ASection 69A

Income Tax Act, 1961 for the Assessment Year 2019-2020. 2. The Assessee has raised following grounds of appeal : “I. VALIDITY OF REOPENING OF ASSESSMENT UNDER SECTION 148 OF THE ACT GROUND NO 1 On the facts and in circumstances of the case and in law, National Faceless Appeal Centre ... erred in confirming the assumption of jurisdiction by the learned Assessing Officer in Assessment Year 2019-2020 reopening the assessment for the captioned assessment year which is wholly without jurisdiction, illegal, void ab-initio and violating the principle of natural justice. 1.1 The appellant contends that the learned Assessing Officer

Champat Singh (Through Legal Heir Sh. Kannu Singh), Ghaziabad vs. The ITO-Ward-2(1)(2), Cgo Complex Hapur Chungi Ghaziabad

ITA 5623/DEL/2024[2012-13]Status: DisposedITAT Delhi29 Oct 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandraasstt. Yr: 2012-13

Section 144Section 147Section 148

case the assessee died on 16.04.2018 and the order of assessment was passed on 09.12.2019. Notice under Section 148 of the Act for reopening of assessment in the case of the assessee was issued on 26.03.2019, appearing at page 1 of the paper book filed before us by the assessee ... finalized in the name of the assessee on 09.12.2019. No notice could have been issued in the name of deceased assessee for reopening of assessment under Section 148 of the Act neither reassessment proceedings could be proceeded with on the basis of such invalid notice. Thus, the notice

Omkar Singh, Noida vs. ITO Ward - 5(2)(1), Noida

In the result, the appeal of the assessee is allowed

ITA 3574/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Oct 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 115BSection 139(1)Section 143(2)Section 147Section 148Section 151Section 69A

case of Deepak Wadhwa Versus Asstt. Commissioner of Income Tax, Circle 31(1), reported in 2021 (3) TMI 332, held that Reopening of assessment u/s 147 whether notice issued prior to the THAT:- Notice under Section 148 of the Act was issued after obtaining requisite concerned officer obtaining necessary administrative

Sonali Mahendra Naik Gaunekar, Panaji vs. Income Tax Officer, Ward - 1(1), Panaji

The appeal of the assessee is partly allowed for statistical purpose

ITA 313/PAN/2025[2016-17]Status: DisposedITAT Panaji28 Oct 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Rahul Sarda [‘Ld. AR’]For Respondent: Mr Renga Rajan [‘Ld. DR’]

Section 147Section 148Section 250Section 253(1)Section 263Section 50C

during the appeal proceedings despite the fact that the same was duly provided. Failure to adhere to mandatory procedure for reopening of assessment 3. The Appellant submits that the above grounds of appeal are in addition to, in the alternative and without prejudice to each other as well as without

Joint Commissioner of Income Tax (in Situ) Circle-I, Ludhiana vs. Kapil Thapar, Ludhiana

In the result, appeal of the Department is dismissed and Cross

ITA 246/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh28 Oct 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 148Section 153CSection 69A

Chandigarh Bench' of the ITAT in the case of M/s Taj Land Developers and Promoters Pvt. Ltd. as stated 'supra' and the reopening of assessment have been quashed in that case and the facts are identical as in the case of assessee and, thus, by relying upon the finding

Navnirman Infracon Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 689/KOL/2025[2011-12]Status: DisposedITAT Kolkata28 Oct 2025AY 2011-12

Bench: S/Shriand Rajesh Kumar & Sonjoy Sarma

For Appellant: Shri Manish Tiwari, FCAFor Respondent: Shri Sandeep Kumar Mehta, Addl. Sr. DR

Section 148Section 250Section 56(2)(via)Section 56(2)(viia)

time of hearing, Id. AR objected to the initiation of reassessment proceedings stating that the reasons recorded by the Assessing Officer for reopening the assessment suffers from various infirmities within the meaning of section 147 to 151 of the Act. He also submitted that in the said notice there ... ACIT in Writ Petition (T) No.367 of 2027, wherein, similar view has been expressed. Further, Id. AR submitted that the Assessing Officer while reopening the assessment held that the assessee company had taken unsecured loans of Rs.2,18,00,000/- from his sister concern M/s. Cresent Dealer

Bangamata Tie-Up Private Limited, Kolkata vs. ITO 13(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1332/KOL/2025[2015-16]Status: DisposedITAT Kolkata28 Oct 2025AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Bangamata Tie-Up Private Ito 13(1) Limited Aaykar Bhawan, 41, Central Plaza, Bb Ganguly Kolkata-700069, West Bengal Vs. Street Bowbazar, Kolkata-700012, West Bengal (Appellant) (Respondent) Pan No. Aaecb9495M Assessee By : Shri Akshay Ringasia, Ar Revenue By : Shri Soumitra Ghosh, Dr Date Of Hearing: 21.08.2025 Date Of Pronouncement: 28.10.2025

For Appellant: Shri Akshay Ringasia, ARFor Respondent: Shri Soumitra Ghosh, DR

Section 147Section 148Section 148ASection 149

ACIT in WP(C) No. 17639/2022 order dated 13.12.2024 wherein it has Bangamata Tie-up Private Limited; A.Y. 2015-16 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

DCIT Central Circle 1 4 Kolkata, Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2245/KOL/2024[2016-17]Status: DisposedITAT Kolkata28 Oct 2025AY 2016-17

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

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR

Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

adjudication. A.Y. 2013-14 CO No. 42/KOL/2025 04. Since, the assessee has raised legal issue in cross objection filed, challenging the validity of reopening of assessment u/s 147 of the Income-tax Act, 1961 (the Act) on the ground that the conditions envisaged in proviso to Section ... premises of the assessee on 04.011.2019, during which some documents were found. Based on the findings of the survey team, the ld. AO reopened the assessment u/s 147 of the Income-tax Act, 1961 (the Act) by issuing notice u/s 148 of the Act on 01.04.2021, which were duly served

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2196/KOL/2024[2018-19]Status: DisposedITAT Kolkata28 Oct 2025AY 2018-19

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

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR

Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148