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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

Dipak Chhaganlal Naik L/H Amitaben Dipak Naik, Surat vs. ITO, Ward 2(3)(1), Surat

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

ITA 1118/SRT/2024[2013-14]Status: DisposedITAT Surat17 Oct 2025AY 2013-14

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1118/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Dipak Chhaganlal Naik Income Tax Officer Ward-2(3)(1), बनाम/ L/H Amitaben Dipak Naik Surat, Room No. 627, Aaykar Vs. 44, China Gate-2, B/Hgayatri Bhawan, Majura Gate, Surat-395 Mandir, Althan S.O, Althan, 001 Surat- 395 017 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadhn 5872 L (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Rajesh Upadhyay, Ar राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 28/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 17/10/2025

Section 144Section 148Section 148ASection 2(47)Section 250Section 50CSection 80C

Dipak C. Naik/L/h Amitaben D Naik 2. Ld. CIT(A), NFAC, Delhi has erred in law and on fact to confirm AO’s reopening of assessment under amended provisions of Section 148A of the Act which came into force w.e.f 01/04/2021. 3. Ld. CIT(A), NFAC, Delhi has erred

Income Tax Officer, Tenali vs. Suryaprakasarao Kanaparthy, Bethapudi, Repalle

In the result, the Cross Objection filed by the assessee is allowed in terms of our aforesaid observations, while for the appeal filed by the revenue having been rendered as academic in nature, is ...

ITA 239/VIZ/2025[2018]Status: DisposedITAT Visakhapatnam17 Oct 2025

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.239/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Income Tax Officer, Vs. Suryaprakasarao Tenali. Kanaparthy, Bethapudi, Repalle, Bapatla. Pan: Dmqpk7509P (Appellant) (Respondent)

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 151Section 151ASection 69A

achieve the ultimate object of simplifying the tax administration, ease compliance and reduce litigation. 6.3 But prior to pre-Finance Act, 2021, while reopening an assessment, the procedure of giving the reasons for reopening and an opportunity to the assessee and the decision of the objectives were required ... with effect from 01.04.2023. In taxing statutes, intendment cannot be assumed unless specifically expressed in the provision enacted by the legislature. Therefore, the reopening of assessment without sanction/approval of the specified authority in accordance with Section 151 of the Act was bad in law. Consequently, reassessment order dated 16.01.2024 also

Mr. Arpanbhai Virambhai Desai, Gandhinagar vs. The Pr. CIT, Ahmedabad-3, Ahmedabad

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

ITA 759/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2015-16
For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

shall have to be determined with reference to the reasons recorded for reopening of the assessment. (iv) The basic requirement of law for reopening and assessment is application of mind by the Assessing Officer, to the materials produced prior to the reopening of the assessment, to conclude that ... something therein, which is critical to the formation of the belief must be referred to. Otherwise, the link would go missing. (vii) The reopening of assessment under Section 147 is a potent power and should not be lightly exercised. It certainly cannot be invoked casually or mechanically. (viii

Mr. Arpanbhai Virambhai Desai, Gandhinagar vs. Pr.CIT, Ahmedabad-3, Ahmedabad

In the result, all four appeals filed by the assessee are allowed in above terms

ITA 758/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2014-15

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

shall have to be determined with reference to the reasons recorded for reopening of the assessment. (iv) The basic requirement of law for reopening and assessment is application of mind by the Assessing Officer, to the materials produced prior to the reopening of the assessment, to conclude that ... something therein, which is critical to the formation of the belief must be referred to. Otherwise, the link would go missing. (vii) The reopening of assessment under Section 147 is a potent power and should not be lightly exercised. It certainly cannot be invoked casually or mechanically

Mr. Arpanbhai Virambhai Desai, Gandhinagar vs. The ITO, Ward-1, Int.Tax., Ahmedabad

In the result, all four appeals filed by the assessee are allowed in above terms

ITA 339/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

shall have to be determined with reference to the reasons recorded for reopening of the assessment. (iv) The basic requirement of law for reopening and assessment is application of mind by the Assessing Officer, to the materials produced prior to the reopening of the assessment, to conclude that ... something therein, which is critical to the formation of the belief must be referred to. Otherwise, the link would go missing. (vii) The reopening of assessment under Section 147 is a potent power and should not be lightly exercised. It certainly cannot be invoked casually or mechanically

Mr. Arpanbhai Virambhai Desai, Gandhinagar vs. The ITO, Ward-1, Int.Tax., Ahmedabad

In the result, all four appeals filed by the assessee are allowed in above terms

ITA 338/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2017-18

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

shall have to be determined with reference to the reasons recorded for reopening of the assessment. (iv) The basic requirement of law for reopening and assessment is application of mind by the Assessing Officer, to the materials produced prior to the reopening of the assessment, to conclude that ... something therein, which is critical to the formation of the belief must be referred to. Otherwise, the link would go missing. (vii) The reopening of assessment under Section 147 is a potent power and should not be lightly exercised. It certainly cannot be invoked casually or mechanically

DCIT, Central Circle-1(1), Kolkata vs. Rajesh Kumar Kedia, Kolkata

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

ITA 138/KOL/2025[2019-20]Status: DisposedITAT Kolkata17 Oct 2025AY 2019-20

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

For Appellant: S/Shri S.M Surana &For Respondent: Shri Sanat Kumar Raha, DR
Section 132(1)Section 132(4)Section 143(1)Section 147Section 148Section 148ASection 69A

enquiry or application of mind by the AO to the information received from the Investigation Wing and thus on this score also the reopening of assessment is invalid and nullity in the eyes of law. Therefore, considering the above facts and circumstances and the various decisions discussed above ... allowed. CO No. 25/KOL/2025 013. The issue raised in ground no.1 to 4 is a legal issue and is against the invalid reopening of assessment by the learned AO u/s 147 of the Act. 014. The facts were already discussed and narrated in detail while disposing the Revenue’s appeal

DCIT, Central Circle-1(1), Kolkata vs. Rajesh Kumar Kedia, Kolkata

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

ITA 137/KOL/2025[2016-17]Status: DisposedITAT Kolkata17 Oct 2025AY 2016-17

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

For Appellant: S/Shri S.M Surana &For Respondent: Shri Sanat Kumar Raha, DR
Section 132(1)Section 132(4)Section 143(1)Section 147Section 148Section 148ASection 69A

enquiry or application of mind by the AO to the information received from the Investigation Wing and thus on this score also the reopening of assessment is invalid and nullity in the eyes of law. Therefore, considering the above facts and circumstances and the various decisions discussed above ... allowed. CO No. 25/KOL/2025 013. The issue raised in ground no.1 to 4 is a legal issue and is against the invalid reopening of assessment by the learned AO u/s 147 of the Act. 014. The facts were already discussed and narrated in detail while disposing the Revenue’s appeal

M.A. Financial Services Pvt. Ltd., Kolkata vs. ITO, Ward 4(1), Kolkata

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

ITA 1272/KOL/2025[2015-2016]Status: DisposedITAT Kolkata17 Oct 2025AY 2015-2016

Bench: Shri Pradip Kumar Choubey & Shri Sanjay Awasthiassessment Year: 2015-16 M. A Financial Services Pvt. Ltd.……………………….……….……….……Appellant 2, Lal Bazaar Street, 1St Floor, Kol-700001.. [Pan: Aaccm0481E] Vs. Ito, Ward-4(1), Kolkata…….…………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Ar, Appeared On Behalf Of The Appellant. Shri Praveen Kishore, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 09, 2025 Date Of Pronouncing The Order : October 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. Brief Facts Of The Case Of The Assessee Are That The Assessee Filed Its Return Of Income For The A.Y 2015-16 U/S 139 Of The Act On 20.07.2015 Declaring Total Income Of Rs.9,647/-. The Said Return Was Processed U/S 143(1) Of The Act. Later On, Based On Information Received Through Itba Software Under The Head High Risk Transaction Case Notice U/S 148A(B) Of The Act Was Issued & Finally Notice U/S 148 Of The Act Was Issued On 13.07.2022. In Response, The Assessee Filed Return On 02.11.2021 Declaring Total Income Of Rs.9,647. Assessment Was Made Under Sec. 147 M. A Financial Services Pvt. Ltd Read With Section 144B Of The Act On 24.05.2023 Determining Total Income Of Rs.6,55,31,471/- Inter-Alia Making Following Addition:

Section 139Section 143(1)Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 250Section 69A

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: 149. (1) No notice under

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

3012/Mum/2025

ITA 3227/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

referred to as CIT (A) erred in holding that the DCIT, Central Circle 8(1) (herein referred to as AO) was right in reopening the assessment under section 148 of the Act. The Appellants submit that the conditions precedent to reopening of the assessment are not compiled with ... Order passed by the AO is without jurisdiction and therefore the reopening of assessment is bad in law and void ab-initio and the Appellants pray that the Order be quashed. 2. Without prejudice to the above, the CIT erred in holding that AO was right in making an addition

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3225/MUM/2025[2019-20]Status: DisposedITAT Mumbai17 Oct 2025AY 2019-20
Section 132Section 132(4)Section 69A

referred to as CIT (A) erred in holding that the DCIT, Central Circle 8(1) (herein referred to as AO) was right in reopening the assessment under section 148 of the Act. The Appellants submit that the conditions precedent to reopening of the assessment are not compiled with ... Order passed by the AO is without jurisdiction and therefore the reopening of assessment is bad in law and void ab-initio and the Appellants pray that the Order be quashed. 2. Without prejudice to the above, the CIT erred in holding that AO was right in making an addition

Kritika Jain, New Delhi vs. ITO Ward 36(1), New Delhi

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

ITA 777/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Oct 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.777/Del./2025, A.Y. 2019-20 Kritika Jain Income Tax Officer, C/O. Ds Legal & Associates, Ward 36(1), B-50, Lgf, South Extension-Ii, Vs. Civic Centre, New Delhi Minto Road, New Delhi Pan: Aftpa6657B (Appellant) (Respondent) Appellant By Sh. Shaantanu Jain, Advocate Sh. Dipanshu Jain, Advocate Ms. Jahanvi Khanna, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 29/07/2025 Date Of Pronouncement 17/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2019-20 Is Directed Against The Order Dated 22.01.2025 Of The Commissioner Of Income Tax (Appeals), Nfac, New Delhi [‘Cit(A)’].

Section 143(2)

account of unexplained expenditure is confirmed. Accordingly, Ground No. 3 is dismissed.” 4. Before us the Ld. Counsel contended that the reopening of assessment was not justified as the non-compliance by the supplier of the goods was the only basis on which the inference had been drawn ... Counsel prayed for relief. 5. On the other hand, the Ld. CIT-DR contended that the AO had recorded reasons for reopening the assessment. He submitted that the Ld. Counsel had not brought any material on the record to contradict the finding of the Ld. CIT(A) and to demonstrate

Ge Global Parts & Products Gmbh, Switzerland vs. Assistant Commissioner of Income Tax, Circle Int Tax 1(3)(1), Delhi

In the result, Appeal of the Assessee is partly allowed

ITA 1932/DEL/2025[2022-23]Status: DisposedITAT Delhi17 Oct 2025AY 2022-23

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ge Global Parts & Products Vs Assistant Commissioner Of Gmbh, Brown Boverit Strasse Income Tax, Circle 8, Baden, Switzerland International Taxation 1(3)(1) Pan: Aagcg3668K Civic Centre, Minto Road, New Delhi

Section 143(3)Section 144C(13)Section 285

case of Blackstone Capital Partners (Singapore) VI FDI Three Pte. Ltd. (supra), Hon’ble jurisdictional High Court, while dealing with the issue of reopening of assessment based on information received from third party, observed, though such information can form basis for an examination/investigation 5 GE Global Parts & Products Vs. ACIT ... Assessing Officer, but the decision to reopen the assessment has to be of the Assessing Officer and not of the third party. The Assessing Officer cannot merely do a cut and paste job for reopening the assessment without independent application of mind or verification or investigation. The aforesaid ratio laid

Deputy Commissioner of Income Tax, Jhandewalan, New Delhi vs. Israni Buildwell Private Limited, Delhi

ITA 3132/DEL/2024[2014-15]Status: HeardITAT Delhi17 Oct 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 148Section 194CSection 194ISection 68Section 69Section 69C

respondent assessee filed its ITR on 24.01.2022 declaring income of Rs.13,83,860/-. The case was scrutinized. The respondent assessee challenged the reopening of assessment before the Hon’ble Delhi High Court; however, the same, vide order dated 11.02.2022, was dismissed as withdrawn. 3.2 During the course of assessment proceedings

Raheja Developers Limited, New Delhi vs. DCIT, Central Circle 19, New Delhi

ITA 2284/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

case of the Assessee was selected for re-assessment u/s 147 of the Act after recording reasons for reopening. An assessment order came to be passedon 31/12/2018 u/s 143(3) r.w. Section 147 of the Act by Raheja Developers Ltd. vs. ACIT making addition ... disbelieve that escarpment of income and after taking approval from the competent authority, issued notice u/s 148 of the Act. The requirement for reopening of assessment proceedings u/s 147 of the Act is the availability of prima facie material of evasion tax and not the conclusive establishment of escarpment

Raheja Developers Limited, New Delhi vs. ACIT, Central Circle 19, Delhi

ITA 2283/DEL/2023[2011-12]Status: DisposedITAT Delhi17 Oct 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

case of the Assessee was selected for re-assessment u/s 147 of the Act after recording reasons for reopening. An assessment order came to be passedon 31/12/2018 u/s 143(3) r.w. Section 147 of the Act by Raheja Developers Ltd. vs. ACIT making addition ... disbelieve that escarpment of income and after taking approval from the competent authority, issued notice u/s 148 of the Act. The requirement for reopening of assessment proceedings u/s 147 of the Act is the availability of prima facie material of evasion tax and not the conclusive establishment of escarpment

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Aman Feed Industries, Khanna

In the result, appeals of the assessee for A

ITA 457/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 145(3)Section 153ASection 153DSection 250Section 68

section 151 of the Act is to introduce a supervisory check over the work of the AO, particularly, in the context of reopening of assessment. The law expects the AO to exercise the power under section 147 of the Act to reopen an assessment only after due application of mind

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. M/S Afi Agro Pvt. Ltd., Khanna

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

ITA 373/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

section 151 of the Act is to introduce a supervisory check over the work of the AO, particularly, in the context of reopening of assessment. The law expects the AO to exercise the power under section 147 of the Act to reopen an assessment only after due application of mind

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Aman Feed Industries, Khanna

In the result, appeals of the assessee for A

ITA 181/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh16 Oct 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 145(3)Section 153ASection 153DSection 250Section 68

section 151 of the Act is to introduce a supervisory check over the work of the AO, particularly, in the context of reopening of assessment. The law expects the AO to exercise the power under section 147 of the Act to reopen an assessment only after due application of mind

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Afi Agro Pvt. Ltd., Khanna

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

ITA 180/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh16 Oct 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

section 151 of the Act is to introduce a supervisory check over the work of the AO, particularly, in the context of reopening of assessment. The law expects the AO to exercise the power under section 147 of the Act to reopen an assessment only after due application of mind