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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

Urmish M. Udani, Mumbai vs. Aci 10(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 6144/MUM/2017[2009-10]Status: DisposedITAT Mumbai09 Oct 2025AY 2009-10

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Shri Madhur Agrawal/Shri Fenil Bhatt, A/RsFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 139(4)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 68

undisputed position before us that on 25.01.2000 when the Assessing Officer issued a notice under Section 148 of the Act to reopen the assessment for Assessment Year 1999-2000, even before the time to issue notice under Section 143(2) of the Act to assess under section ... expires/come to an end. 10. On the other hand, Section 147/148 of the Act empowers an Assessing Officer to reopen an assessment wherever he has reason to believe that income chargeable to tax has escaped assessment. This power under Section 147/148 of the Act is subject to various limitation provided

Income Tax Officer, Ward-2(1), Guntur vs. Shivani Cotton Industries Private Limited, Guntur

In the result, appeals ITA

ITA 460/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

Private Limited has been confirmed by the learned CIT(A) and, therefore, the legal ground taken by the assessee challenging the validity of reopening of assessment under section 147 of the Act for making protective additions are redundant for adjudication. In otherwords, although, the assessee has raised the legal ground ... ground that may be decided against him by the lower authority or Court. In the present case, since, the assessee has challenged the reopening of assessment proceedings by 18 ITA.Nos.359, 367, 368 & 460/Hyd./2024 filing legal grounds before the learned CIT(A) and the learned

Income Tax Officer, Ward- 1(1), Guntur vs. Potti Kumara Naga Venkata Sai Chakravarthy, Guntur

In the result, appeals ITA

ITA 368/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

Private Limited has been confirmed by the learned CIT(A) and, therefore, the legal ground taken by the assessee challenging the validity of reopening of assessment under section 147 of the Act for making protective additions are redundant for adjudication. In otherwords, although, the assessee has raised the legal ground ... ground that may be decided against him by the lower authority or Court. In the present case, since, the assessee has challenged the reopening of assessment proceedings by 18 ITA.Nos.359, 367, 368 & 460/Hyd./2024 filing legal grounds before the learned CIT(A) and the learned

Income Tax Officer, Guntur vs. Madhusushana Venkata Subba Rao Potti, Guntur

In the result, appeals ITA

ITA 367/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

Private Limited has been confirmed by the learned CIT(A) and, therefore, the legal ground taken by the assessee challenging the validity of reopening of assessment under section 147 of the Act for making protective additions are redundant for adjudication. In otherwords, although, the assessee has raised the legal ground ... ground that may be decided against him by the lower authority or Court. In the present case, since, the assessee has challenged the reopening of assessment proceedings by 18 ITA.Nos.359, 367, 368 & 460/Hyd./2024 filing legal grounds before the learned CIT(A) and the learned

Assistant Commissioner of Income Tax, Guntur vs. Ms.Vijayasai Lakshmi Srinivasa Cotton Mills, Guntur

In the result, appeals ITA

ITA 359/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

Private Limited has been confirmed by the learned CIT(A) and, therefore, the legal ground taken by the assessee challenging the validity of reopening of assessment under section 147 of the Act for making protective additions are redundant for adjudication. In otherwords, although, the assessee has raised the legal ground ... ground that may be decided against him by the lower authority or Court. In the present case, since, the assessee has challenged the reopening of assessment proceedings by 18 ITA.Nos.359, 367, 368 & 460/Hyd./2024 filing legal grounds before the learned CIT(A) and the learned

Income Tax Officer, Ward-2(3), Vijayawada vs. Sreelakshmi Musunuru, Penamaluru

ITA 278/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2013-14

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.278/Viz/2024 (िनधा"रण वष"/Assessment Year: 2013-14) Income Tax Officer, Vs. Sreelakshmi Musunuru, Ward-2(3), Penamaluru. Vijayawada. Pan: Aojpm4884K (Appellant) (Respondent)

For Appellant: Sri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 147Section 148Section 149(1)(b)Section 69

Upon hearing learned counsel for the parties and upon perusal of the documents and record, what we gather is that the notice of reopening of assessment has been issued beyond the period of four years from the assessment year. The reasons recorded by the Assessing Officer are elaborate and refer ... formed on the basis of material already on record. Looked from any angle, the Assessing Officer cannot justify issuing the notice of reopening of assessment beyond the period of four years from the end of relevant assessment year. 8. Under the circumstances, impugned notice is quashed. Petition allowed and disposed

Pitti Holdings Private Limited, Hyderabad vs. ACIT., Central Circle-1(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 450/HYD/2025[2018-19]Status: DisposedITAT Hyderabad08 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

For Appellant: Shri A. Srinivas, C.AFor Respondent: Dr. Sachin Kumar, DR
Section 148Section 148A

shell company and the assessee is found to be a beneficiary of accommodation transaction in the shape of unsecured loans. Therefore, the reopening of assessment is based on tangible material available with the Assessing Officer regarding the accommodation entries received by the assessee in the shape of unsecured loans ... HYDERABAD.” 8.1 As per the Annexure to notice u/s.148A(b) of the Act, the Assessing Officer has given the reasons for reopening of assessment that the assessee is the beneficiary of accommodation entries to the tune of Rs.1.25 Crores in the form of unsecured loans. The Assessing Officer has also

M/S. Sunglow Vinimay Private Limited, Kolkata vs. ITO, Ward 6(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 263/KOL/2025[2015-16]Status: DisposedITAT Kolkata08 Oct 2025AY 2015-16

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 144BSection 147Section 148Section 148A

record the reasons and the satisfaction ITA No.1372/KOL/2024 Sudha Surana; A.Y. 2015- 16 for having granted such approval. In our opinion, the reopening of assessment on the basis of said approval is bad in law. Case of the assessee find force from the decision of Capital Broadways ... notice. In the present case, since reopening was beyond the period of four years, it was for the PCIT to record satisfaction for reopening the assessment. In the case of SBC Minerals Pvt. Ltd. vs. Assistant Commissioner of Income Tax Circle 22(2), Delhi, WP (C) 7885/2023, we had clearly

M/S. Sunglow Vinimay Private Limited, Kolkata vs. ITO, Ward 6(1), Kolkata

In the result, the appeal of the assessee is

ITA 262/KOL/2025[2014-15]Status: DisposedITAT Kolkata08 Oct 2025AY 2014-15

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 144BSection 147Section 148Section 148A

reasons and the satisfaction Page | 6 ITA No.1372/KOL/2024 Sudha Surana; A.Y. 2015- 16 for having granted such approval. In our opinion, the reopening of assessment on the basis of said approval is bad in law. Case of the assessee find force from the decision of Capital Broadways ... notice. In the present case, since reopening was beyond the period of four years, it was for the PCIT to record satisfaction for reopening the assessment. In the case of SBC Minerals Pvt. Ltd. vs. Assistant Commissioner of Income Tax Circle 22(2), Delhi, WP (C) 7885/2023, we had clearly

Viswanathan Pappathi, Vellore vs. ITO, Ward-2, Vellore

In the result, appeal filed by the assessee is allowed

ITA 1620/CHNY/2025[2016-17]Status: DisposedITAT Chennai08 Oct 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R.Raghunathaआयकर अपील सं./Ita No.: 1620/Chny/2025 िनधा#रण वष# / Assessment Year: 2016-17 Viswanathan Pappathi Income Tax Officer No. 24C, Pudupet Road, Vs. Ward – 2, 4Th Street, Tirupattur, Vellore. Vellore – 635 601. Tamil Nadu. [Pan: Ceqpp-4595-H] (अपीलाथ%/Appellant) (&'थ%/Respondent) अपीलाथ% की ओर से/Appellant By : Ms. T. V. Muthu Abirami, Advocate &'थ% की ओर से/Respondent By : Shri. N. Rajakumar, Addl. C.I.T.

For Appellant: Ms. T. V. Muthu Abirami, AdvocateFor Respondent: Shri. N. Rajakumar, Addl. C.I.T
Section 144BSection 147Section 148Section 148ASection 151ASection 69A

since it has been issued contrary to law and is against the ‘Rule of Law’; which impugned action of the JAO vitiates the reopening of assessment for AY 2018-19 by issuance of impugned notice dated 31.03.2022 u/s.148 of the Act and is therefore held to be illegal

Huawei International Pte Ltd, Singapore vs. ACIT-Circle 2(1)(1), Intl. Tax, New Delhi

In the result, the appeal of the assessee is allowed and stay application of 7

ITA 2648/DEL/2025[2014-15]Status: DisposedITAT Delhi08 Oct 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganesh & Sa 298/Del/2025 (Assessment Year: 2014-15) Huawei International Pte. Ltd, Vs. Acit, 51, Change Business Park, Circle-2(1)(1), Central-2, #07-08, The International Signature, Singapore Taxation, New Delhi (Appellant) (Respondent) Pan: Aacch3694N Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Aggarwal, Adv Shri Yash Nagar, Adv Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 01/10/2025 Date Of Pronouncement 08/10/2025

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri M. s. Nethrapal, CIT DR
Section 144CSection 147Section 148Section 148ASection 149

Permanent Establishment (PE) in India of the assessee. This by any stretch of imagination cannot be construed as formation of belief warranting reopening of assessment. The Learned AO is only stating that he would like to make detailed investigation on the claims made by the assessee with regard to taxability ... filed its return of income. In our considered opinion, this is not the issue before us at all. The validity of reopening of assessment made by the Learned AO is not sought to be addressed on the existence of tangible material with the Learned AO in the instant case

Kataria Snack Pellets Private Limited, Rajkot vs. Assistant Commissioner of Income Tax, Circle-1(1), Rajkot

In the result, appeal of the assessee is dismissed

ITA 468/RJT/2024[2015-16]Status: DisposedITAT Rajkot07 Oct 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.468/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Kataria Snack Pellets Pvt. Ltd. The Acit, Circle-1(1) बनाम 510, Gidc, Metoda Kalawad Road Rajkot Rajkot-360021, Gujarat Vs. Pan : Aafck2028L (अपीलाथ"/Appellant) (""यथ"/Respondent) :

For Appellant: Shri Nishit B. Jesur, ld.ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

assessee, are as follows: Kataria Snack Pellets Pvt. Ltd. ITA No.468 /RJT/2024 (AY : 2015-16) 2 1.The Ld. CIT(A) erred in confirming reopening of assessment u/s 147 of the Act, as valid. 2.The Ld. CIT(A) erred in confirming addition of Rs. 3,99,20,000/- made

Narendra Kachrulal Abad, Jalna vs. Income-Tax Officer, Ward - 1, Jalna

In the result, appeal of the assessee partly allowed

ITA 866/PUN/2019[2009-10]Status: DisposedITAT Pune06 Oct 2025AY 2009-10

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.866/Pun/2019 निर्धारण वषा / Assessment Year: 2009-10 Shri Narendra Kachrulal Abad, V The Income Tax Officer, Abad House, Nal Galli, S Ward-1, Jalna. Kadrabad, Jalna – 431203. Maharashtra. Pan: Acspa9531C Appellant/ Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Arvind Renge –Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 06/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)-1, Aurangabadpassed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2009-10 Dated 30.03.2019, Emanating From Order U/S.143(3) R.W.S 147Of The Income Tax Act, 1961, Dated 03.11.2017. The Assessee Has Raised The Following Concise Grounds Of Appeal :

Section 143(3)Section 148Section 250

concise grounds of appeal : ITA No.866/PUN/2025 [A] “The following grounds of appeal are taken independently and without prejudice to one another. 1. The reopening of assessment by issuing notice u/s 148 of the Income Tax Act is invalid and bad-in-law as; the notice has been issued on borrowed ... which client code modification was involved. Thus, the above recording does not satisfyrequirement of law mandatory for assuming jurisdiction to reopen the assessment. My above view is supported by the decision of the Bombay High Court in the case of Coronation Agro Industries Ltd. Vs. DCIT reported

Huhtamaki India Limited (Vista Film and Packaging Private Limited Merged Into Positive Packaging Industries Limited Which in Turn Merged Into Hutamaki India Limited), Mumbai vs. Dy Commissioner of Income Tax 14(1)(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 3365/MUM/2025[2008-09]Status: DisposedITAT Mumbai06 Oct 2025AY 2008-09

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarhuhtamaki India Limited V/S. Deputy Commissioner Of (Vista Film & Packaging Pvt Ltd बनाम Income Tax, Ward – Merged Into Positive Packaging 14(1)(1), Aayakar Bhavan, Industries Ltd. Which In Turn Merged Maharishi Karve Road, New Limited), 7Th Into Huhtamaki India Marine Lines, Mumbai – Floor, Bellona, The Walk, 400020, Maharashtra Hiranandani Estate, Ghodbunder Road, Sandozbaugh, Thane– 400 607, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaact0086E Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: NoneFor Respondent: Shri Hemanshu Joshi, (Sr. DR)
Section 143(3)Section 147Section 148

principles of natural justice. The appellant prays that the order passed by the learned CIT(A) be set aside. 3. Ground No. 3- Reopening of assessment 3.1.Without prejudice to the above grounds, on the facts and circumstances of the case. as well as in law, the learned CIT(A) erred

Amrit Corporation, Mumbai vs. DCIT-CC-1(1), Mumbai

ITA 1661/MUM/2025[2021-2022]Status: DisposedITAT Mumbai06 Oct 2025AY 2021-2022

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Aditya M. RaiFor Respondent: Shri Jayant Bhatt
Section 148Section 69C

ground taken by the appellant relates to challenging the reopening of the assessment because there is no material available with the Department to reopening of assessment and hence it is bad in law. 5. During the hearing before ITAT, the Ld. AR of the appellant requested the Bench to keep

Amrit Corporation, Mumbai vs. DCIT-CC-1(1), Mumbai

ITA 1660/MUM/2025[2020-2021]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-2021

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Aditya M. RaiFor Respondent: Shri Jayant Bhatt
Section 148Section 69C

ground taken by the appellant relates to challenging the reopening of the assessment because there is no material available with the Department to reopening of assessment and hence it is bad in law. 5. During the hearing before ITAT, the Ld. AR of the appellant requested the Bench to keep

Amrit Corporation, Mumbai vs. DCIT-CC-1(1), Mumbai

ITA 1659/MUM/2025[2019-2020]Status: DisposedITAT Mumbai06 Oct 2025AY 2019-2020

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Aditya M. RaiFor Respondent: Shri Jayant Bhatt
Section 148Section 69C

ground taken by the appellant relates to challenging the reopening of the assessment because there is no material available with the Department to reopening of assessment and hence it is bad in law. 5. During the hearing before ITAT, the Ld. AR of the appellant requested the Bench to keep

Income Tax Officer, Churchgate vs. M/S Nnm Securities Pvt. Ltd., Fort

ITA 1207/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Oct 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am) Ito-4(2)(1) M/S. Nnm Securities P. Ltd. Room No. 644 1111 Stock Exchange Tower Aayakar Bhavan Vs. Dalal Street, Fort M.K. Road Mumbai-400 023. Mumbai-400 020. Pan : Aaacn8070G Appellant Respondent C.O. No. 154/Mum/2025 (Assessment Year : 2016-17)

For Appellant: Shri Leyaqat Ali AafaquiFor Respondent: Shri Vimal Punmiya

ground of appeal of Revenue. Secondly, the Revenue challenged the order of Ld. CIT(A), who passed the order of AO against the reopening of assessment. 2 M/s. NNM Securities P. Ltd. 2. As against this main ground of appeal, the appellant filed cross objection stating that the appellant raised ... grounds of appeal on reopening of assessment as well as on merits, but the Ld. CIT(A) adjudicated the issue of reopening of assessment in assessee’s favour by quashing the reopening the assessment without adjudicating other grounds on merits. Hence, the appellant filed the cross objection. 3. Briefly stating

Late Shri Jitendra Nagar Through His L/R Smt. Deepika Nagar, Baran vs. Income Tax Officer Ward Baran, Baran

In the result, appeal of the assessee is allowed

ITA 1382/JPR/2024[2016-2017]Status: DisposedITAT Jaipur01 Oct 2025AY 2016-2017

Bench: The Date Of Hearing.”

For Appellant: Shri Sidharth Ranka, AdvFor Respondent: Shri. Gautam Singh Choudhary, JCIT a
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 151Section 250Section 69A

dated 11.03.2025 after considering the aforesaidjudgment of Hon’ble Supreme Court in Rajeev Bansal (supra) has held: Reopening of assessment - validity of notice issued u/sec.148 Mandation to get approval must be obtained from the Principal Chief Commissioner or Principal Director General.HELD THAT:- Respectfully following the decision of Union of India ... dated 28.02.2025 after considering the aforesaidjudgment of Hon’ble Supreme Court in Rajeev Bansal (supra) has held: Validity of reopening of assessment - jurisdictional requirements of Sections 147 to 151 - whether approval obtained from the appropriate authority? - whether the Principal Commissioner of Income Tax or the Principal Chief Commissioner of Income

Deputy Commissioner of Income Tax, Delhi vs. Kawatra Tent and Caterers Private Limited, Delhi

ITA 2734/DEL/2023[2012-13]Status: DisposedITAT Delhi01 Oct 2025AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. Avdhesh Kumar Mishra

For Appellant: NoneFor Respondent: Sh. D. S. Sidhu, CIT-DR
Section 132Section 132ASection 139Section 147Section 148Section 149Section 151Section 153Section 153A

completed assessment in the ease of the assessee. 5.2.3 Further, on perusal of assessment order, it is evident that sole basis for reopening of assessment proceedings under section 148 is the information of search of the appellant and no other information or material relevant to the year under appeal