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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

Income Tax Officer 11(2)(1), Mumbai vs. Shrem Alloys Private Limited, Mumbai

In the result, all the appeals filed by the Revenue stand dismissed

ITA 2192/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Sept 2025AY 2014-15

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

Section 143(3)Section 147Section 148Section 153ASection 68

long-term capital gains and short-term capital losses for beneficiaries. It was this broad revelation that formed the sole foundation for the reopening of assessments in the case of the present assessee, even though the assessee’s own transactions were always disclosed as business income and not as exempt

Income Tax Officer 11 (2) (1), Mumbai vs. Everfine Alloys Private Limited, Mumbai

In the result, all the appeals filed by the Revenue

ITA 2186/MUM/2025[2015-16]Status: DisposedITAT Mumbai10 Sept 2025AY 2015-16
Section 143(3)Section 147Section 148Section 153ASection 68

long-term capital gains and short-term capital losses for beneficiaries. It was this broad revelation that formed the sole foundation for the reopening of assessments in the case of the present assessee, even though the assessee's own transactions were always disclosed as business income and not as exempt

Income Tax Officer, Mumbai vs. Everfine Alloys Private Limited, Mumbai

In the result, all the appeals filed by the Revenue stand dismissed

ITA 2185/MUM/2025[2013-14]Status: DisposedITAT Mumbai10 Sept 2025AY 2013-14

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

Section 143(3)Section 147Section 148Section 153ASection 68

long-term capital gains and short-term capital losses for beneficiaries. It was this broad revelation that formed the sole foundation for the reopening of assessments in the case of the present assessee, even though the assessee’s own transactions were always disclosed as business income and not as exempt

DCIT, Circle- 19(1), Delhi vs. R. Gopal Impex Pvt.Ltd., Delhi

In the result, the appeal of the Assessee as well as the Revenue

ITA 82/DEL/2025[2017-18]Status: DisposedITAT Delhi10 Sept 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 1Section 147Section 151

NFAC ITD has erred both on facts and in law in confirming the order of the AD despite the fact that reopening the assessment under Section 1.47 of the Act and consequent reassessment without complying with the statutory conditions and the procedure prescribed under the law are bad and liable ... NFAC, ITD has erred both on facts and in law in confirming the order of the AO despite the fact that reopening the assessment under Section 147 of the Act and consequent reassessment order are illegal, without jurisdiction, invalid and liable to be quashed. 4. (1) On the facts

Assistant Commissioner of Income Tax, Delhi vs. Prem Chand Pravesh Kumar, Delhi

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

ITA 736/DEL/2025[2014-15]Status: DisposedITAT Delhi10 Sept 2025AY 2014-15

Bench: Shri M. Balaganesh & Shri Sudhir Kumaracit, Vs. Prem Chand Pravesh New Delhi Kumar, (Through Erstwhile Partner Sanchit Garg), 292, Katra Peran, Tilak Bazar, Delhi- 110006 (Appellant) (Respondent) Pan: Aajfp9925A Co No. 120/Del/2025 (In Ita No. 736/Del/2025) (Assessment Year: 2014-15) Prem Chand Pravesh Vs. Acit, Kumar, (Through New Delhi Erstwhile Partner Sanchit Garg), 292, Katra Peran, Tilak Bazar, Delhi- 110006 (Appellant) (Respondent) Pan: Aajfp9925A Assessee By : Shri Ved Jain, Adv Shri Pawan Garg, Ca Ms. Ishika Dua, Ca Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 10/09/2025

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 147Section 148Section 148ASection 149Section 151

barred by limitation. Accordingly, the Ground No. 2 raised by the assessee in his Cross Objection is allowed. 7. Since, reopening of assessment has been quashed hereinabove, the adjudication of the other grounds raised by the assessee in the Cross Objection and the grounds raised by the revenue becomes academic

Mahashian Di Hatti (P) Ltd, New Delhi vs. PCIT-4, New Delhi

ITA 1987/DEL/2025[2020-21]Status: DisposedITAT Delhi10 Sept 2025AY 2020-21

Bench: Shri M. Balaganesh & Sh. Yogesh Kumar U.S.

Section 143(2)Section 143(3)Section 263Section 80Section 80G

1ITA No. 1987/Del/2025 Mahasian Di Hatti (P) Ltd. Vs. PCIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘G

R. Gopal Impex Pvt Ltd, Delhi vs. ACIT Circle - 19(1), Delhi

In the result, the appeal of the Assessee as well as the Revenue

ITA 5607/DEL/2024[2017-18]Status: DisposedITAT Delhi10 Sept 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 1Section 147Section 151

NFAC ITD has erred both on facts and in law in confirming the order of the AD despite the fact that reopening the assessment under Section 1.47 of the Act and consequent reassessment without complying with the statutory conditions and the procedure prescribed under the law are bad and liable ... NFAC, ITD has erred both on facts and in law in confirming the order of the AO despite the fact that reopening the assessment under Section 147 of the Act and consequent reassessment order are illegal, without jurisdiction, invalid and liable to be quashed. 4. (1) On the facts

DCIT, Circle-7(1), Delhi vs. Delhi Transco Ltd., Delhi

In the result, the appeal of Revenue is dismissed

ITA 1402/DEL/2024[2012-13]Status: DisposedITAT Delhi10 Sept 2025AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2012-13 Deputy Commissioner Of Income Vs. Delhi Transco Limited, Tax, Circle 7(1), Shakti Sadan, Kotla Road, Delhi-1100 02 Central Delhi, Delhi-1100 02 Pan :Aabcd6342A (Appellant) (Respondent)

Section 115Section 115JSection 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 250

such amount. 8. From examination of record in light of aforesaid rival contentions, it is crystal clear that Ld. AO mentioned reasons for reopening of assessment as under: 5 ITA No. 1402/Del.2024 “From perusal of assessment record for assessment years 2012-13 (F.Y. 2011-12) and observation made

Agri Gold Foods and Farm Products Limited, Vijayawada vs. Asst.Commissioner of Income Tax, Circle-2(1), Vijayawada

ITA 2000/HYD/2017[2007-08]Status: DisposedITAT Visakhapatnam09 Sept 2025AY 2007-08

Bench: Us:

Section 143(3)

change of opinion on the part of Assessing Officer. Emergence of new issue out of the file can be the basis for reopening of assessment. Further, initiation of reassessment proceedings was based on definite materials which were not considered at the time of original assessment proceedings. Under such circumstances, reopening ... Income Tax (SC) 102 ITR 287. 5.2.6. In the case of ACIT Vs. Kanga & Co. 2010-TIOL-464-ITAT-Mumbai held that for reopening of assessment u/s,148 of the Act, the 'Tangible material' need not be from outside the return of income. 5.2.7 When an income liable

Yugal Madhukar Khairnar, Satana vs. The Income-Tax Officer, Ward 1, Malegaon

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

ITA 1322/PUN/2025[2012-13]Status: DisposedITAT Pune09 Sept 2025AY 2012-13

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1322/Pun/2025 िनधा"रण वष" / Assessment Year: 2012-13 Yugal Madhukar Khairnar, V The Income Tax Officer, Dongrej Virgaon, Satana, S Ward-1, Malegaon. Dist-Nashik, Nashik – 423301. Pan: Anmpk4805E Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S. Shingte – Ar Revenue By Shri Ambarnath Khule - Jcit(Dr) Date Of Hearing 04/09/2025 Date Of Pronouncement 09/09/2025 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 A.Y.2012-13 Dated 24.03.2025 Emanating From The Assessment Order Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961. The Grounds Of Appeal Raised By The Assessee Are As Under : “1. On The Basis Of The Facts & In The Circumstances Of The Case, The Assessing Officer Is Not Justified In Making Addition Of Rs. 22,94,000/-

Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

Assessing Officer based on the information issued notice u/s.148 of the Act on 22.01.2019 after recording reasons for reopening. The Assessing Officer assessed the income at Rs.22,94,000/-. 4.1 Aggrieved by the assessment order, assessee filed appeal before the ld.CIT(A). The grounds of appeal raised before the ld.CIT ... case, the Court would like to observe that on a routine basis, a large number of writ petitions are filed challenging the reopening of assessments by the Revenue under sections 147 and148 of the Act and despite numerous judgments on this issue, the same errors are repeated by the concerned

Chinnappan Peter Francis, Kumbakonam vs. ITO, Ward-1, Kumbakonam

In the result, appeal filed by the assessee is allowed

ITA 1484/CHNY/2025[2018-19]Status: DisposedITAT Chennai09 Sept 2025AY 2018-19

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1484/Chny/2025 धनिाारण वर्ा / Assessment Year: 2018-19 M/S. Chinnappan Peter Ito, Francis, Vs. Ward I, No. 113, Kamraj Road, Kumbakonam. Bishops House, Kumbakonam – 612 001. Tamil Nadu. [Pan: Bwspp-2816-G] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) (अपीलाथी/Appellant) (प्रत्यथी/Respondent) : Mr. Y. Sridhar, F.C.A अपीलाथी की ओर से/ Appellant By प्रत्यथी की ओर से /Respondent By : Mr. R. Raghupathy, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 05.08.2025 : 09.09.2025 घोर्णा की तारीख /Date Of Pronouncement आदेश / O R D E R Per S.R.Raghunatha, Am. This Appeal By The Assessee Is Arising Out Of The Order Dated 17.04.2025, Passed By The Commissioner Of Income Tax (Appeal), Nfac, Delhi For The Assessment Year 2018-19 Against The Order U/S.147 R.W.S. 144 Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Passed By The Ito (Assessing Officer), Ward I, Thanjavur Dated 30.01.2024. 2. At The Outset, The Ld. Ar For The Assessee Mr.Y.Sridhar, Advocate For The Assessee Has Raised An Additional Ground Relating To Jurisdiction Of Jurisdictional Assessing Officer (‘Jao’) In The Light Of The Cbdt Notification Dated 29.03.2022 & The Decision Of The Hon’Ble Madras High Court In The Case Of Tvs Credit Services Ltd. Vs. Dcit (W.P.No.22402 Of 2024 Dated 24.06.2025). The Ld.Dr, Mr.R.Raghupathy, Addl.Cit, Objected Admission Of Additional Ground Raised By The Assessee.

For Respondent: Mr. R. Raghupathy, Addl.CIT
Section 139(1)Section 147Section 148Section 148ASection 151A

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

ACIT Central Circle 7 4, Mumbai vs. Zytex Biotech Private Limited, Mumbai

The appeal of the revenue is dismissed

ITA 492/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Sept 2025AY 2014-15

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri, Swapnil Choudhary, Sr. DR
Section 133ASection 143(3)Section 147Section 148Section 2Section 250Section 50(2)Section 50B

Whether on the facts and circumstances of the case and in law, the Learned CIT(A) is justified in holding that the reopening of assessment under Section 147 was invalid, despite the discovery of fresh tangible material Zytex Biotech Private Ltd. during the survey under Section 133A, which demonstrated that ... Whether on the facts and circumstances of the case and in law, the Learned CIT(A) is justified in concluding that the reopening of assessment under Section 147 was based on a "change of opinion," despite the fact that fresh tangible material emerged after the original assessment under Section

Late Sh Sulekh Chand Jain Through Legal Heir Sh Atul Jain, Delhi vs. Income Tax Officer, Ward 44(6), Delhi

ITA 2199/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Sept 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2015-16

Section 147Section 148

also not disputed the assessee’s assessment jurisdiction at Delhi in his detailed discussion as under: “Grounds 2 to 6 are raised against reopening of assessment u/s 147/148. The appellant stated that territorial jurisdiction of the case lies with the ITO Ward 26(4) New Delhi and contrary ... Dushyant Kr. Jain Vs. DCIT [(2016) 381 ITR 428 (Del)]. The appellant also submitted that reason for reopening the assessment was not informed while issuing notice u/s 148. The assessing officer has initiated the reassessment proceedings u/s 147 of the IT Act relying on the information from the investigation wing

Sainik Co Operative House Building Society Limited, Jammu and Kashmir vs. ITO Ward 1(1), Jammu

In the result the appeal of the assessee is allowed on the legal issue as indicated above

ITA 698/ASR/2024[2013-14]Status: DisposedITAT Amritsar08 Sept 2025AY 2013-14

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 698/Asr/2024 Assessment Year: 2013-14

Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69A

favour of assessee] 2025 (6) TMI 1484 - ITAT DELHI HARISH KUMAR VERSUS NFAC, DELHI AND ACIT, NEW DELHI VERSUS HARISH KUMAR Validity of reopening of assessment - period of limitation - Scope of TOLA - Period of limitation under new tax regime - Notice issued old law - HELD THAT:- We note that ... GUJARAT HIGH CQURT, KRISHNA NAITIK PATEL PQA HOLDER OF ISHWERBHAI KESHAVBHAI PATEL VERSUS ASSESSMENT UNIT INCOME TAX DEPARTMENT & ANR Reopening of assessment - Period of limitation under new tax regime - validity of the notice issued under TOLA between 31.3.2021 and 30.6.2021 - HELD THAT:- Respondent could not controvert the facts that

Laurels Properties Private Limited, Delhi vs. DCIT CC-1(4), Mumbai

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

ITA 1179/MUM/2025[2015-16]Status: DisposedITAT Mumbai05 Sept 2025AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 250

traded in 'F' and even provided documents thereto during assessment, there being no failure to truly and fully disclose material facts, reopening of assessment after four years was not justified. iii. Decision of Hon'ble High Court of Gujarat in the case of Nila Infrastructures Ltd. Vs. Assistant Commissioner

Zalavadiya Kalubhai Mohanbhai, HUF, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 806/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad04 Sept 2025AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha, Accountannt Member Assessment Year 2015-16

For Appellant: Shri Tushar Hemani, Sr. A.R. &For Respondent: Shri Abhijit, Sr. D.R
Section 10(38)Section 142(1)Section 143(2)Section 147Section 148

quashed. 3. Ground No. 3-Assessment us. 147 is bad-in-law: The AO has erred in law and on facts in reopening the assessment proceedings on the basis of Information received from Insight Portal. The AO has not provided any tangible evidence of escapement of income except report ... absence of some tangible matter or information being live nexus with such information available on Insight Portal. It is well settled that reopening of assessment in absence of any intangible material is bad in law and without jurisdiction. The ld. A.R. relied upon the following decisions:- ➤03 Developers

Deputy Commissioner of Income Tax, Salem vs. Govinda Rajulu Srinivasan, Salem

In the result, appeal of the Revenue stands dismissed

ITA 1245/CHNY/2025[2014-15]Status: DisposedITAT Chennai04 Sept 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Bhupendran, AdvocateFor Respondent: Mrs.C. Yamuna, CIT
Section 147Section 148Section 40Section 40A(3)

grievance of the Revenue is against the impugned action of the Ld.CIT(A) allowing the legal issue raised by the assessee against the reopening of assessment by the AO. Govinda Rajulu Srinivasan :: 2 :: 3. Brief facts relating to the impugned action of the Ld.CIT(A) is that assessee is noted ... regarding some transactions pertaining to TDS deduction, he was of the view that income chargeable to tax has escaped assessment and therefore, he reopened the assessment u/s.147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act‘) by issuing notice u/s.148 of the Act on 29.06.2021. Thereafter

Jayaraman Rudrasekar, Vellore vs. DCIT, Central Circle-1(4), Chennai

In the result, appeal filed by the assessee is allowed

ITA 1142/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Sept 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.N. Arjun Raj, AdvocateFor Respondent: Ms.Anitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

making certain additions. 9. The assessee’s contention is that jurisdictional notice issued by the JAO u/s 148 after 29.03.2022 in order to reopen the assessment is bad in law since he didn’t adhere to the provisions of Section 151 of the Act and the scheme notified ... 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 07.04.2022 u/s.148 of the Act and is therefore held to be illegal

Mohanlal Chunilal Mutta, Mumbai vs. Income Tax Office-19(2)(2), Mumbai

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

ITA 4692/MUM/2025[2011-12]Status: DisposedITAT Mumbai04 Sept 2025AY 2011-12

Bench: Shri Sandeep Gosain

Section 143(3)Section 145Section 147Section 250

order without complying with the principles of natural justice. 2. The Ld. Commissioner of Income Tax (Appeals) ought to have appreciated that the reopening of assessment u/s 147 of the Act was invalid and bad in Law. 2 Mohanlal Chunilal Mutta., Mumbai. 3. The Ld. Commissioner of Income Tax (Appeals

Gunomal Santumal Rochlani, Ulhasnagar vs. Income Tax Officer, Ward 2(1) Kalyan, Kalyan

In the result, appeal is allowed as indicated above

ITA 4300/MUM/2025[2015-16]Status: DisposedITAT Mumbai04 Sept 2025AY 2015-16

Bench: Shri Saktijit Dey & Ms. Padmavathy Sgunomal Santumal Rochlani, Income Tax Officer, 48, Roshan Apartment, Netaji Road, Ward- 2(1)), Ullhasnagar, Vs. Kalyan-Dombivali-421301 Thane - 421004 (Appellant) : (Respondent) Pan No. Ahppr 0832B Appellant By : Shri Mohit S. Makhija, Advocate Respondent By : Shri Arun Kanti Datta, Cit- Dr (Appellant) (Respondent) Date Of Hearing : 26.08.2025 Date Of Pronouncement : 04.09.2025

For Appellant: Shri Mohit S. Makhija, AdvocateFor Respondent: Shri Arun Kanti Datta, CIT- DR
Section 143(3)Section 147Section 148Section 149Section 3(1)

assessee that the impugned assessment order is barred by limitation as the Assessing Officer (AO) had no power to reopen the assessment u/s. 147 of the Act after expiry of six years from the end of the relevant assessment year i.e. A.Y. 2015- 16. In support of such contention, learned ... that under the new regime of Section 147 of the Act introduced by Finance Act, 2021 w.e.f. 01.04.2021, the AO has power to reopen the assessment before expiry of 10 years from the end of the relevant assessment year. Thus, he submitted, the notice issued