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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

ACIT, Aaykar Bhawan, M.K. Road, Mumbai vs. Railroad Logistics India Private Limited, Mumbai

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

ITA 3873/MUM/2025[2012-13]Status: DisposedITAT Mumbai04 Sept 2025AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankaracit Vs. Railroad Logistics India Room No. 607, Aayakar Pvt Ltd Bhavan, Mk Road, Mumbai C/O, Metal Trim, Gala – 400020. No.1, Tankiwala Indl Estate, Steel Made Compound, Marol, Maroshi Road, Mumbai Pan/Gir No. Aaccr3484J (Applicant) (Respondent) Assessee By Shri Satish R. Mody, Adv. Revenue By Shri Annavaran Kasuri, Sr. Ar Date Of Hearing 12.08.2025 Date Of Pronouncement 09.09.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 07.03.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre / Cit(A), Mumbai For The Assessment Year 2012- 13. 2. Both The Grounds Raised By The Revenue Are Interrelated & Interconnected & Relates To Challenging The Order Of Ld. Cit(A) In Terming The Order Passed By Ao As Infructuous.

Section 139Section 142(1)Section 143(3)Section 144Section 144BSection 147Section 148Section 250Section 263

before us and also the orders passed by the revenue authorities. From the records we noticed that, the case of the assessee was reopened and assessment was completed u/s 144 r.w.s 147 on 12.12.2019 determining the total income at Rs.5,04,23.261/-. The said assessment order was subsequently set aside ... facie, there is no suppression of relevant facts by the assessee in the present case which warrants the reassessment and therefore the reopening of assessment is invalid and unsustainable. As we have held the validity of reassessment proceeding to be non-est, the subsequent revisionary order passed

DCIT, Circle- 24(2), New Delhi vs. Superstar Innovation Pvt. Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 834/DEL/2018[2009-10]Status: DisposedITAT Delhi04 Sept 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.834/िद"ी/2018(िन.व. 2009-10) Deputy Commissioner Of Income Tax, Circle-24(2), R. No. 328, C.R Building, I.P Estate, ...... अपीलाथ"/Appellant New Delhi बनाम Vs. M/S. Superstar Innovation Pvt. Ltd., D-6/6032/2, Ground Floor, Vasant Kunj, New Delhi 110070 ..... "ितवादी/Respondent Pan: Aabcs 7795 Q Co No. 141/Del/2023 (A.Y.2009-10) In Ita No. 834/Del/2018 M/S. Superstar Innovation Pvt. Ltd., D-6/6032/2, Ground Floor, Vasant Kunj, New Delhi 110070 ...... अपीलाथ"/Appellant Pan: Aabcs 7795 Q बनाम Vs. Deputy Commissioner Of Income Tax, Circle-24(2), R. No. 328, C.R Building, I.P Estate, ..... "ितवादी/Respondent New Delhi अपीलाथ" "ारा/ Appellant By : Dr. Rakesh Gupta, S/Shri Somil Agarwal, Deepesh Garg & Shrey Jain, Advocates "ितवादी"ारा/Respondent By : Ms. Maninder Kaur & Ms. Neeju Gupta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 06/06/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025

For Appellant: Dr. Rakesh Gupta, S/Shri Somil AgarwalFor Respondent: Ms. Maninder Kaur &
Section 143(3)Section 147Section 148

Delhi (hereinafter referred to as 'the CIT(A)’) dated 24.11.2017, for assessment year 2009-10, assailing findings of the CIT(A) in holding reopening of assessment as invalid. 2. The assessee has filed cross objection in appeal by the Revenue supporting the order of CIT(A) and also raising legal ... ground that the assessment order is illegal as the same has been passed without disposing of the objections filed by the assessee against reopening of assessment. 3. Ms. Maninder Kaur, representing the department narrating facts of the case submits that the assessment in the case of assessee

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 91/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh03 Sept 2025AY 2018-19

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

must form a belief thereon. In the circumstances, there is no merit in the civil appeal. The Department was not entitled to reopen the assessment. Civil appeal is, accordingly, dismissed. II. The Hon'ble Gujarat High Court in the case of M/s Avakar Infrastructure Company Vs. DCIT Circle -9 reported ... mind to record of case to ascertain as to whether cost of investment as declared by assessee was in fact under- reported - Whether reopening of assessment merely on basis of report of DVO was without authority of law and could not be sustained. 7.3 During the course of search

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 90/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh03 Sept 2025AY 2017-18

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

must form a belief thereon. In the circumstances, there is no merit in the civil appeal. The Department was not entitled to reopen the assessment. Civil appeal is, accordingly, dismissed. II. The Hon'ble Gujarat High Court in the case of M/s Avakar Infrastructure Company Vs. DCIT Circle -9 reported ... mind to record of case to ascertain as to whether cost of investment as declared by assessee was in fact under- reported - Whether reopening of assessment merely on basis of report of DVO was without authority of law and could not be sustained. 7.3 During the course of search

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

In the result, the appeal of the assessee is to be allowed

ITA 127/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh03 Sept 2025AY 2016-17

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 127, 90 & 91 /Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2016-17, 2017-18 & 2018-19 AFI Feed Industries Shop No. 13, Khanna City Centre, G.T. Road, Ground Floor, Bolck-C, Khanna, Punjab-141401 स्थायी लेखा सं./PAN NO: ABDFA5916B अपीलार्थी/Appellant निर्धारिती की ओर से/Assessee by : राजस्व की ओर से / Revenue by : बनाम The DCIT Central Circle-l Ludhiana प्रत्यर्थी / Respondent Shri Ashwani Kumar, Ms. Deepali

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

must form a belief thereon. In the circumstances, there is no merit in the civil appeal. The Department was not entitled to reopen the assessment. Civil appeal is, accordingly, dismissed. II. The Hon'ble Gujarat High Court in the case of M/s Avakar Infrastructure Company Vs. DCIT Circle -9 reported ... mind to record of case to ascertain as to whether cost of investment as declared by assessee was in fact under- reported - Whether reopening of assessment merely on basis of report of DVO was without authority of law and could not be sustained. 7.3 During the course of search

M/S Lorgan Lifestyle Ltd., Pune vs. ITO, Ward14(4), Pune

In the result, appeal of the assessee is allowed as per terms indicated above

ITA 215/PUN/2025[2015-16]Status: DisposedITAT Pune03 Sept 2025AY 2015-16

Bench: Dr.Manish Borad & Ms.Astha Chandra

For Appellant: Shri B S RajpurohitFor Respondent: Shri Amol Khairnar
Section 143(3)Section 250

Lorgan Lifestyle Limited (supra) (2011) 331 ITR 236 and has submitted that since no addition on account of reasons to believe for reopening of assessment was made and the alleged disallowance of bad debts is not part of the reasons to believe, therefore, in light of the judgment ... Lorgan Lifestyle Limited for the assessee is that ld. AO has not made addition for the reasons mentioned in the reasons recorded for reopening the assessment proceedings. By way of legal issue raised in the additional ground, validity of re-assessment proceedings have been challenged. In light of the judgment

Aviral Marketing Pvt. Ltd., Kolkata vs. DCIT, Circle 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1423/KOL/2025[2012-2013]Status: DisposedITAT Kolkata03 Sept 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Aviral Marketing Pvt. Ltd…….……………..............................……….……Appellant 7, Camac Street, Azimganj House, 1St Floor, Shakespeare Sarani, Kol- 700017. [Pan: Aacca3794N] Vs. Dcit, Circle-4(1), Kolkata……………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Appellant. Shri Ruchika Sharma, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 02, 2025 Date Of Pronouncing The Order : September 03, 2025 Order Per Rajesh Kumar: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

Section 143(3)Section 147Section 148Section 250Section 68

Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. The issue raised in Ground No.1 & 2 is against the invalid reopening of assessment u/s 147 of the Act by the Assessing Officer which was upheld by the ld. CIT(A) and accordingly the reassessment framed as well ... validity of the proceedings under Section 147 of the said Act. The Tribunal, in essence, held that the purported reasons for reopening the assessments were entirely vague and devoid of any material. As such, on the available material, no reasonable person could have any reason to believe that income

Star Ceramics, Chitradurga vs. Income Tax Officer, Ward-1, Chitradurga

In the result, the appeal of the assessee is allowed

ITA 1064/BANG/2025[2016-17]Status: DisposedITAT Bangalore03 Sept 2025AY 2016-17

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Ms. Richa Bakiwala & Shri Hemasundar Rao P., CAsFor Respondent: Shri Thamba Mahendra, CIT(DR)(ITAT), Bengaluru
Section 147Section 148Section 148ASection 68Section 69A

delay in question arose due to the legal and technical opinion to be obtained from the AR of the Petitioner regarding the reopening of assessment and therefore there is a nominal delay of 6 days which may be condoned. 4. The ld. DR vehemently objected to the same ... examination provided to the assessee. The assessee also challenged the same stating that the transactions are genuine. The assessee also objected to the reopening of assessment stating that reopening has been made on the borrowed satisfaction. The ld. CIT(A) dismissed the grounds on reopening and further with respect

Sapana Rajendra Kumar Marathe, Mumbai vs. ITO Ward 23(3)(1), Mumbai

Appeal of the assessee is allowed

ITA 4363/MUM/2025[2015-16]Status: DisposedITAT Mumbai03 Sept 2025AY 2015-16

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Swapnil Choudhary, Sr. DR
Section 147Section 148Section 148ASection 250Section 69A

legal ground is beyond jurisdiction. 3. The Ld. Commissioner of Income Tax (Appeals) -NFAC failed to appreciate that the grounds challenging the reopening of assessment under section 147 of the Income Tax Act, 1961 goes to the root of the validity of re-assessment and the directions to frame ... newly developed building in lieu of her old flat. Since the assessee has not offered the monetary consideration received, the AO reopened the assessment by issue of notice under section 148 of the Act between 01.04.2021 to 30.06.2021. In view of the decision of the Hon'ble Supreme Court

Gupta Builders and Developers, Mumbai vs. Asst. Commissioner of Income Tax Central Circle 4(3), Mumbai

Appeal of the assessee is allowed

ITA 4361/MUM/2025[2015-16]Status: DisposedITAT Mumbai03 Sept 2025AY 2015-16

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Ms. Ritika Agarwal, Advocate
Section 133ASection 143(1)Section 148Section 148ASection 151Section 250Section 68

section 151 of the Act. Without Prejudice, 3. BECAUSE, the impugned assessment order is bad in law since the reasons for reopening of assessment are recorded solely on "suspicion" without bringing on record any tangible material. 4. BECAUSE the CIT(A) has erred upholding that the reopening of the assessment ... Granth Exim Pvt. Ltd. which as per survey report was found to be a bogus party. Accordingly, the Assessing Officer (AO) reopened the assessment vide notice dated 31.03.2021 under section 148 of the Act. After perusal of details furnished by the assessee, the AO treated the loan as unexplained under

Aggarwal Abhushan Private Limited, Delhi vs. DCIT Circle 1(1), Delhi/National Faceless Appeal Centre Delhi, New Delhi

In the result, the appeal of the assessee is allowed

ITA 712/DEL/2025[2016-17]Status: DisposedITAT Delhi03 Sept 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri Sudhir Kumaraggarwal Abhushan Vs. Dcit Circle-1(1), Delhi/ Private Limited, National Faceless Appeal B-5/153, Sector-7, Centre, Delhi-110002 Rohini, Delhi-110085

For Appellant: Ms. Meenal Goyal, Adv. &For Respondent: Shri Om Prakash, Sr. DR
Section 147Section 148Section 148ASection 149

barred by limitation. Accordingly, the Additional grounds raised by the assessee are allowed. 7. Since, reopening of assessment has been quashed hereinabove, the adjudication of the other original grounds raised by the assessee becomes academic in nature and they are left open. 8. In the result, the appeal

Ap Goyal Charitable Trust, East Delhi, Delhi India vs. ITO, Civic Centre, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1941/DEL/2025[2014-15]Status: HeardITAT Delhi03 Sept 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshap Goyal Charitable Trust, Vs. Ito, Ward B-125, Anand Vihar, Exempt-1(1), East Delhi, Delhi-110092 Delhi, Civic Centre, Delhi-110002 (Appellant) (Respondent) Pan: Aabta8575B

For Appellant: Shri Nitin Kanwar, AdvocateFor Respondent: Shri Sahil Kumar Bansal, Sr. DR
Section 12ASection 132Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 151

barred by limitation. Accordingly, Ground Nos. 1 to 5 raised by the assessee are allowed. 12. Since, reopening of assessment has been quashed, the adjudication of the other grounds raised by the assessee becomes academic in nature and they are left open. 13. In the result, the appeal

DCIT Central Circle 1(1) Ahmedabad, Ahmedabad vs. Mahendrakumar Chunilal Sanghvi, Ahmedabad

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 1351/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2021-22

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 147Section 148Section 148ASection 149Section 69C

appearing for the assessee submitted before us a Paper Book and case laws in support of his arguments. Ld. Counsel submitted that the reopening of assessment for the Asst. Year 2017-18 is done after three years. As I.T.A No. 1267/Ahd/2024 A.Y. 2017-18 Page No 3 Mahendrakumar Chunilal Sanghvi

Bees Infracon Private Limited, Ahmedabad vs. Income Tax Officer, Ward1(1)(2), Ahmedabad

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

ITA 1283/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143Section 143(3)Section 148Section 2Section 2(22)(e)

escaped assessment and therefore a notice u/s.148 of the Act was issued on the assessee on 26-03- 2018. The assessee objected the reopening of assessment and clarified that the loan obtained from sister concern M/s. Sunburg was purely business purposes and part of the loan also repaid during

Mahendrakumar Chunilal Sanghvi, Mumbai vs. DCIT CC 1(1) Ahmedabad, Ahmedabad

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 1267/AHD/2024[2017-2018]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2017-2018

Bench: or at the time of hearing of the appeal."

Section 147Section 148Section 148ASection 149Section 69C

appearing for the assessee submitted before us a Paper Book and case laws in support of his arguments. Ld. Counsel submitted that the reopening of assessment for the Asst. Year 2017-18 is done after three years. As I.T.A No. 1267/Ahd/2024 A.Y. 2017-18 Page No 3 Mahendrakumar Chunilal Sanghvi

Sportking India Ltd., New Delhi vs. JCIT, Circle-9(1), New Delhi

The appeal of the assessee is allowed as above

ITA 2223/DEL/2018[2006-07]Status: DisposedITAT Delhi01 Sept 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 115JSection 143(3)Section 147Section 148Section 151Section 250

dismissed the appeal vide order dated 28.02.2013. wherein the proceedings were adjudicated vide order dated 28.02.2013, wherein grounds challenging the validity of reopening of assessment under section 148 of the Act was dismissed as withdrawn and other grounds were decided against the appellant assessee. 3 Sportking India Ltd. 3.1 Aggrieved ... remanded appellate proceeding, the Ld. CIT(A) did not decide the issue of sufficiency of reasons recorded by the AO for reopening the assessment and its approval thereof under section 151 of the Act on the reasoning that the assessee had withdrawn the said ground of appeal earlier; hence, this

Abdulkadar Hajiahmed Vadiwala, Jamnagar vs. Pr. Commissioner of Income Tax, Jamnagar

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

ITA 103/RJT/2025[2016-17]Status: DisposedITAT Rajkot29 Aug 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.103/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2016-17 Abdulkadar Hajiahmed Vadiwala The Pr.Cit बनाम Maniar Street, Lindi Bazar Jamanagar. Jamnagar-361001 Vs. Pan : Aatpv 4729 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

For Appellant: Shri Chetan Agarwal, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 143(3)Section 147Section 148Section 151Section 263

before going into merits of issues raised by your honour in notice u/s.263 of the Act, at the outset we submit that the reopening of assessment u/s.147 is bad in law and void ab initio, hence, once the reopening of assessment and consequent assessment order ... issuing a notice under section 148. The purpose behind this procedural check is to save the assesses from harassment resulting from the mechanical reopening of assessments. A table representing the prescription under the old and new regime is set out below: 74. The above table indicates that the specified authority

Deputy Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Kag India Private Limited, Velachery

ITA 632/CHNY/2025[2021-22]Status: DisposedITAT Chennai29 Aug 2025AY 2021-22

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

assessment for the A.Y.2014-15 is unabated as on the date of search. We have carefully considered the rival submissions and find that the reopening of assessment u/s.147 of the Act on being approved by the JCIT of an assessment which is passed after the approval of the JCIT ITA No.322

Deputy Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Kag India Private Limited, Chennai

ITA 325/CHNY/2025[2018-19]Status: DisposedITAT Chennai29 Aug 2025AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

assessment for the A.Y.2014-15 is unabated as on the date of search. We have carefully considered the rival submissions and find that the reopening of assessment u/s.147 of the Act on being approved by the JCIT of an assessment which is passed after the approval of the JCIT ITA No.322

Deputy Commissioner of Income Tax, Chennai vs. Kag India Private Limited, Chennai

ITA 324/CHNY/2025[2017-18]Status: DisposedITAT Chennai29 Aug 2025AY 2017-18

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

assessment for the A.Y.2014-15 is unabated as on the date of search. We have carefully considered the rival submissions and find that the reopening of assessment u/s.147 of the Act on being approved by the JCIT of an assessment which is passed after the approval of the JCIT ITA No.322