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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

Bhikhalal Prahaladrai Agarwal HUF, Gandhidham vs. Assistant Commissioner of Income Tax, Gandhidham Circle, Gandhidham

ITA 780/RJT/2024[2016-17]Status: DisposedITAT Rajkot21 Aug 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

assessee carried the matter in appeal before the Ld. CIT(A), who has confirmed the action of the Assessing Officer. So far reopening of assessment is concerned, the ld. CIT(A) observed that no any non-compliance with the procedural ITA Nos.779&780/RJT/2024/AYs.2011-12&2016-17 Bhikhalal Prahladrai Agarwal-HUF aspects ... assessee is in further appeal before us. 7. Shri Vimal Desai, Ld. Counsel for the assessee, submitted that reopening of assessment in the case of the assessee for assessment year (A.Y.) 2011- 12 is bad in law. The ld. Counsel took us through the reasons recorded by the Assessing Officer

Bhikhalal Prahladrai Agarwal HUF, Gandhidham vs. Assistant Commissioner of Income Tax Gandhidham Circle, Gandhidham

ITA 779/RJT/2024[2011-12]Status: DisposedITAT Rajkot21 Aug 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

assessee carried the matter in appeal before the Ld. CIT(A), who has confirmed the action of the Assessing Officer. So far reopening of assessment is concerned, the ld. CIT(A) observed that no any non-compliance with the procedural ITA Nos.779&780/RJT/2024/AYs.2011-12&2016-17 Bhikhalal Prahladrai Agarwal-HUF aspects ... assessee is in further appeal before us. 7. Shri Vimal Desai, Ld. Counsel for the assessee, submitted that reopening of assessment in the case of the assessee for assessment year (A.Y.) 2011- 12 is bad in law. The ld. Counsel took us through the reasons recorded by the Assessing Officer

Aamya Resources LLP, Andheri East vs. ITO, Ward 24(1)(1) Mumbai, Mumbai

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

ITA 4423/MUM/2025[2016-17]Status: DisposedITAT Mumbai21 Aug 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Om Prakash Kantvs. Ito, Ward 24(1)(1) Aamya Resources Llp Piramal Chamber, 1, Wilson House, Old Mumbai – 400012. Nagardas Road, Andheri (E), Mumbai – 400069. Pan/Gir No. Abcfa4651A (Applicant) (Respondent) Assessee By Shri Satish Aggarwal (Virtually Appear) Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 21.08.2025 Date Of Pronouncement 24.09.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 11.10.2019 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 2015- 16. 2. Although, Assessee Had Raised Number Of Grounds In The Present Appeal But At The Outset Ld. Ar Pressed Ground No.4 Which Is Legal In Question & It Goes To The Roots Of The Case. Therefore, We Have Decided To Adjudicate This Ground Firstly, Ground No. 4, Which Is Reproduced Herein Below:

Section 148Section 149Section 151Section 250Section 3(1)

case of Union of India Vs. Rajeev Bansal 167 taxmann.com 70 and in confirming the action of the Ld. Ld.AO in reopening the assessment despite the approval / sanction for issue of notice u/s 148 of the Act not having in consonance with the provisions ... This ground raised by the assessee relates to challenging the order of Ld. CIT(A) in confirming the action of AO in reopening the assessment despite the approval / sanction for issuance of notice u/s 148 of the Act. Not having in consonance with the provisions

Tuffwud India Private Limited, Bangalore vs. DCIT, Circle-7(1)(1), Bangalore

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

ITA 571/BANG/2025[2015-16]Status: DisposedITAT Bangalore20 Aug 2025AY 2015-16

Bench: Shri George George K & Shri Soundararajan Kassessment Year: 2015-16

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Muthu Shankar, CIT (DR)
Section 148Section 151Section 153CSection 234ASection 250Section 68Section 69C

under vide dated 17.03.2025 “1. The assessment order framed in accordance with the TOLA provisions is invalid as the notice issued for reopening of assessment for the impugned year does not fall for completion during the period prescribed under TOLA and accordingly TOLA is not applicable for the impugned year

Sunshine Technobuild Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

Accordingly ground no. 1 raised by the assessee stands allowed

ITA 592/MUM/2025[2011-12]Status: DisposedITAT Mumbai20 Aug 2025AY 2011-12

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

Section 132Section 132(4)Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 151Section 153ASection 153C

Income Tax Act after taking an approval from Pr. CIT 8, Mumbai which was only a technical approval without recording of satisfaction for reopening of assessment which is against the provisions of section 151 of the Act. any 2. On the basis of an invalid and void ab initio notice

Satbir Sharma, Panipat vs. Income Tax Officer, Panipat

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

ITA 4020/DEL/2025[2012-13]Status: DisposedITAT Delhi20 Aug 2025AY 2012-13

Bench: Shri M. Balaganeshsatbir Sharma, Vs. Ito, H. No. 40/13, Bhatnagar Ward-4, Panipat, Gali, Samalkha Distt. Haryana Panipat, Panipat, Haryana Pan: Csbps0914A Assessee By : Shri Manoj Kumar, Adv Revenue By: Shri Manoj Kumar, Sr. Dr Date Of Hearing 11/08/2025 Date Of Pronouncement 20/08/2025

For Appellant: Shri Manoj Kumar, AdvFor Respondent: Shri Manoj Kumar, Sr. DR
Section 174

raised by the assessee on merits are allowed for statistical purposes. 5. The other grounds raised by the assessee challenging the validity of reopening of assessment are also restored to the file of ld CITA. The assessee is given liberty to file additional grounds and additional evidences

Income Tax Officer, Ward-20(3), Delhi, New Delhi vs. Rmp Holdings Pvt Ltd, New Delhi

In the result the appeal of the Revenue is dismissed

ITA 1002/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Aug 2025AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Ito, Vs. Rmp Holdings Pvt. Ltd. New Delhi 138-C, Block -B Group -4 Dilshad Garden New Delhi Pan No.Aaacr5533N (Appellant) (Respondent)

Section 132Section 143Section 147Section 148Section 148ASection 151Section 68

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 Sri krishna (P.) Ltd. v. ITO [1996] 87 Taxman 315/221 ITR 538 (SC)/[1996] 9 SCC 534. A table representing the prescription under

Sunanda Constructions, Pune vs. DCIT, Central Circle 2(2), Pune

In the result, both the appeals filed by the assessee are allowed

ITA 784/PUN/2025[2013-14]Status: DisposedITAT Pune19 Aug 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajendra AgiwalFor Respondent: Shri Akhilesh Srivastva, Addl.CIT
Section 132

therefore, reopened case of the assessee by recording the following reasons: “Vide letter dated 22/03/2022, you have requested for reasons recorded for reopening of assessment. The same are reproduced as under: 1. Brief details of the Assessee: The Assessee is a partnership firm carries out business activity of builder ... allowed. 14. The Ld. DR on the other hand heavily relied on the order of the Ld. CIT(A). He submitted that the reopening of assessment was made on account of wrong claim of interest expenditure. The Assessing Officer in the order passed u/s 143(3) r.w.s. 147 has disallowed

Sunand Constructions, Pune vs. DCIT Central Circle 2(2), Pune

In the result, both the appeals filed by the assessee are allowed

ITA 783/PUN/2025[2014-15]Status: DisposedITAT Pune19 Aug 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajendra AgiwalFor Respondent: Shri Akhilesh Srivastva, Addl.CIT
Section 132

therefore, reopened case of the assessee by recording the following reasons: “Vide letter dated 22/03/2022, you have requested for reasons recorded for reopening of assessment. The same are reproduced as under: 1. Brief details of the Assessee: The Assessee is a partnership firm carries out business activity of builder ... allowed. 14. The Ld. DR on the other hand heavily relied on the order of the Ld. CIT(A). He submitted that the reopening of assessment was made on account of wrong claim of interest expenditure. The Assessing Officer in the order passed u/s 143(3) r.w.s. 147 has disallowed

Aha Holdings Private Limited, Mumbai vs. Circle 6(1)(1), Mumbai

In the result, appeal is allowed as indicated above

ITA 1340/MUM/2025[2016-2017]Status: DisposedITAT Mumbai19 Aug 2025AY 2016-2017

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Aha Holdings Pvt. Ltd., Circle 6(1)(1), Unit No.404, New Udyog Mandir No.2 Aaykar Bhavan, Mogul Lane, Mahim West, Maharishi Karve Road, Vs. Mumbai-400016 New Marine Lines, Mumbai 400020 (Appellant) : (Respondent) Pan No. Aafcs 6404E Appellant By : Shri K. Gopal & Ms. Neha Paranjpe Respondent By : Shri Rajesh Kumar Yadav, (Cit- Dr) (Appellant) (Respondent) Date Of Hearing : 11.08.2025 Date Of Pronouncement : 19.08.2025

For Appellant: Shri K. Gopal & Ms. Neha ParanjpeFor Respondent: Shri Rajesh Kumar Yadav, (CIT- DR)
Section 133ASection 147Section 263

short-term capital loss. 10. Before us, learned counsel appearing for the assessee drew attention to the reasons recorded for reopening of assessment and submitted that the reopening was made on the allegation of escapement of income from chargeability to tax of an amount of Rs.4,78,92,404/- being ... expenditure incurred of Rs.1,80,68,937/- towards project written off should have been disallowed. 13. Based on the aforesaid reasoning, the AO reopened the assessment u/s. 147 of the Act and called for necessary details from the assessee. In response, the assessee furnished requisite details. After examining the details

Sri Dhrub Narayan Parihast, Deoghar vs. ITO, Ward-3(1), Deoghar

In the result, appeal of the assessee stands allowed

ITA 51/RAN/2020[2009-10]Status: DisposedITAT Ranchi18 Aug 2025AY 2009-10

Bench: S/ S/Hri George Mathan & Ratnesh Nandan Sahayratnesh Nandan Sahayratnesh Nandan Sahayassessment Year : 2009-2010 Sri Dhrub Narayan Parihast, Sri Dhrub Narayan Parihast, Vs. Income Tax Office, Ward- Income Tax Office, Ward S/O. S/O. Shri Shri Deo Deo Narayan Narayan 3(1), Deoghar Parihast, Parihast, Dhanuk Dhanuk Tola, Tola, Jousagarhi, Deoghar. Jousagarhi, Deoghar. Pan/Gir No. .Bmrpp 9353 D (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Devesh Poddar, Adv Poddar, Adv Revenue By : Shri Khub Chand Pandya,, Ld Sr Dr Revenue By , Ld Sr Dr Date Of Hearing : 18/08/202 2025 Date Of Pronouncement : 18/08/2 2025 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Ord This Is An Appeal Filed By The Assessee Against The Ord Cit(A), Cit(A), Dhanbad Dhanbad Dated 19.9.2019 In Appeal No.Cit(A),Dhanbad/10147/2016 Dhanbad/10147/2016-17 For The Assessment Year For The Assessment Year 2009-2010. 2. Shri Devesh Poddar, Shri Devesh Poddar, Ld Ar Appeared For The Assessee. Shri Appeared For The Assessee. Shri Khub Chand Pandya, Ld Sr Dr Ld Sr Dr Represented On Behalf Of The Revenue. Represented On Behalf Of The Revenue.

For Appellant: Shri Devesh Poddar, AdvFor Respondent: Shri Khub Chand Pandya,, ld Sr DR
Section 148

Jurisdictional High Court has quashed the identical reasons recorded for P a g e 6 | 9 Assessment Year : 2009-2010 reopening of assessment in assessee’s mother case, the impugned reasons recorded are liable to be quashed. 6. In reply, ld Sr DR vehemently supported the order ... present case clearly shows that the assessee was working as “Head Pujari” in Shiv Temple during the impugned period. The Assessing Officer has reopened the assessment on the basis of investigation report. The Hon’ble Jurisdictional High Court has in the case of assessee’s mother quashed the reopening

Jigar Industries, Jamwadi vs. Income Tax Officer, Rajkot

In the result, question is decided against the Revenue

ITA 405/RJT/2025[2010-11]Status: DisposedITAT Rajkot18 Aug 2025AY 2010-11
For Appellant: Shri R.B. Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr-DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

matter in appeal before Ld.CIT(A), who has confirmed the action of the Assessing Officer. The Ld.CIT(A), on technical issue of reopening of assessment under section 147/148 of the Act, held that the case was reopened on the basis of tangible information received by the assessing officer indicating unaccounted ... assessee is in appeal before us. 10. Learned Counsel for the assessee raised technical issue in ground No.1, in appeal memo, regarding reopening of assessment, which was made merely based on the notice of Excise Department. The learned Counsel stated that reopening of assessment was made by the assessing officer

Binalben Pinkeshbhai Naik, Na vs. Arivs.ITO, Ward-1, Navsari

ITA 1061/SRT/2024[2012-13]Status: DisposedITAT Surat18 Aug 2025AY 2012-13

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT

Dakshaben Ajitbhai Desai, Surat vs. ITO, Ward 2(3)(1), Surat

ITA 1060/SRT/2024[2012-13]Status: DisposedITAT Surat18 Aug 2025AY 2012-13

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपीलसं./Ita No. 1059/Srt/2024 (निर्धारण वर्ष / Assessment Year: (2012-13) Anilbhai Desai 87, Brahman Faliya, Udhna Kharwasa Road, Dindoli, Surat – 394210 Vs. Income Tax Officer, Ward 2(3)(1), Surat स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Gcbpd0303J (Appellant) (Respondent) आयकर अपीलसं./Ita No. 1060/Srt/2024 (निर्धारण वर्ष / Assessment Year: (2012-13) Dakshaben Ajitbhai Desai Income Tax Officer, Ward 87, Brahman Faliyu, Dindoli, Choryasi. Surat – 394 210 Vs. 2(3)(1), Surat स्थायी लेखासं./जीआइआरसं./Pan/Gir No.: Ayspd 0711F (Appellant) (Respondent) आयकर अपीलसं./Ita No. 1061/Srt/2024 (निर्धारण वर्ष / Assessment Year: (2012-13) Binalben Pinkeshbhai Naik Vs. Income Tax Officer, Ward -1, 132/2 Zaveri Faliya, Kachhori Gandevi Navsari Navsari - 396445 स्थायी लेखासं./जीआइआरसं./Pan/Gir No.: Aftpn 6207 L (Appellant) (Respondent) Appellant By Respondent By Date Of Hearing Date Of Pronouncement : Shri Sapnesh R Sheth, Ca : Shri Ajay Uke, Ld. Sr. Dr : 05/08/2025 : 18/08/2025

IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT

M/S. Tafe Motors Amd Tractors Ltd., Chennai vs. DCIT, Corporate Circle-3(1), Chennai

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

ITA 1513/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Aug 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1511, 1512 & 1513/Chny/2025 िनधा"रण वष"/Assessment Years: 2010-11, 2017-18 & 2018-19 V. M/S.Tafe Motors & Tractors Ltd., The Dcit, New No.77, Old No.35, Corporate Cirlce-3(1), Pottipati Plaza, Chennai. Nungambakkam High Road, Nungambakkam, Chennai-600 034. [Pan: Aacct 2459 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 10(38)Section 143(2)Section 143(3)Section 147Section 148Section 35

1513/Chny/2025 (AYs 2010-11, 2017-18 & 2018-19) M/s.TAFE Motors & Tractors Ltd. :: 2 :: 1.1 NFAC CIT(A) ought to have held that reopening of Assessment by issue of Notice u/s 148 on 28.3.2017 beyond 4 years from the end of the Assessment year, without mentioning the omission on the part ... assessment u/s 143(3) 26.3.2013 was after examination of records and no fresh material has been found to support the reopening of assessment and hence the NFAC CIT(A) ought to have held that the reassessment is bad in law. 3. Brief facts are that the assessee is a company

M/S. Tafe Motors Amd Tractors Ltd., Chennai vs. DCIT, Corporate Circle-3(1), Chennai

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

ITA 1512/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Aug 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1511, 1512 & 1513/Chny/2025 िनधा"रण वष"/Assessment Years: 2010-11, 2017-18 & 2018-19 V. M/S.Tafe Motors & Tractors Ltd., The Dcit, New No.77, Old No.35, Corporate Cirlce-3(1), Pottipati Plaza, Chennai. Nungambakkam High Road, Nungambakkam, Chennai-600 034. [Pan: Aacct 2459 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 10(38)Section 143(2)Section 143(3)Section 147Section 148Section 35

1513/Chny/2025 (AYs 2010-11, 2017-18 & 2018-19) M/s.TAFE Motors & Tractors Ltd. :: 2 :: 1.1 NFAC CIT(A) ought to have held that reopening of Assessment by issue of Notice u/s 148 on 28.3.2017 beyond 4 years from the end of the Assessment year, without mentioning the omission on the part ... assessment u/s 143(3) 26.3.2013 was after examination of records and no fresh material has been found to support the reopening of assessment and hence the NFAC CIT(A) ought to have held that the reassessment is bad in law. 3. Brief facts are that the assessee is a company

M/S. Tafe Motors Amd Tractors Ltd., Chennai vs. DCIT, Corporate Circle-3(1), Chennai

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

ITA 1511/CHNY/2025[2010-11]Status: DisposedITAT Chennai18 Aug 2025AY 2010-11

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1511, 1512 & 1513/Chny/2025 िनधा"रण वष"/Assessment Years: 2010-11, 2017-18 & 2018-19 V. M/S.Tafe Motors & Tractors Ltd., The Dcit, New No.77, Old No.35, Corporate Cirlce-3(1), Pottipati Plaza, Chennai. Nungambakkam High Road, Nungambakkam, Chennai-600 034. [Pan: Aacct 2459 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 10(38)Section 143(2)Section 143(3)Section 147Section 148Section 35

1513/Chny/2025 (AYs 2010-11, 2017-18 & 2018-19) M/s.TAFE Motors & Tractors Ltd. :: 2 :: 1.1 NFAC CIT(A) ought to have held that reopening of Assessment by issue of Notice u/s 148 on 28.3.2017 beyond 4 years from the end of the Assessment year, without mentioning the omission on the part ... assessment u/s 143(3) 26.3.2013 was after examination of records and no fresh material has been found to support the reopening of assessment and hence the NFAC CIT(A) ought to have held that the reassessment is bad in law. 3. Brief facts are that the assessee is a company

Raj International Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Mumbai

ITA 6286/MUM/2024[2014-15]Status: DisposedITAT Mumbai18 Aug 2025AY 2014-15

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri K. Gopal Adv. & Ms. Neha
Section 143(3)Section 147Section 148Section 151ASection 250Section 69A

facts and in law, the learned CIT(A) National Faceless Appeal Centre (hereinafter referred to as 'CIT(A)'), erred in confirming the reopening of assessment under section 147 of the Income Tax Act, 1961 ('the Act'). 1.1 Under the facts and in law, the learned CIT(A) failed to consider ... fact that the reopening of assessment proceedings is bad in law, without jurisdiction and has no backing of the law. 1.2 Under the facts and in law, the learned CIT(A) erred in not considering the fact that the reopening is merely on the basis of change of opinion without

Raj International Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Mumbai

ITA 6285/MUM/2024[2013-14]Status: DisposedITAT Mumbai18 Aug 2025AY 2013-14

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri K. Gopal Adv. & Ms. Neha
Section 143(3)Section 147Section 148Section 151ASection 250Section 69A

facts and in law, the learned CIT(A) National Faceless Appeal Centre (hereinafter referred to as 'CIT(A)'), erred in confirming the reopening of assessment under section 147 of the Income Tax Act, 1961 ('the Act'). 1.1 Under the facts and in law, the learned CIT(A) failed to consider ... fact that the reopening of assessment proceedings is bad in law, without jurisdiction and has no backing of the law. 1.2 Under the facts and in law, the learned CIT(A) erred in not considering the fact that the reopening is merely on the basis of change of opinion without

Snowcem Paints Private Limited, Mumbai vs. Income Tax Officer, Nashik

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

ITA 2001/PUN/2024[2014-15]Status: DisposedITAT Pune14 Aug 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Prathamesh BorkarFor Respondent: Shri Akhilesh Srivastva
Section 147Section 148Section 148ASection 250Section 250(6)Section 69C

mail id could not 2 Snowcem Paints Private Limited be accessed. He further submitted that the assessee has raised grounds challenging the reopening of assessment proceedings and the validity of notice u/s.148 of the Act. 3. On the other hand, ld. Department submitted that the matter needs to be restored