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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

M/S. Bna Commerce Pvt. Ltd., Kolkata vs. ITO, Ward 5(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 155/KOL/2025[2014-15]Status: DisposedITAT Kolkata21 May 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Sunil Surana, FCAFor Respondent: Shri Ankur Goyal, DR
Section 132Section 143(3)Section 144BSection 147Section 148

above income of the assessee has escaped assessment within the meaning of provisions of sec. 147 of the I.T. Act, 1961." 06. Therefore, reopening of assessment beyond four years has been made in violation of first proviso to Section 147 of the Act which provides that where assessment has been ... framed u/s 143(3) of the Act, no reopening of assessment can be made u/s 147 of the Act if there is no failure on the part of the assessee to disclose fully and truly all material facts qua the assessment of income. On perusal of the reasons recorded

M/S. Bna Commerce Pvt. Ltd., Kolkata vs. ITO, Ward 5(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 154/KOL/2025[2013-14]Status: DisposedITAT Kolkata21 May 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Sunil Surana, FCAFor Respondent: Shri Ankur Goyal, DR
Section 132Section 143(3)Section 144BSection 147Section 148

income of the assessee has escaped assessment within the meaning of provisions of sec. 147 of the 1.T. Act, 1961.” 06. Therefore, reopening of assessment beyond four years has been made in violation of first proviso to Section 147 of the Act which provides that where assessment has been ... framed u/s 143(3) of the Act, no reopening of assessment can be made u/s 147 of the Act if there is no failure on the part of the assessee to disclose fully and truly all material facts qua the assessment of income. On perusal of the reasons recorded

Vinkas Estates Pvt. Ltd., Kolkata vs. DCIT, Cir. 9(2), Kolkata

In the result, both appeals of the assessee are allowed

ITA 451/KOL/2024[2010-11]Status: DisposedITAT Kolkata21 May 2025AY 2010-11

Bench: Shri George Mathan & Shri Sanjay Awasthi

For Appellant: None (Adjournment letter filed)For Respondent: Ms. Monalisa Pal Mukherjee, Sr. DR
Section 133(6)Section 142(1)Section 143(1)Section 147Section 148

asked for some information/documents related to the sale of property/land. All the papers/ documents as required were duly submitted. Later on, the A.O. reopened the assessment and initiated the proceedings u/s 147 without serving any notice u/s 148. The A.O. did not provide any reason for reopening of the assessment ... issued notice u/s 142(1). The appellant asked the A.O. to provide the reason for reopening of assessment and raised its objection on the reopening. Time and again assessee raised its objection. But the Ld. A.O. did not reply to the objection raised nor passed any comment or order

Vinkash Estates Pvt. Ltd., Kolkata vs. DCIT, Cir. 9(2), Kolkata

In the result, both appeals of the assessee are allowed

ITA 450/KOL/2024[2011-12]Status: DisposedITAT Kolkata21 May 2025AY 2011-12

Bench: Shri George Mathan & Shri Sanjay Awasthi

For Appellant: None (Adjournment letter filed)For Respondent: Ms. Monalisa Pal Mukherjee, Sr. DR
Section 133(6)Section 142(1)Section 143(1)Section 147Section 148

asked for some information/documents related to the sale of property/land. All the papers/ documents as required were duly submitted. Later on, the A.O. reopened the assessment and initiated the proceedings u/s 147 without serving any notice u/s 148. The A.O. did not provide any reason for reopening of the assessment ... issued notice u/s 142(1). The appellant asked the A.O. to provide the reason for reopening of assessment and raised its objection on the reopening. Time and again assessee raised its objection. But the Ld. A.O. did not reply to the objection raised nor passed any comment or order

Suvidhi Gold Private Limited, Ahmedabad vs. Deputy Commissioner of Income Tax Central Circle 3(2) Kolkata, Kolkata

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

ITA 2120/KOL/2024[2015-16]Status: DisposedITAT Kolkata21 May 2025AY 2015-16

Bench: us, the Ld. AR pointed out the chronology of event through detailed submissions filed for the purpose of assisting the Bench. He reiterated the fact that ultimately the notice u/s 148 of the Act was issued beyond the time prescribed for issuing such notice. 2.2 The Ld. DR relied on the orders of authorities below.

Section 148Section 148ASection 149Section 250

cases where income that escaped assessment amounts to ₹50 lakhs or more, assessments can be reopened within ten years. The new regime prohibits reopening of assessments that were time-barred under the old regime. The provisions of section 149 of the new regime are as under: 149. (1) No notice

Alka Sand, Faridabad vs. ITO Ward 1(1) Faridabad, Faridabad

The appeal of the assessee is allowed

ITA 5615/DEL/2024[2013-14]Status: DisposedITAT Delhi21 May 2025AY 2013-14

Bench: Ms. Madhumita Royalka Sand Vs. Ito, Ward 1(1) C/O, Ca Mr Sahu, House C R Building No. 651, 1St Floor, Faridabad 121001 Sector-10A, Nr. Gd Haryana Goenka Public School Gurgaon – 122001 Haryana "थायीलेखासं./जीआइआरसं./Pan/Gir No: Arips8647N Appellant .. Respondent

For Appellant: Sh. M.R. Sahu, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 44A

Alka Sand (AY: 2013-14) appearing for the assessee that by and under a representation dated 22.12.2021 the assessee raised objection against the reopening of assessment on the ground of notice under Section 148 of the Act having been issued without jurisdiction, barred by limitation, bad in law, illegal ... invalid. Further that the assessee categorically requested for a copy of the reason recorded by the Ld. AO for reopening of assessment along with the copy of the standard format wherein the approval of the higher authorities was obtained and further that the copy of the statement/material relied upon

Nakul Singh, Uttar Pradesh vs. ITO, Ward -2(2)(5), Uttar Pradesh

The appeal of the assessee is allowed

ITA 5323/DEL/2024[2012-13]Status: DisposedITAT Delhi21 May 2025AY 2012-13

Bench: Ms. Madhumita Roynakul Singh Vs. Ito, Ward 2(2)(5) House No. 100, Penga-1, House No. 100, Penga-1 Penga Modinagar, Penga Modinagar Dist. Ghaziabad Dist. Ghaziabad Uttar Pradesh – 201204 Uttar Pradesh – 201204 "थायीलेखासं./जीआइआरसं./Pan/Gir No:Dqmps3893G Appellant .. Respondent

For Appellant: Sh. Shantanu Kanungo, Adv &For Respondent: Sh. Sanjay Kumar, Sr. DR
Section 133(6)Section 143(2)Section 144Section 148

assessee the same were not considered. However, as the same was not part of the reason recorded by the AO for reopening of assessment, the assessment is without jurisdiction and thus, liable to be set aside. 6. We have heard the rival submissions made by the respective parties ... been Rs.64,00,000/- which further establishes the fact of non-application of mind by the Ld. AO while recording the reason for reopening of assessment and further approval granted by the Ld. PCIT, Ghaziabad. 8. Thus, having regard to the entire aspect of the matter the addition made

Goel Pawan Kumar & Family (HUF), Sonipat vs. Income Tax Officer, New Delhi

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

ITA 5252/DEL/2024[2012-13]Status: DisposedITAT Delhi21 May 2025AY 2012-13

Bench: Shris.Rifaur Rahman

For Appellant: Shri Roshan Kumar, AdvocateFor Respondent: Shri B.S. Anand, Sr. DR
Section 143Section 147Section 148

material or any additional evidences to support his case. - 4. Aggrieved assessee is in appeal before us raising following grounds of appeal:- - "1. Reopening of Assessment is Invalid and Without Jurisdiction: That the LD. [CIT(A)] erred in law and on facts in upholding the reopening of the assessment under

Chetan Prabhakar, New Delhi vs. ITO Ward 41(5), New Delhi

In the result, impugned order is set aside and appeal of the assessee is allowed

ITA 3194/DEL/2024[2010-11]Status: DisposedITAT Delhi21 May 2025AY 2010-11

Bench: SHRI VIKAS AWASTHY (Judicial Member)

For Appellant: Shri Abhishek Jain, Chartered Accountant and Ms. Sunidi Sharma, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR
Section 139(1)Section 148Section 151

filing return of income for AY 2010-11. The ld. AR further submitted that the Competent Authority who has granted approval for reopening of assessment has not examined the records and in a mechanical manner approved the proposal for reopening forwarded by the AO. In support of his submissions ... assessee further submitted that the assessee vide letter dated 18.11.2024 asked for reasons recorded for reopening the assessment, copy of approval u/s. 151 of the Income Tax Act,1961(hereinafter referred to as ‘the Act’), copy of notice issued u/s. 148 of the Act and copy of ITR filed

Vinod Kohli, Gurgaon vs. ACIT Circle 35(1), New Delhi

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

ITA 896/DEL/2021[2012 - 2013]Status: DisposedITAT Delhi21 May 2025

Bench: Shri S. Rifaur Rahman

For Appellant: Ms. Monalisa Maity, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 148Section 148(2)Section 292B

PROCEEDINGS IN THE GIVING FACTS ARE BAD IN LAW 1. The reasons recorded arc undated: It is submitted that the reasons recorded for reopening the assessment proceedings were undated. In this regard, kind attention is invited to...rage no. 4 of the assessment order dated 27.12.2019 whereunder the ld. Assessing ... addition is clearly non-sustainable. 3.2 In regard to the second property i.e. the property "Rajpur Residency, Dehradun" mentioned in the reasons for reopening, the Assessing Officer has wrongly determined the value of such property at Rs.7,20,000/- (page 2 of the assessment order). Whereas in the reasons recorded

Ajeet Kumar Rampuria, Tonk vs. ITO Ward 7(2), Tonk

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

ITA 44/JPR/2025[2013-14]Status: DisposedITAT Jaipur20 May 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sandeep Jhanwar, C.AFor Respondent: Sh. Anup Singh, Addl. CIT
Section 147Section 148Section 250

deciding the appeal against the assessee without appropriately considering the facts of the case. 2. Under the fact and circumstances of the case reopening of assessment under the provision of sec 147/148 and consequent the order passed by the Id. AO u/s147 is bad in law and deserves

DCIT, Circle-2(1)(1), Ahmedabad vs. Navnirman Co Op. Bank Ltd, Ahmedabad

In the result, the appeal of the Revenue is hereby dismissed

ITA 1974/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad20 May 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1974/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 The Dcit Navnirman Co-Op. Bank Ltd. बनाम/ Circle-2(1)(1) Navnirman Bhawan V/S. Ahmedabad – 380 015 Opp. Hdfc Bank Ahmedabad City Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aabfn 2975 L (अपीलाथ'/ Appellant) (!( यथ'/ Respondent) Assessee By : Shri Hem Chhajed, Ar Revenue By : Shri C. Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 13/05/2025 घोषणा की तारीख /Date Of Pronouncement: 20/05/2025

For Appellant: Shri Hem Chhajed, ARFor Respondent: Shri C. Dharani Nath, Sr.DR
Section 143(2)Section 147Section 148Section 68

being supervised by the Reserve Bank of India. Assessee requested Ld.Assessing Officer (AO) to provide the copy of documents relied upon for reopening of assessment and to provide cross examination. Ld.AO failed to provide any information. Even PAN of the party was also not provided. Assessee asked for cross-verification ... proceedings u/s 250, appellant submitted as under: DCIT vs. Navnirman Co-op. Bank Ltd. Asst. Year : 2017-18 1. Appellant submit that reopening of assessment u/s 148 is invalid and void ab initio as it has not followed the provisions and guidelines issued by board and rulings of judiciary

Jigneshkumar Jivrajbhai Patel, Ahmedabad vs. National Faceless Assessment Centre (NFAC), Delhi Present Jurisdiction the ITO, Ward-7(2)(1), Ahmedabad

In the result, all the captioned three appeals of the assessee are hereby allowed

ITA 1624/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad20 May 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha1. आयकर अपील सं /Ita No.1622/Ahd/2024 – Asst.Year 2013-14 2. आयकर अपील सं /Ita No.1623/Ahd/2024 – Asst.Year 2015-16 3. आयकर अपील सं /Ita No.1624/Ahd/2024 – Asst.Year 2016-17

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Amit Pratap Singh, Sr.DR
Section 143(1)(a)Section 148Section 148ASection 250

appellant. 4. In law and in the facts and circumstances of Appellant's case, the LD.CIT(A) ought to have appreciate that the reopening of assessments initiated with similar reasons of "alleged unaccounted receipt from M/s Kiran Gems Pvt. Ltd" for various other labor contractors associated with M/s Kiran Gems ... submitted to your office as required to be filed under the Act. (4) It is also further submitted that the letter of reopening the assessment proceedings for A.Y. 2013-14 issued u/s 147/148 has been done without verifying the records. placed by me on record with your office

Jigneshkumar Jivrajbhai Patel, Ahmedabad vs. National Faceless Assessment Centre(NFAC), Delhi Present Jurisdiction the ITO, Ward-7(2)(1), Ahmedabad

In the result, all the captioned three appeals of the assessee are hereby allowed

ITA 1623/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad20 May 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha1. आयकर अपील सं /Ita No.1622/Ahd/2024 – Asst.Year 2013-14 2. आयकर अपील सं /Ita No.1623/Ahd/2024 – Asst.Year 2015-16 3. आयकर अपील सं /Ita No.1624/Ahd/2024 – Asst.Year 2016-17

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Amit Pratap Singh, Sr.DR
Section 143(1)(a)Section 148Section 148ASection 250

appellant. 4. In law and in the facts and circumstances of Appellant's case, the LD.CIT(A) ought to have appreciate that the reopening of assessments initiated with similar reasons of "alleged unaccounted receipt from M/s Kiran Gems Pvt. Ltd" for various other labor contractors associated with M/s Kiran Gems ... submitted to your office as required to be filed under the Act. (4) It is also further submitted that the letter of reopening the assessment proceedings for A.Y. 2013-14 issued u/s 147/148 has been done without verifying the records. placed by me on record with your office

Jigneshkumar Jivrajbhai Patel, Ahmedabad vs. National Faceless Assessment Centre, Delhi Present Jurisdiction : the ITO, Ward-7(2)1), Ahmedabad

In the result, all the captioned three appeals of the assessee are hereby allowed

ITA 1622/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad20 May 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha1. आयकर अपील सं /Ita No.1622/Ahd/2024 – Asst.Year 2013-14 2. आयकर अपील सं /Ita No.1623/Ahd/2024 – Asst.Year 2015-16 3. आयकर अपील सं /Ita No.1624/Ahd/2024 – Asst.Year 2016-17

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Amit Pratap Singh, Sr.DR
Section 143(1)(a)Section 148Section 148ASection 250

appellant. 4. In law and in the facts and circumstances of Appellant's case, the LD.CIT(A) ought to have appreciate that the reopening of assessments initiated with similar reasons of "alleged unaccounted receipt from M/s Kiran Gems Pvt. Ltd" for various other labor contractors associated with M/s Kiran Gems ... submitted to your office as required to be filed under the Act. (4) It is also further submitted that the letter of reopening the assessment proceedings for A.Y. 2013-14 issued u/s 147/148 has been done without verifying the records. placed by me on record with your office

Ushasree Bandaru, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

In the result, appeals filed by the assessee are allowed

ITA 529/HYD/2024[2016-17]Status: DisposedITAT Hyderabad20 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.528/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2016-17) Satyasree Kamineni Vs. Dy.Commissioner Of Hyderabad Income Tax [Pan :Adopk6338C] Circle-5(1) Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.529/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2016-17) Ushasree Bandaru Vs. Dy.Commissioner Of Hyderabad Income Tax [Pan :Acepb2973M] Circle-5(1) Hyderabad निर्धाररती द्वधरध/Assessee By: Shri K.C.Devdas, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 01/05/2025 घोर्णध की तधरीख/ 21/05/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Two Appeals Filed By The Two Related Assessees Are Directed Against Two Separate Orders Of Principal Commissioner Of Income Tax (“Ld.Pcit”) Both Dated 26.03.2024 Passed U/S 263 The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2016-17. Identical Grounds Have Been Raised By Both The Assessees. The Grounds Raised In The Ita No.528/Hyd/2024 Are Reproduced As Under :

For Appellant: Shri K.C.Devdas, ARFor Respondent: Shri B.Bala Krishna, CIT-DR
Section 142(1)Section 147Section 148Section 263Section 56(2)(vii)

Ld.PCIT is not sustainable in law and liable to be quashed. 6. On the other hand, Ld.DR has submitted that the assessment was reopened to assess income escaped on account of shares purchased by the assessee against inadequate consideration in comparison to the fair market value of the shares ... impugned order of the Ld.PCIT. 7. We have considered the rival submissions as well as the relevant material on record. The AO reopened the assessment for the year under consideration by issuing notices u/s 148 on 31.03.2021 recording the reasons for reopening of assessment reproduced in para No.2 as under

Satyasree Kamineni, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

In the result, appeals filed by the assessee are allowed

ITA 528/HYD/2024[A.Y.2016-17]Status: DisposedITAT Hyderabad20 May 2025

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.528/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2016-17) Satyasree Kamineni Vs. Dy.Commissioner Of Hyderabad Income Tax [Pan :Adopk6338C] Circle-5(1) Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.529/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2016-17) Ushasree Bandaru Vs. Dy.Commissioner Of Hyderabad Income Tax [Pan :Acepb2973M] Circle-5(1) Hyderabad निर्धाररती द्वधरध/Assessee By: Shri K.C.Devdas, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 01/05/2025 घोर्णध की तधरीख/ 21/05/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Two Appeals Filed By The Two Related Assessees Are Directed Against Two Separate Orders Of Principal Commissioner Of Income Tax (“Ld.Pcit”) Both Dated 26.03.2024 Passed U/S 263 The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2016-17. Identical Grounds Have Been Raised By Both The Assessees. The Grounds Raised In The Ita No.528/Hyd/2024 Are Reproduced As Under :

For Appellant: Shri K.C.Devdas, ARFor Respondent: Shri B.Bala Krishna, CIT-DR
Section 142(1)Section 147Section 148Section 263Section 56(2)(vii)

Ld.PCIT is not sustainable in law and liable to be quashed. 6. On the other hand, Ld.DR has submitted that the assessment was reopened to assess income escaped on account of shares purchased by the assessee against inadequate consideration in comparison to the fair market value of the shares ... impugned order of the Ld.PCIT. 7. We have considered the rival submissions as well as the relevant material on record. The AO reopened the assessment for the year under consideration by issuing notices u/s 148 on 31.03.2021 recording the reasons for reopening of assessment reproduced in para No.2 as under

Sabita Gupta, Bahadurgarh vs. ITO, Ward-2, Rohtak

In the result, appeal of the assessee is partly allowed for statistical purpose in the terms aforesaid

ITA 2897/DEL/2024[2016-17]Status: DisposedITAT Delhi20 May 2025AY 2016-17

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

For Appellant: Ms. Rano Jain, Ms. Mansi Jain & Ms Sakshi Rustogi, AdvocatesFor Respondent: Shri Manish Gupta, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 69A

pressing grounds of appeal no. 2 to 5 and 7. The assessee in the aforesaid grounds had raised legal issues challenging reopening of assessment. In the light of statement made by ld. Counsel for the assessee, grounds of appeal no. 2 to 5 and 7 are dismissed as not pressed

DCIT, Circle-2(1), Hyderabad vs. Ingenerie Technologies Solutions Private Limited, Hyderabad

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

ITA 837/HYD/2024[2016-17]Status: DisposedITAT Hyderabad19 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: MS Hema Murali Krishnan, AdvocateFor Respondent: Shri Narender Kumar Naik, CIT-DR
Section 147Section 148Section 68Section 69A

Rajeev Bansal (2024) 469 ITR 46 (SC) submitted that, if any notice issued after 01st April, 2021, the Competent Authority for sanctioning of reopening of assessment is Principal Chief Commissioner or Chief Commissioner. Further, the same 11 ITA.No.837/Hyd./2024 has not been done and the sanction was obtained from

Vdr Consultants Pvt. Ltd., Kolkata vs. ITO, Ward 11(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 338/KOL/2025[2015-16]Status: DisposedITAT Kolkata19 May 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito, Ward 11(1) Vdr Consultants Pvt. Ltd. Kolkata 401, Ashok Road, Near Kings Aaykar Bhavan, P-7, Bakery, Ganguly Bagan, Vs. Chowringhee Square, Kolkata-700084, West Bengal Kolkata-700069 West Bengal (Appellant) (Respondent) Pan No. Aaacv8920H Assessee By : Shri Devesh Poddar, Ar Revenue By : Ms. Ranu Biswas, Dr Date Of Hearing: 13.05.2025 Date Of Pronouncement : 19.05.2025

For Appellant: Shri Devesh Poddar, ARFor Respondent: Ms. Ranu Biswas, DR
Section 143(1)Section 147Section 148

Considering all these facts and also legal infirmity in issuing the notice u/s 148 of the Act, we are inclined to quash the reopening of assessment as well as the assessment framed by the ld. Assessing Officer. VDR Consultants Pvt. Ltd.; A.Y. 2015-16 010. In the result, the appeal