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“reassessment proceedings”

ReassessmentSections 147-151Sections 147-1518,150 judgments

The decision most relied on for reassessment proceedings is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on reassessment proceedings

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

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.

ITO v. Lakhmani Mewal Das
103 ITR 437 · 1976 · Supreme Court
721
citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

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.

Ranbaxy Laboratories Ltd. v. CIT
336 ITR 136 · 2011 · High Court
398
citing judgments

In reassessment proceedings under Section 147/148, the Assessing Officer can assess other income not specified in the original notice if the initial ground for reopening assessment is found to be valid. However, if the income for which the assessment was initially reopened is found not to have escaped assessment, the Assessing Officer cannot proceed to assess any other income.

Judgments citing reassessment proceedings

Shyam Sunder, Gururgam vs. ITO ( Circle 4(1), Gurgram

In the result, the appeal of the assessee is dismissed

ITA 4779/DEL/2024[2011-12]Status: DisposedITAT Delhi31 Aug 2026AY 2011-12

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(2)Section 147Section 148Section 2Section 2(14)Section 54BSection 54F

taxability of the land sold and the consequent addition on account of long-term capital gains. 9.1 At the outset, we find that the reassessment proceedings were validly initiated under section 147 of the Act after due recording of reasons and obtaining the requisite approval. The notices under sections

Rakesh Palepu, Devarakonda vs. Income Tax Officer, Ward-1, Nalgonda

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

ITA 448/HYD/2025[2018-19]Status: DisposedITAT Hyderabad21 Aug 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri B. Sri Harsha, C.AFor Respondent: Ms. P. Sumitha, SR-DR
Section 139Section 144Section 147Section 148Section 148ASection 151

proceedings were initiated under Section 147 of the Act, and notice under Section 148 of the Act was issued to the assessee. During the reassessment proceedings, the Ld. AO noted total credits of Rs.3,28,14,586/- in the assessee’s bank account, for ITA No.448/Hyd/2025 4 which the assessee

Sreepathy Trust, Thrissur vs. Commissioner of Income Tax Cirle 1(1), Thrissur

In the result, both the captioned appeals are dismissed

ITA 66/COCH/2024[2016-2017]Status: DisposedITAT Cochin10 Aug 2026AY 2016-2017

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr AR
Section 12ASection 143(3)Section 148Section 68

income on 18.04.2018. Notices under Sections 143(2) and 142(1) were issued, to which the assessee complied by furnishing certain details. During the reassessment proceedings, the Assessing Officer (AO) specifically asked the assessee to furnish complete details of persons from whom loans or advances had been received. This included

Sreepathy Trust, Thrissur vs. CIT, Circle 1, Thrissur

In the result, both the captioned appeals are dismissed

ITA 65/COCH/2024[2013-14]Status: DisposedITAT Cochin10 Aug 2026AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr AR
Section 12ASection 143(3)Section 148Section 68

income on 18.04.2018. Notices under Sections 143(2) and 142(1) were issued, to which the assessee complied by furnishing certain details. During the reassessment proceedings, the Assessing Officer (AO) specifically asked the assessee to furnish complete details of persons from whom loans or advances had been received. This included

DCIT, New Delhi vs. Vishwanath Singhal, Delhi

In the result, the appeal of the revenue is dismissed

ITA 2028/DEL/2025[2018-19]Status: DisposedITAT Delhi31 Jul 2026AY 2018-19

Bench: Shri M. Balaganeshacit, Vs. Vishwanath Singhal, Circle-58(1), 40, Priya Enclave, Delhi Delhi Pan: Aasps988Ik Assessee By : Shri Neeraj Mangla, Ca Revenue By: Shri Manoj Kumar, Sr. Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 27/08/2025

For Appellant: Shri Neeraj Mangla, CAFor Respondent: Shri Manoj Kumar, Sr. DR
Section 10(38)Section 115BSection 133(6)Section 147Section 148Section 68

issuing notice under section 148 of the Act on 27-03-2022 after taking prior approval from the competent authority. In the reassessment proceedings, the learned AO noted that assessee had claimed exemption under section 10(38) of the Act amounting to Rs 28,91,775/- on account of long

Asstt. Commissioener of Income Tax, Circle-2(1)(1) Agra, Sanjay Place Agra vs. Mamta Agarwal, Bhagwati International

In the result, the appeal of the revenue is dismissed

ITA 398/AGR/2024[2013-14]Status: DisposedITAT Agra22 Jun 2026AY 2013-14

Bench: Shri M. Balaganesh**

For Appellant: Shri Amol Sinha, AdvFor Respondent: Shri Shailender Shrivastava, Sr. DR
Section 147Section 148Section 148A

basis of information received from Investigation Wing pertaining to one Prakash Gupta and his proprietorship concern namely Shri Trading Company, had initiated the reassessment proceedings in the case of the assessee with an allegation that assessee had made purchases of Rs. 1,77,64,049/- from the said entity which ... duly recording the quantity date and amount of sales made against such alleged ingenuine purchases and other documents as listed above again during the reassessment proceedings before the ld AO. In other words, the assessee vehemently pleaded that the purchase made by her from Shri Trading Company was genuine

Pawan Kumar Gupta, Gurgaon vs. Income Tax Officer-3(3) Bijnore, Bijnore

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

ITA 1355/DEL/2024[2017-18]Status: DisposedITAT Delhi20 Apr 2026AY 2017-18

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 132Section 147Section 148Section 151Section 151(2)Section 153C

assessment year under consideration was deemed to be a case where Income chargeable to tax has escaped assessment. 2. The assessee claimed that the reassessment proceedings were without jurisdiction. In this regard, it is to submit that the PAN is lying with jurisdiction of Assessing Officer and the case

Himanshu Daksheshkumar Katwala, Khambhat Anand vs. Income Tax Officer, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee is allowed

ITA 199/AHD/2026[2017-2018]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2017-2018

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Hardik J Raval & Vivek D Rao, ARsFor Respondent: Shri Girish Parihar, Sr. DR
Section 115BSection 132Section 143(3)Section 147Section 69A

live nexus between the appellant and the alleged escapement of income and therefore the assumption of jurisdiction under section 147 is invalid. 4. The reassessment proceedings are vitiated as the Assessing Officer failed to follow due procedure and failed to pass a speaking order while dealing with objections, HImanshu Daksheshkumar ... providing bogus entries during search proceedings conducted under section 132. HImanshu Daksheshkumar Katwala vs. ITO Asst.Year –2017-18 - 3– 4. During the course of reassessment proceedings, notices under sections 143(2) and 142(1) of the Act were issued and the assessee furnished certain explanations stating that he was engaged

Deputy Commissioner of Income Tax, Gandhinagar vs. Gujarat State Petroleum Corporation Limited, Gandhinagar

ITA 1254/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

28/01/2019 Appellate Order by Ld. CIT(A) Appeal dismissed confirming the disallowance made u/s 14A 23/03/2022 Show Cause Notice issued during to disallow u/s. reassessment proceedings 14A- Average value of investment @ 0.5% which is short deducted by Rs.10,02,013/- 27/03/2022 Notice u/s. 148 Issued 3 ITA Nos. 1165 & 1166/Ahd/2025 ... Court on identical set of facts by reopening the assessment to disallow u/s.14A of the Act, in the case Gujarat Gas Ltd. quashed the reassessment proceedings by observing as follows: “… 7. Having heard the learned advocates for the respective parties and considering the facts of the case

Deputy Commissioner of Income Tax, Gandhinagar vs. Gujarat State Petroleum Corporation Limited, Gandhinagar

ITA 1249/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

28/01/2019 Appellate Order by Ld. CIT(A) Appeal dismissed confirming the disallowance made u/s 14A 23/03/2022 Show Cause Notice issued during to disallow u/s. reassessment proceedings 14A- Average value of investment @ 0.5% which is short deducted by Rs.10,02,013/- 27/03/2022 Notice u/s. 148 Issued 3 ITA Nos. 1165 & 1166/Ahd/2025 ... Court on identical set of facts by reopening the assessment to disallow u/s.14A of the Act, in the case Gujarat Gas Ltd. quashed the reassessment proceedings by observing as follows: “… 7. Having heard the learned advocates for the respective parties and considering the facts of the case

Gujarat State Petroleum Corporation Limited, Gandhinagar vs. DCIT, Gandhinagar Circle, Gandhinagar

ITA 1166/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

28/01/2019 Appellate Order by Ld. CIT(A) Appeal dismissed confirming the disallowance made u/s 14A 23/03/2022 Show Cause Notice issued during to disallow u/s. reassessment proceedings 14A- Average value of investment @ 0.5% which is short deducted by Rs.10,02,013/- 27/03/2022 Notice u/s. 148 Issued 3 ITA Nos. 1165 & 1166/Ahd/2025 ... Court on identical set of facts by reopening the assessment to disallow u/s.14A of the Act, in the case Gujarat Gas Ltd. quashed the reassessment proceedings by observing as follows: “… 7. Having heard the learned advocates for the respective parties and considering the facts of the case

Gujarat State Petroleum Corporation Limited, Gandhinagar vs. DCIT, Gandhinagar Circle, Gandhinagar

ITA 1165/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

28/01/2019 Appellate Order by Ld. CIT(A) Appeal dismissed confirming the disallowance made u/s 14A 23/03/2022 Show Cause Notice issued during to disallow u/s. reassessment proceedings 14A- Average value of investment @ 0.5% which is short deducted by Rs.10,02,013/- 27/03/2022 Notice u/s. 148 Issued 3 ITA Nos. 1165 & 1166/Ahd/2025 ... Court on identical set of facts by reopening the assessment to disallow u/s.14A of the Act, in the case Gujarat Gas Ltd. quashed the reassessment proceedings by observing as follows: “… 7. Having heard the learned advocates for the respective parties and considering the facts of the case

Arham Anmol Projects Private Limited, Village Valshind, Bhiwandi vs. Circle 1 Kalyan, Kalyan, Thane

In the result, the legal grounds challenging the validity of the assessment are dismissed

ITA 5011/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Mar 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararham Anmol Projects Dcit Circle 1, Private Limited 2Nd Floor, Rani H. No. 1113, Ground Vs. Mansion, Murbad Floor, Arham Logiparc, Road, Kalyan Nh-3, Nashik Highway, (West), Thane, Village Valshind, Maharashtra – 421 Bhiwandi, Maharashtra – 301 421 302. Pan/Gir No. Aagca9644P (Applicant) (Respondent) Assessee By Shri Subhash Bains, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 26.03.2026

Section 144Section 144BSection 147Section 148Section 194CSection 194ISection 234FSection 250

Jurisdictional Assessing Officer and the faceless units. The scheme, in our opinion, is therefore one of functional allocation rather than jurisdictional extinction. 23. In reassessment proceedings under the post-2021 regime, the statutory structure itself reflects segmentation of stages. The inquiry under section 148A, issuance of notice under section ... Builders (P.) Ltd.167 taxmann.com 759 and held that both the Jurisdictional Assessing Officer and the Faceless Assessing Officer possess concurrent jurisdiction to initiate reassessment proceedings. It rejected the contention that the scheme completely divests the Jurisdictional Assessing Officer of authority. The Hon’ble Court further clarified that dismissal of special

Vidya Shanker Jaiswal, Sarguja vs. ITO, Ward-2, Ambikapur

The appeals of the assessee are allowed

ITA 142/RPR/2026[2014-15]Status: DisposedITAT Raipur24 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

Society for Worldwide Inter Bank Financial, Tele-2023 SCC OnLine Del 7382 communications', this court invalidated a reassessment proceeding after noting that the notice under section 143(2) of the Act was not issued to the assessee pursuant to the filing of the return. In other words, it was held ... complied with or that on placing the objection the assessee had waived the notice for further processing of the reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the assessee had placed its objection and reiterated its earlier return filed as one filed

Vidya Shanker Jaiswal, Sarguja vs. ITO, Ward-2, Ambikapur

The appeals of the assessee are allowed

ITA 141/RPR/2026[2013-14]Status: DisposedITAT Raipur24 Mar 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

Society for Worldwide Inter Bank Financial, Tele-2023 SCC OnLine Del 7382 communications', this court invalidated a reassessment proceeding after noting that the notice under section 143(2) of the Act was not issued to the assessee pursuant to the filing of the return. In other words, it was held ... complied with or that on placing the objection the assessee had waived the notice for further processing of the reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the assessee had placed its objection and reiterated its earlier return filed as one filed

Banarsi Lal, Firozabad vs. ITO 2(2)(1), Firozabad

In the result, the appeal of the assessee is allowed

ITA 317/AGR/2025[2014-2015]Status: DisposedITAT Agra20 Mar 2026AY 2014-2015

Bench: Us Challenging The Validity Of Assumption Of Jurisdiction U/S 147 Of The Act. These Additional Grounds Go To The Root Of The Matter & The Facts Relevant For Its Adjudication Are Placed On Record. Hence, We Admit The Additional Grounds & Take Up The Same First For Adjudication.

Section 147Section 148Section 151Section 250

similar kind of approval granted in a mechanical manner would vitiate the basic assumption of jurisdiction of the Ld. AO resulting in quashing of reassessment proceedings. Similar view was also taken by the Hon’ble Bombay High Court in the case of Vodafone India Ltd. vs DCIT reported ... instant case by not taking approval u/s 151 of the Act from the competent authority in the manner known to law. Accordingly, the entire reassessment proceedings are hereby quashed. Hence, one of the additional grounds challenging the validity of assumption of jurisdiction u/s 147 of the Act is allowed

Sharanjit Kaur, Chandigarh vs. Income Tax Officer, Ward 2(1), Chandigarh

The appeal stand partly allowed

ITA 237/CHANDI/2025[2014-2015]Status: DisposedITAT Chandigarh19 Mar 2026AY 2014-2015

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.237/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2014-15) Smt. Sharanjit Kaur Ito Ward-2 (1) बनाम/ Vs. H. No. 2359, Sector – 23C, Aaykar Bhawan, Sector – 17 Chandigarh - 160023 Chandigarh - 160017 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Acwpk-0060-A (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : S/Shri M. R. Sharma (Advocate) & Om Datt Sharma (Advocate) – Ld. Ars ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 24-02-2026 घोषणाकीतारीख /Date Of Pronouncement 19-03-2026 : आदेश / O R D E R Laliet Kumar () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2014-15 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 09-01-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 147 R.W.S. 144B Of The Act On 23-03-2022. The Prime Grievance Of The Assessee Is Denial Of Deduction U/S 54F Under The Head Long-Term Capital Gains

For Appellant: S/Shri M. R. Sharma (Advocate) & Om DattFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 118Section 139(5)Section 147Section 148Section 54F

Another addition as made by Ld. AO was for Rs.84,940/- which represent difference in original returned income and income returned during reassessment proceedings. Since the assessee failed to file revised return u/s 139(5), this amount was added to assessee’s income. 2.3 The Ld. CIT(A) upheld

Vineet Kumar, Dharamshala vs. Income Tax Officer, Dharmshala

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

ITA 1090/CHANDI/2025[2017-2018]Status: DisposedITAT Chandigarh19 Mar 2026AY 2017-2018

Bench: SHRI. LALIET KUMAR (Judicial Member)

For Appellant: NoneFor Respondent: Shri Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 148ASection 250(6)Section 69A

furnished to substantiate the source of cash deposits. 4. Aggrieved, the assessee has raised multiple grounds of appeal, primarily challenging the validity of reassessment proceedings, invocation of section 144, violation of principles of natural justice, and also the addition made under section 69A of the Act. The grounds, inter alia

Arimilli Rama Krishna, West Godavari Dist vs. ACIT, Circle-1, Rajahmundry

ITA 639/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam18 Mar 2026AY 2014-15

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 194CSection 194JSection 2(22)(e)Section 263

holding that the assessing officer having not provided the Reasons recorded for reopening in spite of specific request by the appellant, the reassessment proceedings are liable to be quashed. 4. The learned Commissioner of Income Tax (Appeals) is not justified in not quashing the assessment order passed by the assessing ... Kamala Devi Sharma, ITA No. 197/2018, dated 10/07/2018, had observed that the issue of notice under section 143(2) of the Act in reassessment proceedings, prior to finalizing reassessment order cannot be condoned by referring to section 292BB of the Act and was fatal to the order of the reassessment

Allrui Srinivas Raju, Hyderabad vs. DCIT, Circle-12(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1923/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Mar 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1923/Hyd/2025 ("नधा"रणवष"/ Assessment Year: 2016-17) Allrui Srinivas Raju, Vs. Dcit, Hyderabad. Circle-12(1), Pan: Ahepr6968H Hyderabad. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri K C Devdas, Ca Assessee Represented By राज"वका""त"न"ध"व/ : Dr. Narendra Kumar Naik, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 12/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Allrui Srinivas Raju, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 17/10/2025 For The A.Y.2016-17. Allrui Srinivas Raju Vs. Dcit 2. The Assessee Has Raised The Following Rounds Of Appeal:

Section 144Section 147Section 148Section 2

same total income of Rs.16,31,790/- as declared in the original return filed under section 139 of the Act. During the course of reassessment proceedings, the Ld. AO observed that the assessee had entered into a JDA dated 10.07.2015 with M/s Jeedimetla Residential Homes Private Limited along with three