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“reassessment proceedings”

ReassessmentSections 147-151Sections 147-1518,150 judgments

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, 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, 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,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, 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,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, 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, 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

SHRI PARASRAM COMMODITIES PVT LTD.,DELHI vs. DCIT, CIRCLE-23(1), DELHI

In the result the appeal of the assessee is allowed

ITA 4630/DEL/2025[2012-13]Status: DisposedITAT Delhi18 Mar 2026AY 2012-13

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2012-13

Section 143(3)Section 147Section 148Section 68

made in respect of issues recorded by Assessing Officer for re-opening assessment, Assessing Officer cannot make addition on any other issue in reassessment proceedings. 6. The Ld. AR submitted that the re-opening is not justified, hence the assessment order is liable to be quashed ... transaction was not genuine.Thus the addition is made on the suspicion. The Assessing Officer cannot make any addition on the other issue in reassessment proceedings. Respectfully following the decision of the Hon’ble High Court and ITAT we find that the Assessing Officer made the addition without mentioning the proper

SHAILESH KUMAR,NEW DELHI vs. CENTRAL CIRCLE- 27, NEW DELHI

In the result, Appeal of the Assessee is allowed

ITA 3641/DEL/2025[2015-16]Status: DisposedITAT Delhi18 Mar 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Amitabh Shuklashailesh Kumar Vs Acit W-82/1, Eastern Avenue, Sainik Central Circle-27 Farms, New Delhi Jhandewalan, New Delhi Pan: Afppk1645B (Applicant) (Respondent) Appellant By Sh. R. P. Mall, Adv Respondent By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 26.02.2026 Date Of Pronouncement 18.03.2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-29, (‘Ld. Cit (A)’ For Short), New Delhi Dated 28/03/2025 For The Assessment Year 2015-16. 2. Brief Facts Of The Case Are That, Assessee Filed Its Return Of Income For The Year Under Consideration Declaring Income Of Rs. 18,18,380/-. An Assessment Order Came To Be Passed U/S 147 Of The Act On 30/05/2023 By Computing The Income Of The Assessee At Rs. 72,84,905/- As Against The Returned Income Of Rs. 18,18,380/-. Aggrieved By The Assessment Order Dated 30/05/2023, Assessee Preferred Appeal Before The Ld. Cit(A). The Ld. Cit(A) Vide Order Dated 28/03/2025, Dismissed The Appeal Of The Assessee.

Section 147Section 148Section 148ASection 149Section 149(1)Section 149(1)(b)Section 3(1)

Assessee. 2 Shailesh Kumar Vs. ACIT 3. The Ld. Counsel for the Assessee addressing on the additional grounds of Appeal submitted that the reassessment proceedings for year under consideration is time-barred. Further submitted that the notice u/s 148 was issued on 05/04/2021, followed bythe notice u/s 148A(b) dated ... could not validly be issued for Assessment Year 2015- 16 in view of the limitation prescribed u/s 149 of the Act, rendering the entire reassessment proceedings void and without jurisdiction. The Ld. Counsel for the Assessee relying on the Judgment of Hon'ble Supreme Court Union of India Vs. Rajeev

VANDANA SINGH,NOIDA vs. ITO 5(2)(5) NOIDA, NOIDA

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

ITA 2816/DEL/2024[2015-16]Status: DisposedITAT Delhi18 Mar 2026AY 2015-16

Bench: Shri Ramit Kochar & Shri Sudhir Kumarvandana Singh, Ito, 5(2)(5), 302, Abhinav Apartments, Noida, U.P. Vasundhra Enclave V. Delhi-110096 Pan-Dcrps8979A (Appellant) (Respondent)

Section 144Section 147Section 148Section 249(4)(b)Section 250Section 69

assessee was reopened for framing reassessment by invoking provisions of section 147. The AO issued notices to the assessee from time to time during reassessment proceedings u/s 148 as well 142(1) and 6 Vandana Singh v. ITO SCN u/s 144 of the Act, but the same were not complied ... with by the assessee before the AO during reassessment proceedings, which led to an ex-parte reassessment order wherein additions to the time of Rs. 1,36,45,500/- were made by the AO.We have detailed additions in preceding para’s of this order and the same are not repeated

SHREE MALLIKARJUN SHIPPING PRIVATE LIMITED,VASCO vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), PANAJI

ITA 8/PAN/2025[2007-08]Status: DisposedITAT Panaji17 Mar 2026AY 2007-08
Section 143(3)Section 69A

considered the grounds of appeal, submissions of the assessee and findings of the A.O but has sustained the validity of reassessment proceedings u/sec147 of the Act and addition of unexplained money u/sec69A of the Act and the CIT(A)has granted relief in other grounds of appeal and partly allowed ... disputed issues in the grounds of appeal of the assessee that that the CIT(A) has erred in sustaining the validity of initiation of reassessment proceedings u/sec147 of the Act and sustaining the addition u/sec69A of the Act without providing proper opportunity and overlooking the facts and material evidences

MOHAMMED USMAN, BHILAI,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, DURG

In the result, appeal of the assessee is allowed

ITA 180/RPR/2026[2011-12]Status: DisposedITAT Raipur17 Mar 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.180/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 Mohammed Usman C/25, Nandini Road, Power House, Bhilai-490 011, Dist. Durg Pan: Aafpu9292H

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 142(1)Section 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 7 Mohammed Usman Vs. ITO-2(1), Bhilai (C.G.) assessee had placed its objection

DINDAYAL AGARWAL,BERHAMPUR vs. THE INCOME TAX OFFICER, WARD-1, BERHAMPUR., BERHAMPUR

In the result, the appeal of the assessee is allowed

ITA 471/CTK/2025[2017-18]Status: DisposedITAT Cuttack16 Mar 2026AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2016-17 Dindayal Agarwal Ito, Ward-1, Berhampur

For Appellant: Shri Pranaya Ku. Mishra, Prashant KumarFor Respondent: Shri Shakeer Ahamed, Sr. DR
Section 148Section 148ASection 151

revenue and upheld the decision of the Hon’ble Bombay High Court wherein it was held that where approval for initiation of reassessment proceedings was granted by Commissioner after expiry of 3 years from end of relevant assessment year, said approval should have been granted by Principal Chief Commissioner, thus

INCOME TAX OFFICER WARD 6 (1), MOHALI vs. SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, KHRAR PUNJAB

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1217/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)
Section 143(3)Section 148Section 68

since formation of belief of escapement of income as well as approval for reopening of the case proceeded on wrong foundation of facts, the reassessment proceedings could not be sustained in law. The Ld. CIT-DR, in the written submissions, has stated that the case was reopened on specific, reliable

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