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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

Champat Singh (Through Legal Heir Sh. Kannu Singh), Ghaziabad vs. The ITO-Ward-2(1)(2), Cgo Complex Hapur Chungi Ghaziabad

ITA 5623/DEL/2024[2012-13]Status: DisposedITAT Delhi29 Oct 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandraasstt. Yr: 2012-13

Section 144Section 147Section 148

notice could have been issued in the name of deceased assessee for reopening of assessment under Section 148 of the Act neither reassessment proceedings could be proceeded with on the basis of such invalid notice. Thus, the notice is not valid in the eyes of law and the proceeding

ACIT, New Delhi vs. Vrinda Farms Private Limited, New Delhi

In the result, the appeal of the Revenue as well as cross objections of the assessee are dismissed

ITA 4849/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Acit, Central Circle 4, Vs. Vrinda Farms Private Limited, New Delhi. 43, Community Centre, Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) Co Nos.13 & 19/Del/2025 (In Ita No.4849/Del/2024) (Assessment Year: 2016-17) Vrinda Farms Private Limited, Vs. Acit, Central Circle 4, 43, Community Centre, New Delhi. Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) (Appellant) (Respondent) Assessee By : Shri Biren Shah, Ca Revenue By : Shri Dheeraj Kumar Jain, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Order : 29.10.2025 Order Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short]

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Section 132(4)Section 133(6)Section 68

Additional reason - Notice issued by AO on the ground that the assessee had accepted accommodation entries in the garb of share capital-During the reassessment proceedings additions made in respect of the credits received from some other parties additions for accommodation entries were made were not found valid and additions

Omkar Singh, Noida vs. ITO Ward - 5(2)(1), Noida

In the result, the appeal of the assessee is allowed

ITA 3574/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Oct 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 115BSection 139(1)Section 143(2)Section 147Section 148Section 151Section 69A

quashed and CIT(A) erred in not holding so 4. On the facts and circumstances of the case and in law, the reassessment proceedings initiated are contrary to the provisions of law including the specific provisions of section 147 to section 151 of Income Tax Act, 1961 and therefore ... reassessment proceeding initiated along with assessment order passed are liable to be quashed and CIT(A) erred in not holding so. 5. On the facts and circumstances of the case and in law, the order passed by the learned assessing officer and the addition made therein

Haridas Mulji Rughani, Porbandar vs. Income Tax Officer - Ward 2(3), Porbandar

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

ITA 686/RJT/2024[2017-18]Status: DisposedITAT Rajkot28 Oct 2025AY 2017-18
For Appellant: 1. The reopening u/s. 147 of the Act is bad in law
Section 115BSection 144Section 147Section 69A

ITA NO. 686/RJT/2024 Haridas Mulji Rughani IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI

Kanaiya Food Products, Jamkandorana vs. The Principal Commissioner of Income Tax-1, Rajkot

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

ITA 336/RJT/2024[2017-18]Status: DisposedITAT Rajkot28 Oct 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 336/Rjt/2024 (Assessment Year: 2017-18) (Hybrid Hearing) Kanaiya Food Products, Vs. The Principal Commissioner Of A A, Dhoraji Jamkandorana Income Tax-1, Rajkot 2Nd Floor, Aaykar Bhawan, Race Road, Near Gujarat Pani Purvatha Tank, Course Ring Road, Rajkot Jamkandodrana-360405 Rajkot-361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamfk9437F (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT-DR
Section 147Section 263Section 40ASection 40A(3)

made by the assessing officer, in respect of the main reasons recorded by the assessing officer to reopen the assessee`s case, therefore, reassessment proceedings initiated by the assessing officer is itself bad in law. Moreover, the issue pertaining to I.T.A No. 336/Rjt/2024 A.Y. 2017-18 Kanaiya Food Products section ... assessment proceedings, then there should be end of litigation on that issue. 9. Learned Counsel for the assessee, further submitted that even during the reassessment proceedings under section 147 of the Act, the assessee has submitted relevant documents and evidences before the assessing officer, which were considered by the assessing

Ram Ji Lal Meena, Jaipur vs. ACIT, Holding Additional Charge of ITO, Ward 6(1), Jaipur

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

ITA 419/JPR/2025[2008-09]Status: DisposedITAT Jaipur28 Oct 2025AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: NoneFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR
Section 143(2)Section 143(3)Section 144Section 151Section 50CSection 56(2)(vii)

facts of the case. Relief may 2 SHRI RAM JI LAL MEENA VS ITO, WARD 6 (1), JAIPUR please be granted by quashing the reassessment proceedings being illegal and without jurisdiction 2. Without prejudice to Ground of Appeal No. 1. the Ld. Assessing Officer (AO) has grossly erred in completing

Ram Khilari Meena, Dausa vs. ITO, Dausa

In the result, the appeal of the assessee is allowed

ITA 1292/JPR/2025[2019-20]Status: DisposedITAT Jaipur28 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Mukesh Khandelwal, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 139Section 147Section 148Section 148ASection 44A

Assessing Officer is empowered to make additions even on the ground on which reassessment notice might not have been issued where during the reassessment proceedings, he concludes that some other income has escaped assessment which comes to his notice during the course of the proceedings for reassessment under section ... Special Leave Petition (Civil) No. 13028 of 2011 against this decision was dismissed on 6 Ram Khilari Meena vs. ACIT August 19, 2011. The reassessment proceedings, thus, in the present case, cannot be held to be vitiated." 8.2 The Hon'ble High Court of Karnataka in N Govindarajuvs Income

Mali Ram Yadav, Therkyo Ki Dhani vs. ITO, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1110/JPR/2025[2017-18]Status: DisposedITAT Jaipur28 Oct 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं. / ITA No. 1110/JPR/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Mali Ram Yadav Thekryo Ki Dhani, Village & Post: Jahota, Tehsil: Amer Distt: Jaipur 303 701 बनाम Vs. The ITO Ward - 7(2) Jaipur प्रत्यर्थी / Respondent स्थायी लेखा सं. / जीआईआर सं. / PAN/GIR No.: ABJPY 6715A अपीलार्थी / Appellant निर्धारिती की ओर से / Assesseeby : Shri Rakesh Kumar Kabra, CA Mrs. Prachela Kabra, CA राजस्व की ओर से /

For Appellant: Shri Rakesh Kumar Kabra, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 144Section 147Section 148Section 148ASection 234ASection 69

Return of the lender, which fully established the identity, creditworthiness, and genuineness of the transaction. 3. Notice Barred by Limitation That the initiation of reassessment proceedings u/s 147 of the Income Tax Act, 1961 and issuance of notice u/s 148A is illegal, arbitrary, and void ab initio as the same ... appellant contended that the notice u/s 148 was issued after the expiry of the limitation period, making the reassessment proceedings void ab initio. 3.2 The appellant claimed that the loan of Rs. 15,00,000/- was taken from Smt. Amrita Agarwal, supported by bank statements and confirmation letters. However

Navnirman Infracon Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 689/KOL/2025[2011-12]Status: DisposedITAT Kolkata28 Oct 2025AY 2011-12

Bench: S/Shriand Rajesh Kumar & Sonjoy Sarma

For Appellant: Shri Manish Tiwari, FCAFor Respondent: Shri Sandeep Kumar Mehta, Addl. Sr. DR
Section 148Section 250Section 56(2)(via)Section 56(2)(viia)

That on the facts and circumstances of the case the Leamed National Faceless Appeal Centre. Delhi erred in confirming the validity of the impugned reassessment proceedings initiated vide Notice dated 28th March, 2017 issued by the Assessing Officer under section 148 of the Act without appreciating that the reasons recorded ... That on the facts and circumstances of the case, the Id. National Faceless Appeal Centre Delhi erred in confirming the validity of the impugned reassessment proceedings although the purported sanction accorded by the Id. Commissioner of Income Tax, Kolkata for the initiation of the impugned reassessment proceedings was clearly

DCIT Central Circle 1 4 Kolkata, Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2245/KOL/2024[2016-17]Status: DisposedITAT Kolkata28 Oct 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

income u/s 139(1) of the Act on 18.09.2015 declaring the loss of ₹10,17,55,446/-. The ld. AO during the course of reassessment proceedings issued notice u/s 143(2) and 142(1) of the Act along with ITA Nos. 2178, 2179, 2187, 2245, 2196/KOL/2024 Murlidhar Ratanlal Exports Limited ... material found in the survey. But ironically the AO did not refer any impounded document/paper with its identity mark either for initiation of reassessment proceeding or for the purpose of making addition of Rs. 44,83,667/- to the total income. Thus, absence of reference of impounded material relating

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2196/KOL/2024[2018-19]Status: DisposedITAT Kolkata28 Oct 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

income u/s 139(1) of the Act on 18.09.2015 declaring the loss of ₹10,17,55,446/-. The ld. AO during the course of reassessment proceedings issued notice u/s 143(2) and 142(1) of the Act along with ITA Nos. 2178, 2179, 2187, 2245, 2196/KOL/2024 Murlidhar Ratanlal Exports Limited ... material found in the survey. But ironically the AO did not refer any impounded document/paper with its identity mark either for initiation of reassessment proceeding or for the purpose of making addition of Rs. 44,83,667/- to the total income. Thus, absence of reference of impounded material relating

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2187/KOL/2024[2015-16]Status: DisposedITAT Kolkata28 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

income u/s 139(1) of the Act on 18.09.2015 declaring the loss of ₹10,17,55,446/-. The ld. AO during the course of reassessment proceedings issued notice u/s 143(2) and 142(1) of the Act along with ITA Nos. 2178, 2179, 2187, 2245, 2196/KOL/2024 Murlidhar Ratanlal Exports Limited ... material found in the survey. But ironically the AO did not refer any impounded document/paper with its identity mark either for initiation of reassessment proceeding or for the purpose of making addition of Rs. 44,83,667/- to the total income. Thus, absence of reference of impounded material relating

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2179/KOL/2024[2014-15]Status: DisposedITAT Kolkata28 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

income u/s 139(1) of the Act on 18.09.2015 declaring the loss of ₹10,17,55,446/-. The ld. AO during the course of reassessment proceedings issued notice u/s 143(2) and 142(1) of the Act along with ITA Nos. 2178, 2179, 2187, 2245, 2196/KOL/2024 Murlidhar Ratanlal Exports Limited ... material found in the survey. But ironically the AO did not refer any impounded document/paper with its identity mark either for initiation of reassessment proceeding or for the purpose of making addition of Rs. 44,83,667/- to the total income. Thus, absence of reference of impounded material relating

Thomas Victor, Chennai vs. Income Tax Officer, Non Corp Ward 19(6), Chennai

In the result, appeal filed by the assessee is allowed

ITA 2987/CHNY/2024[2015-16]Status: DisposedITAT Chennai28 Oct 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.R. Venkata Raman, CA
Section 139Section 147Section 148Section 148ASection 151ASection 271D

2269/D/2017 dated 10.12.2018 (ITAT, Delhi Bench) ITA. No.3009 to 3012/DEL/2017 “6.1………….It is well settled Law that assessee can challenge the validity of the reassessment proceedings in the collateral proceedings (relating to examination of validity of Order passed) under section 263 of the I.T. Act. We rely upon the Order ... PCIT in ITA No. 4749/D/2019 dated 31.12.2019 (ITAT, Delhi) “6. We have considered the rival submissions. It is well settled Law that since reassessment proceedings are invalid and bad in law, therefore, such proceedings could not be revised under section 263 of the I.T. Act. It is also well settled

Mayank Jayantilal Desai, Mumbai vs. ITO- Ward 19(2)(2), Mumbai

In the result appeal filed by the assessee stands allowed and appeal filed by the revenue stands dismissed

ITA 706/MUM/2025[2007-08]Status: DisposedITAT Mumbai28 Oct 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Arun Khodpia ()

Section 145(3)Section 147

application of mind to the facts. 3. REASSESSMENT 3.1 The Ld. CIT (A) erred in confirming the action of the A.O. in initiating the reassessment proceeding and framing the assessment of the 3 ITA No.1300 & 706/Mum/2025; A.Y. 2007-08 Mayank Jayantilal Desai Appellant by invoking the provisions of section ... within the parameters laid down by section 147 r.w.s. 148 r.w.s. 149 & 151 of the Act; and (ii) The necessary preconditions for initiating the reassessment proceeding and completion thereof were not satisfied. 3.3 It is submitted that in the facts and the circumstances of the case, and in law, action

DCIT, Central Circle-8(1), Mumbai vs. Ei Resorts & Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3926/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Oct 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

jurisdictional Assessing officer in contravention E I Resorts & Clubs Pvt. Ltd. of Section 151A of the Act & the scheme frame thereafter and therefore the reassessment proceedings are bad in law. (ii) The AR argued that as per the scheme formulated vide Notification S.O1466 (E)(18/2022) dated March ... ACIT [2025] 170 taxmann.com 422 (Bombay). C) Defective Notice issued under section 148 E I Resorts & Clubs Pvt. Ltd. The AR argued that the reassessment proceedings are invalid in law, as the notice issued under section 148 of the Income Tax Act in the case of E I Resorts & Clubs

DCIT, Central Circle-8(1), Mumbai vs. E I Resorts and Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3886/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

jurisdictional Assessing officer in contravention E I Resorts & Clubs Pvt. Ltd. of Section 151A of the Act & the scheme frame thereafter and therefore the reassessment proceedings are bad in law. (ii) The AR argued that as per the scheme formulated vide Notification S.O1466 (E)(18/2022) dated March ... ACIT [2025] 170 taxmann.com 422 (Bombay). C) Defective Notice issued under section 148 E I Resorts & Clubs Pvt. Ltd. The AR argued that the reassessment proceedings are invalid in law, as the notice issued under section 148 of the Income Tax Act in the case of E I Resorts & Clubs

Tarun Nandkumar Seksaria, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3239/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

under section 148 was issued by jurisdictional Assessing officer in contravention of Section 151A of the Act & the scheme frame thereafter and therefore the reassessment proceedings are bad in law. (ii) The AR argued that as per the scheme formulated vide Notification S.O1466 (E)(18/2022) dated March ... pronouncements of the Hon'ble Bombay High Court command full precedential authority over this Tribunal. 54. Having held so, it necessarily follows that the reassessment proceedings initiated under section 148 by the jurisdictional Assessing Officer, in violation of the Faceless Scheme under section 151A stand vitiated in law. The notice

Ei Beneficiary Trust, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3230/Mum/2025

ITA 3236/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Oct 2025AY 2018-19
Section 132Section 132(4)Section 69A

under section 148 was issued by jurisdictional Assessing officer in contravention of Section 151A of the Act & the scheme frame thereafter and therefore the reassessment proceedings are bad in law. (ii) The AR argued that as per the scheme formulated vide Notification S.O1466 (E)(18/2022) dated March ... India vs ACIT [2025] 170 taxmann.com 422 (Bombay). B. Defective notice issued under section 148 of the Act The AR argued that the reassessment proceedings are invalid in law, as the notice issued under section 148 of the Income Tax Act in the case of E I Resorts & Clubs

Ei Beneficiary Trust, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3230/Mum/2025

ITA 3235/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

under section 148 was issued by jurisdictional Assessing officer in contravention of Section 151A of the Act & the scheme frame thereafter and therefore the reassessment proceedings are bad in law. (ii) The AR argued that as per the scheme formulated vide Notification S.O1466 (E)(18/2022) dated March ... India vs ACIT [2025] 170 taxmann.com 422 (Bombay). B. Defective notice issued under section 148 of the Act The AR argued that the reassessment proceedings are invalid in law, as the notice issued under section 148 of the Income Tax Act in the case of E I Resorts & Clubs