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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

Nirmaljit Singh Khatra, Chandigarh vs. ITO, Ward-2(1), Chandigarh

In the result, Assessee’s appeal is allowed for Statistical Purposes

ITA 976/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh27 Oct 2025AY 2016-17

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 976/Chd/2025 "नधा"रण वष" / Assessment Year : 2016-17 Nirmaljit Singh Khatra, The Ito, बनाम 3010, Sector 38-D, Ward 2(1), Chandigarh Chandigarh Vs. "थायी लेखा सं./ Pan No: Acepk0729N अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Anil Arora, Ca राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr. Dr (Virtual) सुनवाई क" तार"ख/Date Of Hearing : 13.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.10.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 28.06.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Pertaining To A.Y. 2016-17. 2. Grounds Of Appeal Are As Under:

For Appellant: Sh. Anil Arora, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 144Section 147Section 148A

head 'unexplained investments' is unjustified, as the said amount represents reinvestment of matured fixed deposits and not any fresh unexplained income. 4. That the reassessment proceedings u/s 147 r.w.s. 144 were initiated without compliance with the procedure laid down under section 148A of the Act, making the assessment order void

Deputy Commissioner of Income Tax, Jalgaon vs. Taradevi Ratanlal Bafna, Jalgaon

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 497/PUN/2025[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

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

For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Bhasakar Kisanrav Giram, Jalna vs. ITO Ward 3, Jalna

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

ITA 1380/PUN/2025[2012-13]Status: DisposedITAT Pune27 Oct 2025AY 2012-13

Bench: Dr.Manish Borad

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Ajitesh Meena
Section 131Section 144Section 148

disclosed in the income-tax return and probable escapement of income, ld. Assessing Officer issued notice u/s.148 of the Act for carrying out the reassessment proceedings. During the course of reassessment proceedings, assessee furnished the written submission stating that the source of cash deposit of Rs.22.00 lakh on a single ... whereas the buyer has stated that only Rs.3.00 has been paid. I notice that the statement have been recorded after the conclusion of the reassessment proceedings but before the passing of the impugned order. It clearly indicates that ld. AO had carried out certain enquiries but ld.CIT

Shresth Dealers Pvt. Ltd., Kolkata vs. DCIT, CC 4(1), Kolkata

Appeal of the assessee is allowed

ITA 427/KOL/2025[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 250

Commissioner of Income Tax (Appeals), Kolkata-27 [hereafter “the Ld. CIT(A)]. 2. The issue is Ground No. 1 is against the invalid reassessment proceedings u/s 147 of the Act which are nullity and bad in law. 3. Brief facts are that the assessee filed return of income

Justin Tradelink Private Limited, Kolkata vs. ITO, Ward 9(1), Kolkata

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

ITA 1293/KOL/2025[2012-2013]Status: DisposedITAT Kolkata27 Oct 2025AY 2012-2013

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 148Section 151Section 250

natural justice. 4. That the Ld. AO failed to provide the copy of reason recorded and serve the notices issued in relation to reassessment proceedings, depriving the appellant of the opportunity to present its matter which is in contravention of principle of natural justice. Thus, the issue of notice ... course of the appeal, the assessee has filed an affidavit stating that no compliance could be made during the course of reassessment proceedings since no physical notice of hearing was received by the assessee. All the notices were issued to email ID m.jain15575@gmail.com of one of the directors which

Pramod Lakra, Deputy Commissioner of Income Tax, Circle 11(1), Kolkata vs. M/S. Dalmia Impex Private Limited, Kolkata

In the result the Cross Objection No

ITA 2544/KOL/2024[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 143(3)Section 148Section 148A

assessee. Aggrieved, the Revenue has preferred the present appeal. The assessee, in turn, filed a Cross Objection challenging the very validity of the reassessment proceedings on legal grounds, contending that the notice issued under section 148 and the subsequent proceedings are barred by limitation ... benches, we hold that the notice under section 148 A(d) issued on 29.07.2022 is time-barred and therefore, invalid in law. Consequently, the reassessment proceedings initiated and completed pursuant to such notice are void ab initio. Since the reassessment itself is held to be invalid, the additions made therein

Sudha, Tirunelveli vs. ITO, Ward-4, Tirunelveli

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

ITA 2360/CHNY/2025[2018-19]Status: DisposedITAT Chennai27 Oct 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2360/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 V. Sudha, The Ito, 4-254, Panchayat Street, Ward-4, Avaraikulam, Tirunelveli. Radhapuram, Tirunelveli-627 133. [Pan: Gbtps 0255 K] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: NoneFor Respondent: Mr.Krishna Murthy AT, JCIT
Section 144BSection 147Section 148Section 148ASection 250

subsequently, in appeal, the Supreme Court vide SLP (C) Diary No. 13266/2025, order dated 04.04.2025, categorically directed that the Revenue may proceed with the reassessment proceedings, but any adverse order against the petitioner therein shall not be given effect to until further orders. This direction of the Supreme Court ... Supreme Court, has not been stayed. 10. This Court has maintained a consistent position, that both JAO and FAO possess concurrent jurisdiction to initiate reassessment proceedings under Section 148 of the Act. In fact, in PC Jeweller Ltd. (Supra), a coordinate bench of this Court had dismissed a writ petition

Sri Ramalingam Radha, Namakkal vs. ACIT, Circl-I, Erode

ITA 2342/CHNY/2025[2013-14]Status: DisposedITAT Chennai27 Oct 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2342/Chny/2025 निर्धारण वर्ष/Assessment Year: 2013-14 Sri Ramalingam Radha, Oa-13, Kumaresapuram, 7Th Street, Rajiv Nagar, Tiruchengode, Namakkal-637 211. [Pan: Accpr 2234 H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से / Respondent By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. The Acit, Circle-1, Erode. (प्रत्यर्थी/Respondent) : Mr.R. Venkata Raman, Fca : Mr.Krishna Murthy At, Jcit : 22.10.2025 : 27.10.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeal By The Assessee Is Arising Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 26.06.2025 For Ay 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. Learned Commissioner Of Income Tax (Appeals) Is Not Justified In Dismissing The Appeal, On The Ground That The Assessee Did Not Respond To Three Notices Issued. 2. Learned Commissioner Of Income Tax Tax (Appeals) Ought Not To Have Relied On A Few Decisions Rendered Under Other Acts & On A Few Under The Income Tax Act, None Of Which Apply To The Facts Of The Assessee'S Case. :: 2 ::

Section 144BSection 147Section 148

subsequently, in appeal, the Supreme Court vide SLP (C) Diary No. 13266/2025, order dated 04.04.2025, categorically directed that the Revenue may proceed with the reassessment proceedings, but any adverse order against the petitioner therein shall not be given effect to until further orders. This direction of the Supreme Court ... Supreme Court, has not been stayed. 10. This Court has maintained a consistent position, that both JAO and FAO possess concurrent jurisdiction to initiate reassessment proceedings under Section 148 of the Act. In fact, in PC Jeweller Ltd. (Supra), a coordinate bench of this Court had dismissed a writ petition

Pichaimani Gunasundari, Kancheepuram vs. ITO, Nc-22(1), Tambaram

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

ITA 2333/CHNY/2025[2019-20 ]Status: DisposedITAT Chennai27 Oct 2025

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2333/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 V. Pichaimani Gunasundari, The Ito, No.65, Saratha Flats, Non-Corporate Ward-22(1), Ganapathi Nagar, Tambaram. 4Th Street, Urapakkam, Kancheepuram-603 210. [Pan: Cqgpg 6518 M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.N. Arjunraj, AdvocateFor Respondent: Mr.Krishna Murthy AT, JCIT
Section 147Section 148Section 148ASection 250(6)Section 69Section 69A

subsequently, in appeal, the Supreme Court vide SLP (C) Diary No. 13266/2025, order dated 04.04.2025, categorically directed that the Revenue may proceed with the reassessment proceedings, but any adverse order against the petitioner therein shall not be given effect to until further orders. This direction of the Supreme Court ... Supreme Court, has not been stayed. 10. This Court has maintained a consistent position, that both JAO and FAO possess concurrent jurisdiction to initiate reassessment proceedings under Section 148 of the Act. In fact, in PC Jeweller Ltd. (Supra), a coordinate bench of this Court had dismissed a writ petition

Nmc Industries Pvt Ltd, Mumbai vs. JCIT (OSD) CC2(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5215/MUM/2025[2010-11]Status: DisposedITAT Mumbai27 Oct 2025AY 2010-11

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 143(3)Section 147Section 148Section 271(1)(c)

identified as hawala operators providing accommodation bills, the Assessing Officer reopened the case under section 147 and issued notice under section 148. 4. During reassessment proceedings, the Assessing Officer noted that the assessee had made purchases from eight such parties alleged to be non-genuine. The assessee, however, produced purchase

Vipul Mathuradas Thakkar, Mumbai vs. ITO Ward 3(2), Kalyan

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

ITA 4936/MUM/2025[2009-10]Status: DisposedITAT Mumbai27 Oct 2025AY 2009-10

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhanvipul Mathuradas Thakkar Ito Ward 3(2), 402, Madhav Baug, Gaushala Road, Rani Mansion, Kalyan Shivaji Path, Kalyan, Maharashtra- Vs. Maharashtra-421301 421301 Pan: Aaipt0824B (Appellant) (Respondent) Assessee Represented By : Shri Haridas Bhatt, Ld. Ar Department Represented By : Ms. Kavita Kaushik, Ld. Dr Date Of Conclusion Of Hearing : 17.09.2025 Date Of Pronouncement : 27.10.2025

Section 131Section 142(1)Section 143(1)Section 143(2)Section 148Section 250Section 68

component of Rs. 60,00,000/-remains unexplained and is to be added back as unaccounted income in the case of assessee. 3. Accordingly, reassessment proceedings were initiated by issue of notice u/s 148 of the Act dated 30.03.2016 duly served to the assessee on 31.03.2016. Notices

Income Tax Officer-41(2)(4), Mumbai, Bkc vs. Rbi Employees Bhagvati Coop Housing Society Ltd, Mulund East, Mumbai

ITA 4073/MUM/2025[2011]Status: DisposedITAT Mumbai27 Oct 2025

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Fenil BhattFor Respondent: Shri Annavaran Kosuri
Section 139Section 143(3)Section 147Section 148Section 2(47)(v)Section 271(1)(c)Section 48Section 50CSection 53A

No.243/Mum/2025 Assessment Year 2011-2012 received interest-free refundable deposit of INR.1,00,000/- in terms of the aforesaid Development Agreement. Therefore reassessment proceedings were initiated in case of the Assessee under Section 147 of the Act. In response to notice issued under Section 148 of the Act, the Assessee ... filed return of income for the Assessment Year 2011-2012 on 28/04/2018 declaring ‘Nil’ income. The aforesaid reassessment proceedings culminated into passing of Assessment Order, dated 10/12/2018, under Section 143(3) read with Section 147 of the Act whereby an addition of INR.4,97,60,657/- was made

Income Tax Officer-41(2)(4), Mumbai, Kautilya Bhavan, Bkc vs. Rbi Employees Bhagvati Co-Op Housing Society Ltd., Mulund East, Mumbai

ITA 3595/MUM/2025[2011-12]Status: DisposedITAT Mumbai27 Oct 2025AY 2011-12

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Fenil BhattFor Respondent: Shri Annavaran Kosuri
Section 139Section 143(3)Section 147Section 148Section 2(47)(v)Section 271(1)(c)Section 48Section 50CSection 53A

No.243/Mum/2025 Assessment Year 2011-2012 received interest-free refundable deposit of INR.1,00,000/- in terms of the aforesaid Development Agreement. Therefore reassessment proceedings were initiated in case of the Assessee under Section 147 of the Act. In response to notice issued under Section 148 of the Act, the Assessee ... filed return of income for the Assessment Year 2011-2012 on 28/04/2018 declaring ‘Nil’ income. The aforesaid reassessment proceedings culminated into passing of Assessment Order, dated 10/12/2018, under Section 143(3) read with Section 147 of the Act whereby an addition of INR.4,97,60,657/- was made

Income Tax Officer, Mumbai vs. Sha Tarachand Fojmal and Company, Mumbai

In the result, the appeal filed by the Revenue stands dismissed

ITA 2541/MUM/2025[2011-12]Status: DisposedITAT Mumbai27 Oct 2025AY 2011-12
Section 143(3)Section 147

purchases from certain entities declared as hawala dealers, who had allegedly issued accommodation bills without effecting any actual supply of goods. 3. In the reassessment proceedings, the learned Assessing Officer ("ld. AO”) observed that the assessee had shown purchases aggregating to ₹11,88,65,874/- from such alleged non-genuine

Sachin Shrikant Naik, Santacruz East, Mumbai vs. Dy. Commissioner of Income Tax - 42(3)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2183/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Oct 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2015-16

For Appellant: Mr. Dhiraj S. DandgavalFor Respondent: 03/09/2025
Section 69A

against the interes is against the interest of natural justice and the whole of the t of natural justice and the whole of the reassessment proceedings shall be quashed. reassessment proceedings shall be quashed. 5. On the facts and in the circumstances of the case ... Assessing Officer. Hence, showcasing the confusion of the Assessing Officer. Hence, showcasing the confusion of the Assessing Officer. Hence, whole of the reassessment proceedings are not valid and whole of the reassessment proceedings are not valid and whole of the reassessment proceedings are not valid and needs to be quashed

Shalibhadra Exprorts Pvt Ltd, Mumabi vs. Dy Commissioner of Income Tax, Central Circle-7(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1287/MUM/2022[2013-14]Status: DisposedITAT Mumbai27 Oct 2025AY 2013-14

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Sharwan KR. Jha, AdvFor Respondent: Shri. Saurabh Kumar Rai, CIT DR
Section 131Section 133(6)Section 139(1)Section 143(3)Section 145(3)Section 147Section 148Section 250Section 68

failed to disclose. (2) On the facts and in the circumstances of the case and in law, the Ld. A.O. erred in completing the reassessment proceedings on the same grounds and facts and on the basis of same records and materials available during the detailed original scrutiny proceedings ... other words, the Ld. A.O. erred in completing the reassessment proceedings with a change of opinion. (3) On the facts and in the circumstances of the case and in law, the Ld. A.O. erred in reassessing the income of the appellant at Rs. 96,31,82,861/- as against returned

Manoj Bindal, Haryana vs. Income Tax Officer, Ward-1(5), Faridabad, Haryana

In the result, appeal of the assessee is allowed

ITA 2999/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Oct 2025AY 2014-15

Bench: Shri Vikas Awasthyआअसं. 1134 और 2999/िद"ी/2025 (िन.व. 2013-14 & 2014-15)

For Appellant: Shri Ajay Wadhwa, Ms. Ragini Handa, &For Respondent: Ms. Sudha Gupta, Sr. DR
Section 133(6)Section 143(3)Section 148

accepted, books of account not rejected, the purchases which were earlier accepted in the original assessment proceedings cannot be held to be bogus in reassessment proceedings. The ld. Counsel further pointed that in the case of Ram Kishan Bindal vs. ITO in ITA No. 6405/Del/2019 ... considered view that since the AO had already examined the issue and had accepted the purchases of Rs. 59,75,000/- as genuine, the reassessment proceedings were initiated merely on the basis of ‘change of opinion’, hence, not sustainable. Even otherwise reasons for reopening are ambiguous, the reassessment proceedings

Shri Sati Hosiery Pvt Ltd, Delhi vs. ITO Ward-23(3), Delhi

In the result, appeal of assessee in ITA No

ITA 1804/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Oct 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Dinesh Bansal, CAFor Respondent: Shri Sushil Kumar Kulheri, Sr. DR
Section 148Section 148ASection 151

Shri Sati Hosiery u/s 148 for AY 2014-15 was issued on 16.04.2021 under the amended provisions. The admitted fact is that the reassessment proceedings relates to A.Y 2014-15 and on the basis of the order u/s 148A(d) dated 25.07.2022, the notice u/s 148 was issued

Manoj Bindal, Haryana vs. Income Tax Officer Ward 1(5) Fbd, Faridabad

In the result, appeal of the assessee is allowed

ITA 1134/DEL/2025[2013-14]Status: DisposedITAT Delhi27 Oct 2025AY 2013-14

Bench: Shri Vikas Awasthyआअसं. 1134 और 2999/िद"ी/2025 (िन.व. 2013-14 & 2014-15)

For Appellant: Shri Ajay Wadhwa, Ms. Ragini Handa, &For Respondent: Ms. Sudha Gupta, Sr. DR
Section 133(6)Section 143(3)Section 148

accepted, books of account not rejected, the purchases which were earlier accepted in the original assessment proceedings cannot be held to be bogus in reassessment proceedings. The ld. Counsel further pointed that in the case of Ram Kishan Bindal vs. ITO in ITA No. 6405/Del/2019 ... considered view that since the AO had already examined the issue and had accepted the purchases of Rs. 59,75,000/- as genuine, the reassessment proceedings were initiated merely on the basis of ‘change of opinion’, hence, not sustainable. Even otherwise reasons for reopening are ambiguous, the reassessment proceedings

Sunita Saini, Haryana vs. Income Tax Officer, Ward 1(4), Faridabad, Haryana

In the result, appeal of the Assessee is allowed

ITA 1877/DEL/2024[2016-17]Status: DisposedITAT Delhi27 Oct 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.1877/Del/2024 िनधा"रणवष"/Assessment Year:2016-17 बनाम Sunita Saini, Income Tax Officer, House No.743P, Sector-38, Vs. Ward 1(4), Gurugram, Haryana. Faridabad. Pan No.Awmps2317Q अपीलाथ" Appellant ""यथ"/Respondent

Section 10(38)Section 147Section 151Section 263

order dt: 10.03.2022 is based on the presumption that the assessing authority has not confronted the material and complete information to the appellant during reassessment proceedings in respect of scrip i.e. M/s Yamini Investment Company Ltd which has been rigged up and on which the appellant has claimed exemption ... contrary to facts on records as no material was discussed in reason recorded on the basis of which reassessment proceedings was initiated u/s 147/148. Therefore, the impugned order of revision is therefore bad in law and needs be quashed. 4. The Ld. Pr. CIT has assumed power