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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

Chinthalapudi Ramakrishna, Khammam vs. ITO., Ward-1, Kothagudem

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

ITA 473/HYD/2025[2018-19]Status: DisposedITAT Hyderabad08 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139Section 147Section 148Section 148ASection 69Section 69A

response, the assessee filed his return of income on 13.05.2022 declaring a total income of Rs.2,93,100/-. During the reassessment proceedings, the Ld. AO found that the assessee had deposited cash of ITA No.473/Hyd/2025 4 Rs.136,68,180/- along with other credits of Rs.8,29,492/- in his bank ... assessee for the year under consideration was Rs.155,09,900/- . However, as no supporting bills/vouchers were produced by the assessee during the reassessment proceedings, the Ld. AO treated the entire deposit of Rs.144,97,672/- in the bank account as unexplained money under section 69A of the Act and completed

Pitti Holdings Private Limited, Hyderabad vs. ACIT., Central Circle-1(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 450/HYD/2025[2018-19]Status: DisposedITAT Hyderabad08 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

For Appellant: Shri A. Srinivas, C.AFor Respondent: Dr. Sachin Kumar, DR
Section 148Section 148A

made any addition on the issue of reopening. The Ld. AR of the assessee has submitted that the Assessing Officer has initiated the reassessment proceedings by issuing the notice u/s. 148A(b) of the Act dated 12.03.2022 giving the reasons that as per the information in the possession ... less than what is required to be submitted to counter the issues mentioned in the notice, the assessee can use the reassessment proceedings to validate his claim by producing relevant corroborative evidences required rather than requesting to drop the proposals to reopen under section 148 of LT Act by stating

Hanmandlu Pampati, Karimnagar vs. Income Tax Officer, Ward-2, Karimnagar

In the result, the appeal of the assessee is allowed

ITA 229/HYD/2025[2013-14]Status: DisposedITAT Hyderabad08 Oct 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.228/Hyd/2025 (निर्धारण वर्ष/Assessment Year:2013-14) 1. Shri Srinivas Pampati, Karimnagar. Pan: Abopp0603R Vs. Income Tax Officer, Ward-2, Karimnagar. आ.अपी.सं / Ita No.229/Hyd/2025 (निर्धारण वर्ष/Assessment Year:2013-14) 2. Shri Hanmandlu Pampati, Karimnagar. Pan: Abmpp0324R Vs. Income Tax Officer, Ward-2, Karimnagar. (Appellant) (Respondent) निर्धारिती द्वारा /Assessee By: Shri Lalith Kishore Sharma, Advocate. राजस्व द्वारा / Revenue By: | Dr. Sachin Kumar, Sr-Dr सुनवाई की तारीख / Date Of Hearing: घोषणा की तारीख /Pronouncement: 17/09/2025 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : These Two Appeals Are Filed By Shri Srinivas Pampati & Shri Hanmandlu Pampati ("The Assessees”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)"), Dated 04.12.2024 & 05.12.2024 Respectively For The A.Y. 2013-14. Since The Grounds Raised By The Assessees Are Identical, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri Lalith Kishore SharmaFor Respondent: Dr. Sachin Kumar, SR-DR
Section 144BSection 147Section 148Section 148ASection 154Section 48Section 54F

response to the said notice, the assessee filed return of income on 29.01.2023 declaring total income of Rs.5,16,650/-. During reassessment proceedings, on the basis of submissions of the assessee, the Ld. AO noticed that the assessee along with three others had entered into a Development Agreement-cum-General ... order of the Ld. AO, wherein the Ld. AO has stated that the photographs of the property was also submitted during reassessment proceedings, to show that the flats were still under construction and had not been completed. In view of these facts, he argued that there was no “transfer” within

Srinivas Pampati, Karimnagar vs. Income Tax Officer, Ward-2, Karimnagar

In the result, the appeal of the assessee is allowed

ITA 228/HYD/2025[2013-14]Status: DisposedITAT Hyderabad08 Oct 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Lalith Kishore SharmaFor Respondent: Dr. Sachin Kumar, SR-DR
Section 144BSection 147Section 148Section 148ASection 54F

response to the said notice, the assessee filed return of income on 29.01.2023 declaring total income of Rs.5,16,650/-. During reassessment proceedings, on the basis of submissions of the assessee, the Ld. AO noticed that the assessee along with three ITA Nos.228 & 229/Hyd/2025 4 others had entered into ... order of the Ld. AO, wherein the Ld. AO has stated that the photographs of the property was also submitted during reassessment proceedings, to show that the flats were still under construction and had not been completed. In view of these facts, he argued that there was no “transfer” within

Mohd Azgar Ali, Nalgonda vs. ITO., Ward-1, Nalgonda

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

ITA 1283/HYD/2025[2017-18]Status: HeardITAT Hyderabad08 Oct 2025AY 2017-18

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 139(1)Section 142(1)Section 144(1)Section 144BSection 147Section 148Section 148ASection 151ASection 69A

material on record, and had gone through the orders of the authorities below. There is no dispute with regard to the fact that the reassessment proceedings before the A.O. are ex parte because, the assessee neither filed the return of income in response to the notice issued under Section ... grounds taken by the assessee. 11. We further make it clear that, the assessee is at liberty to challenge the legality of the reassessment proceedings initiated by the A.O. consequent to the notice issued under Section 148 of the Act, by the jurisdictional A.O. in the consequent assessment proceedings

Sesham Ramanaiah, Prakasam vs. ITO., Ward-1, Ongole

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

ITA 1062/HYD/2025[2016-17]Status: FixedITAT Hyderabad08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Ms. Swathi Sheela, C.AFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139Section 147Section 148Section 69Section 69A

response, the assessee filed return of income on 05.10.2023, declaring income of Rs.3,98,584/- for A.Y. 2016–17. During the reassessment proceedings, the Learned Assessing Officer (“Ld. AO”) noticed cash deposits of Rs.25,00,000/- in the assessee’s Syndicate Bank account. On being called upon to explain

A R Udyog, Howrah vs. ITO, Ward 46(3), Kolkata

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

ITA 1166/KOL/2025[2011-2012]Status: DisposedITAT Kolkata08 Oct 2025AY 2011-2012

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139Section 144Section 148Section 250Section 68

said to be valid. [Para 13] a In the instant case, admittedly, the assessee did not appear before the Assessing Officer during the reassessment proceedings to prove the deduction claimed for purchases. There is no justification for non- appearance before the Assessing Officer to establish the purchases. The plea ... details before making the addition. Such a conduct of the assessee cannot be accepted. It was incumbent upon the assessee to have joined the reassessment proceedings, discharge the initial onus of proving the purchases and seek details, if any. Having not joined the reassessment proceedings, the contentions raised

R. Jayanna HUF, Bengaluru vs. DCIT, Central Circle-2(2), Bangalore

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

ITA 986/BANG/2025[2013-14]Status: DisposedITAT Bangalore08 Oct 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2013-14

For Appellant: Shri Raghavendra Chakravarthy, CAFor Respondent: Shri Balusamy N, JCIT (DR)
Section 139Section 147Section 148Section 2(47)Section 54F

first time during appellate proceedings is not allowable because of the following reasons; (A) First and foremost, such a claim in the reassessment proceedings is not maintainable in view of a plethora of judgements. Most importantly, as per CIT v. Sun Engineering Works ... claims unrelated to the original assessments. (a) The appellant failed to claim Section 54F in their original return (filed under Section 139) or during reassessment proceedings. Raising it now violates the principle that reassessment is not a "second chance" to rectify omissions. . Page 3 of 6 (b) The said judgement

Income Tax Officer, Piramal Chambers vs. Soni Ajay Jain, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3841/MUM/2025[2016-17]Status: DisposedITAT Mumbai08 Oct 2025AY 2016-17

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankar

For Appellant: Shri G. V. GindeFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 10(38)Section 147Section 148Section 148ASection 149Section 151Section 250

notice under section 148 of the Act was issued by the Jurisdictional Assessing officer. After considering the submissions of the assessee filed during the reassessment proceeding, the AO passed the order dated 19.05.2023 under section 147 read with section 144 read with section 144B of the Act assessing the total ... Principal Commissioner of Income Tax. Accordingly, as per the assessee, the Revenue has not followed the mandatory provisions of the Act while initiating the reassessment proceedings, and the sanction of the Specified Authority is not in conformity with the law prevalent at the time of grant of sanction

Shri Malkiat Singh, Delhi vs. CIT(Appeal), Delhi

In the result, this appeal of assessee is allowed

ITA 4366/DEL/2025[2017-18]Status: DisposedITAT Delhi08 Oct 2025AY 2017-18

Bench: Shri Mahavir Singhshri Malkiat Singh, Vs.Ito, Ward 45(1), Wz 46/3B, Krishna Puri, New Delhi Gali No. 1, Tilak Nagar, Delhi – 110 018 (Pan:Bsrps2158H) (Appellant) (Respondent) Appellant By : Sh. P.K. Bansal, Adv. & Sh. Tarun Sharma, Ca Respondent By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 09.09.2025 Date Of Pronouncement 08.10.2025 Order

For Appellant: Sh. P.K. Bansal, Adv. & Sh. Tarun Sharma, CAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 1Section 139(1)Section 147Section 148Section 148ASection 149Section 149(1)(a)Section 149(1)(b)Section 194C

this appeal of the assessee is as regards to order of NFAC confirming the action of the Assessing Officer in upholding the validity of reassessment proceedings initiated u/s. 147 r.w.s. 148 of the Act, although the reopening is barred by limitation being escaped income was less than Rs. 50 lacs ... assessee has raised the following two grounds:- (i) That the NFAC has erred in law and on facts in upholding the validity of reassessment proceedings initiated under section 148 of the Act without appreciating that the notice under section 148 was issued beyond the limitation prescribed under section

Huawei International Pte Ltd, Singapore vs. ACIT-Circle 2(1)(1), Intl. Tax, New Delhi

In the result, the appeal of the assessee is allowed and stay application of 7

ITA 2648/DEL/2025[2014-15]Status: DisposedITAT Delhi08 Oct 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganesh & Sa 298/Del/2025 (Assessment Year: 2014-15) Huawei International Pte. Ltd, Vs. Acit, 51, Change Business Park, Circle-2(1)(1), Central-2, #07-08, The International Signature, Singapore Taxation, New Delhi (Appellant) (Respondent) Pan: Aacch3694N Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Aggarwal, Adv Shri Yash Nagar, Adv Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 01/10/2025 Date Of Pronouncement 08/10/2025

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri M. s. Nethrapal, CIT DR
Section 144CSection 147Section 148Section 148ASection 149

298/Del/2025 Huawei International Pte. Ltd Therefore, necessary provision are duly met by assessee company, which reflects that the said income has escaped assessment. A.3 Reassessment proceedings are not valid as per new regime (amended by Finance Act, 2021) as the reassessment proceedings were initiated merely on the basis of information ... separately in proceedings u/s 147 of the Act. The assessee will get ample opportunities to explain the case u/s 147 of the Act (during reassessment proceedings). Reliance is again placed on case of Raymond Mills (SC), where it was held that the AO just needs a prima facie satisfaction

Kataria Snack Pellets Private Limited, Rajkot vs. Assistant Commissioner of Income Tax, Circle-1(1), Rajkot

In the result, appeal of the assessee is dismissed

ITA 468/RJT/2024[2015-16]Status: DisposedITAT Rajkot07 Oct 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.468/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Kataria Snack Pellets Pvt. Ltd. The Acit, Circle-1(1) बनाम 510, Gidc, Metoda Kalawad Road Rajkot Rajkot-360021, Gujarat Vs. Pan : Aafck2028L (अपीलाथ"/Appellant) (""यथ"/Respondent) :

For Appellant: Shri Nishit B. Jesur, ld.ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

vide letter dated 13.05.2021. The objection of the assesse was disposed of by passing a speaking order, by the assessing officer. 5. During the reassessment proceedings, it was noticed by the assessing officer that the assessee has issued 8000 share, whose face value is Rs. 10 and at a premium

Kaminiben Gemalsinh Thakor, Surat vs. ITO, Ward 1(3)(7), Surat

ITA 610/SRT/2025[2009-10]Status: DisposedITAT Surat07 Oct 2025AY 2009-10

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Kaminiben Gemalshinh Thakor, Ito Ward 1(3)(7), B-11, Sun Light Complex, B/H Room No. 306, Income Tax Office, Bhulka Bhavan, Anand Mahal Vs. Anavil Business Centre, Adajan Road,, Adajan, Surat-395009. Hazira Road, Adajan, Surat-395007. Pan No. Aclpt 5623 P Appellant Respondent

For Appellant: None for AssesseeFor Respondent: Mr. J.K. Chandnani, Sr. Dr
Section 147Section 148Section 250Section 50C

response, the assessee filed a return of income on 31.07.2016 declaring a total income of ₹2,82,450/-. During the reassessment proceedings, the Assessing Officer noticed that the assessee had not declared the capital gain arising from the sale of a property, and further that the sale consideration declared

Jitubhai Narottambhai Patel, Na vs. Arivs.Income Tax Officer, NFAC

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

ITA 606/SRT/2025[2019-20]Status: HeardITAT Surat07 Oct 2025AY 2019-20

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2019-2020 Jitubhai Narottambhai Patel, Ito Kumbhar Faliya,Gopivadi, Satem, New Delhi, New Delh110001. Navsari-396466. Vs. Pan No. Ablpp 4256 B Appellant Respondent : None For Assessee Assessee By : Ms. Namita Patel, Sr. Dr Revenue By Date Of Hearing : 06/10/2025 Date Of Pronouncement : 07/10/2025

For Appellant: Ms. Namita Patel, Sr. DRFor Respondent: None for
Section 142(1)Section 144Section 272A(1)(d)Section 273B

compliance with the notices issued under section 142(1) of the Act. The Assessing Officer, in the impugned penalty order, recorded that during the reassessment proceedings, it was noticed that the assessee had deposited cash of Rs. 24,35,000/- in his account maintained with the Bank of Baroda

Jayantibhai Dahyabhai Patel, Bharuch vs. Income Tax Officer, Faceless Assessment Unit

In the result, the appeal of the assessee is dismissed

ITA 408/SRT/2025[2012-13]Status: HeardITAT Surat07 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-2013 Jayantibhai Dahyabhai Patel, Ito, New Delhi, 283, Padm Punj, Siddhanth Bharuch-392001. Nagar Soceity, Gujarat Housing Vs. Board, Bharuch-392001. Pan No. Aebpp 3770 P Appellant Respondent : None For Assessee Assessee By : Ms. Namita Patel, Sr. Dr Revenue By : 06/10/2025 Date Of Hearing : 07/10/2025 Date Of Pronouncement

For Appellant: Ms. Namita Patel, Sr. DRFor Respondent: None for
Section 143(3)Section 147Section 271(1)Section 271(1)(c)

Departmental Representative (DR) and perusing the record with due care. 3. On perusal of the assessment records, it transpires that the reassessment proceedings under section 147 read with section 143(3) of the Act were completed on 12.12.2019, wherein the Assessing Officer made an addition of ₹5,25,000/- representing

Jagdish Solanki, Jhabua vs. Income Tax Officer Jhabua, Jhabua

ITA 169/IND/2025[2017-18]Status: DisposedITAT Indore07 Oct 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Sanjay Jayantilal Shah, Ahmedabad vs. The ITO, Ward-2(1)(1), Ahmedabad

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

ITA 79/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad07 Oct 2025AY 2014-15

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2014-2015 Sanjay Jayantilal Shah Ito, Ward-2(1)(1) 202/A, Shivalik 10 Vs. Vejalpur Opp: Sbi Zonal Office Ahmedabad. Ambawadi, Ahmedabad 380 015 Pan : Aktps 8891 A (Applicant) (Responent) : Assessee By Shri S.N. Divatia & Shri Samir Vora, Ars. : Shri Kalpesh Rupavatia, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश/O R D E R आदेश आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 29.11.2024 Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As "Cit(A)"], For The Assessment Year 2014–15, Arising Out Of The Assessment Order Dated 31.03.2022 Passed U/S 147 Read With Section 144B Of The Income-Tax Act, 1961 (Hereinafter Referred To As "The Act") By The National Faceless Assessment Centre, Delhi [Hereinafter Referred To As "Assessing Officer Or Ao"].

Section 10(38)Section 144BSection 147Section 148Section 234ASection 271(1)(c)Section 68Section 69C

Income Tax Department, the case of the assessee was reopened by issue of notice u/s 148 on 30.03.2021. 2.2 During the course of reassessment proceedings, the Assessing Officer noted that the assessee had sold 24,800 equity shares of M/s. Looks Health Services Ltd. for a total consideration of Rs.1

Smt. Ritu Soin, Ludhiana vs. ACIT, CC-II, Ludhiana

In the result, both the appeals are allowed

ITA 305/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh06 Oct 2025AY 2012-13
For Appellant: Shri Ashwani Kumar, CA andFor Respondent: Smt. Kusum Bansal, CIT DR
Section 10(38)Section 143(3)Section 153ASection 153DSection 263

both the appeal that search action was carried out on the assessee on 4.10.2012 and at the time of search action no assessment or reassessment proceedings were pending is undisputed. It is also not disputed that no incriminating documents or record or any other evidence was found or seized during

Huhtamaki India Limited (Vista Film and Packaging Private Limited Merged Into Positive Packaging Industries Limited Which in Turn Merged Into Hutamaki India Limited), Mumbai vs. Dy Commissioner of Income Tax 14(1)(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 3365/MUM/2025[2008-09]Status: DisposedITAT Mumbai06 Oct 2025AY 2008-09

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarhuhtamaki India Limited V/S. Deputy Commissioner Of (Vista Film & Packaging Pvt Ltd बनाम Income Tax, Ward – Merged Into Positive Packaging 14(1)(1), Aayakar Bhavan, Industries Ltd. Which In Turn Merged Maharishi Karve Road, New Limited), 7Th Into Huhtamaki India Marine Lines, Mumbai – Floor, Bellona, The Walk, 400020, Maharashtra Hiranandani Estate, Ghodbunder Road, Sandozbaugh, Thane– 400 607, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaact0086E Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: NoneFor Respondent: Shri Hemanshu Joshi, (Sr. DR)
Section 143(3)Section 147Section 148

case. as well as in law, the learned CIT(A) erred in confirming the action of the learned AO, inasmuch as the reassessment proceedings initiated under section 147 of the Act and the consequential order dated 26th March 2014 passed under section 147 read with section

Amrit Corporation, Mumbai vs. DCIT-CC-1(1), Mumbai

ITA 1661/MUM/2025[2021-2022]Status: DisposedITAT Mumbai06 Oct 2025AY 2021-2022

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Aditya M. RaiFor Respondent: Shri Jayant Bhatt
Section 148Section 69C

principles of natural justice for affording an opportunity to the appellant to cross examine the alleged evidences collated and relied upon in the reassessment proceedings. 5. The appellant craves right to alter, amend, withdraw or substitute any ground or grounds or to add any new ground or grounds of appeal