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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

Sri Ksheera Ramalingeswara Swamy Temple, Palakol vs. Income Tax Officer (Exemptions), Rajahmundry

ITA 199/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam30 Sept 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.199/Viz/2023 (िनधा"रण वष"/Assessment Year: 2017-18) Sri Ksheera Ramalingeswara Vs. Income Tax Officer Swamy Temple, (Exemptions), Palakol. Rajahmundry. Pan: Aakas5615E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 24/09/2025 घोषणा की तारीख/Date Of 30/09/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 15/05/2023, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 144 Of The Income Tax Act, 1961 (For Short, “Act”), Dated 28/12/2019 For A.Y. 2017-18. 2 I Sri Ksheera Ramalingeswara Swamy Temple Vs. Ito (Exemptions)

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 10Section 11Section 12ASection 142(1)Section 143(2)Section 144

held that where the A.O did not issue notice u/s.143(2) of the Act upon the assessee, then the initiation of reassessment proceedings; order rejecting the assessee’s objection against the assumption of jurisdiction for reopening and also the reference to the TPO were to be quashed. 20. Apropos

Lalit Kumar Jain, Alwar vs. ITO Ward, 1(2), Alwar

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

ITA 1126/JPR/2025[2018-2019]Status: DisposedITAT Jaipur30 Sept 2025AY 2018-2019

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

For Appellant: Shri Rohan Sogani, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 147Section 148Section 151Section 69

/NFAC is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by quashing the reassessment proceedings being without jurisdiction. 4 In the facts and circumstances of the case and in law, Id. CIT(A)/NFAC has erred in confirming the action

Late Ashvinbhai Umedbhai Patel (Deceased) by Legal Heir Smit Ashvinbhai Patel, Kheda vs. The ITO, Ward-1, Nadiad

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

ITA 1106/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad30 Sept 2025AY 2011-12
Section 271(1)Section 271CSection 69Section 69A

held now. 3. The ld NFAC/CIT(A) further grievously erred in law and on facts in not appreciating that the very reassessment proceedings initiated were without jurisdiction in view of legal position decided by binding judgments that deposit in bank account cannot be a reason to believe that such deposits ... under section 148 was issued much later on 28.03.2018. Since the assessee was already deceased at the time of issue of notice, the entire reassessment proceedings are void ab initio and a nullity in the eyes of law. The Counsel emphasized that there is no legal obligation on the part

Late Ashvinbhai Umedbhai Patel (Deceased) by Legal Heir Smit Ashvinbhai Patel, Kheda vs. The ITO, Ward-1, Nadiad

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

ITA 1105/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad30 Sept 2025AY 2011-12
Section 271(1)Section 271CSection 69Section 69A

held now. 3. The ld NFAC/CIT(A) further grievously erred in law and on facts in not appreciating that the very reassessment proceedings initiated were without jurisdiction in view of legal position decided by binding judgments that deposit in bank account cannot be a reason to believe that such deposits ... under section 148 was issued much later on 28.03.2018. Since the assessee was already deceased at the time of issue of notice, the entire reassessment proceedings are void ab initio and a nullity in the eyes of law. The Counsel emphasized that there is no legal obligation on the part

Deputy Commissioner of Income-Tax vs. The Jawaharlal Nehru Port Trust, Raigad

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 545/PUN/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Counsel for the assessee that once the said return and audit report in required form has been submitted before the Assessing Officer in the reassessment proceedings, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision ... Engineering Works (P.) Ltd. 198 ITR 297 (SC), we are not in agreement with the contention of the Ld. DR that in the reassessment proceedings under section 148, no deduction can be allowed in respect of the income which has escaped assessment. In reassessment proceedings even the income which

Deputy Commissioner of Income-Tax vs. The Jawaharlal Nehru Port Trust, Raigad

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Counsel for the assessee that once the said return and audit report in required form has been submitted before the Assessing Officer in the reassessment proceedings, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision ... Engineering Works (P.) Ltd. 198 ITR 297 (SC), we are not in agreement with the contention of the Ld. DR that in the reassessment proceedings under section 148, no deduction can be allowed in respect of the income which has escaped assessment. In reassessment proceedings even the income which

Deputy Commissioner of Income-Tax vs. The Jawaharlal Nehru Port Trust, Raigad

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Counsel for the assessee that once the said return and audit report in required form has been submitted before the Assessing Officer in the reassessment proceedings, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision ... Engineering Works (P.) Ltd. 198 ITR 297 (SC), we are not in agreement with the contention of the Ld. DR that in the reassessment proceedings under section 148, no deduction can be allowed in respect of the income which has escaped assessment. In reassessment proceedings even the income which

Jawahar Lal Nehru Port Trust, Navi Mumbai vs. ACIT Panvel, Panvel

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Counsel for the assessee that once the said return and audit report in required form has been submitted before the Assessing Officer in the reassessment proceedings, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision ... Engineering Works (P.) Ltd. 198 ITR 297 (SC), we are not in agreement with the contention of the Ld. DR that in the reassessment proceedings under section 148, no deduction can be allowed in respect of the income which has escaped assessment. In reassessment proceedings even the income which

Jawahar Lal Nehru Port Trust, Navi Mumbai vs. ACIT Panvel, Panvel

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Counsel for the assessee that once the said return and audit report in required form has been submitted before the Assessing Officer in the reassessment proceedings, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision ... Engineering Works (P.) Ltd. 198 ITR 297 (SC), we are not in agreement with the contention of the Ld. DR that in the reassessment proceedings under section 148, no deduction can be allowed in respect of the income which has escaped assessment. In reassessment proceedings even the income which

Jawahar Lal Nehru Port Trust, Navi Mumbai vs. ACIT Panvel, Panvel

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1153/MUM/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Counsel for the assessee that once the said return and audit report in required form has been submitted before the Assessing Officer in the reassessment proceedings, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision ... Engineering Works (P.) Ltd. 198 ITR 297 (SC), we are not in agreement with the contention of the Ld. DR that in the reassessment proceedings under section 148, no deduction can be allowed in respect of the income which has escaped assessment. In reassessment proceedings even the income which

Baljit Singh Gambhir, Mumbai vs. Income Tax Officer, International Taxation, Ward-2(3)(1), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 912/MUM/2025[2019-20 ]Status: DisposedITAT Mumbai30 Sept 2025

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.912/Mum/2025 (निर्धारण वर्ा/Assessment Year: 2019-20) Baljit Singh Gambhir V/S. Income Tax Officer, C/O Tejmohan Singh, बिधम International Taxation, Advocate 527, Sector Ward 2(3)(1), Mumbai 10-D, Chandigarh Income Tax Officer, 160011 International Taxation, Ward 2(3)(1), Mumbai 400076 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No: Amgpg9637H Appellant/अपीलधथी .. Respondent/प्रनिवधदी निर्धाररिी की ओर से /Assessee By: Shri. Tejomohan Singh, Adv. रधजस्व की ओर से /Revenue By: Shri. Krishna Kumar (Sr Dr) सुिवधई की िधरीख / Date Of Hearing 29.07.2025 घोर्णध की िधरीख/Date Of Pronouncement 30.09.2025

For Appellant: Shri. Tejomohan Singh, AdvFor Respondent: Shri. Krishna Kumar (SR DR)
Section 144C(5)Section 148Section 148A

declaring income of Rs. 20,41,680/- for A.Y. 2019-20. Subsequently, on the basis of information available on Insight Portal of the department, reassessment proceedings were initiated. Vide order u/s. 148 A(d) dated 31.03.2023, the case was found fit for issuance of notice u/s. 148 which was also ... legal grounds challenging the validity of notice issued by JAO while the same was required to be issued by FAO and initiation of reassessment proceedings on the ground that no addition remains on the reason for which proceedings u/s. 148A were initiated. Since the assessee’s grounds on merit have

Income Tax Officer Ward-22(1)(1), Mumbai vs. Gopal Ramchand Kanjani, Mumbaifh

ITA 733/MUM/2025[2012]Status: DisposedITAT Mumbai30 Sept 2025

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri M. Subramaniam, AR
Section 143(1)Section 147Section 148Section 250Section 69C

/Mum/2025 Gopal Ramchand Kanjani at similar diamond traders like Gautam Jain and others. During the course of reassessment proceedings, the assessee could not file the invoice bills before the AO. For this, the assessee submits that his regular business building known as Bhagwan Dham was demolished as per Mumbai High

Chattanathan Devarajan, Mumbai vs. Income Tax Officer 34(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4976/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Sept 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2014-15 Chattanathan Devarajan Income Tax Officer - 34(1)(1) 1101, Raheja Tipco Heights Mumbai Rani Sati Marg, Vs. Malad East Mumbai – 400067 (Pan: Abjpc6332P) (Assessee) (Respondent)

For Appellant: Shri Haridas Bhat, CAFor Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 147Section 148Section 156Section 192Section 194Section 194ASection 271(1)(c)

said notice, assessee filed his return of income on 04.05.2021, reporting total income at Rs.88,21,870/-. 3.2. In the course of reassessment proceedings, ld. Assessing Officer noted that on verification of Form 26AS and interest certificate issued by ICICI Bank, certain interest on fixed deposits were not included

Setron Textile Mills Pvt Ltd, Mumbai vs. Income Tax Officer, Ward 4(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 4847/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Sept 2025AY 2014-15

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

Section 143Section 147Section 148

Supreme Court in the case of Raymond Woollen Mills Ltd. v. ITO [(1999) 236 ITR 34 (SC)] held that for initiation of reassessment proceedings, it is sufficient if there is a prima facie reason to believe that income has escaped assessment; the adequacy or correctness of the material cannot ... reasons were provided to the appellant. The appellant's objections were duly disposed of by the AO by passing a speaking order. Thus, the reassessment proceedings are in line with law and cannot be termed invalid. Therefore, ground no. 1 & 2 of the appeal are dismissed and not allowed

M/S. Fortune Gourmet Specialities Private Limited, Mumbai vs. ACIT Circle 6(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4191/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Sept 2025AY 2016-17

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrim/S. Fortune Gourment Vs. Acit Circle 6(3)(1) Specialities Private Limited Aayakar Bhavan, 107 Adhyaru Industrial Mumbai-400020. Estate, Sun Mill Comound, Lower Parel, Mumbai-400013. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacf4952B Appellant .. Respondent

For Appellant: Shri Gunjan KakkadFor Respondent: Ms. Kavitha Kaushik (Sr. DR)
Section 14Section 143(3)Section 147Section 14ASection 250

assessee furnished return in response to this notice on 28.05.2021 declaring income of Rs. 5,84,32,231/-. During the reassessment proceedings, after considering the assessee’s objection total expenditure related to exempt income was worked out at Rs. 11,76,409/-. Taking into account, the suo moto disallowance

Mangala Shivadas Dindokar, Thane vs. Income Tax Officer, 41(1)(3), Mumbai

ITA 3438/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Sept 2025AY 2015-16

Bench: Shri Pawan Singh (Jm) & Shri Omkareshwar Chidara (Am) Mangala Shivadas Dindokar Ito-41(1)(3) 1301, G Wing, Palacia, 607, Kautilya Ghodbunder Road, Vs. Bhavan, G Block Hiranandani Estate, Thane Bandra Kurla Maharashtra-400 615. Complex, Bandra E Mumbai-400 051. Pan : Ahppd0620B Appellant Respondent

For Appellant: Shri Annavaran KosuriFor Respondent: Shri Kumar Kale
Section 139(1)Section 148Section 148ASection 54

supra) specifically says that the claims not connected with the income which is to be taxed only should not be entertained during the reassessment proceedings. In view of the same, the appellant is entitled to claim deduction under section 54 of the Act as per law. With these directions

Poornima Sanjay Prabhu, Mumbai vs. Assessment Unit, Faceless Assessment Centre

In the result, the appeal of the assessee is allowed

ITA 2006/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Sept 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. RENU JAUHRI (Accountant Member)

Section 115BSection 143(1)Section 147Section 148Section 194ISection 6Section 69

addition of ₹1,76,16,200/– is arbitrary, contrary to evidence, and unsustainable in law. 10.6 Without prejudice, it was further contended that the reassessment proceedings themselves are invalid ab initio. The notice u/s 148 dated 30/06/2021 was issued without jurisdiction, since there was no tangible material to suggest escapement

Praful Arjun Rane, Mumbai vs. ITO Int Tax Ward-4(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1046/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Sept 2025AY 2015-16

Bench: SHRI SAKTIJIT DEY, HON’BLE (Vice President), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Bhupendra Shah, CAFor Respondent: Shri Krishna Kumar, Sr. DR
Section 10Section 144C(5)Section 147Section 148Section 148ASection 18Section 56Section 69

regime is barred by limitation and hence bad in law, liable to be quashed, resulting in impugned reassessment proceedings as well as the impugned reassessment order bad in law. Accordingly, additional ground raised by the assessee is allowed. 16 Praful Arjun Rane AY 2015-16 12.4. Since, the impugned order

Chirag Kirpal, Delhi vs. Assistant Commissioner of Income Tax, International Taxation, Gurgaon

In the result, the appeal of the assessee is allowed

ITA 656/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Sept 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri Vimal Kumarchirag Kirpal, Vs. Acit, C/O. Anuj Bhatia, C-3, Bali International Taxation, Nagar, New Raja Garden, Gurgaon New Delhi (Appellant) (Respondent) Pan: Bwxpk8788D Assessee By : Shri. S. K. Gupta, Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 30/09/2025

For Appellant: Shri. S. K. Gupta, CAFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 139Section 143(2)Section 144BSection 144C(1)Section 144C(13)Section 144C(5)Section 147Section 148Section 148ASection 151

Officer instead of the Faceless Assessing Officer (FAO) and whether the non-issuance of the statutory notice by the FAO would vitiate the entire reassessment proceedings. The provisions of section 151 A of the Act mandates that the notice under section 148 of the Act could be issued ... Learned JAO is hereby quashed and hence the assumption of jurisdiction by the assessing officer has been invalidly made which vitiates the entire reassessment proceedings. The reassessment proceedings are hereby quashed. Accordingly, the Ground No. 1 raised by the assessee is hereby allowed. 10. Since the entire reassessment is quashed

Assistant Commissioner of Income Tax, Central Circle-19, Delhi, New Delhi vs. M/S Jkm Infra Projects Ltd., Noida, Uttar Pradesh

In the result, the appeal of the revenue is dismissed and Cross

ITA 3031/DEL/2025[2013-14]Status: DisposedITAT Delhi30 Sept 2025AY 2013-14

Bench: Shri M. Balaganesh & Shri Sudhir Kumaracit, Vs. M/S. Jkm Infra Projects Ltd, Central Circle-19, Sector-9, Noida Delhi Maharishinagar, Maharishi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H Co 132/Del/2025 (In Ita No. 3031/Del/2025) (Assessment Year: 2013-14) M/S. Jkm Infra Projects Ltd, Vs. Acit, Sector-9, Noida Central Circle-19, Maharishinagar, Maharishi Delhi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 143(3)Section 147Section 148Section 149Section 149(1)Section 149(1)(b)

present petition, inter alia, impugning a notice dated 21.03.2024 [impugned notice] issued under Section 148 of the Income Tax Act, 1961 [Act] and the reassessment proceedings conducted pursuant to the impugned notice. It is the petitioner's case that the impugned notice is barred by limitation and therefore, the reassessment ... cannot be made and accordingly the notice issued under section 148 of the Act dated 23-4- 2021 is barred by limitation. Consequentially, the reassessment proceedings are hereby quashed. Accordingly, the Ground No. 3 raised by the assessee in its Cross Objection is allowed. CO 132/Del/2025 M/s. JKM Infra Projects