“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

Bajranglal Bhawarlal Sharma, Borivali East vs. Income Tax Officer, Kautilya Bhavan

ITA 285/MUM/2026[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajesh SalujaFor Respondent: Shri Aditya Rai

Section 143(3)Section 144BSection 147Section 148Section 148ASection 50CSection 50C(2)

148A(d) of the Act and issuing notice dated 31/07/2022, the Assessing Officer obtained approval/sanction from the Principal Commissioner of Income Tax, Mumbai. The reassessment proceedings culminated into passing of the Assessment Order, dated 22/05/2023, under Section 147 read with Section 144B of the Act. The appeal preferred ... without complying with the jurisdictional and mandatory requirements and conditions envisaged in section 147/148/151 of the IT Act, 1961 and therefore the entire Reassessment proceedings under section 147 are liable to be quashed. 2 Assessment Year 2017-2018 2. On the facts and in the circumstances of the case

Sapna Umesh Dutta, Mumbai vs. ITO Ward, 41(2)(5), Mumbai

ITA 263/MUM/2026[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: passing Order, under Section 148A(d) of the Act and issuing notice dated 31/07/2022, the Assessing Officer obtained approval/sanction from the Principal Commissioner of Income Tax, Mumbai. The reassessment proceedings culminated into passing of the Assessment Order, dated 23/05/2023, under Section 147 of the Act. The appeal preferred by the Assessee against the aforesaid Assessment Order was dismissed by the CIT(A) vide Order, dated 27/11/2025. Being aggrieved, the Assessee has preferred th

For Appellant: Shri Tanmay PhadkeFor Respondent: Shri Aditya Rai

Section 147Section 148Section 148ASection 151Section 151A

148A(d) of the Act and issuing notice dated 31/07/2022, the Assessing Officer obtained approval/sanction from the Principal Commissioner of Income Tax, Mumbai. The reassessment proceedings culminated into passing of the Assessment Order, dated 23/05/2023, under Section 147 of the Act. The appeal preferred by the Assessee against the aforesaid ... that the notice originally issued under Section 148 of the Act (old regime) was issued after obtaining sanction from appropriate authority. Therefore, the reassessment proceedings were validly initiated and the same could not be regarded as bad in law. Thus, in the facts and circumstances of the present case

Hemaben Babubhai Parekh, Mumbai vs. DCIT 19(1), Mumbai

ITA 8549/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Ms. Sneha KothariFor Respondent: Shri Bhagirath Ramawat

Section 139(1)Section 144BSection 147Section 148Section 80G

under Section 80GGC of the Act towards donation made to political party (i.e., Kisan Party of India) amounting to INR.2,00,000/-. When the reassessment proceedings were initiated in the case of the Assessee, the Assessee filed return of income on 19/05/2023 in response to notice issued under Section ... under Section 80GGC of the Act (as claimed in the original return of income). 5. The contention of the Assessee is that during the reassessment proceedings the Assessee had pointed out to the Assessing Officer that 2 Assessment Year 2019-2020 the Assessee had offered additional income of INR.200

Shri Bhagwan Agarwal(Legal Heir of Sunita Agarwal, Mumbai vs. ITO Ward 26(2)(1), Mumbai

Accordingly, we delete the addition INR.2,96,133/- made by the Assessing Officer under Section 69C of the Act. Thus, Ground No. 4 to 4.2 raised by the Assessee are allowed

ITA 8537/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Feb 2026AY 2014-15

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Ms. Dinkle Hariya &For Respondent: Shri Bhagirath Ramawat

Section 144Section 144BSection 147Section 69C

referred to as ‘the Act’] for the Assessment Year 2014- 2015. 2. The relevant facts in brief are that in the case of Assessee reassessment proceedings were initiated for the Assessment Year Assessment Year 2014-2015 2014-2015. On receiving information from the Investigation Wing to the effect that Assessee

Sheetal Rajeev Gadre, Mumbai vs. ITO Ward 34(3)(2), Mumbai

ITA 8534/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Ashish ThakurdesaiFor Respondent: Shri Bhagirath Ramawat

Section 115BSection 144Section 144BSection 147Section 148ASection 151ASection 68

took accommodation entries and earned bogus Long Term Capital Gain/ Short Term Capital Loss in trading of penny script. OASIS TRADELINK LTD. During the reassessment proceedings the 2 Assessment Year 2018-2019 Asessee didn't offer any explanation for the bogus LTCG/STCL made by her. Since the Assessee ... appeal, written submissions. and all material available on record. 6.1 Challenging the jurisdiction of the AO 6.1.1 The assessee has challenged the validity of reassessment proceedings mainly on the grounds that the notice u/s 148A(b) and 148 was issued by the jurisdictional AO and not under the faceless mechanism

Jesaram Purohit, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

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

ITA 8345/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law, L.d

Section 132Section 132(4)Section 153CSection 69

correct and authenticated to the extent assessee paid ‘on-money’ in cash, no addition can be made and even otherwise during the entire reassessment proceedings the veracity and reliability of the data recorded in the pendrive was not checked or tested. Therefore, in such a scenario no addition is warranted

Juararam Chogaji Purohit, Mumbai vs. DCIT Central Circle, Mumbai

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

ITA 8193/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law

Section 153CSection 69

Juararam Chogaji Purohit, Mumbai vs. DCIT Central Circle 4(2), Mumbai

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

ITA 8192/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law

Section 153CSection 69

Juararam Chogaji Purohit, Mumbai vs. DCIT Central Circle 4(2), Mumbai

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

ITA 8191/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law

Section 153CSection 69

Ummesalma Huzefa Ghadiali, Mumbai vs. DCIT-Central Circle 4(2), Mumbai

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

ITA 8187/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the Appellant's case and in law the Id. CIT

Section 132(4)Section 153C

Ummesalma Huzefa Ghadiali, Mumbai vs. DCIT-Central Circle 4(2), Mumbai

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

ITA 8186/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the Appellant's case and in law the Id. CIT

Section 132(4)Section 153C

Kishor Changya Patil, Mumbai vs. ITO41(1)(2), Mumbai

In the result, both appeals filed by the assessee are allowed for statistical purposes

ITA 7938/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Shri Amit Shukla () & Shri Girish Agrawal ()

Section 144Section 147Section 271A

Hearing 25.02.2026 Date of Pronouncement 26.02.2026 ORDER PER AMIT SHUKLA (J.M.): 1. These two appeals by the assessee arise out of the same reassessment proceedings framed under section 147 read with section 144 of the Income Tax Act, 1961 for Assessment Year 2019-20. The first appeal is directed against

Kishor Changya Patil, Mumbai vs. ITO41(1)(2), Mumbai

In the result, both appeals filed by the assessee are allowed for statistical purposes

ITA 7937/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Shri Amit Shukla () & Shri Girish Agrawal ()

Section 144Section 147Section 271A

Jinal Akshay Jain, Mumbai vs. Deputy Commissioner of Income-Tax (DCIT), Central Circle-4(2), Mumbai

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

ITA 6737/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Feb 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. This appeal is directed against the

Section 132Section 132(4)Section 143(3)Section 153CSection 250Section 69

Jinal Akshay Jain, Mumbai vs. Deputy Commissioner of Income-Tax (DCIT), Central Circle-4(2), Mumbai

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

ITA 6736/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. This appeal is directed against the

Section 132Section 132(4)Section 143(3)Section 153CSection 250Section 69

ITO 13(2)(1), Mumbai vs. Ska Sales Private Limited, Mumbai

ITA 5967/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Prakash Jhunjhunwala &For Respondent: Shri Nakul Agrawal

Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C

formed a belief that for the Assessment Year 2017-2018 income to the extent of INR.3,32,57,605/- had escaped assessments and therefore, reassessment proceedings were initiated in the case of the Assessee. The aforesaid proceedings culminated to passing of the Assessment Order under Section ... appeal preferred by the Assessee against the above Assessment Order, dated 28/03/2022, the Learned CIT(A) upheld the validity of the reassessment proceedings. However, the Learned CIT(A) granted substantial relief to the Assessee on merits by restricting Assessment Year 2017-2018 the addition made under Section

Ska Sales Pvt Ltd, Mumbai vs. Income Tax Officsr, Ward 13(2)(1), Mumbai

ITA 5527/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C

formed a belief that for the Assessment Year 2017-2018 income to the extent of INR.3,32,57,605/- had escaped assessments and therefore, reassessment proceedings were initiated in the case of the Assessee. The aforesaid proceedings culminated to passing of the Assessment Order under Section ... appeal preferred by the Assessee against the above Assessment Order, dated 28/03/2022, the Learned CIT(A) upheld the validity of the reassessment proceedings. However, the Learned CIT(A) granted substantial relief to the Assessee on merits by restricting the addition made under Section 68 of the Act in respect

Dy. Commissioner of Income-Tax-1(1)(1), Mumbai vs. M/S. Hindustan Petroleum Corporation Limited, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3866/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Feb 2026AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawaldy. Commissioner Of Income- Vs Hindustan Petroleum Tax-1(1)(1), Corporation Limited Mumbai Petroleum House Jamshedji Tata Road, Marine Lines S.O Mumbai - 400020 (Pan: Aaach1118B) Appellant Respondent Present For: Assessee By : Ms. Hirali Desai, Ca Revenue By : Shri Ritesh Misra, Cit Dr Date Of Hearing : 23.02.2026 Date Of Pronouncement : 26.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2024-25/1075143492(1) Dated 27.03.2025 Passed Against The Assessment Order By The Assessment Unit, U/S. 147 R.W.S. 144 Read With Sec. 144B Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 25.05.2023 For Ay 2015-16. 2. Grounds Taken By The Revenue Are Reproduced As Under: “. Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Erred In Deleting The Addition Of Rs. 9,60,00,000/ - On Account Of Disallowance Of Investment Allowance Claimed U/S. 32Ac On Dispensing Units In Retail Outlets Ignoring The Fact That The Dispensing Units Do Not Fall Within The Meaning Of Plant & Hence, Not Eligible For Claim Of Deduction U/S. 32Ac.

For Appellant: Ms. Hirali Desai, CAFor Respondent: Shri Ritesh Misra, CIT DR

Section 115JSection 144BSection 147Section 148Section 151ASection 32A

kept open. In this respect, assessee had filed additional grounds before the ld. CIT(A) challenging the impugned reassessment proceedings, contesting that it is barred by the limitation in view of the decision of Hon'ble Supreme Court in the case of Union of India vs. Rajeev Bansal ... 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, grounds of appeal raised on the merits of the case by the Revenue are rendered academic and are therefore, dismissed

DCIT(It)-4(1)(2), Mumbai vs. Arun Madhavachari Rangachari, Mumbai

ITA 3814/MUM/2025[2011-12]Status: DisposedITAT Mumbai26 Feb 2026AY 2011-12

For Appellant: Shri Gaurav KabraFor Respondent: Shri Ajay Chandra, CIT-DR

Section 250Section 254Section 9(1)(vii)

amount of INR 465 crore in the hands of the assessee was upheld for the year under consideration on a protective basis. During the reassessment proceedings, the assessee was asked to give the details of the amount of INR 465 crore received from GFH, and if he fails ... Director of these two entities, i.e. DAR Capital Ltd. and Thurles International Ltd., and also owned 100% shares in these entities, the AO initiated reassessment proceedings under section 147 of the Act in the case of the assessee, alleging that the entire receipt equivalent to INR 465 crore is taxable

Hemant Kumar Tikariha, Raipur vs. Income Tax Officer, Ward-1(1), Raipur

In the result, appeal of the assessee in ITA No

ITA 98/RPR/2026[2012-13]Status: DisposedITAT Raipur25 Feb 2026AY 2012-13

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.97 & 98/Rpr/2026 "नधा"रण वष" /Assessment Years : 2011-12 & 2012-13

For Appellant: Shri Prafulla Pendse, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 69Section 69A

present appeal is that the AO made the addition of Rs.10,00,000/- under Sec.69A of the Act towards unexplained investment. Assessing officer during reassessment proceedings called for the information but due to noncompliance of the appellant, the AO concluded the assessment ex-parte. 5.2 The facts of the case