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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

ITO-34.2.1, Mumbai vs. Mangal Suresh Karkhanis, Mumbai

In the result, the appeal filed by the Revenue is,

ITA 486/MUM/2025[2016]Status: DisposedITAT Mumbai04 Sept 2025
Section 147Section 148Section 148ASection 151

reopen the assessment. 3. At the very outset, the Learned Authorised Representative ("Ld. AR") appearing for the assessee assailed the validity of the reassessment proceedings themselves. He specifically questioned the competence of the sanction granted under section 151 of the Act, which, in the present case, had been accorded ... Madras High Court in Core Logistics Company v. ACIT (2025), which dealt with a similar issue. The Court there quashed reassessment proceedings where sanction had been obtained from a Principal Commissioner despite the amount of escapement exceeding ₹50 lakhs and the reopening being beyond three years. The High Court held

ACIT, Aaykar Bhawan, M.K. Road, Mumbai vs. Railroad Logistics India Private Limited, Mumbai

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

ITA 3873/MUM/2025[2012-13]Status: DisposedITAT Mumbai04 Sept 2025AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankaracit Vs. Railroad Logistics India Room No. 607, Aayakar Pvt Ltd Bhavan, Mk Road, Mumbai C/O, Metal Trim, Gala – 400020. No.1, Tankiwala Indl Estate, Steel Made Compound, Marol, Maroshi Road, Mumbai Pan/Gir No. Aaccr3484J (Applicant) (Respondent) Assessee By Shri Satish R. Mody, Adv. Revenue By Shri Annavaran Kasuri, Sr. Ar Date Of Hearing 12.08.2025 Date Of Pronouncement 09.09.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 07.03.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre / Cit(A), Mumbai For The Assessment Year 2012- 13. 2. Both The Grounds Raised By The Revenue Are Interrelated & Interconnected & Relates To Challenging The Order Of Ld. Cit(A) In Terming The Order Passed By Ao As Infructuous.

Section 139Section 142(1)Section 143(3)Section 144Section 144BSection 147Section 148Section 250Section 263

grounds, we would proceed to decide the first issue which is whether or not the assessee is entitled to raise the grounds challenging the reassessment proceeding at the appellate stage in a revisionary proceeding. For this, the Id. AR has relied on the decision of the coordinate bench ... Mumbai, ITA No. 688/M/2016 [2017] 88 taxmann.com 439, order dated 24.06.2016 which has held that the assessee can challenge the validity of the reassessment proceeding that the same is non-est in the eyes of law and that the subsequent revisionary order passed u/s. 263 of the Act would

DCIT, Circle- 24(2), New Delhi vs. Superstar Innovation Pvt. Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 834/DEL/2018[2009-10]Status: DisposedITAT Delhi04 Sept 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.834/िद"ी/2018(िन.व. 2009-10) Deputy Commissioner Of Income Tax, Circle-24(2), R. No. 328, C.R Building, I.P Estate, ...... अपीलाथ"/Appellant New Delhi बनाम Vs. M/S. Superstar Innovation Pvt. Ltd., D-6/6032/2, Ground Floor, Vasant Kunj, New Delhi 110070 ..... "ितवादी/Respondent Pan: Aabcs 7795 Q Co No. 141/Del/2023 (A.Y.2009-10) In Ita No. 834/Del/2018 M/S. Superstar Innovation Pvt. Ltd., D-6/6032/2, Ground Floor, Vasant Kunj, New Delhi 110070 ...... अपीलाथ"/Appellant Pan: Aabcs 7795 Q बनाम Vs. Deputy Commissioner Of Income Tax, Circle-24(2), R. No. 328, C.R Building, I.P Estate, ..... "ितवादी/Respondent New Delhi अपीलाथ" "ारा/ Appellant By : Dr. Rakesh Gupta, S/Shri Somil Agarwal, Deepesh Garg & Shrey Jain, Advocates "ितवादी"ारा/Respondent By : Ms. Maninder Kaur & Ms. Neeju Gupta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 06/06/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025

For Appellant: Dr. Rakesh Gupta, S/Shri Somil AgarwalFor Respondent: Ms. Maninder Kaur &
Section 143(3)Section 147Section 148

assessee made threefold submissions in support of impugned order. The first limb of argument made by ld. Counsel for the assessee is, that the reassessment proceedings were initiated beyond the period of four years, therefore, first proviso to section 148 of the Act gets attracted. The AO ought to have ... Sabh Infrastructure ltd. vs ACIT 398 ITR 0198 (Delhi) 4.1. The second argument made by ld. Counsel for the assessee is, the reassessment proceedings are liable to be quashed as assessment cannot be reopened merely on the basis of CCM. In support of his contentions he placed reliance on following

Satya Enterprises, Bilaspur vs. Income Tax Officer, Ward-1(2), Bilaspur

In the result, appeal of the assessee is allowed

ITA 396/RPR/2025[2017-18]Status: DisposedITAT Raipur03 Sept 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.396/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Satya Enterprises Ward No.3, Shanti Nagar, Bilaspur (C.G.)-495 001 Pan: Adcfs1415L .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 144Section 148Section 292B

Society for Worldwide Inter Bank Financial, Tele-2023 SCC OnLine Del 7382 communications', this court invalidated a reassessment proceeding after noting that the notice under section 143(2) of the Act was not issued to the assessee pursuant to the filing of the return. In other words, it was held ... complied with or that on placing the objection the assessee had waived the notice for further processing of the reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the assessee had placed its objection and reiterated its earlier return filed as one filed

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, NFAC, Delhi

In the result, the appeal of the assessee is allowed

ITA 186/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR
Section 119Section 142(1)Section 147Section 148Section 69A

which is nothing, but said to be borrowed satisfaction. Since no tangible and/or new material has come in possession of the Assessing Officer, the reassessment proceedings can also be said on the basis of the change of opinion, which, according to our considered opinion, is not permissible

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, Ward 3(1)(1), Rajkot-

In the result, the appeal of the assessee is allowed

ITA 185/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR
Section 119Section 142(1)Section 147Section 148Section 69A

which is nothing, but said to be borrowed satisfaction. Since no tangible and/or new material has come in possession of the Assessing Officer, the reassessment proceedings can also be said on the basis of the change of opinion, which, according to our considered opinion, is not permissible

Nandigam Veerabrahmam, Rajahmundry vs. Income Tax Officer, Ward-2(1), Rajahmundry

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 271/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam03 Sept 2025AY 2018-19

Bench: Us:

Section 147Section 148Section 148A

Income Tax (Appeals) ought to have quashed the notice issued u/s 148 of the Act as invalid, and consequently ought to have quashed the reassessment proceedings as void ab initio, inasmuch as there was no nexus between the information available and the belief formed. 4. The learned Commissioner of Income ... provide for clear 7 days of time to the appellant and hence the same is invalid and consequently the entire reassessment proceedings are liable to be quashed. 3 N. Veerabrahmam 2. The notice dt.04.04.2022 issued u/s 148 of the Act is invalid as the same was issued

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 91/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh03 Sept 2025AY 2018-19

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

Valuation Officer which cannot be substituted by the amount actually recorded in the books. 7.1 From the above, it can be inferred that reassessment proceedings could not have been initiated u/s 147 of the Act, in respect of assessment which has already been completed simply relying upon the valuation report

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 90/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh03 Sept 2025AY 2017-18

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

Valuation Officer which cannot be substituted by the amount actually recorded in the books. 7.1 From the above, it can be inferred that reassessment proceedings could not have been initiated u/s 147 of the Act, in respect of assessment which has already been completed simply relying upon the valuation report

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 127/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh03 Sept 2025AY 2016-17

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 127, 90 & 91 /Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2016-17, 2017-18 & 2018-19 AFI Feed Industries Shop No. 13, Khanna City Centre, G.T. Road, Ground Floor, Bolck-C, Khanna, Punjab-141401 स्थायी लेखा सं./PAN NO: ABDFA5916B अपीलार्थी/Appellant निर्धारिती की ओर से/Assessee by : राजस्व की ओर से / Revenue by : बनाम The DCIT Central Circle-l Ludhiana प्रत्यर्थी / Respondent Shri Ashwani Kumar, Ms. Deepali

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

Valuation Officer which cannot be substituted by the amount actually recorded in the books. 7.1 From the above, it can be inferred that reassessment proceedings could not have been initiated u/s 147 of the Act, in respect of assessment which has already been completed simply relying upon the valuation report

M/S Lorgan Lifestyle Ltd., Pune vs. ITO, Ward14(4), Pune

In the result, appeal of the assessee is allowed as per terms indicated above

ITA 215/PUN/2025[2015-16]Status: DisposedITAT Pune03 Sept 2025AY 2015-16

Bench: Dr.Manish Borad & Ms.Astha Chandra

For Appellant: Shri B S RajpurohitFor Respondent: Shri Amol Khairnar
Section 143(3)Section 250

regarded as an interpretational error in the view which was taken by certain courts that the Assessing Officer has to restrict the assessment or reassessment proceedings only to the issues in respect of which reasons were recorded for reopening the assessment. The corrective exercise embarked upon by Parliament

Uday Prabhakar Paranjpe, Pune vs. DCIT, Circle-3, Pune

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

ITA 947/PUN/2024[2010-11]Status: DisposedITAT Pune03 Sept 2025AY 2010-11

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Smt. Deepa KhareFor Respondent: Shri Akhilesh Srivastva
Section 143(3)Section 147Section 148

dated 07.02.2025. 3. Assessee has raised following grounds of appeal : “1. The learned CIT(A) erred both in law and in facts in initiating reassessment proceedings based on the information relating to some other person and resorted to reassess income on the basis of incorrect information. 2 Uday Prabhakar Paranjpe

Star Ceramics, Chitradurga vs. Income Tax Officer, Ward-1, Chitradurga

In the result, the appeal of the assessee is allowed

ITA 1064/BANG/2025[2016-17]Status: DisposedITAT Bangalore03 Sept 2025AY 2016-17

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Ms. Richa Bakiwala & Shri Hemasundar Rao P., CAsFor Respondent: Shri Thamba Mahendra, CIT(DR)(ITAT), Bengaluru
Section 147Section 148Section 148ASection 68Section 69A

filed a paperbook containing 57 pages and also placed written submissions on record. In the written submissions assessee has challenged the validity of reassessment proceedings u/s. 147 of the Act. It was submitted that the Act requires prior approval from the Chief Commissioner of Principal Chief Commissioner and not Principal ... this case, approval is obtained from Principal Commissioner of Income Tax and therefore the same is not valid and hence the whole reassessment proceedings culminating into reassessment order is invalid. For this proposition, he has relied upon several judicial precedents of the coordinate Benches and further decision

Ratan Rajmal Mehta, Mumbai vs. Income Tax Officer Ward 23(3)(1), Mumbai

ITA 4130/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Sept 2025AY 2018-19

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am Ratan Rajmal Mehta Income Tax Officer, Ward 5, Harihar Niwas, Besant Road, 22(3)(1), Mumbai Vs. Santacruz (West), Mumbai – 400054. Pan/Gir No. Bdipm2252G (Appellant) : (Respondent) Assessee By : Shri Ketan Vajani (Virtually) Respondent By : Shri Annavaran Kasuri, Sr. Ar. Date Of Hearing : 01.09.2025 Date Of Pronouncement : 03.09.2025 O R D E R Per Arun Khodpia, Am:

For Appellant: Shri Ketan Vajani (Virtually)For Respondent: Shri Annavaran Kasuri, SR. AR
Section 143Section 147Section 148Section 250Section 270A

Keystone 2 Ratan Rajmal Mehta Realtors P. Ltd. as per redevelopment agreement. As per penalty order, the Ao had concluded that if the reassessment proceedings would not have been initiated the assessee would not have declared the correct income, thus, had under reported her income, accordingly, liable to be penalized

Aggarwal Abhushan Private Limited, Delhi vs. DCIT Circle 1(1), Delhi/National Faceless Appeal Centre Delhi, New Delhi

In the result, the appeal of the assessee is allowed

ITA 712/DEL/2025[2016-17]Status: DisposedITAT Delhi03 Sept 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri Sudhir Kumaraggarwal Abhushan Vs. Dcit Circle-1(1), Delhi/ Private Limited, National Faceless Appeal B-5/153, Sector-7, Centre, Delhi-110002 Rohini, Delhi-110085

For Appellant: Ms. Meenal Goyal, Adv. &For Respondent: Shri Om Prakash, Sr. DR
Section 147Section 148Section 148ASection 149

issued on 27-7-2022, the said notice is to be treated as barred by limitation and consequentially reassessment proceedings would be liable to be quashed as void ab initio. This issue was also subject matter of consideration by the Hon’ble Jurisdictional High Court in the case ... noted above, by virtue of TOLA, the AO had period of twenty-nine days limitation left on the date of commencement of the reassessment proceedings, which began on 01.06.2021, to issue a notice under Section 148 of the Act. The said notice was required to be accompanied by an order

Ap Goyal Charitable Trust, East Delhi, Delhi India vs. ITO, Civic Centre, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1941/DEL/2025[2014-15]Status: HeardITAT Delhi03 Sept 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshap Goyal Charitable Trust, Vs. Ito, Ward B-125, Anand Vihar, Exempt-1(1), East Delhi, Delhi-110092 Delhi, Civic Centre, Delhi-110002 (Appellant) (Respondent) Pan: Aabta8575B

For Appellant: Shri Nitin Kanwar, AdvocateFor Respondent: Shri Sahil Kumar Bansal, Sr. DR
Section 12ASection 132Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 151

order on 1-9- 2021 on the Writ Petition filed by the assessee along with others, restraining the revenue from continuing with the reassessment proceedings in any manner pursuant to the aforesaid notice under section 148 of the Act. On 21- 03-2022, the assessee submitted its reply before ... dated 25-11-2021 along with the Hon’ble Delhi High Court order dated 16-03-2022 intimating the learned AO that the reassessment proceedings could not be proceeded with. 3 4. The decision of the Hon’ble Supreme Court in the case of Ashish Agarwal reported

Hardeep Singh Kandola, Ratia vs. ITO, Fatehabad

ITA 456/CHANDI/2025[2011-12]Status: DisposedITAT Chandigarh02 Sept 2025AY 2011-12

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ankit Kumar (Advocate) a/w Shri LalitFor Respondent: Shri Manav Bansal (CIT) a/w Shri Vivek
Section 143(3)Section 144Section 263

Having heard rival submissions and upon perusal of case records, the appeal is disposed-off as under. 2. The assessee was subjected to reassessment proceedings and an order was passed by Ld. AO u/s 143(3) r.w.s. 147 of the Act on 08- 11-2018. The case was reopened

Hardeep Singh Kandola, Ratia vs. ITO, Fatehabad

ITA 455/CHANDI/2025[2011-12]Status: DisposedITAT Chandigarh02 Sept 2025AY 2011-12

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ankit Kumar (Advocate) a/w Shri LalitFor Respondent: Shri Manav Bansal (CIT) a/w Shri Vivek
Section 143(3)Section 144Section 263

Having heard rival submissions and upon perusal of case records, the appeal is disposed-off as under. 2. The assessee was subjected to reassessment proceedings and an order was passed by Ld. AO u/s 143(3) r.w.s. 147 of the Act on 08- 11-2018. The case was reopened

Kalabhai Karshanbhai Patel, Banaskantha vs. The ITO, Ward-3, Palanpur

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

ITA 11/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Shri T.R. Senthil Kumar

For Appellant: Shri Hiren Trivedi, ARFor Respondent: Shri Hargovind Singh, Sr DR
Section 143(3)Section 250Section 50C

facts and in the circumstances of the case, the ld. CIT (Appeal) NFAC has erred in not appreciating the fact that reassessment proceedings for A.Y 2014-15 were totally without jurisdiction and bad in law. 3. In law and in the facts and circumstances of the case of the Appellant

DCIT Central Circle 1(1) Ahmedabad, Ahmedabad vs. Mahendrakumar Chunilal Sanghvi, Ahmedabad

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 1351/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2021-22

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 147Section 148Section 148ASection 149Section 69C

notice u/s.148A cannot be issued beyond three years and the assumption of jurisdiction itself is bad in law and therefore requested to quash the reassessment proceedings. The Ld CIT[A] wrongly held that the as per seized material income exceeding Rs. 50 lakhs is found to have escaped assessment ... assessee raised similar objections during the reassessment proceedings which was disposed off the same by the Ld AO. It is thereafter the AO passed the reassessment order on 09- 06-2023 and assessed the total income at Rs.75,74,350/- and demanded tax thereon. 6.1. It is undisputed fact that