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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

Rajnikant Raichand Shah, Ahmedabad vs. The ITO, Ward-1(3)(1), Ahmedabad

The appeal of the assessee is allowed for statistical purposes

ITA 1326/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2015-16

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri M K Patel, AdvocateFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 144Section 147Section 54ESection 54F

immovable property investment details in Schedule AL of the ITR, even though the total income exceeded Rs. 25 lakhs, which mandates such disclosure. During reassessment proceedings, Assessing Officer noted that the assessee did not cooperate, he failed to furnish details of the capital gain computation, investment evidence under sections ... assessment was based on factually incorrect grounds, and submitted that the reassessment order was invalid. However, the CIT(A) held that the reassessment proceedings were validly initiated and rightly completed under law. The CIT(Appeals) observed that the assessee not only failed to explain the revised stand on capital gain

Bees Infracon Private Limited, Ahmedabad vs. Income Tax Officer, Ward1(1)(2), Ahmedabad

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

ITA 1283/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2013-14

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

Section 143Section 143(3)Section 148Section 2Section 2(22)(e)

with interest of Rs.6,16,800/=, hence no question of invoking deemed dividend u/s.2[22][e] of the Act and requested to drop the reassessment proceedings. But the AO held that since the assessee is holding 10.71% shares in M/s. Sunburg Tradelink Pvt Ltd and the accumulated profit of Rs.80 ... That the learned NFAC/CIT(A) has erred in not holding, that the notice issued under section 148 of the Act and the subsequent reassessment proceeding and the order passed by the Id.AO, is without jurisdiction and bad in law and therefore the order passed by the learned AO is required

Mahendrakumar Chunilal Sanghvi, Mumbai vs. DCIT CC 1(1) Ahmedabad, Ahmedabad

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

ITA 1267/AHD/2024[2017-2018]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2017-2018

Bench: or at the time of hearing of the appeal."

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

M/S. Gyanchand Poddar HUF, Kolkata vs. ITO, Ward 43(1), Kolkata

Appeal of the assessee is allowed

ITA 1391/KOL/2025[2013-2014]Status: DisposedITAT Kolkata02 Sept 2025AY 2013-2014
Section 147Section 250Section 271(1)(c)

penalty order passed by is without the Faceless AO jurisdiction and therefore the penalty order is liable to be quashed. 4 For that the reassessment proceedings initiated and completed were invalid and bad in law and therefore the penalty proceedings initiated in the course of such proceedings are also

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Ltd, Kolkata

Appeal of the Revenue is dismissed

ITA 2541/KOL/2024[2008-09]Status: DisposedITAT Kolkata02 Sept 2025AY 2008-09

Bench: 30th day of September 2007.

Section 143(3)Section 147Section 148Section 250Section 32

cast on assessee as its failure to disclose the income fully and truly. The relevant facts and material on the basis of which the reassessment proceedings u/s 147 was made were part of the record and duly examined in the first round of assessment completed u/s 143(3) on 02/11/2010 ... appellant are very relevant in the facts and circumstances of this case. They stipulate the correct position of law in initiation of reassessment proceeding u/s 147, after expiry of 4 years from end of relevant assessment year, in a case where assessment u/s already been completed. 4 Murlidhar Ratanlal Exports

Ramasamy Pushpa, Namakkal vs. ITO, International Taxation Ward-2(1), Chennai

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

ITA 489/CHNY/2025[2016-17]Status: DisposedITAT Chennai02 Sept 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.489/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Ramasamy Pushpa, Vs. The Income Tax Officer, D.No. 2/31, Sankarampalayam Village, International Taxation Ward 2(1), Kumaripalayam Post, Chennai. Namakkal 637 015. [Pan:Cvwpp7128R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T.S. Lakshmi Venkataraman, F.C.A ""थ" की ओर से/Respondent By : Shri C. Sivakumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 21.08.2025 घोषणा की तारीख /Date Of Pronouncement : 02.09.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 13.01.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals)-16, Chennai For The Assessment Year 2016-17. 2. The Assessee Raised 6 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Order Of The Assessing Officer Passed Under Section 147 R.W.S. 144 Of The Income Tax Act, 1961 [“Act” In Short]

For Appellant: Shri T.S. Lakshmi Venkataraman, F.C.A ""For Respondent: Shri C. Sivakumar, Addl. CIT
Section 144CSection 147Section 56

statute. Having held so, the Tribunal held the contention of the assessee therein are devoid of any merit and held that the reassessment proceedings were conducted after the amended provision which came into effect from 01.04.2020 to be justified. In view of the same, we find the arguments

Ganpat Ram Singhal, New Delhi vs. ACIT, Circle 25(1), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2054/DEL/2023[2011-12]Status: DisposedITAT Delhi02 Sept 2025AY 2011-12

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Pranav Yadav, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 147Section 148Section 151

quashed and CIT (A) erred in not holding so. 2. On the facts and circumstances of the case and in law, the reassessment proceedings initiated are contrary to the provisions of law including the specific provisions of section 147 to section 151 of Income Tax Act, 1961 and therefore ... reassessment proceedings initiated along with assessment order passed are liable to be quashed and CIT (A) erred in not holding so. 3. On the facts and circumstances of the case and in law, the CIT (A) erred in confirming the addition of Rs.1,21,75,220/- made by the assessing

Noratan Lal Sharma, Jaipur vs. Income Tax Officer, Ward 2(2), Jaipur

In the result, the appeal of the assessee is technically dismissed

ITA 323/JPR/2025[2008-09]Status: DisposedITAT Jaipur01 Sept 2025AY 2008-09

Bench: Shri Gagan Goyal & Shri Narinder Kumarnoratan Lal Sharma, 35-A Nanupuri, Jhotwara, Jaipur 302 012 Pan No.: Bcyps 6349P ...... Appellant Vs. Ito, Ward 2(2), Jaipur …...Respondent Appellant By : None Respondent By : Mr. Gautam Singh Choudhary, Addl. Cit Ld. Dr Date Of Hearing : 01/09/2025 Date Of Pronouncement : 01/09/2025 O R D E R Per Gagan Goyal, A.M:

For Appellant: NoneFor Respondent: Mr. Gautam Singh Choudhary, Addl. CIT
Section 142(1)Section 144Section 147Section 148Section 154Section 250

appeal: - 2 Noratan Lal Sharma 1. On the facts and circumstances of the case and in law also Ld. A.O. grossly erred in initiating reassessment proceedings u/s. 147 of the Income Tax Act, 1961. 2. No notice U/s. 148 or U/s. 142(1) or U/s. 144 was served ... person. Therefore entire proceedings are abinitio void. 3. That the Return of income filed by the assessee was not referred at all before initiating reassessment proceedings. Even the fact that assessee holds PAN was not considered. 4. On the facts and circumstances of the case and in law also

M/S. Deepak Purshottam Shah (HUF), Mumbai vs. ACIT, Central Circle -2, Thane

In the result, both the appeals filed by the assessee are allowed

ITA 5593/MUM/2024[2013-14]Status: DisposedITAT Mumbai01 Sept 2025AY 2013-14

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 132Section 132ASection 139Section 143(3)Section 144Section 147Section 148Section 149Section 151Section 153

appeal of the assessee are allowed. Since we have already held that no addition could have been made in the reassessment proceedings u/s 153C of the Act, the grounds challenging on merit is not required to be adjudicated upon. The ground No. 3 and 4 challenging the order passed without

M/S. Deepak Purshottam Shah, Mumbai vs. ACIT, Central Circle -2, Thane

In the result, both the appeals filed by the assessee are allowed

ITA 5591/MUM/2024[2012-13]Status: DisposedITAT Mumbai01 Sept 2025AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 132Section 132ASection 139Section 143(3)Section 144Section 147Section 148Section 149Section 151Section 153

appeal of the assessee are allowed. Since we have already held that no addition could have been made in the reassessment proceedings u/s 153C of the Act, the grounds challenging on merit is not required to be adjudicated upon. The ground No. 3 and 4 challenging the order passed without

Sportking India Ltd., New Delhi vs. JCIT, Circle-9(1), New Delhi

The appeal of the assessee is allowed as above

ITA 2223/DEL/2018[2006-07]Status: DisposedITAT Delhi01 Sept 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 115JSection 143(3)Section 147Section 148Section 151Section 250

been done without proper 10 Sportking India Ltd. approval from the competent authority, as required under section 151 of the Act. Consequently, the entire reassessment proceedings are hereby quashed and the impugned order thus stands set aside. Since the reassessment was invalidated, we did not need to address the other

Abdulkadar Hajiahmed Vadiwala, Jamnagar vs. Pr. Commissioner of Income Tax, Jamnagar

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

ITA 103/RJT/2025[2016-17]Status: DisposedITAT Rajkot29 Aug 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.103/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2016-17 Abdulkadar Hajiahmed Vadiwala The Pr.Cit बनाम Maniar Street, Lindi Bazar Jamanagar. Jamnagar-361001 Vs. Pan : Aatpv 4729 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

For Appellant: Shri Chetan Agarwal, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 143(3)Section 147Section 148Section 151Section 263

order of the ld.Pr.CIT, the assessee is in appeal before us. 8. The ld.Counsel for the assessee, at the outset, argued that the reassessment proceedings initiated by the AO under section 147 read with section 148 of the Act, itself is invalid, that is, re-assessment proceedings initiated against ... 147/148 was issued to the assessee on 29.07.2022 which is beyond three years, that is, which is after expiry of three years. Therefore, the reassessment proceedings initiated by the AO should be quashed. 10.The ld.Counsel for the assessee also took us through the approval under section

Pakalapati Padma Jyothi, West Godavari Dist vs. Income Tax Officer, Ward-1, Tadepalligudem

In the result, appeal of the assessee is allowed

ITA 275/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam29 Aug 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.275/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Pakalapati Padma Jyothi V. Income Tax Officer – Ward – 1 D.No. 1-17, Singarajupalem Income Tax Office Muthyalamma Gudi Street Aayakar Bhawan Avapadu, Nellajerla D.No. 2-1-56/1, K.N. Road West Godavari District Tadepalligudem – 534101 Andhra Pradesh [Pan:Blwpp5193B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparnavilluri, Sr.Ar

Section 142(1)Section 147Section 148Section 148ASection 151ASection 69A

invalid and barred by limitation. In view of the above findings and in light of binding judicial precedents, we hold that the reassessment proceedings initiated for AY 2015-16 are without jurisdiction, and hence the notice issued under section 148 and subsequent proceedings are quashed. Accordingly, the assessment completed under

Sudharani Surisetty, Visakhapatnam vs. Income-Tax Officer, Ward - 1(1), Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 166/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam29 Aug 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.No.166/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Sudharani Surisetty V. Income Tax Officer – Ward – 1 29-2-34, Opposite Judge Court Flat No. 401, 4Th Floor Main, Dabagardens Prathyakshar Bhawan Prakasharaopeta Mvp Double Road Visakhapatnam – 530020 Visakhapatnam – 530020 Andhra Pradesh Andhra Pradesh [Pan:Cnbps4046N] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri C. Subrahmanyam, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparnavilluri, Sr.Ar

Section 142(1)Section 147Section 148Section 148ASection 149(1)(b)Section 250

invalid and barred by limitation. In view of the above findings and in light of binding judicial precedents, we hold that the reassessment proceedings initiated for AY 2015-16 are without jurisdiction, and hence the notice issued under section 148 and subsequent proceedings are quashed. Accordingly, the assessment completed under

Shobha Yadav, Chandpura Bachhana, Bilhaur vs. Commissioner of Income-Tax (Appeals), Knp-W

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

ITA 278/LKW/2025[2019-20]Status: DisposedITAT Lucknow29 Aug 2025AY 2019-20

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2019-20 Shobha Yadav, Vs. Commissioner Of Income Tax Chandpura Bachhana, Bilhaur, (Appeals), Kanpur Kanpur Nagar, U.P.-209202 Pan:Auxpy6004H (Appellant) (Respondent) Assessee By: Sh. Shivam Singh Yadav, Adv Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 30.07.2025 Date Of Pronouncement: 29.08.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Passed Under Section 250 Of The Income Tax Act, 1961 On 28.02.2025, Dismissing The Appeal Of The Assessee In Limine. The Grounds Of Appeal Are As Under:- “1. That The Learned Commissioner Of Income Tax (Appeals) (Cit(A)) Has Erred In Law & On Facts In Dismissing The Appeal On The Ground Of Delay In Filling Of The Appeal By 33 Days, Without Appreciating The Bona Fide Reasons & Genuine Hardship Faced By The Appellant. 2. That The Learned Cit(A) Failed To Appreciate That The Appellant Is An Illiterate Village Woman With No Access Or Understanding Of Technology & That She Neither Received The Notice Nor The Assessment Order In Physical Form, Leading To Unintentional Delay In Filing The Appeal. 3. That The Learned Cit(A) Failed To Consider That The Appellant'S Cause For Delay Was Neither Deliberate Nor Due To Negligence, But Solely Due To Lack Of Awareness & Therefore Deserved Liberal Construction In The Interest Of Substantial Justice. 4. That The Learned Cit(A) Erred In Holding That The Appellant Did Not Show "Sufficient Cause" For Condonation Of Delay, Despite Her Candid Declaration Of Illiteracy, Lack Of Access To Email & Absence Of Physical Service Of Notices Circumstances Beyond Her Control.

For Appellant: Sh. Shivam Singh Yadav, AdvFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 115BSection 139(1)Section 142(1)Section 144Section 147Section 148Section 148ASection 250Section 69A

cause" especially where substantive justice is at stake, and technicalities should not defeat meritorious cases. 6. That the Learned Assessing Officer erred in initiating reassessment proceedings under Section 147 without proper service of notice as mandated under the Act, thereby vitiating the entire reassessment proceedings. 7. That the reassessment order

Assistant Commissioner of Income Tax-5, Kanpur vs. M.K.U Pvt. Ltd., Kanpur

In the result, appeal in ITA No

ITA 509/LKW/2018[2011-12]Status: DisposedITAT Lucknow29 Aug 2025AY 2011-12

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 143Section 143(3)Section 147Section 250

ingredients of section 147 were fulfilled and failure to take steps under section 143(3), would not render the ld. AO powerless to initiate reassessment proceedings. The ld. AO also pointed out that the re-assessment proceedings had not been finalized and due opportunity would be provided to the assessee

Gulamahemad Hamidulla Khan, Pune vs. ITO Ward 14(3), Pune

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

ITA 166/PUN/2025[2014-15]Status: DisposedITAT Pune29 Aug 2025AY 2014-15

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamore

Section 132Section 144Section 147Section 148Section 148ASection 153CSection 250Section 69A

appeal : 1. On the facts and in the circumstances of the case and in law the learned Assessing Officer erred in initiating the reassessment proceedings u/s 147, as enacted w.e.f. 01/04/2021, as the proceedings are time barred in view of judgement of Hon'ble Supreme Court in the case ... quashed 2. On the facts and in the circumstances of the case and in law the learned Assessing Officer erred in initiating reassessment proceedings under section 147 by issuing notice under section 148 dated 25/07/2022 without specifying the DIN & Notice No as envisaged in CBDT circular No. 19/2019 dated 14/08/2019

Deputy Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Kag India Private Limited, Velachery

ITA 632/CHNY/2025[2021-22]Status: DisposedITAT Chennai29 Aug 2025AY 2021-22

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

632/Chny/2025 (AY 2014-15, 2015-16, 2017-18, 2018-19, 2019-20 & 2021-22) KAG India Private Limited :: 8 :: 26.02.2021, the reassessment proceedings initiated u/s.148 of the Act stood abated. The ld.CIT(A)’s failure to examine this legal position vitiates the appellate order. It is further submitted that ... relief extended on the aspect of procedural infirmity is incorrect. On hearing the case, the AR of the assessee stated that while the original reassessment proceedings is by itself bad in law and has no legs to stand, the question whether such assessment is abated or unabated does not arise

Deputy Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Kag India Private Limited, Chennai

ITA 325/CHNY/2025[2018-19]Status: DisposedITAT Chennai29 Aug 2025AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

632/Chny/2025 (AY 2014-15, 2015-16, 2017-18, 2018-19, 2019-20 & 2021-22) KAG India Private Limited :: 8 :: 26.02.2021, the reassessment proceedings initiated u/s.148 of the Act stood abated. The ld.CIT(A)’s failure to examine this legal position vitiates the appellate order. It is further submitted that ... relief extended on the aspect of procedural infirmity is incorrect. On hearing the case, the AR of the assessee stated that while the original reassessment proceedings is by itself bad in law and has no legs to stand, the question whether such assessment is abated or unabated does not arise

Deputy Commissioner of Income Tax, Chennai vs. Kag India Private Limited, Chennai

ITA 324/CHNY/2025[2017-18]Status: DisposedITAT Chennai29 Aug 2025AY 2017-18

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

632/Chny/2025 (AY 2014-15, 2015-16, 2017-18, 2018-19, 2019-20 & 2021-22) KAG India Private Limited :: 8 :: 26.02.2021, the reassessment proceedings initiated u/s.148 of the Act stood abated. The ld.CIT(A)’s failure to examine this legal position vitiates the appellate order. It is further submitted that ... relief extended on the aspect of procedural infirmity is incorrect. On hearing the case, the AR of the assessee stated that while the original reassessment proceedings is by itself bad in law and has no legs to stand, the question whether such assessment is abated or unabated does not arise