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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

Sunita Bhardwaj, New Delhi vs. ITO Ward 61(1), New Delhi

ITA 1432/DEL/2024[2015-2016]Status: DisposedITAT Delhi29 Aug 2025AY 2015-2016

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

Section 1Section 147Section 148Section 250Section 68

dated 19.11.2019 requested for the further time however, looking to the time bearing limits, AO proceeded to ITA No.1435, 1434, 1433 & 1432/Del/2024 complete the reassessment proceedings on the basis of the material available on record and accordingly, total income was assessed at INR 2,56,99,540/- by making addition ... technical reasons, and later notice was issued and assessments were taken up afresh-After considering submissions of assessee and documents produced in reassessment proceedings, AO added back a sum of Rs.1,35,00,000/- - CIT(A) held against assessee an legality of reassessment notice but allowed assessee's appeal

Dinesh Jat, Sagar vs. CIT(A), NFAC

ITA 196/JAB/2025[2013-14]Status: DisposedITAT Jabalpur28 Aug 2025AY 2013-14

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

For Appellant: Sh. Jaiswal Sancheti, C.AFor Respondent: Shri. N.M. Prasad, Sr. DR
Section 144Section 147Section 250Section 251(1)(a)Section 271(1)(c)Section 44ASection 69A

that no notice under sections 148, 142(1), or 144 was served at his correct residential address, and therefore, he was unaware of the reassessment proceedings. The order passed ex parte under section 144, without providing an effective opportunity of hearing, is violative of the principles of natural justice ... direct consequence of an ex parte assessment under section 144, which was passed without valid service of notice upon the appellant. The reassessment proceedings were initiated solely on AIR information, and the assessment was completed without giving the appellant an effective opportunity of being heard. Therefore, the penalty

Dinesh Jat, Sagar vs. CIT (A), Sagar

ITA 195/JAB/2025[2013-2014]Status: DisposedITAT Jabalpur28 Aug 2025AY 2013-2014

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

For Appellant: Sh. Jaiswal Sancheti, C.AFor Respondent: Shri. N.M. Prasad, Sr. DR
Section 144Section 147Section 250Section 251(1)(a)Section 271(1)(c)Section 44ASection 69A

that no notice under sections 148, 142(1), or 144 was served at his correct residential address, and therefore, he was unaware of the reassessment proceedings. The order passed ex parte under section 144, without providing an effective opportunity of hearing, is violative of the principles of natural justice ... direct consequence of an ex parte assessment under section 144, which was passed without valid service of notice upon the appellant. The reassessment proceedings were initiated solely on AIR information, and the assessment was completed without giving the appellant an effective opportunity of being heard. Therefore, the penalty

Sainik Co-Operative House Building Society Ltd, Jammu and Kashmir vs. ITO Ward 1(1), Jammu, Jammu and Kashmir

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

ITA 701/ASR/2024[2015-16]Status: DisposedITAT Amritsar28 Aug 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 147Section 148Section 148ASection 149(1)Section 24Section 250Section 69

Rs.87.66 lakhs, FD interest from bank amounting to Rs.9.09 lakhs and income from rent on Plant & Machinery amounting to Rs.1.77 lakhs. 4. The reassessment proceedings were initiated as per procedure vide issue of notice u/s 148 of the Act dated 29.03.2022, calling for return of income, and in absence ... have heard the rival submissions and considered the materials on record and we find that there has not been any compliance in course of reassessment proceedings and the assessee has been a non filer. However, considering the arguments on merits as submitted by the ld. AR of the assessee

Sainik Cooperative House Building Society Limited, Sainik Colony vs. Income Tax Officer - Ward-1, Jammu

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

ITA 406/ASR/2024[2015-16]Status: DisposedITAT Amritsar28 Aug 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 147Section 148Section 148ASection 149(1)Section 24Section 250Section 69

Rs.87.66 lakhs, FD interest from bank amounting to Rs.9.09 lakhs and income from rent on Plant & Machinery amounting to Rs.1.77 lakhs. 4. The reassessment proceedings were initiated as per procedure vide issue of notice u/s 148 of the Act dated 29.03.2022, calling for return of income, and in absence ... have heard the rival submissions and considered the materials on record and we find that there has not been any compliance in course of reassessment proceedings and the assessee has been a non filer. However, considering the arguments on merits as submitted by the ld. AR of the assessee

Samatham Gangadhara Rao, Bhimavaram vs. Income Tax Officer, Ward-1, Bhimavaram

In the result, appeal of the assessee is allowed

ITA 320/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam28 Aug 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.320/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Samatham Gangadhara Rao V. Income Tax Officer – Ward – 1 D.No. 19-22-5/3 Income Tax Office Sunkara Brahmaiah Nagar, J.P. Road, Sivaraopet Sbi Colony Bhimavaram – 534201 Andhra Pradesh Bhimavaram – 534201 [Pan:Amyps7071D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt A. Aruna, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparna Villuri, Sr.Ar

Section 143(2)Section 147Section 148Section 148ASection 149(1)(b)Section 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 Page

M/S Deeps Special Steels Limited, Ludhiana vs. DCIT, Circle-1, Alwar

ITA 1016/JPR/2024[2015-16]Status: DisposedITAT Jaipur28 Aug 2025AY 2015-16

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Rajendra Ojha, CIT
Section 115JSection 142(1)Section 143(1)Section 50C

January, 2008, during which various incriminating documents were found and impounded wherein several unaccounted transaction were recorded. 16 M/S Deeps Special Steels Ltd., Ludhiana. Reassessment proceedings were initiated by issuing notice under Section 147 R/W 148 of the Act. Vide Show Cause Notice the assessee was specifically asked

Arusuvai Food Processors Pvt. Ltd., Salem vs. DCIT, Circle-1(1), Salem

In the result, appeal filed by the assessee is allowed

ITA 416/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Aug 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.D. Anand, Advocate
Section 133(6)Section 142(1)Section 143(3)Section 264Section 270ASection 270A(1)Section 270A(9)(a)Section 270A(9)(c)Section 271Section 41(1)

file of AO for verification of Rs 10,93,74,074/-and pass order accordingly. 5. Pursuant to the Ld.PCIT’s directions, reassessment proceedings under Section 143(3) read with Section 264 were initiated. And notice under Section 142(1) was issued, calling for detailed information and evidence. With respect ... Sales, the assessee submitted VAT returns, purchase confirmations, ledgers, and exemption details under TNVAT Act for the sale of pulses and grams. In the reassessment proceedings under Section 143(3) read with Section 264, the AO accepted the appellant’s explanations regarding cash sales and dropped the corresponding addition

Paalar Shoes Pvt. Ltd., Chennai vs. ACIT, Central Circle-1(1), Chennai

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

ITA 1640/CHNY/2025[2019-20]Status: DisposedITAT Chennai28 Aug 2025AY 2019-20

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1640/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 Paalar Shoes Private Limited, Vs. The Assistant Commissioner Of No. 151/4, Mount Poonamalee Road, Income Tax, Ramapuram, Chennai 600 089. Central Circle 1(1), Chennai. [Pan:Aaecp6556B] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri N. Rajakumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.08.2025 घोषणा की तारीख /Date Of Pronouncement : 28.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 15.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 18, Chennai, For The Assessment Year 2019-20. 2. The Assessee Raised 4 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer Under Section 36(1)(Va) Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri N. Rajakumar, Addl. CIT
Section 147Section 36(1)(va)

case of CIT v. Ramachandra Hatcheries (2008) 305 ITR 117 (Mad) and argued that the Assessing Officer has no jurisdiction to commence reassessment proceedings on the issue, which has already been adjudicated upon by the ld. CIT(A) and the Hon’ble High Court held the Tribunal correctly decided ... earlier C.I.T.(A)'s order has reached finality which arises from the earlier assessment proceedings. Hence the Assessing Officer has no jurisdiction to commence reassessment proceedings on the issue which has already been adjudicated upon by the C.I.T.(A). The Tribunal correctly decided the matter and the reasons given

Vazhoor Sudarsanan Thampi, Thrissur vs. Income Tax Officer, (International Taxation), Ward-2(1), Bengaluru

Appeal is partly allowed

ITA 893/BANG/2025[2015-16]Status: DisposedITAT Bangalore28 Aug 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan Ka. Y. 2015-16 Appellant Respondent Vazhoor Sudarshanan The Income Tax Officer Thampi International Taxation Vazhoor House, Ward 2 (1) T C 5/1892Valappad Bangalore Vallapad Beach Thrissur Kerala 680567 Pan Afxpt6193D For Appellant Shri Sidhesh N Gadi, Ca For Respondent Dr. Divya K J Cit Dr Date Of Hearing 19-08-2025 Date Of Pronouncement 28-08-2025

Section 142Section 143Section 144Section 144CSection 147Section 148Section 148ASection 69

further held that at the time of filing of the return of income, assessee has claimed refund of ₹ 108,880 in the reassessment proceedings, as reassessment proceedings are for the benefit of the revenue and not for the benefit of the assessee and as there Page ... No.45/Viz/2025 dated 15/4/2025 where in Page 13 of 14 it was on identical facts allowed the claim of the assessee of refund in reassessment proceedings even when the assessee di not file original return u/s 139 of the act. Thus, respectfully following the decision of the coordinate bench, we direct

Krishnamurthy L/R by Smt. Nagarathnamma, Bangalore vs. DCIT, Circle-2(1), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 570/BANG/2025[2012-13]Status: DisposedITAT Bangalore28 Aug 2025AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2012-13 Shri. Krishnamurthy, Vs. Dcit, Represented By His Lr Smt. Nagarathnamma, Circle –2(1), No.152, 2Nd Floor, Hanuman Chambers, Bangalore. 7Th Cross, 2Nd Main, Chamarajpet, Bangalore – 560 018. Pan : Admpk 2463 J Appellant Respondent Assessee By : Shri. Ravishankar S. V, Advocate Revenue By : Shri. Balusamy N, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 22.07.2025 Date Of Pronouncement : 28.08.2025

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore
Section 139(1)Section 139(9)Section 140ASection 143(1)Section 143(2)Section 148Section 292B

assessee filed return manually, declared income of Rs.1,08,25,483/-. The scanned of return copy is as under: 3. During the course of reassessment proceedings, the documents were called for which were submitted. The AO, after verification of the books of Page 3 of 9 accounts, the income declared

DCIT-2(1)(1), Mumbai vs. Inventure Growth & Securities Limited, Mumbai

In the result, the appeal of the Revenue is dismissed and the cross-objection of the assessee is also dismissed

ITA 4163/MUM/2025[2013-14]Status: DisposedITAT Mumbai28 Aug 2025AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 10(38)Section 115JSection 143(3)Section 144Section 147Section 148Section 148ASection 68

been offered to tax under the head ‗business income.‘ Therefore, there is no evasion of tax.‖ • ―It is further noted that in the reassessment proceedings for the appellant‘s own case for A.Ys. 2016-17, 2018-19 and 2019-20, on similar issues, no adverse inference was drawn ... principles of taxation. 12. Another striking aspect noted by the CIT(A), which in our view fortifies the assessee‘s case, is that in reassessment proceedings for the assessee‘s own subsequent years, namely A.Ys. 2016-17, 2018-19 and 2019-20, where similar allegations of penny stock transactions were

Kpmg Assurance and Consulting Services LLP, Mumbai vs. Principal Commissioner of Income Tax -8, Mumbai

ITA 2396/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri S.K. Agarwal, Shri Ajit JainFor Respondent: Shri Ritesh Misra, CIT DR
Section 147Section 148Section 263Section 9(1)(vii)

learned PCIT has erred in invoking the provisions of Section 263 of the Act without appreciating that the learned AO, in the reassessment proceedings, allowed the said payments by following the Jurisdictional High Court and Jurisdictional Tribunal rulings. Accordingly, the order under Section 263 of the Act, dated February ... PCIT has stepped into the shoes of the learned AO and even challenged the documents/details submitted and accepted by the learned AO during the reassessment proceedings. Accordingly, the order under Section 263 of the Act, is bad in law and prayed to be quashed. 3. On the facts and circumstances

Shivalik Ventures Private Limited, Mumbai vs. DCIT CC 8(1), Mumbai

ITA 1444/MUM/2025[2020-2021]Status: DisposedITAT Mumbai28 Aug 2025AY 2020-2021

Bench: Ms Padmavathy S, Am & Shri Sandeep Singh Karhail, Jm

Section 133ASection 143(1)Section 143(3)Section 147Section 148Section 148ASection 194Section 250Section 40

Income-tax Act, 1961 ("the Act"), arguing that once the primary issue for reopening has been dropped by CIT(A), the reassessment proceedings automatically become invalid. The appellant relies heavily on the Hon'ble Bombay High Court's decision in CIT v. Jet Airways (India ... Airways (India) Ltd. [2011] 331 ITR 236 (Bom), the Hon'ble Bombay High Court clearly established the principle that once reassessment proceedings are validly initiated based on new tangible information indicating escapement of income, the jurisdiction of the Assessing Officer (AO) extends beyond merely addressing the original reason for reopening

Shivalik Ventures Private Limited, Mumbai vs. ACIT CC 8(1), Mumbai

ITA 1443/MUM/2025[2019-2020]Status: DisposedITAT Mumbai28 Aug 2025AY 2019-2020

Bench: Ms Padmavathy S, Am & Shri Sandeep Singh Karhail, Jm

Section 133ASection 143(1)Section 143(3)Section 147Section 148Section 148ASection 194Section 250Section 40

Income-tax Act, 1961 ("the Act"), arguing that once the primary issue for reopening has been dropped by CIT(A), the reassessment proceedings automatically become invalid. The appellant relies heavily on the Hon'ble Bombay High Court's decision in CIT v. Jet Airways (India ... Airways (India) Ltd. [2011] 331 ITR 236 (Bom), the Hon'ble Bombay High Court clearly established the principle that once reassessment proceedings are validly initiated based on new tangible information indicating escapement of income, the jurisdiction of the Assessing Officer (AO) extends beyond merely addressing the original reason for reopening

Shivalik Ventures Private Limited, Mumbai vs. ACIT CC 8(1), Mumbai

ITA 1442/MUM/2025[2018-2019]Status: DisposedITAT Mumbai28 Aug 2025AY 2018-2019

Bench: Ms Padmavathy S, Am & Shri Sandeep Singh Karhail, Jm

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 133ASection 143(1)Section 143(3)Section 147Section 148Section 148ASection 194ISection 250Section 40

Income-tax Act, 1961 ("the Act"), arguing that once the primary issue for reopening has been dropped by CIT(A), the reassessment proceedings automatically become invalid. The appellant relies heavily on the Hon'ble Bombay High Court's decision in CIT v. Jet Airways (India ... Airways (India) Ltd. [2011] 331 ITR 236 (Bom), the Hon'ble Bombay High Court clearly established the principle that once reassessment proceedings are validly initiated based on new tangible information indicating escapement of income, the jurisdiction of the Assessing Officer (AO) extends beyond merely addressing the original reason for reopening

Income Tax Officer, Panipat vs. Suresh Malhotra, Panipat

In the result, the appeal of the Revenue is dismissed

ITA 4638/DEL/2024[2018-2019]Status: DisposedITAT Delhi28 Aug 2025AY 2018-2019

Bench: Shri Anubhav Sharma & Shri Manish Agarwalincome Tax Officer, Suresh Malhotra Partner M/S Sai Nath Sector-6, Panipat Vs. Industries Kabri Road, Haryana-132103. Kacha Phatak, Industial Area, Panipat Haryana-132103. Pan:Aaqpm3214N (Appellant) (Respondent) Assessee By Ca Shilpi Jain Department By Shri Manish Gupta Sr. Dr Date Of Hearing 04/06/2025 Date Of Pronouncement 28/08/2025 O R D E R Per Manish Agarwal, Am, This Appeal Is Filed By The Revenue Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac), Delhi [Cit(A), In Short] In Appeal No. Nfac/2017-18/10236779 Dated 05.08.2024 Arising Out Of The Order Passed U/S 147 R.W.S 144 Of The Act Dated 23.03.2023 For Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Filed His Return Of Income On 27.09.2018 Declaring Total Income At Rs.5,00,460/-. Subsequently, Ao Received Information That Assessee Has Taken Accommodation Entries Managed By One Sh. Rajesh Mittal In The Shape Of Bogus Bills Of Purchase From Three Different Parties Managed & Run By Shri Rajesh Mittal Amounting To Rs.95,48,153/-. Based On Such Information, Ao Initiated Reassessment Proceedings After Taking Approval From Competent Authority & Notice U/S 148

Section 147Section 148Section 69C

purchase from three different parties managed and run by Shri Rajesh Mittal amounting to Rs.95,48,153/-. Based on such information, AO initiated reassessment proceedings after taking approval from competent authority and notice u/s 148 2. ITA No.4638 /Del/2024 ITO vs. Suresh Malhotra was issued on 29.03.2022. Thereafter, various notices ... appeal taken and as observed above by us also, the Revenue has not challenged the action of the Ld. CIT(A) who hold the reassessment proceedings as non-maintainable and had not decided other issues taken by the assessee on merits, however the Revenue has taken no any ground against

Deputy Commissioner, Delhi vs. Ravindra Singh, Greater Noida

In the result, the Appeals of the Revenue in I

ITA 2459/DEL/2023[2014-15]Status: DisposedITAT Delhi28 Aug 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

Section 132Section 153ASection 156Section 69Section 69A

such annulment by the Commissioner. Therefore, the intention of the legislation seems to be that in case of search only the pending assessment/ reassessment proceedings shall abate and the AD would assume the jurisdiction to assess or reassess the 'total income' for the entire six years period/block assessment period ... search no incriminating material is found, in case of completed/unabated assessment, the only remedy available to the Revenue would be to initiate the reassessment proceedings under section 147/48 of the Act, subject to fulfilment of the conditions mentioned in section 147/148, as in such a situation, the Revenue cannot

Deputy Commissioner, Delhi vs. Ravindra Singh, Greater Noida

In the result, the Appeals of the Revenue in I

ITA 2458/DEL/2023[2013-14]Status: DisposedITAT Delhi28 Aug 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

Section 132Section 153ASection 156Section 69Section 69A

such annulment by the Commissioner. Therefore, the intention of the legislation seems to be that in case of search only the pending assessment/ reassessment proceedings shall abate and the AD would assume the jurisdiction to assess or reassess the 'total income' for the entire six years period/block assessment period ... search no incriminating material is found, in case of completed/unabated assessment, the only remedy available to the Revenue would be to initiate the reassessment proceedings under section 147/48 of the Act, subject to fulfilment of the conditions mentioned in section 147/148, as in such a situation, the Revenue cannot

Deputy Commissioner, Delhi vs. Ravindra Singh, Greater Noida

In the result, the Appeals of the Revenue in I

ITA 2457/DEL/2023[2012-13]Status: DisposedITAT Delhi28 Aug 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

Section 132Section 153ASection 156Section 69Section 69A

such annulment by the Commissioner. Therefore, the intention of the legislation seems to be that in case of search only the pending assessment/ reassessment proceedings shall abate and the AD would assume the jurisdiction to assess or reassess the 'total income' for the entire six years period/block assessment period ... search no incriminating material is found, in case of completed/unabated assessment, the only remedy available to the Revenue would be to initiate the reassessment proceedings under section 147/48 of the Act, subject to fulfilment of the conditions mentioned in section 147/148, as in such a situation, the Revenue cannot