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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

Devendra Kumar, Noida vs. Additional / Joint / Deputy / Assistant Commissioner of Income Tax, Delhi

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

ITA 5784/DEL/2024[2016-17]Status: DisposedITAT Delhi25 Aug 2025AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2016-17 Davendra Kumar, Additional/Joint/Deputy/Assistant Vs. H. No. 52, Vill. Barola, Commissioner Of Income Tax, Sector 49, Noida, U.P. Delhi Pin: 201 301 Pan: Caipk0485M (Appellant) (Respondent)

Section 10(37)Section 142(1)Section 144BSection 147Section 148Section 151Section 250Section 271(1)(c)Section 57

void-ab-initio. 1.1. That on the facts and circumstances of the case and in law, the proceedings under section 147 of the Act ("Reassessment Proceedings") having been initiated on the basis of incorrect facts and without there being reason to believe that income of the appellant had escaped assessment ... jurisdiction, illegal. bad in law and liable to be quashed. 1.2. That on the facts and circumstances of the case and in law, the Reassessment Proceedings having been initiated merely on the basis of ex-parte information received, without any independent application of 3 ITA No. 5784/Del./2024 mind

ITO Ward-66(4), New Delhi vs. Vijay Shankar Bajpai, Rajasthan

Accordingly, Revenue’s appeal in this case is dismissed

ITA 4657/DEL/2019[2008-09]Status: DisposedITAT Delhi25 Aug 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayita No.4657/Del/2019 (Assessment Year 2008-09) Income Tax Officer, Shri Vijay Shankar Ward-66(4), Bajpai, New Delhi. Vs. 104, Riico Ind. Area, School Of Aeronautics Delhi Jaipur Highway, Neemrana, Rajsthan-301705. Pan-Aeppb6550D (Appellant) (Respondent) Assessee By Shri Rahul Bardia, Ca Department By Ms. Harpreet Kaur, Sr. Dr Date Of Hearing 19/08/2025 Date Of Pronouncement 25/08/2025

Section 147Section 148Section 253(2)Section 271Section 271(1)(c)

conclusion that since no proper service of notice had been effected under Section 148 (1) of the Act on the Assessee, the reassessment proceedings were liable to be quashed. Consequently, the question framed is answered in the affirmative, le, in favour of the Assessee and against the Revenue. 6.1.8 Further ... above appeal has been adjudicated by the undersigned in appeal No. 10572/2016-17 dated 19.03.2019 wherein the reassessment proceedings u/s 147 initiated by the appellant have been held to be vitiated, void ab initio and bad in law and have been quashed. 6.1.1 Considering the factual matrix of the case

ITO Ward-66(4), New Delhi vs. Vijay Shankar Bajpai, Rajasthan

Accordingly, Revenue’s appeal in this case is dismissed

ITA 4656/DEL/2019[2008-09]Status: DisposedITAT Delhi25 Aug 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayita No.4657/Del/2019 (Assessment Year 2008-09) Income Tax Officer, Shri Vijay Shankar Ward-66(4), Bajpai, New Delhi. Vs. 104, Riico Ind. Area, School Of Aeronautics Delhi Jaipur Highway, Neemrana, Rajsthan-301705. Pan-Aeppb6550D (Appellant) (Respondent) Assessee By Shri Rahul Bardia, Ca Department By Ms. Harpreet Kaur, Sr. Dr Date Of Hearing 19/08/2025 Date Of Pronouncement 25/08/2025

Section 147Section 148Section 253(2)Section 271Section 271(1)(c)

conclusion that since no proper service of notice had been effected under Section 148 (1) of the Act on the Assessee, the reassessment proceedings were liable to be quashed. Consequently, the question framed is answered in the affirmative, le, in favour of the Assessee and against the Revenue. 6.1.8 Further ... above appeal has been adjudicated by the undersigned in appeal No. 10572/2016-17 dated 19.03.2019 wherein the reassessment proceedings u/s 147 initiated by the appellant have been held to be vitiated, void ab initio and bad in law and have been quashed. 6.1.1 Considering the factual matrix of the case

Erothi Purnima Rani, Visakhapatnam vs. Income Tax Officer, Ward-4(1), Visakhapatnam

In the result, appeal filed by the assessee is allowed

ITA 185/VIZ/2023[2009-10]Status: DisposedITAT Visakhapatnam22 Aug 2025AY 2009-10

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 184/Viz/2023 निर्धारण वर्ा/ Assessment Year:2009-10) Erothi Latha Rani V. Income Tax Officer – Ward – 4(1) D.No. 34-10-1/B Income Tax Office Daya’S Street, Gnanapuram Pratyakshakar Bhavan Visakhapatnam – 530004 M.V.P. Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan:Aavpe7676H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita No. 185/Viz/2023 निर्धारण वर्ा/ Assessment Year:2009-10) Erothi Purnima Rani V. Income Tax Officer – Ward – 4(1) D.No. 34-10-1/B Income Tax Office Daya’S Street, Gnanapuram Pratyakshakar Bhavan Visakhapatnam – 530004 M.V.P. Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan:Aavpe7311H] (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 143(3)Section 147Section 148

learned Commissioner of Income Tax (Appeals) ought to have quashed the notice u/s 148 of the Act as invalid and the consequent reassessment proceedings as void ab initio. 3. The learned Commissioner of Income Tax (Appeals) is notjustified in sustaining the addition of Rs.9,00,000 made by the assessing ... hearing.” 8. Ground Nos. 1 and 4 are general in nature and needs no adjudication. 9. Ground No. 2 is relating to initiation of reassessment proceedings under section 148 of the Act, which was not argued by the Ld. Authorised Representative [hereinafter “Ld.AR”]. 10. Ground No. 3 relates to sustaining

Erothi Latha Rani, Visakhapatnam vs. Income Tax Officer, Ward-4(1), Visakhapatnam

In the result, appeal filed by the assessee is allowed

ITA 184/VIZ/2023[2009-10]Status: DisposedITAT Visakhapatnam22 Aug 2025AY 2009-10

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 184/Viz/2023 निर्धारण वर्ा/ Assessment Year:2009-10) Erothi Latha Rani V. Income Tax Officer – Ward – 4(1) D.No. 34-10-1/B Income Tax Office Daya’S Street, Gnanapuram Pratyakshakar Bhavan Visakhapatnam – 530004 M.V.P. Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan:Aavpe7676H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita No. 185/Viz/2023 निर्धारण वर्ा/ Assessment Year:2009-10) Erothi Purnima Rani V. Income Tax Officer – Ward – 4(1) D.No. 34-10-1/B Income Tax Office Daya’S Street, Gnanapuram Pratyakshakar Bhavan Visakhapatnam – 530004 M.V.P. Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan:Aavpe7311H] (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 143(3)Section 147Section 148

learned Commissioner of Income Tax (Appeals) ought to have quashed the notice u/s 148 of the Act as invalid and the consequent reassessment proceedings as void ab initio. 3. The learned Commissioner of Income Tax (Appeals) is notjustified in sustaining the addition of Rs.9,00,000 made by the assessing ... hearing.” 8. Ground Nos. 1 and 4 are general in nature and needs no adjudication. 9. Ground No. 2 is relating to initiation of reassessment proceedings under section 148 of the Act, which was not argued by the Ld. Authorised Representative [hereinafter “Ld.AR”]. 10. Ground No. 3 relates to sustaining

M/S.Cool Minds Technologies P. Ltd, Cochin vs. The ACIT, Cochin

The appeals are dismissed

ITA 375/COCH/2016[2007-08]Status: DisposedITAT Cochin22 Aug 2025AY 2007-08

Bench: CIT(A) the it was claimed by the Assessee that deduction under Section 10B of the Act was initially claimed by the Assessee under the bona fide belief that it is entitled to deduction under Section 10B of the Act. The CITT(A) dismissed the appeal of the Assessee agreeing with the Assessing Officer and holding that the Assessing Officer was justified in not considering the claim made by the Assessee under Section 10A of the Act. Now the Assessee is in

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Smt. Leena Lal, Sr. DR
Section 10ASection 10BSection 143(3)Section 147Section 148Section 250Section 263

income from export of software. The case was selected for scrutiny through CASS and assessment was completed u/s 143(3) of the Act. Later, reassessment proceedings were initiated under Section 148 of the Act. The Assessee filed return under Section 148 of the Act on 19/04/2012 claiming deduction under Section

Ajit Bondriya, Limassol, Cyprus vs. ITO 2(5), Bhopal, Madhya Pradesh

Appeal is allowed for statistical purpose

ITA 523/IND/2025[2016-17]Status: DisposedITAT Indore22 Aug 2025AY 2016-17

Bench: Shri B.M. Biyani

Section 142(1)Section 144BSection 147Section 148Section 148ASection 151Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M. JOSHI

Akhilesh Kumar Patel, Shahdol vs. Income Tax Officer Dhar, Dhar

ITA 627/IND/2024[2018-19]Status: DisposedITAT Indore22 Aug 2025AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 147

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Anil Kumar Mittal H.No. 143, Dlf Valley Panchkula, Panchkula vs. The Income Tax Officer Ward 6(1), Ludhiana, Punjab

In the result, the appeal of the assessee is allowed

ITA 1135/CHANDI/2024[2012-2013]Status: DisposedITAT Chandigarh22 Aug 2025AY 2012-2013

Bench: the Ld. CIT(A) who has since confirmed the order of the Ld. AO. Against the order of the Ld. CIT(A), the assessee is in appeal before us.3. During the course of hearing, the Ld. AR submitted that the notice under Section 148 dated 30/03/2019 has not been served on the assessee on his address and some other address has been mentioned in the notice which doesn't belong to the assessee. It was submitted that on inspection of the assessment records, it has been noted that the notice has been re

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 144Section 148Section 282Section 69A

been served on the assessee. It was submitted that non service of notice under section 148 is a jurisdictional defect and therefore the reassessment proceedings so initiated by the AO deserves to be set aside. 4. In this regard, reference was drawn to the written submissions filed on behalf ... Tribunal was right in its conclusion that since no proper service of notice had been affected under section 148 (1) on the assessee, the reassessment proceedings were liable to be quashed. [Para 47]" • Smt. Charanjit Kaur in IT A No.193/CHD/2020, dated 15.03.2021 wherein, it has been held as under

Deputy Commisioner of Income Tax Circle 3(1)(1) Ahmedabad, Ahmedabad vs. Phoenix Flexibles Private Limited, Ahmedabad

In the result, appeal of the Revenue is allowed and the Cross

ITA 669/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad22 Aug 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 144Section 147Section 148Section 151Section 251(1)(a)Section 68Section 69C

Page 5 of 6 7.1 It is further found that the Assessing Officer had raised the following grounds challenging the validity of reassessment proceedings and issue of notice under Section 148 of the Act: - “1. The Ld. AO erred in law as well as on fact in issuing notice u/s.148A

M/S. Abheek Dealtrade Private Limited, Kolkata vs. ITO, Ward 4(3), Kolkata

Appeal of the assessee is dismissed

ITA 232/KOL/2025[2012-13]Status: DisposedITAT Kolkata22 Aug 2025AY 2012-13

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 144Section 147Section 153(3)Section 250Section 251(1)(a)Section 69A

failure to verify the information or to produce any contrary evidence undermines the validity of the addition. 6.2 It is observed that the reassessment proceedings were initiated based on the assumption that the assessee received Rs. 9,88,000/- from CMFPL, an assertion for which evidence should have been collected ... well as on facts. 3 M/s Abhishek Dealtrade Private Limited 2. For that Ld. CIT(A) erred in setting aside the reassessment proceedings back to the Ld. AO in spite of the Ld. CIT(A) having found that (i) the Ld. AO did not provide the assessee with reasons recorded

Chahida Begam, Puducherry vs. Income Tax Officer, Ward 3, Puducherry Range, Income Tax Office, Puducherry

In the result, appeal filed by the assessee is allowed

ITA 1219/CHNY/2025[2019-20]Status: DisposedITAT Chennai22 Aug 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Hithesh, AdvocateFor Respondent: Ms.Anitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

been alleged by the Revenue in the Office Memorandum. Further, in paragraph 3.2 of the Office Memorandum, with respect to the reassessment proceedings, the reference to 'random allocation' has correctly been made as random allocation of cases to the Assessment Units by the National Faceless Assessment Centre. When random allocation

Manickam Chettiar Velmurugan, Chennai vs. ITO, Ncc-19(1), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1166/CHNY/2025[2016-17]Status: DisposedITAT Chennai22 Aug 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Hithesh, AdvocateFor Respondent: Ms.Anitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

faceless reassessment regime prescribed under Section 151A, which mandates that such notices be issued only by the Faceless Assessing Officer? 2. Whether the reassessment proceedings initiated by the Jurisdictional Assessing Officer are void ab initio, having been commenced without authority of law, as held by the Hon'ble Madras High ... Court in TVS Credit Services Ltd. v. DCIT, W.P. No. 22402 of 2024? 3. Whether the entire reassessment proceedings stand vitiated for want of jurisdiction, the initiation itself being contrary to the statutory scheme and binding judicial precedent, rendering all consequential actions unsustainable in law? The Appellant craves leave

Manickam Chettiar Velmurugan, Chennai vs. ITO, Ncc-19(1), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1165/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Aug 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Hithesh, AdvocateFor Respondent: Ms.Anitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

faceless reassessment regime prescribed under Section 151A, which mandates that such notices be issued only by the Faceless Assessing Officer? 2. Whether the reassessment proceedings initiated by the Jurisdictional Assessing Officer are void ab initio, having been commenced without authority of law, as held by the Hon'ble Madras High ... Court in TVS Credit Services Ltd. v. DCIT, W.P. No. 22402 of 2024? 3. Whether the entire reassessment proceedings stand vitiated for want of jurisdiction, the initiation itself being contrary to the statutory scheme and binding judicial precedent, rendering all consequential actions unsustainable in law? The Appellant craves leave

Sunny Madhukar Bhagat, Mumbai vs. Assessing Officer, Kautilya Bhavan, Mumbai

In the result, appeal of the assessee is allowed as per our aforesaid

ITA 2450/MUM/2025[2011-12]Status: DisposedITAT Mumbai22 Aug 2025AY 2011-12

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.2450/Mum/2025 निर्धारण वर्ष / Assessment Year :2011-12 Sunny Madhukar Bhagat A-303, Om Sai Chsl, Bldg. No.2, Tagore Nagar, Nr. Eastern Express Hwy Vikhroli E, Mumbai Pan: Anfpb5386E ........अपीलार्थी / Appellant बनाम / V/S. The Income Tax Officer, Ward-41(20) (5), Mumbai ......प्रत्यर्थी / Respondent Assessee By : Ms. Ankita Tarafdar, Ca Revenue By : Shri Aditya Rai, Sr. Dr सुनवाई की तारीख / Date Of Hearing :18.08.2025 घोषणा की तारीख / Date Of Pronouncement : 22.08.2025 2 Sunny Madhukar Bhagat Vs. Ito, Ward-41(2)(5), Mumbai

For Appellant: Ms. Ankita Tarafdar, CAFor Respondent: Shri Aditya Rai, Sr. DR

assessment order, it is noticed that despite issuing several notice by the AO, the appellant could not respond with reply during the 147 reassessment proceedings. Accordingly, the AO resorted to best Judgment assessment proceedings u/s 144 of IT Act. 1961 and based on the information and available record, the assessment

Amar Chemicals, Delhi vs. DCIT, Central Circle 15, Delhi

ITA 3981/DEL/2025[2019-20]Status: DisposedITAT Delhi22 Aug 2025AY 2019-20

Bench: Shri Mahavir Singh, Hon'Ble

For Respondent: Sh. Sachin Kumar, CA
Section 133ASection 139Section 143(2)Section 144Section 147Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “SMC”, NEW DELHI BEFORE SHRI MAHAVIR SINGH, HON'BLE VICE PRESIDENT ITA

Assistant Commissioner of Income Tax, Delhi vs. Vijendra Surendra Exports Private Limited, Delhi

ITA 1880/DEL/2025[2012-13]Status: DisposedITAT Delhi22 Aug 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mayank Patawari, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 147Section 148

Shri Rajendra Jain and Shri Surendra Jain whereas no infirmity was found in the invoices, confirmations, audited financials, bank statements, ledgers etc. 20. The reassessment proceedings were initiated based on the statement of Shri Surendra Jain and Shri Rajendra Jain, and the additions in all the years under appeal were

Assistant Commissioner of Income Tax, Delhi vs. Vijendra Surendra Exports Private Limited, Delhi

ITA 1871/DEL/2025[2011-12]Status: DisposedITAT Delhi22 Aug 2025AY 2011-12

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mayank Patawari, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 147Section 148

Shri Rajendra Jain and Shri Surendra Jain whereas no infirmity was found in the invoices, confirmations, audited financials, bank statements, ledgers etc. 20. The reassessment proceedings were initiated based on the statement of Shri Surendra Jain and Shri Rajendra Jain, and the additions in all the years under appeal were

Assistant Commissioner of Income Tax, Delhi vs. Vijendra Surendra Exports Private Limited, Delhi

ITA 1870/DEL/2025[2010-11]Status: DisposedITAT Delhi22 Aug 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mayank Patawari, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 147Section 148

Shri Rajendra Jain and Shri Surendra Jain whereas no infirmity was found in the invoices, confirmations, audited financials, bank statements, ledgers etc. 20. The reassessment proceedings were initiated based on the statement of Shri Surendra Jain and Shri Rajendra Jain, and the additions in all the years under appeal were

ITO, Ward 47(1), Delhi vs. Pure Agri World, Delhi

In the result, the appeal of the Revenue is dismissed and

ITA 5379/DEL/2024[2015-16]Status: DisposedITAT Delhi22 Aug 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No. 5379/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Ito, Pure Agri World, 2618/19, 2Nd Floor, Ward 47(1), Vs. Delhi. Maruti Bhawan, Naya Bazar, Delhi. Pan No.Aaofp2516N अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection No.54/Del/2025 (Arising Out Of Ita No. 5379/Del/2024) िनधा"रणवष"/Assessment Year: 2015-16 बनाम Pure Agri World, Ito, 2618/19, 2Nd Floor, Vs. Ward 47(1), Maruti Bhawan, Delhi. Naya Bazar, Delhi. Pan No.Aaofp2516N अपीलाथ" Appellant ""यथ"/Respondent

Section 133(6)Section 133ASection 147Section 148Section 151A

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 151A of Income Tax Act, 1961 and therefore ... reassessment proceeding 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 order passed by the Ld. Assessing Officer and the addition made therein