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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

Hemlata Harakchand Shah, Ahmedabad vs. The ITO, Ward-6(1)(4), Ahmedabad

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

ITA 835/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad13 Aug 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent byFor Respondent: Date of Hearing
Section 139(1)Section 142(1)Section 144Section 148Section 249(4)Section 249(4)(b)

grounds of appeal either before or at the time of hearing of the appeal." 4. The brief facts of the case are that reassessment proceedings were initiated in case of the assessee on the basis of information available with the Department demonstrating that the assessee had engaged in share transactions

Lakhubhai Nathubhai Sisodiya, Ahmedabad vs. ITO, Ward 3(2)(3), Ahmedabad, Current ITO Ward 3(1)(2)

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

ITA 716/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad13 Aug 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri P D Shah, ARFor Respondent: Shri Prateek Sharma, Sr. DR
Section 139Section 147Section 148Section 271(1)(c)Section 69

assessee filed a return declaring Lakhubhai Nathubhai Sisodiya vs. ITO Asst. Year –2012-13 - 3– income of Rs. 1,78,290/-. During the reassessment proceedings, the Assessing Officer noted that the assessee had purchased property during the year in which his share amounted to Rs. 8,75,000/-. Since ... reopened, the assessee would have succeeded in concealing the said income, and the addition was made only after it came to light during the reassessment proceedings. Hence, the AO held that this was a fit case for imposition of penalty under section 271(1)(c) for concealment of income. Accordingly

Dipa Prakashkumar Velani, Ahmedabad vs. The ITO, Ward-1(2), Bhavnagar

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

ITA 1039/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad13 Aug 2025AY 2015-16

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Manish J Shah & Shri Rushin Patel ARSFor Respondent: Shri Prateek Sharma, Sr. DR
Section 115BSection 147Section 148Section 148ASection 156Section 69

amend or alter the grounds of appeal at the time of hearing if need arise." 4. The brief facts of the case are that reassessment proceedings were initiated in the case of the assessee on the basis of information received through the Non-Filer Management System and Risk Management Strategy ... order passed by CIT (Appeals) dismissing the appeal of the assessee. Having considered the facts and circumstances of the case, we observe that the reassessment proceedings in the case of the assessee were initiated based on information showing substantial purchase and sale of immovable properties during the relevant assessment year

Highgrowth Vyapaar Pvt. Ltd., Kolkata vs. ITO, Ward 12(1), Kolkata

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

ITA 1022/KOL/2025[2011-2012]Status: DisposedITAT Kolkata13 Aug 2025AY 2011-2012

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1022/Kol/2025 Assessment Year: 2011-12 Highgrowth Vyapaar Pvt. Ltd…………..……..…………………....Appellant 42E, Cornfield Road, Ground Floor, Ballygunge, Kol-19. [Pan: Aacch0203R] Vs. Ito, Ward-12(1), Kolkata..…………....…..………………….…..... Respondent Appearances By: Shri Avijit Ghoshal, Advocate, Appeared On Behalf Of The Appellant. Shri Soumitra Ghosh, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 28, 2025 Date Of Pronouncing The Order : August 13, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre Dated 15.03.2024 Passed Against The Assessment Order Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2011–12. 2. At The Outset, It Is Noted That There Is A Delay Of 347 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication. 3. Brief Facts Of The Case Are That In The Case Of The Assessee, The Return Of Income Was Filed On 18.03.13 Disclosing A Loss Of Rs.11,281/-.

Section 143(1)Section 143(2)Section 147Section 250Section 68

Kolkata the return filed by the assessee was believed that income escaped within the meaning of section 147 of the Act and accordingly reassessment proceedings were initiated. It was noticed by the Assessing Officer that the assessee company had received an accommodation entry amounting to Rs.50,00,000/- which

Rasaiyan Mariya Alasu Rajan, Chennai vs. DCIT, Ncc-8(1), Chennai

In the result, the appeal filed by the assessee for A

ITA 997/CHNY/2025[2016-17]Status: DisposedITAT Chennai13 Aug 2025AY 2016-17

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Ms. Lekha, CAFor Respondent: Ms. Kumar Chandan, JCIT
Section 142(1)Section 143(3)Section 144Section 271(1)(b)Section 273B

notices of the AO. Subsequently, the penalty proceedings u/s.271(1)(b) was also initiated for non-compliance of notices issued. 5. During the reassessment proceedings the AO had issued statutory notices to file the required details for completing the assessment. However, the assessee had not responded to the said notices ... impugned dispute are that the assessee failed to comply to the notices issued by the AO for the A.Y. 2016-17 during the reassessment proceedings. Accordingly, the penalty u/s.271(1)(b) of the Act has been levied for non- compliances to the notices issued u/s.142

Duraisamy Rajeswari, Coimbatore vs. ITO, Ncw-3(1), Coimbatore

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

ITA 673/CHNY/2025[2018-19]Status: DisposedITAT Chennai13 Aug 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:673/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2018-19 Duraiswamy Rajeswari, Ito, 17, Lakshmanan Nagar, Vs. Non-Corp Ward 3(1), 2Nd Street, Coimbatore. Gandhipuram, Coimbatore – 641 012. [Pan:Afipr-0877-H (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Ms. M. Mathangi, Advocate प्रत्यथी की ओर से/Respondent By : Ms. Pryati Sharma, J.C.I.T.

For Appellant: Ms. M. Mathangi, AdvocateFor Respondent: Ms. Pryati Sharma, J.C.I.T
Section 142(1)Section 147Section 148Section 151ASection 272A(1)(d)Section 273B

Appellant. 3. Without prejudice, the Impugned Penalty is unjust, as the reason for not responding to the notices issued during reassessment was that the reassessment proceeding was nil and void, on violation of Section 151A of the Act. 4. Without prejudice, the Impugned Penalty is excessive and unfair ... u/s.272A(1)(d) was also initiated for non- compliance of notices issued u/s.142(1) of the Act dated 12.07.2023 and 04.09.2023. 5. During the reassessment proceedings the AO had issued statutory notices to file the required details for completing the assessment. However, the assessee had :-3-: ITA. No:673/Chny/2025

Raj Rani Gupta, New Delhi vs. ITO, Ward 35(1), Delhi

In the result, the Assessee’s appeal is allowed

ITA 3418/DEL/2025[2015-16]Status: DisposedITAT Delhi13 Aug 2025AY 2015-16

Bench: SHRI MAHAVIR SINGH, HON'BLE (Vice President)

For Appellant: Shri Parikshit Agarwal, CA &For Respondent: Shri Sangeet Bansal, Sr. DR
Section 148Section 148ASection 149Section 250

issued. In response to the notice the assessee filed ITR on 27.4.2022 by declaring nil income. During the course of reassessment proceeding the assessee submitted that she stood as a guarantor and had mortgaged her properties on behalf of M/s Sainsons Pulp and Paper Ltd. for securing loan for that ... issued on 06.04.2022, thus, the issuance of notice under Section 148 of the Act on 06.04.2022 is barred by limitation. Consequently, the reassessment proceedings culminating in the order under section 147 r.w.s. Section 144B of the Act are rendered void ab initio, having been initiated beyond the prescribed statutory period

Ram Kumar Tyagi, Ghaziabad vs. ITO, Ghaziabad

The appeal of the assessee is partly allowed

ITA 2676/DEL/2016[2008-09]Status: DisposedITAT Delhi13 Aug 2025AY 2008-09

Bench: Shri Vikas Awasthy & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 148Section 250

error or omission on the part of the AO while issue of notice u/s 143(2) therefore the Page | 6 ITA No.2676/Del/2016 reassessment proceedings as concluded by AO deserve to be hold as in accordance with law. 13. Heard the contentions of both the parties and perused the material available

Ri-Bhoi Ispat & Rolling Mills, Byrnihat vs. ITO, Ward- Byrnihat, Byrnihat

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

ITA 241/GTY/2024[2018-2019]Status: DisposedITAT Guwahati12 Aug 2025AY 2018-2019

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 133ASection 147Section 250Section 69C

view of the fact that the AO has strictly adhered to the provisions of the Act and followed the due procedure in the entire reassessment proceedings, the ground 1 of the appellant that the order passed u/s 147 is bad in law is duly dismissed. Accordingly, the ground

Rajeshbhai Bhagwandas Patel, Vadodara vs. Income Tax Officer, Ward 5 (3) (2), Ahmedabad

In the result, the appeal of the assessee is allowed on the ground of lack of jurisdiction, and the assessment order is quashed

ITA 985/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2012-13

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2012-13

For Appellant: Shri Amit Pratap Singh, Sr.DR
Section 142(1)Section 144Section 147Section 148Section 250Section 50C

documentary evidence on record irrefutably shows that the transaction took place in F.Y. 2010–11. Therefore, in our considered view, the initiation of reassessment proceedings under section 147 for A.Y. 2012–13 was without jurisdiction and liable to be quashed. 6.3 Though the issue stands concluded on jurisdictional grounds

Income Tax Officer Ward 4(2)(1), Ahmedabad vs. Alpesh Manharlal Mistry, Ahhmedabad

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

ITA 777/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2012-13

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 142(1)Section 144Section 148Section 69

offered any comments on merits of the case by stating that sufficient opportunities were given to the assessee during the reassessment proceedings. The Ld. CIT(A) after considering the rejoinder from the assessee deleted the addition and allowed the appeal in favour of the assessee by observing as follows

Gautambhai Nansinh Chauhan, Anand vs. The ITO, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee is allowed

ITA 711/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2019-20

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri Amit Pratap Singh, Sr.DR
Section 115BSection 139(1)Section 142(1)Section 144BSection 147Section 148Section 250Section 271ASection 69A

Cash deposits in SB account Bank of Baroda 52,800/- Cash withdrawals from SB account Bank of Baroda 39,83,841/- 2.3 During the reassessment proceedings, notices under section 142(1) were issued on various dates calling for explanation regarding the source and nature of the high-value cash withdrawals

Pinkeshmumar Melapchand Shah, Ahmedabad vs. The ITO, Ward-2(2)(4), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 599/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2012-13

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2012-13 Pinkeshkumar Melapchand Shah The Ito, Ward-2(2)(4) B-1, 1St Floor, Abhinandan Flat Vs. Ahmedabad. Opp: Kothari Tower Ramnagar, Sabarmati, Ahmedabad 380005.Gujarat. Pan : Aeaps 0609 D. (Applicant) (Responent) : Shri Sunil Maloo, Ca Assessee By Revenue By : Shri Amit Pratap Singh, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 31/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 12/08/2025

For Respondent: Shri Amit Pratap Singh, Sr.DR
Section 133(6)Section 139Section 144Section 147Section 148Section 250Section 69A

being an individual with limited educational and financial literacy, had inadvertently failed to respond to the statutory notices issued by the Assessing Officer during reassessment proceedings as he was unaware of the e-proceeding compliance requirements on the income tax portal. It was only after receiving the assessment order that ... Assessing Officer under section 69A was fully justified in the absence of 6 any explanation or supporting documents during the course of reassessment proceedings. The DR emphasized that despite issuance of multiple notices under sections 133(6), 148 and 142(1), the assessee remained completely non-compliant and failed

Hiral Tapankumar Chudgar, Vadodara, Gujarat vs. Income Tax Officer, Ward 1(3)(1), Vadodara, Gujarat

In the result, the appeal filed by the assessee in ITA No

ITA 44/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 10(38)Section 147Section 148Section 148ASection 69Section 69A

since the escaped income claimed is less than Rs.50,00,000/- and there is no question of escaped income and requested to drop the reassessment proceedings. 2.1. The above objection was considered by the Assessing Officer and found not acceptable and proceeded with reassessment by making addition of Rs.29 ... notice u/s.148A cannot be issued beyond three years and the assumption of jurisdiction itself is bad in law and therefore requested to drop the reassessment proceedings. The AO considered the above reply in his order dated 30-07-2022 while disposing the objection u/s.148A[d] of the Act by holding

Hiral Tapankumar Chudgar, Vadodara, Gujarat vs. Income Tax Officer, Ward 1(3)(1), Vadodara, Gujarat

In the result, the appeal filed by the assessee in ITA No

ITA 43/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar, Judicial Member And\nShri Makarand Vasant Mahadeokar, Accountant Member\nITA Nos 43 & 44/Ahd/2025\nAssessment Years: 2017-18 & 2018-19\nHiral Tapankumar\nChudgar\n201/A, Premdarshan,\nBehind Jay Ambe School,\nSamasavli Raod, Vemali,\nVadodara-390008,\nGujarat\nPAN: ANCPC4000H\n(Appellant)\nIncome Tax Officer\nWard-1(3)(1),\nVs Vadodara\n(Respondent)\nAssessee Represented:\nShri Deepak Shah, A.R.\nRevenue Represented:\nShri Abhijit, Sr.D.R.\nDate of hearing\n: 18-06-

Section 10(38)Section 115BSection 147Section 148Section 148ASection 69Section 69A

since the escaped income claimed is less than Rs.50,00,000/- and there is no question of escaped income and requested to drop the reassessment proceedings. 2. 1. The above objection was considered by the Assessing Officer and found not acceptable and proceeded with reassessment by making addition of Rs.29 ... notice u/s.148A cannot be issued beyond three years and the assumption of jurisdiction itself is bad in law and therefore requested to drop the reassessment proceedings. The AO considered the above reply in his order dated 30-07-2022 while disposing the objection u/s.148A[d] of the Act by holding

Rameshkumar G. Patel, Vadodara vs. The ITO, Ward-3(1)(5) Present Jurisdiction ITO, Ward-3(1)(2), Vadodara

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

ITA 397/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2013-14

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri Viranch Modi, AR
Section 133(6)Section 142(1)Section 144Section 148Section 274

requiring details of income and expenses claimed in the return. The assessee either did not respond or sought adjournments. In the course of the reassessment proceedings, the AO also issued a notice under section 133(6) of the Act to the Sub-Registrar, Vadodara, from whom it was gathered that ... record. 3.4 Aggrieved by the above ex parte assessment, the assessee preferred appeal before the learned CIT(A) challenging the validity of the reassessment proceedings on the ground that alleged escapement pertained to non- fulfilment of IDS declaration, which at best related

Rajesh Baburao Shinde, Parbhani vs. ITO, Ward- Hingoli, Hingoli

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

ITA 781/PUN/2025[2015-16]Status: DisposedITAT Pune12 Aug 2025AY 2015-16

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.781/Pun/2025 िनधा"रण वष" / Assessment Year : 2015-16 Rajesh Baburao Shinde, Vs. Assessment Unit, Income Sayala Khating, Tq. Dist. Tax Department, Nfac, Parbhani- 431402. Delhi. Pan : Czcps6546Q Appellant Respondent Assessee By : Shri Shubham N. Rathi Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 22.07.2025 Date Of Pronouncement 12.08.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2015-16. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Akhilesh Srivastva
Section 142(1)Section 145Section 148Section 148ASection 151ASection 69A

grounds of appeal :- “1. THE CHALLENGE TO REASSESSMENT 1.1 The Learned Income Tax Officer, Ward Hingoli ['the Ld. JAO'] has erred in initiating the reassessment proceedings u/s 145 of the Income tax Act, 1961 ["the Act'] without serving notice under section 148 of the Income ... facts and in the circumstances of the case, the Ld. JAO has initiated the reassessment proceedings without fulfilling the preconditions required to initiate the reassessment proceedings U/s 148-151 of the Act. Further, the Ld. JAO failed to follow the directions as provided by the Hon'ble Apex Court

Manish Jashwantrai Bhuta, Nashik vs. ITO Ward 1(1), Nashik

In the result appeal of the assessee is allowed

ITA 1503/PUN/2025[2017-18]Status: DisposedITAT Pune12 Aug 2025AY 2017-18

Bench: Dr. Manish Boradआयकर अपील सं / Ita No.1503/Pun/2025 धििाारण वर्ा / Assessment Year: 2017-2018 Manish Jashwantrai Vs Ito Ward-1(1), Bhuta, Nashik Flat No-8, Pooja Apartment, Shivam Nagar, Hirawadi, Panchavati, Nashik-422003 Maharashtra Pan-Aghpb1619F Appellant Respondent

For Appellant: Shri Sanket JoshiFor Respondent: Shri Sanjay Dhivare
Section 147Section 148Section 151

instant case, in the light of the above judgement I notice that the notices u/s 148 of the Act for carrying out the reassessment proceedings for A.Y. 2017-18 has been issued on 20.07.2022. Also the first notice u/s 148A(b) has been issued on 26.05.2022. Therefore the notices ... without jurisdiction, bad in law and is in violation in provisions of section 151(ii) of the Act. Therefore the initiation of the reassessment proceedings in the instant case is without any jurisdiction and therefore such proceedings are quashed. The legal issue raised in ground No. 1 in assessee

Shamrao Gopal Benake, Pune vs. ITO Ward 1(1), Pune

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

ITA 1036/PUN/2025[2018-19]Status: DisposedITAT Pune12 Aug 2025AY 2018-19

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Respondent: Shri Akhilesh Srivastva
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 69A

however no return was furnished by the assessee. Notice u/s 148A(b) was issued and order u/s 148A(d) was also passed. During the reassessment proceedings, the assessee furnished income tax return in response to notice issued u/s 148 of the IT Act, however the return could not be verified ... treated as an invalid return. During the reassessment proceedings, various notices were issued to the assessee but he remained absent and consequently the assessment order was passed ex-parte. In first appeal the assessee challenged the validity of notices as well as the validity of reassessment along-with other grounds

ITO-23.1.6, Mumbai vs. Ghevarchand Jethmalji Jain, Mumbai

ITA 3859/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Aug 2025AY 2015-16

Bench: Justice (Retd.) C.V. Bhadang & Ms. Padmavathy S.: A.Y. : 2015-16 Ito-23(1)(6), Vs. Ghevarchand Jethmalji Jain 704, 7Th Floor, Safalya Bldg., Tarabag, Mumbai. (Appellant) Love Lane Mazgaon, Mumbai 400 010. Pan : Aadpj2435M (Respondent)

For Appellant: Shri Swapnil ChoudharyFor Respondent: Shri Harsh Kapadia &
Section 147Section 148Section 148ASection 149Section 253ASection 68

unexplained cash credit. The addition was made by the AO vide order dated 16.05.2023 under Section 147 r.w.s. 144 of the Act in reassessment proceedings. 2. The respondent-assessee is in the business of cheque discounting on commission basis. The assessee filed Return of Income (RoI) for the relevant assessment