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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

Gold Plaza India (Pvt)Ltd, Thrissur vs. ITO. Ward 1(1), Thrissur

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

ITA 973/COCH/2024[2006-07]Status: DisposedITAT Cochin31 Jul 2025AY 2006-07

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2006-07 Gold Plaza India (Pvt) Ltd. .......... Appellant Cresent House, Manoor P.O., Kaladi Malappuram 679582 [Pan: Aabcg8869K] Vs. The Income Tax Officer, Wd-1(1), Thrissur .......... Respondent Appellant By: Shri K. Kittu, Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 10.06.2025 Date Of Pronouncement: 31.07.2025

For Appellant: Shri K. Kittu, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 147Section 148

sale value of gold to shareholders. 3. Being aggrieved, an appeal was filed before the CIT(A), challenging the very validity of the reassessment proceedings as the AO reopened the assessment after expiry of 4 years without alleging that there is a failure on the part of the assessee ... have heard the rival contentions and perused the material available on record. The first ground of appeal challenges the very validity of reassessment proceedings on the ground that in the absence of allegation that there is failure on the part of the assessee to disclose material facts truly and wholly

Reena Engineers and Contractors Private Ltd, Panaji vs. ACIT, Central Circle-1, Calicut

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

ITA 271/COCH/2021[2014-2015]Status: DisposedITAT Cochin31 Jul 2025AY 2014-2015

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

revenue and not for the assessee. The submission on behalf of the revenue is that the assessee cannot be permitted to use reassessment proceedings as appeal or revision in disguise and seek relief in respect of items not claimed in the original return of Reena Engineers and Contractors ... total income of the assessee for the said assessment year and therefore, the proviso provides for the abatement of such pending assessments and reassessment proceedings, and it is only the assessment made under section 153A that would be the assessment for the said year. The necessary corollary of the above

Reena Engineers and Contractors Private Ltd, Panaji vs. ACIT, Central Circle-1, Calicut

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

ITA 270/COCH/2021[2016-2017]Status: DisposedITAT Cochin31 Jul 2025AY 2016-2017

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

revenue and not for the assessee. The submission on behalf of the revenue is that the assessee cannot be permitted to use reassessment proceedings as appeal or revision in disguise and seek relief in respect of items not claimed in the original return of Reena Engineers and Contractors ... total income of the assessee for the said assessment year and therefore, the proviso provides for the abatement of such pending assessments and reassessment proceedings, and it is only the assessment made under section 153A that would be the assessment for the said year. The necessary corollary of the above

Reena Engineers and Contractors Private Ltd, Panaji vs. ACIT, Central Circle-1, Calicut

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

ITA 269/COCH/2021[2015-2016]Status: DisposedITAT Cochin31 Jul 2025AY 2015-2016

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

revenue and not for the assessee. The submission on behalf of the revenue is that the assessee cannot be permitted to use reassessment proceedings as appeal or revision in disguise and seek relief in respect of items not claimed in the original return of Reena Engineers and Contractors ... total income of the assessee for the said assessment year and therefore, the proviso provides for the abatement of such pending assessments and reassessment proceedings, and it is only the assessment made under section 153A that would be the assessment for the said year. The necessary corollary of the above

Reena Engineers and Contractors Private Ltd, Panaji vs. ACIT, Central Circle-1, Calicut

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

ITA 268/COCH/2021[2013-2014]Status: DisposedITAT Cochin31 Jul 2025AY 2013-2014

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

revenue and not for the assessee. The submission on behalf of the revenue is that the assessee cannot be permitted to use reassessment proceedings as appeal or revision in disguise and seek relief in respect of items not claimed in the original return of Reena Engineers and Contractors ... total income of the assessee for the said assessment year and therefore, the proviso provides for the abatement of such pending assessments and reassessment proceedings, and it is only the assessment made under section 153A that would be the assessment for the said year. The necessary corollary of the above

Reena Engineers and Contractors Private Ltd, Panaji vs. ACIT, Central Circle-1, Calicut

In the result, the appeals filed by the assessee stand partly

ITA 267/COCH/2021[2012-2013]Status: DisposedITAT Cochin31 Jul 2025AY 2012-2013

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

revenue and not for the assessee. The submission on behalf of the revenue is that the assessee cannot be permitted to use reassessment proceedings as appeal or revision in disguise and seek relief in respect of items not claimed in the original return of income. According to the department ... total income of the assessee for the said assessment year and therefore, the proviso provides for the abatement of such pending assessments and reassessment proceedings, and it is only the assessment made under section 153A that would be the assessment for the said year. The necessary corollary of the above

Suresh Patel, Dewas vs. CIT(A), NFAC, Delhi

Appeal is dismissed

ITA 131/IND/2025[2009-10]Status: DisposedITAT Indore31 Jul 2025AY 2009-10

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

Section 144Section 249(4)(b)Section 253(5)Section 271(1)(c)

view, clause (b) of Section 249(4) of the Act will not apply as there is no question of paying advance tax in reassessment proceedings, even though assessee did not file ROI. 6. In the said circumstances, we find that the impugned order dismissing the appeal on the ground ... deserves to be set-aside”. In the case in hand the assessee has filed return of income and thereafter, the Assessing Officer has initiated reassessment proceedings and passed reassessment order. Therefore, for filing the appeal before CIT(A) the question of payment of advance tax by the assessee

Suresh Patel, Dewas vs. CIT(A), NFAC, Delhi

Appeal is dismissed

ITA 130/IND/2025[2009-10]Status: DisposedITAT Indore31 Jul 2025AY 2009-10

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

Section 144Section 249(4)(b)Section 253(5)Section 271(1)(c)

view, clause (b) of Section 249(4) of the Act will not apply as there is no question of paying advance tax in reassessment proceedings, even though assessee did not file ROI. 6. In the said circumstances, we find that the impugned order dismissing the appeal on the ground ... deserves to be set-aside”. In the case in hand the assessee has filed return of income and thereafter, the Assessing Officer has initiated reassessment proceedings and passed reassessment order. Therefore, for filing the appeal before CIT(A) the question of payment of advance tax by the assessee

Ajay Kumar Rampuria, Tonk vs. Income Tax Officer, Tonk

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

ITA 612/JPR/2025[2013-14]Status: DisposedITAT Jaipur31 Jul 2025AY 2013-14

Bench: Dr. Manish Borad

For Appellant: Shri Sandeep Jhanwar, C.A
Section 147Section 250Section 250(6)Section 69

individual and runs the business under sole proprietorship of Ajay Enterprises. Income of Rs.14,17,010/- declared in the return filed on 28.09.2013. Reassessment proceedings were initiated u/s.147 of the Act and addition of Rs.7,57,911/- made u/s.69 of the Act. Assessment order has been framed

Devendra Pratap Singh, Kumarganj Faizabad vs. ITO-1, Faizabad-New, Faizabad

In the result, the appeal of the assessee is partly allowed

ITA 176/LKW/2025[2017-2018]Status: DisposedITAT Lucknow31 Jul 2025AY 2017-2018

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Purnodaya Kumar Singh, AdvFor Respondent: Sh. Amit Kumar, DR
Section 142(1)Section 147Section 148Section 250Section 69A

appears to be erroneous, as the said deposits duly represent sales proceeds from the appellant's regular business of petrol and diesel. 2. The reassessment proceedings may not have been conducted in strict compliance with legal provisions, and the assessment order dated 30.03.2022 requires reconsideration. The reassessment was initiated without

Pravinbhai Jethabhai Patel, Kheda vs. The ITO, Ward-5, Nadiad

In the result, the appeal of the assessee is allowed

ITA 137/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalpravinbhai Jethabhai Patel, Income Tax Officer, Vs. Teen Khadki, Nr. Bar Ni Khadki, Ward-5, Village-Nar, Tal. Petlad, Nandiad. Kheda-388150. [Pan :Biqpp9029 K] (Appellant) .. (Respondent) Appellant By : Shri Jamin Shah, Ar Respondent By: Shri Bp Makwana, Sr. Dr Date Of Hearing 16.07.2025 Date Of Pronouncement 31.07.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:- This Appeal Has Been Filed By The Assessee Against The Order Dated 21.11.2024, Passed By The Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (Hereinafter Referred To As "Cit(A)" For Short), U/S 250 Of The Income-Tax Act, 1961, (Hereinafter Referred To As "The Act" For Short) For The Assessment Year 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri Jamin Shah, ARFor Respondent: Shri BP Makwana, Sr. DR
Section 142(2)Section 143(2)Section 147Section 148Section 210Section 234ASection 250Section 271(1)(c)Section 56(2)(vii)

Blue Moon (321 ITR 362), wherein the Hon’ble Court has categorically held that issuance of notice u/s 143(2) is mandatory even in reassessment proceedings. The Ld. AR also relied upon the judgment of Hon’ble jurisdictional High Court in the case of CIT v. Sukhini P. Modi ... Revenue to approach the Tribunal in case they could prove issuance of notice u/s 143(2) of the Act. 10. As the reassessment proceedings are held to be invalid, the other grounds raised on merits have become academic and are not adjudicated upon. 11. In the result, the appeal

Gruh Finance Ltd., Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

Appeal is dismissed

ITA 1228/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2011-12

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

aforesaid share premium had escaped assessment. He, accordingly, re- opened the assessment u/s.147 r.w.s.148 of the Act. However, the assessee during the reassessment proceedings carried out u/s.147 of the Act, made a new claim of deduction on account of Employees’ Stock Option Plan (ESOP) cost of Rs.4 ... forward claim for deduction for any expenditure which was relatable to the income which was sought to be assessed as escaped income in the reassessment proceedings. However, it is settled proposition of law that when no such claim relating to ESOP cost was made in the original return of income

Gruh Finance Ltd., Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

Appeal is dismissed

ITA 138/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2014-15

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

aforesaid share premium had escaped assessment. He, accordingly, re- opened the assessment u/s.147 r.w.s.148 of the Act. However, the assessee during the reassessment proceedings carried out u/s.147 of the Act, made a new claim of deduction on account of Employees’ Stock Option Plan (ESOP) cost of Rs.4 ... forward claim for deduction for any expenditure which was relatable to the income which was sought to be assessed as escaped income in the reassessment proceedings. However, it is settled proposition of law that when no such claim relating to ESOP cost was made in the original return of income

Gruh Finance Ltd., Ahmedabad vs. The Dy. CIT, Circle-2(1)(1), Ahmedabad

Appeal is dismissed

ITA 855/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2012-13

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

aforesaid share premium had escaped assessment. He, accordingly, re- opened the assessment u/s.147 r.w.s.148 of the Act. However, the assessee during the reassessment proceedings carried out u/s.147 of the Act, made a new claim of deduction on account of Employees’ Stock Option Plan (ESOP) cost of Rs.4 ... forward claim for deduction for any expenditure which was relatable to the income which was sought to be assessed as escaped income in the reassessment proceedings. However, it is settled proposition of law that when no such claim relating to ESOP cost was made in the original return of income

The ACIT, Circle-2(1)(1), Ahmedabad vs. Gruh Finance Ltd., Ahmedabad

Appeal is dismissed

ITA 1126/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2012-13

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

aforesaid share premium had escaped assessment. He, accordingly, re- opened the assessment u/s.147 r.w.s.148 of the Act. However, the assessee during the reassessment proceedings carried out u/s.147 of the Act, made a new claim of deduction on account of Employees’ Stock Option Plan (ESOP) cost of Rs.4 ... forward claim for deduction for any expenditure which was relatable to the income which was sought to be assessed as escaped income in the reassessment proceedings. However, it is settled proposition of law that when no such claim relating to ESOP cost was made in the original return of income

Omkar Ramchandra Velhal, Kolhapur vs. Income Tax Officer, Ward 1(1), Kolhapur

In the result, appeal of the assessee is Partly Allowed

ITA 672/PUN/2025[2015-16]Status: DisposedITAT Pune31 Jul 2025AY 2015-16

Bench: Shri Vinay Bhamore & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.672/Pun/2025 निर्धारण वर्ष / Assessment Year: 2015-16 Omkar Ramchandra Velhal, V The Income Tax Officer, Plot No.183/3, Omkar Near S Ward-1(1), Kolhapur. Ganga Hospital, A Ward Dudhali, Kolhapur – 416012. Maharashtra. Pan: Asipv6553D Appellant/ Assessee Respondent / Revenue Assessee By Revenue By Date Of Hearing None Shri Aknath Abhang – Addl.Cit(Dr) 23/07/2025 Date Of Pronouncement 31/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Dated 21.01.2025, Emanating From Order U/S.147 Read With Section 144B Of The Income Tax Act, 1961, Dated 31.01.2023. The Assessee Has Raised Following Grounds Of Appeal :

Section 144BSection 147Section 148Section 148ASection 149Section 149(1)(b)Section 250Section 68

amended vide Finance Act, 2021 w.e.f. 01.04.2021. 2. Jurisdiction: The assessment order passed by the NFAC is invalid and beyond its jurisdiction, as the reassessment proceedings were initiated by the jurisdictional Assessing Officer. The entire reassessment proceedings may kindly be quashed 3. Addition of Rs.20,00,000/- on Account

Shri Gautam Gupta, Howrah vs. ITO, Ward 47(1), Kolkata

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

ITA 1192/KOL/2025[2018-2019]Status: DisposedITAT Kolkata31 Jul 2025AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1192/Kol/2025 Assessment Year: 2018-19 Shri Gautam Gupta…………………..……..…………………....Appellant 20/4/4, Sarada Chatterjee Lane, Howrah, Kadamtala S.O (Howrah), Howrah, W.B – 71101. [Pan: Arwpg0842P] Vs. Ito, Ward-47(1), Kolkata……………....…..………………….…..... Respondent Appearances By: Shri Arya Das, Ar & Subhajit Roy, Ar, Appeared On Behalf Of The Appellant. Smt. Ranu Biswas, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 31, 2025 Date Of Pronouncing The Order : 31/07/2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) [Cit(A)], Kolkata, Dated 27.03.2025, Passed Against The Assessment Order Under Section 147/143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2018–19. 2. Brief Facts Of The Case Are That The Assessee, Engaged In The Business Under The Proprietorship Concern Named M/S. Ma Durga Enterprises, Filed The Return Of Income Declaring Income Of ₹6,55,790. During The Course Of Reassessment Proceedings Initiated Under Section 148 Of The Act, The Assessing Officer (Ao) Made An Addition Of ₹20,00,845, Treating The Purchases Made From M/S. Devyansh Delcom Pvt. Ltd. As Bogus, Based On The Findings That The Said Entity Was Non-

Section 147Section 148

under the proprietorship concern named M/s. Ma Durga Enterprises, filed the return of income declaring income of ₹6,55,790. During the course of reassessment proceedings initiated under Section 148 of the Act, the Assessing Officer (AO) made an addition of ₹20,00,845, treating the purchases made from

Oveen Naveen Lewis, Mumbai vs. Income Tax Officer Int. Tax Ward 3(1)(1), Mumbai

In the result the appeal filed by the assessee is allowed

ITA 775/MUM/2025[2015-16]Status: DisposedITAT Mumbai31 Jul 2025AY 2015-16

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 147Section 147rSection 148Section 148ASection 149Section 149(1)Section 56(2)Section 56(2)(vii)

Bansal v/s. UOI, we hold that the notice dated 18/04/2022 issued under section 148 of new regime is barred by limitation. As a consequence reassessment proceedings based on the invalid notice does not survive and the additions made therein are liable to be deleted. Accordingly the Ground

Sujan Gopal Mukherji, Mumbai vs. Ward 22(3)(1), Mumbai

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

ITA 4149/MUM/2025[2016-17]Status: DisposedITAT Mumbai31 Jul 2025AY 2016-17

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year 2016-17

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Aditya M. Rai, Sr.DR
Section 147Section 148Section 148ASection 250Section 69

Subsequently, statutory notices under section 143(2) and section 142(1) of the Act were issued and served on the assessee. 6. During the reassessment proceedings, a show cause notice was issued to the assessee in respect of the amount received by the assessee as hardship allowance. In response, assessee ... which proceedings under section 147 of the Act were initiated, the assessee was issued a show cause notice during the reassessment proceedings and requested to submit a reply with supporting documentary evidence. However, the assessee failed to respond to the show cause notice. Accordingly, in the absence of any reply

Ms. Nisha Sharma, Mumbai vs. Income Tax Officer -1(2), Thane

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

ITA 4097/MUM/2025[2011-12]Status: DisposedITAT Mumbai31 Jul 2025AY 2011-12

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year 2011-12

For Appellant: NoneFor Respondent: Shri Asif Karmali, Sr.DR
Section 144Section 147Section 148Section 250

Ritesh Burad, notice under section 148 of the Act was issued and proceedings under section 147 of the Act were initiated. During the reassessment proceedings, from the perusal of the bank account of the assessee with Kotak Mahindra Bank in the name of M/s Monk Exports, wherein the assessee ... genuine business activities, in absence of any reply by the assessee in response to various statutory notices and show cause notice issued during the reassessment proceedings, the Assessing Officer (“AO”), vide order dated 29/12/2018 passed under section 144 read with section 147 of the Act made the addition on account