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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

ACIT, Central Circle, Patiala vs. M/S Gazebo Constructions Private Limited, Patiala

In the result, Revenue’s appeal is dismissed

ITA 674/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh07 Jul 2025AY 2013-14

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 674/Chd/2022 "नधा"रण वष" / Assessment Year : 2013-14 The Acit, Vs. M/S Gazebo Construction Central Circle, बनाम Private Limited, Patiala 616-A, Gurbax Colony, Patiala "थायी लेखा सं./Pan No: Aaccg8052F अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Deepak Aggarwal, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit,Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 05.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 07.07.2025

For Appellant: Shri Deepak Aggarwal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT,Sr.DR
Section 133ASection 147Section 148Section 69C

Based on the findings of the survey, the Assessing Officer formed the belief that income chargeable to tax had escaped assessment and accordingly initiated reassessment proceedings under section 148 of the Act. b) The assessment under section 147 was completed by the ACIT/DCIT, Central Circle, Patiala, vide order dated

Tours5 Com, Hyderabad vs. ITO., Ward-9(1), Hyderabad

ITA 632/HYD/2025[2016-17]Status: DisposedITAT Hyderabad07 Jul 2025AY 2016-17

Bench: Us:

Section 144Section 147Section 148Section 148ASection 271(1)(b)Section 271(1)(c)Section 69

HYDERABAD. was raised before the CIT(A), had specifically assailed the validity of jurisdiction that was assumed by the AO for initiating the reassessment proceedings. For the sake of clarity, the "Ground of appeal No.2” raised by the assessee company before the CIT(A) is being culled out as under ... adjudicate the grievance of the assessee appellant, as regards the validity of the jurisdiction assumed by the A.O for initiating the assessment or reassessment proceedings to the extent the same can safely be done based on the facts discernible from the record before him. Our aforesaid conviction can safely

Tours5 Com, Hyderabad vs. ITO., Ward-9(1), Hyderabad

ITA 630/HYD/2025[2016-17]Status: DisposedITAT Hyderabad07 Jul 2025AY 2016-17

Bench: Us:

Section 144Section 147Section 148Section 148ASection 271(1)(b)Section 271(1)(c)Section 69

HYDERABAD. was raised before the CIT(A), had specifically assailed the validity of jurisdiction that was assumed by the AO for initiating the reassessment proceedings. For the sake of clarity, the "Ground of appeal No.2” raised by the assessee company before the CIT(A) is being culled out as under ... adjudicate the grievance of the assessee appellant, as regards the validity of the jurisdiction assumed by the A.O for initiating the assessment or reassessment proceedings to the extent the same can safely be done based on the facts discernible from the record before him. Our aforesaid conviction can safely

Murali Mohan Reddy Bonthu, Vijayawada vs. Income-Tax Officer, Ward-3(1), Vijayawada

In the result, appeal of the assessee is allowed

ITA 265/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam04 Jul 2025AY 2013-14

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.265/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2013-14) Murali Mohan Reddy Bonthu V. Income Tax Officer – Ward – 3(1) 14/4, Flat No. 503 Cr Building, 1St Floor Annex Sree Satya Sai Towers M.G. Road, Vijayawada – 522002 Andhra Pradesh Main Road Nunna Andhra Pradesh - 521212 [Pan:Aiopb5077E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri I. Kama Sastry, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparna Villuri, Sr.Ar

Section 112Section 139(4)Section 142(1)Section 147Section 148Section 149(1)(b)Section 234ASection 54FSection 69A

sections 147 to 151 including the newly inserted sections 148A of the Act without having any savings clause for the old provisions relating to reassessment proceedings Section 3 of TOLA Notification No. 20 of 2021 dated 31.03.2021 subsequently amended by notification No. 38/2021 dated 27.04.2021 issued by the CBDT ... aiding the old provisions relating to the Page. No 7 I.T.A.No.265/VIZ/2024 Murali Mohan Reddy Bonthu reassessment proceedings which remained in force till 31.03.2021, non-issuance of impugned notice under the newly inserted section 148A(b) of the Act relating to A.Y. 2013-14 which in the instant case

Bhawani Singh, Jaipur vs. ITO WD 4(1), Jpr, Jaipur

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

ITA 471/JPR/2025[2011-12]Status: DisposedITAT Jaipur04 Jul 2025AY 2011-12

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Nikhilesh Kataria, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 139(1)Section 144Section 147

raised the following grounds: - “1. The Id. AO erred in law as well as on the facts of the present case in initiating reassessment proceedings u/s 147 of the Income Tax Act, 1961 and Id. CIT(A) erred in sustaining the same and hence the consequent assessment may please ... also granted mechanical approval for reopening of assessment which is against the law and settled judicial precedents and hence consequent initiation of reassessment proceedings is also bad in law and hence prayed to be quashed 3. The order passed

All India Womens Conference Kanpur, Kanpur vs. The Income Tax Officer, Ward-1(1)(1), Civil Lines Kanpur

ITA 510/LKW/2024[2022-23]Status: DisposedITAT Lucknow04 Jul 2025AY 2022-23

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2022-23 All India Womens Conference V. The Income Tax Officer Kanpur Ward 1(1)(1) 16/4, Mahila Park, Civil Lines Civil Lines Sarsaiya Ghat, Kanpur Kanpur Tan/Pan:Aacta1200E (Appellant) (Respondent) Appellant By: Shri Swaran Singh, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.06.2024, Passed By The Addl/Jcit(A)-2, Kolkata For Assessment Year 2022-23. 2.0 The Brief Facts Of The Case Are That The Assessee Is A Society Registered Under The Societies Registration Act Xxi Of 1860 & Running Working Women’S Hostel At Subsidized Rate Under The Name & Style Of ‘All India Womens Conference’, Kanpur. The Assessee-Society Is Also Registered Under Section 10Ac Of The Income Tax Act, 1961 (Hereinafter Called “The Act’). During The Year Under Consideration, The Assessee-Society E-Filed Its Return Of Income, Declaring Nil Income. The Assessee-Society During The Year Under Consideration Had Shown Gross Receipts Of Rs.10,52,829/- And

For Appellant: Shri Swaran Singh, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 10Section 10ASection 143(1)

Various Benches of the Tribunal have held that even if Form 10B is filed during the first appellate proceedings or during the course of reassessment proceedings, the benefit of sections 11 and 12 of the Act cannot be denied to the assessee. However, since the request

Rajeev Kumar Sehgal, Lakhimpur Kheri vs. ITO-3(4), Lakhimpur Kheri-2

The appeal of the assessee stands partly allowed

ITA 30/LKW/2024[2014-15]Status: DisposedITAT Lucknow04 Jul 2025AY 2014-15

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2014-15 Rajeev Kumar Sehgal V. The Income Tax Officer 3(4) Punjab Colony Lakhimpur Kheri - 2 Lakhimpur Kheri Tan/Pan:Asbps5131M (Appellant) (Respondent) Appellant By: Shri Saurabh Gupta, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. O R D E R

For Appellant: Shri Saurabh Gupta, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 142(1)Section 143(3)Section 147Section 148Section 44A

amount of Rs.15,47,455/- being the difference in total deposits and turnover of the assessee. It was submitted that during the course of reassessment proceedings, the assessee had duly furnished copies of bank statements along with summary of the same and even proper explanations were offered

Rama Rani, Chandigarh vs. DCIT, Circle 1(1), Chandigarh

The appeal stand allowed in terms of our above order

ITA 933/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh04 Jul 2025AY 2015-16

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 933/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2015-16 Ms. Rama Rani Dcit बनाम/ Vs. H. No 1058, Popular Enclave Circle 1(1), Sector 48-B, Chandigarh Chandigarh. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aerpr-2072-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ravinder Krishan (Advocate)– Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Rajat Kumar Kureel (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 30-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of This Appeal, The Assessee Assails Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax, Chandigarh-1 (Pr.Cit) For Assessment Year (Ay) 2015-16 Vide Impugned Order Dated 14-03-2024 Proposing Revision Of Assessment As Framed By Ld. Ao U/S.147 Of The Act On 29-03-2022. The Registry Has Noted Delay Of 98 Days In The Appeal, The Condonation Of Which Has Been Sought By Ld. Ar On The Strength Of Condonation Petition Which Is Accompanied By An Affidavit Of The Assessee. It Has Been Stated That The Assessee Was Not In India When

For Appellant: Sh. Ravinder Krishan (Advocate)– Ld. ARFor Respondent: Sh. Rajat Kumar Kureel (CIT) – Ld. DR
Section 142(1)Section 143(3)Section 147Section 263Section 54F

from the assessee. The assessee filed the documents / explanations and after due verification thereof, the returned income of Rs.104.40 Lacs was again accepted in reassessment proceedings. The perusal of computation of income would show that the assessee declared Long Term Capital Gains of Rs.184.73 Lacs against which the assessee claimed ... Thus, Ld. AO applied his mind to the impugned issue not only at the time of original assessment proceedings but also during reassessment proceeding and there was no lack of enquiry as alleged. In this background, the assessee assailed revision of the order. However, Ld. Pr. CIT ordered for revision

Mohd Shahbuddin Khan, Chandigarh vs. PCIT-1, Chandigarh

In the result, appeal of the Assessee is dismissed

ITA 564/CHANDI/2024[2013-2014]Status: DisposedITAT Chandigarh04 Jul 2025AY 2013-2014
For Respondent: Shri Ajay Jain, CA and Shri Lovesh Bansal, CA
Section 147Section 263

course of hearing, the assessee submitted that the AO had issued notices and called for information, and all relevant details were submitted during the reassessment proceedings. It was clarified that no property was sold and that the amount was only advanced to him to facilitate a deal which

Gujarat Mineral Development Corporation Limited, Khanji Bhavan vs. Pr. Commissioner of Income Tax-1, Aayakar Bhawan(Vejalpur), Ahmedabad

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

ITA 651/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad04 Jul 2025AY 2020-21

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2020-21

For Appellant: Shri Rignesh Das, CIT-DR
Section 143(1)Section 143(3)Section 14ASection 263Section 80GSection 80I

investigate, but as no addition was made, the Revenue can argue that it is a case of wrong conclusion and decision in the reassessment proceedings. Therefore, to exercise jurisdiction under Section 263 of the 1961 Act, the Commissioner of Income Tax should have examined the merits and only on reaching

Ratansinh Solanki, Mahesana vs. Income Tax Officer Ward 1 Patan, Patan, Gujarat

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

ITA 526/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad04 Jul 2025AY 2018-19

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2018-19 Ratansinh Solanki Ito, Ward-1 Rajput Vas, At – Modhera Vs. Patan. Becharaji, Mehesana, Becharaji So Gujarat. Pan : Exyps 4701 K (Applicant) (Responent)

For Appellant: Shri Sunil Talati, AR
Section 115BSection 133(6)Section 142(1)Section 147Section 148Section 148ASection 250Section 69A

invalid by the Central Processing Centre (CPC), and the assessee’s condonation request was not accepted, as per remarks dated 24.02.2023. Thereafter, during the reassessment proceedings, the Assessing Officer issued several statutory notices under section 142(1) dated 05.04.2023, 08.08.2023, and 27.09.2023, as well as follow-up notices including show ... cash deposits reflected in the assessee’s bank accounts represent sale proceeds generated from such business. The AR contended that during the course of reassessment proceedings, the assessee had filed its financial statements, including the Profit & Loss 5 Account, Balance Sheet, Trading Account, and computation of income, wherein the business

Jhaveri Trading and Investment Private Limited, Ahmedabad vs. The Dy.CIT, Cent. Circle-1(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 9/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad04 Jul 2025AY 2012-13

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2012-13

For Appellant: Shri Deepak Shah, A.RFor Respondent: Shri Kavan Limbasiya, Sr. D.R
Section 143(3)Section 147Section 148Section 153C

same being based on change of opinion and having been passed without consideration of the objections/submissions filed disputing the validity of notice u/s.148 and reassessment proceedings pursuant thereto. 1. The ld. CIT(A) has grievously erred in law and on facts in not appreciating the fact that the reopening ... pursuance of the said notice requires to be quashed. [II] AO has erred in making various additions outside the scope and ambit of reassessment proceedings 1. The ld. CIT(A) has erred in not appreciating the fact that the AO has grievously erred in law and on facts in making

M/S. Draipl-Mskel(Jv), Ahmedabad vs. The Income Tax Officer, Ward-9(2), Ahmedabad

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

ITA 1605/AHD/2014[2007-08]Status: DisposedITAT Ahmedabad04 Jul 2025AY 2007-08

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2007-08 Draipl-Kskel (Jv) Ito, Ward-9(2) 2Nd Floor, “Msk” Vs. Ahmedabad. Passport Office To Panjarapole Rd. Ambawadi Ahmedabad 380 015. Pan : Aaaad 3825 B (Applicant) (Responent)

For Appellant: Shri Deepak Rindani, ARFor Respondent: Shri Abhijit, Sr.DR
Section 143(3)Section 194ASection 271(1)(c)Section 40Section 80I

aside the penalty order to the file of the Assessing Officer to be adjudicated afresh in accordance with the outcome of the quantum reassessment proceedings. 12. The impugned order of the CIT(A) is hereby set aside. The matter is restored to the file of the Assessing Officer, who shall

M/S Fantastic Financial Consultants Pvt. Ltd., Kolkata vs. ITO, Ward-9(1), Kolkata

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

ITA 253/KOL/2025[2013-14]Status: DisposedITAT Kolkata04 Jul 2025AY 2013-14

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 1Section 142(2)Section 143(3)Section 147Section 148Section 148ASection 250Section 251Section 251(1)Section 69A

otherwise, the Ld. CIT(A) erred in not deciding the appeal ground wise whereas there were several grounds relating to the validity of the reassessment proceedings. 3. For that the notice u/s 148 deemed as notice u/s 148A(b) is without jurisdiction and therefore bad in law. Therefore all consequential ... Notification No. S.O. 1466(E) dated 29.03.2022 issued by the Hon'ble CBDT. 12. For that in the instant case, the Ld. AO initiated reassessment proceedings in respect of alleged receipts of Rs.149 Lakh from Nityadhara Dealcomm Pvt. Ltd. whereas in fact the assessee received only Rs.84 Lakh. As such

Gianchand Asodomal Rohera, Pune vs. Ward 2(1), Kalyan

In the result, ground no. 1 of the appeal is allowed

ITA 6862/MUM/2024[2018-19]Status: DisposedITAT Mumbai04 Jul 2025AY 2018-19

Bench: SHRI PAWAN SINGH (Judicial Member)

Section 144Section 147Section 148Section 148ASection 151Section 151ASection 254(1)Section 69C

Shri Anil Gavhane were brought an record at the time of show-cause notice stage, which were withheld during the course of 148A and reassessment proceedings. 7) The CIT (A) erred in upholding the assessment framed u/s. 144 by ignoring the fact that Ld. A.O. has not satisfied

DCIT-1(1), Bhilai vs. Vijaya Deshlahra, Indore

In the result, ITA No. 92/RPR/2025 & C

ITA 94/RPR/2025[2015-16]Status: DisposedITAT Raipur03 Jul 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

For Appellant: Ms. Nisha Lahoti, CA (virtual)For Respondent: Shri S.L. Anuragi, CIT-DR
Section 10(38)Section 148Section 68

contentions of the learned counsel to the fact that the principles of natural justice were not complied with by the Revenue while completing the reassessment proceedings, appears to be therefore correct on record and needs to be appropriately complied with by the Department. Balancing scales of justice, one opportunity

DCIT-1(1), Bhilai vs. Vijaya Deshlahra, Indore

In the result, ITA No. 92/RPR/2025 & C

ITA 93/RPR/2025[2014-15]Status: DisposedITAT Raipur03 Jul 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

For Appellant: Ms. Nisha Lahoti, CA (virtual)For Respondent: Shri S.L. Anuragi, CIT-DR
Section 10(38)Section 148Section 68

contentions of the learned counsel to the fact that the principles of natural justice were not complied with by the Revenue while completing the reassessment proceedings, appears to be therefore correct on record and needs to be appropriately complied with by the Department. Balancing scales of justice, one opportunity

DCIT-1(1), Bhilai vs. Vijaya Deshlahra, Indore

In the result, ITA No. 92/RPR/2025 & C

ITA 92/RPR/2025[2013-14]Status: DisposedITAT Raipur03 Jul 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

For Appellant: Ms. Nisha Lahoti, CA (virtual)For Respondent: Shri S.L. Anuragi, CIT-DR
Section 10(38)Section 148Section 68

contentions of the learned counsel to the fact that the principles of natural justice were not complied with by the Revenue while completing the reassessment proceedings, appears to be therefore correct on record and needs to be appropriately complied with by the Department. Balancing scales of justice, one opportunity

Joint Commissioner of Income-Tax(OSD), Central Circle-4, Ambedkar Circle vs. Siddhartha Totuka, C-Scheme

In the result, appeal of the Revenue is dismissed

ITA 305/JPR/2025[2015-16]Status: DisposedITAT Jaipur03 Jul 2025AY 2015-16

Bench: SHRI MANISH BORAD (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Pramod Patni, C.AFor Respondent: Shri Sushil Kulhari, Addl. CIT-DR
Section 147Section 148Section 153ASection 153C

case of Ramesh Manihar Group. However when the validity of issue of notice u/s 148 of the Act for carrying out reassessment proceedings u/s 147 of the Act challenged before the Hon’ble High Court, assessee succeeded. Hon’ble Court held that since the reassessment proceedings has been carried

Shiv Asrey Singh, Kanpur vs. Dy.CIT-2, Kanpur

The appeal of the assessee stands partly allowed

ITA 579/LKW/2024[2012-13]Status: DisposedITAT Lucknow03 Jul 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Shiv Asrey Singh V. The Dcit-2 Sb-17, Sbi Colony Kanpur Ratanlal Nagar Kanpur Tan/Pan:Aizps6999M (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Shri Sanjeev Krishna Sharma, D.R. O R D E R

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 10(38)Section 115BSection 143(2)Section 147Section 148Section 271(1)(c)

well as on merits. Subsequently, the appeal of the assessee was migrated to NFAC, who dismissed the appeal of the assessee by upholding the reassessment proceedings as well as dismissing the grounds on merits. 2.3 Now, the assessee has approached this Tribunal challenging the dismissal of his appeal ... assessee has been given an opportunity to cross examine the person whose statement has been recorded, the entire premise on which the reassessment proceedings have been initiated are devoid of substance be quashed. 5. Because in any case and all circumstances the amount of Rs.27,63,045/- received against debit