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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

Balaji Bullions and Commodities India Private Limited, Mumbai vs. DCIT Central Circle 7(1), Mumbai

The appeal of the Revenue is allowed for statistical purposes

ITA 3755/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Shri Sharwan Kumar Jha, Adv
Section 133ASection 143(1)

assessee filed its return of income on 29.04.2021, reiterating the loss originally declared. 3. During the course of t During the course of the reassessment proceedings, the he reassessment proceedings, the Assessing Officer called for and examined the details of the assessee’s Assessing Officer called for and examined ... addition, recorded detailed findings. addition, recorded detailed findings. The learned CIT(A) first The learned CIT(A) first addressed the validity of the reassessment proceedings. Upon addressed the validity of the reassessment proceedings. Upon addressed the validity of the reassessment proceedings. Upon consideration of the reasons recorded and the material

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Income Tax Officer, Ward 19(1)(1), Mumbai

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

ITA 2050/MUM/2024[2015-16]Status: DisposedITAT Mumbai23 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2015-16

For Appellant: Mr. Tushar NagoriFor Respondent: Mr. Swapnil Choudhari, Sr. DR
Section 147Section 250Section 69A

without appreciating the fact that the conditions laid down valid without appreciating the fact that the conditions laid down under the Act for initiating reassessment proceedings were not under the Act for initiating reassessment proceedings were not under the Act for initiating reassessment proceedings were not fulfilled

Rajesh Kumar Mishra, Rourkela vs. ITO Ward-1, Rourkela

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

ITA 63/CTK/2026[2018-19]Status: DisposedITAT Cuttack20 Feb 2026AY 2018-19

Bench: Shri George Mathan & Shri Madhusudan Sawdiarajesh Kumar Mishra, I.T.O., Labour Tenament, Qr. No. Pwd/La- Ward-1, Vs. 111, Jail Road, Panpose, Rourkela. Rourkela-756004 (Odisha) Pan No. Amgpm 2651 P Appellant/ Assessee Respondent/ Revenue

Section 115BSection 143(3)Section 144BSection 147Section 154

issues in this appeal are restored to the file of ld. CIT(A) for readjudication alongwith the appeal filed by the assessee against the reassessment proceedings. 3 Rajesh Kumar Mishra Vs ITO 6. In the result, this appeal of the assessee is partly allowed for statistical purposes. Order dictated

Rohitkumar Chinubhai Modi, Ahmedabad vs. The ACIT, Cir. 5(2) Now DCIT, Circle-2(1)(1), Ahmedabad

The appeal of the assessee is hereby dismissed

ITA 1961/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

read with section 147 was completed on 17.12.2014 determining the total income at Rs.45,44,450/-Once again, the Assessing Officer initiated reassessment proceedings by issuing notice under section 148 on 23.03.2016 after recording reasons and obtaining approval as required under the Act. Since the assessee did not file ... assessee’s 25% share therein amounted to Rs.3,31,63,140/-, which had not been disclosed in the return of income. 7. During the reassessment proceedings, the denied receipt of any cash consideration and submitted that that the entire sale consideration was received only by cheque as per the registered

Saurabhbhai Rohitbhai Modi, Ahmedabad vs. The ACIT, Cir. 5(2) Now DCIT, Circle-2(1)(1), Ahmedabad

The appeal of the assessee is hereby dismissed

ITA 1960/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

read with section 147 was completed on 17.12.2014 determining the total income at Rs.45,44,450/-Once again, the Assessing Officer initiated reassessment proceedings by issuing notice under section 148 on 23.03.2016 after recording reasons and obtaining approval as required under the Act. Since the assessee did not file ... assessee’s 25% share therein amounted to Rs.3,31,63,140/-, which had not been disclosed in the return of income. 7. During the reassessment proceedings, the denied receipt of any cash consideration and submitted that that the entire sale consideration was received only by cheque as per the registered

Shantaben Joitaram Patel, Ahmedabad vs. The ITO, Ward-5(3)(2) (Old Ward-5(3)(3)), Ahmedabad

In the result, the appeal filed by the Assessee is treated as allowed for statistical purpose

ITA 1029/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2012-13

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

Section 147Section 148

immovable property of Rs.42,00,000/-, the assessment was reopened by issuing a notice u/s. 148 of the Act. 2.1. During the course of reassessment proceedings, the assessee produced documents to the extent of Rs. 28,00,000/- for the purchase of immovable property, therefore the A.O. made addition

Gopalan Vijaysudha, Coimbatore vs. ITO, Non Corp Ward-4(3), Coimbatore

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

ITA 3884/CHNY/2025[2018-19]Status: DisposedITAT Chennai20 Feb 2026AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Manu Kumar Giri

For Appellant: MR. C. VenugopalFor Respondent: Ms. R ANITHA, Addl. CIT
Section 147Section 148Section 32Section 69A

Acknowledgement No. 666449890130622), declaring a total income of Rs.4,58,860/- and paid tax of Rs.15,126/-, including TDS of Rs.1,236/-. During the reassessment proceedings, the Assessment Unit observed that the appellant had deposited cash amounting to Rs.17,85,380/- in his account with Karur Vysya Bank

M/S.Wellknown Polyesters Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 4(3)(1), Mumbai

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

ITA 8704/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 147Section 148Section 148ASection 151

validity of re-assessment u/s 148 of the Act as well as on merits of the case. The Ld. CIT(A) observed that the reassessment proceedings were validly initiated, as the Ld. AO had recorded reasons based on credible information and provided opportunity of hearing to the assessee u/s 148A ... dated 30/07/2022 to be bad in law and, hence, the same deserves to be quashed and set aside. As a consequence, the reassessment proceedings initiated thereafter also become bad in law. As the re-assessment proceedings stand quashed, the issues raised by the assessee on merits become academic at this

Kiara Amit Duhlani, Mumbai vs. Income Tax Officer Circle 22(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 8098/MUM/2025[2020-2021]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-2021

Bench: Shri Amit Shukla () & Shri Arun Khodpia ()

Section 115BSection 147Section 68

examine the source of funds utilised for such purchase, and consequently assessment came to be framed under the reassessment framework. 4. During the reassessment proceedings, the assessee explained the source of the investment by stating, firstly, that she had availed a housing loan from Canara Bank and, secondly, that

Deputy Commissioner of Income Tax, Central Circle 8(1), Mumbai vs. Veda Real Estate Corporation Private Limited, Mumbai

Accordingly, the present appeal preferred by the Revenue is dismissed

ITA 7966/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Feb 2026AY 2018-19

Bench: the Tribunal. In our view, no benefit would have accrued to the Appellant by delaying filing of appeal. When substantial justice and technical consideration are pitted against each other, the cause of substantial justice deserves to be preferred. Therefore, delay of 150 days in filing the present appeal is condoned. Accordingly, we proceed to examine the grounds raised in the present appeal. 3. We have heard both the sides and have perused the material on record. 4. It emerges that the asse

For Appellant: Shri Pankaj JainFor Respondent: Shri Kavita Kaushik
Section 143(3)Section 147Section 148

before the Learned CIT(A) was partly allowed by the Learned CIT(A), vide order, dated 15/04/2025. The Assessee had challenged the validity of reassessment proceedings as well as the addition made on merits in appeal before the Learned CIT(A). Vide order, dated 15/04/2025, the Learned CIT(A) rejected ... challenge to validity of reassessment proceedings and granted partial relief to the Assessee. Being aggrieved, Assessee preferred appeal in ITA No.3217/Mum/2025 for the Assessment Year 2018-2019 before this 2 Assessment Year 2018-2019 Tribunal challenging the above order passed by the Learned CIT(A) vide Common Order dated 28/11/2025

Ramani Mathuraprasad Mishra, Mumbai vs. ITO Ward 22(3)(6), Mumbai

ITA 7543/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Naimish JoshiFor Respondent: Date
Section 143(1)(a)Section 144Section 144BSection 147Section 56(2)(vii)

31/10/2017 declaring a total income of INR.12,80,650/-. The return of income was processed under Section 143(1)(a) of Act. Subsequently, reassessment proceedings were initiated and Assessing Officer passed order under Sections 147 read with Section 144 and Section 144B of the Act assessing total income

ACIT, CC 6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 4321/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee in the course of reassessment proceedings, ld. Assessing Officer passed the order, assessing total income at Rs.31,52,09,739/- and book profit at Rs.27,39,62,385/- 3.2. Contention ... Original assessment was completed u/s.143(3) by making certain disallowance and additions which we have already dealt in the above paragraphs. In the impugned reassessment proceedings, two disallowances have been made, one relating to claim of deduction u/s.80G and the other for disallowance of interest. 6.1. For the first issue

ACIT, CC 6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 4320/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee in the course of reassessment proceedings, ld. Assessing Officer passed the order, assessing total income at Rs.31,52,09,739/- and book profit at Rs.27,39,62,385/- 3.2. Contention ... Original assessment was completed u/s.143(3) by making certain disallowance and additions which we have already dealt in the above paragraphs. In the impugned reassessment proceedings, two disallowances have been made, one relating to claim of deduction u/s.80G and the other for disallowance of interest. 6.1. For the first issue

ACIT, CC 6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 4319/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee in the course of reassessment proceedings, ld. Assessing Officer passed the order, assessing total income at Rs.31,52,09,739/- and book profit at Rs.27,39,62,385/- 3.2. Contention ... Original assessment was completed u/s.143(3) by making certain disallowance and additions which we have already dealt in the above paragraphs. In the impugned reassessment proceedings, two disallowances have been made, one relating to claim of deduction u/s.80G and the other for disallowance of interest. 6.1. For the first issue

ACIT, CC-6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 4318/MUM/2025[2022-23]Status: DisposedITAT Mumbai20 Feb 2026AY 2022-23

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee in the course of reassessment proceedings, ld. Assessing Officer passed the order, assessing total income at Rs.31,52,09,739/- and book profit at Rs.27,39,62,385/- 3.2. Contention ... Original assessment was completed u/s.143(3) by making certain disallowance and additions which we have already dealt in the above paragraphs. In the impugned reassessment proceedings, two disallowances have been made, one relating to claim of deduction u/s.80G and the other for disallowance of interest. 6.1. For the first issue

ACIT, CC 6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 4090/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari andFor Respondent: Shri R. A. Dhyani, CIT DR and
Section 1

objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee in the course of reassessment proceedings, ld. Assessing Officer passed the order, assessing total income at Rs.31,52,09,739/- and book profit at Rs.27,39,62,385/- 3.2. Contention ... Original assessment was completed u/s.143(3) by making certain disallowance and additions which we have already dealt in the above paragraphs. In the impugned reassessment proceedings, two disallowances have been made, one relating to claim of deduction u/s.80G and the other for disallowance of interest. 6.1. For the first issue

Overseas Infrastructure Alliance(India) Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 6(2), Mumbai

In the result, appeal by the assessee is allowed

ITA 4064/MUM/2025[2022-23]Status: DisposedITAT Mumbai20 Feb 2026AY 2022-23

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari andFor Respondent: Shri R. A. Dhyani, CIT DR and
Section 1

objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee in the course of reassessment proceedings, ld. Assessing Officer passed the order, assessing total income at Rs.31,52,09,739/- and book profit at Rs.27,39,62,385/- 3.2. Contention ... Original assessment was completed u/s.143(3) by making certain disallowance and additions which we have already dealt in the above paragraphs. In the impugned reassessment proceedings, two disallowances have been made, one relating to claim of deduction u/s.80G and the other for disallowance of interest. 6.1. For the first issue

Overseas Infrastructure Alliance(India) Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle -6, Mumbai

In the result, appeal by the assessee is allowed

ITA 4045/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee in the course of reassessment proceedings, ld. Assessing Officer passed the order, assessing total income at Rs.31,52,09,739/- and book profit at Rs.27,39,62,385/- 3.2. Contention ... Original assessment was completed u/s.143(3) by making certain disallowance and additions which we have already dealt in the above paragraphs. In the impugned reassessment proceedings, two disallowances have been made, one relating to claim of deduction u/s.80G and the other for disallowance of interest. 6.1. For the first issue

Overseas Infrastructure Alliance (India) Private Limtied, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 6(2), Mumbai

In the result, appeal by the assessee is allowed

ITA 4044/MUM/2025[2021-22]Status: DisposedITAT Mumbai20 Feb 2026AY 2021-22

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee in the course of reassessment proceedings, ld. Assessing Officer passed the order, assessing total income at Rs.31,52,09,739/- and book profit at Rs.27,39,62,385/- 3.2. Contention ... Original assessment was completed u/s.143(3) by making certain disallowance and additions which we have already dealt in the above paragraphs. In the impugned reassessment proceedings, two disallowances have been made, one relating to claim of deduction u/s.80G and the other for disallowance of interest. 6.1. For the first issue

Overseas Infrastructure Alliance (India) Private Limtied, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 6(2), Mumbai

In the result, appeal by the assessee is allowed

ITA 4043/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee in the course of reassessment proceedings, ld. Assessing Officer passed the order, assessing total income at Rs.31,52,09,739/- and book profit at Rs.27,39,62,385/- 3.2. Contention ... Original assessment was completed u/s.143(3) by making certain disallowance and additions which we have already dealt in the above paragraphs. In the impugned reassessment proceedings, two disallowances have been made, one relating to claim of deduction u/s.80G and the other for disallowance of interest. 6.1. For the first issue