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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

Vrindavan Builders Pvt Ltd, Nagaland vs. ACIT Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 700/COCH/2024[2017-18]Status: DisposedITAT Cochin09 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

appeal before the CIT(A), proceeded to make the addition on protective basis in the hand of the assessee company. During the course of reassessment proceedings, the AO found that the assessee company received funds through bank accounts to the extent of Rs, 2.09.50,500/- from Nagaland based parties ... r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid

Vrindavan Bhavan Pvt Ltd, Nagaland vs. ACIT Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 699/COCH/2024[2016-17]Status: DisposedITAT Cochin09 Jun 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

appeal before the CIT(A), proceeded to make the addition on protective basis in the hand of the assessee company. During the course of reassessment proceedings, the AO found that the assessee company received funds through bank accounts to the extent of Rs, 2.09.50,500/- from Nagaland based parties ... r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid

Vrindavan Builders Pvt Ltd, Nagaland vs. ACIT Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 698/COCH/2024[2015-16]Status: DisposedITAT Cochin09 Jun 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

appeal before the CIT(A), proceeded to make the addition on protective basis in the hand of the assessee company. During the course of reassessment proceedings, the AO found that the assessee company received funds through bank accounts to the extent of Rs, 2.09.50,500/- from Nagaland based parties ... r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid

Vrindavan Builders Pvt Ltd, Nagaland vs. ACIT Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 697/COCH/2024[2014-15]Status: DisposedITAT Cochin09 Jun 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

appeal before the CIT(A), proceeded to make the addition on protective basis in the hand of the assessee company. During the course of reassessment proceedings, the AO found that the assessee company received funds through bank accounts to the extent of Rs, 2.09.50,500/- from Nagaland based parties ... r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid

Vrindavan Builders Pvt Ktd, Nagaland vs. ACIT Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 696/COCH/2024[2013-14]Status: DisposedITAT Cochin09 Jun 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

appeal before the CIT(A), proceeded to make the addition on protective basis in the hand of the assessee company. During the course of reassessment proceedings, the AO found that the assessee company received funds through bank accounts to the extent of Rs, 2.09.50,500/- from Nagaland based parties ... r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid

Vrindavan Builders Pvt Ltd, Nagaland vs. ACIT, Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 695/COCH/2024[2012-13]Status: DisposedITAT Cochin09 Jun 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

appeal before the CIT(A), proceeded to make the addition on protective basis in the hand of the assessee company. During the course of reassessment proceedings, the AO found that the assessee company received funds through bank accounts to the extent of Rs, 2.09.50,500/- from Nagaland based parties ... r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid

Deputy Commissioner of Income Tax, Central Circle, Kollam vs. Allebasi Builders and Developers (P) Ltd, Attingal

In the result, appeal filed by the assessee stands allowed and Revenue’s appeal and assessee’s cross objection stand dismissed

ITA 317/COCH/2024[2015-16]Status: DisposedITAT Cochin09 Jun 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

r.w.s. 147 of the Act. 4. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court and challenging the action ... Lakmani Mewal Das, 1976 103 ITR 437 (SC), and Sheo Nath Singh v. AACIT, 972 SCR (1) 175 (SC). 11.2 Reassessment proceedings were initiated merely on the basis of 'reason to suspect' and not 'reason to believe' for the purpose of making fishing and roving enquiries in connection with

Deputy Commissioner of Income Tax, Central Circle, Kollam vs. Moneymuttam Finance, Pathanamthitta

In the result, assessee’s cross objection stands allowed and appeal filed by the Revenue stands dismissed

ITA 315/COCH/2024[2017-18]Status: DisposedITAT Cochin09 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm Assessment Years: 2017-18

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

r.w.s. 147 of the Act. 4. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court and challenging the action ... income. Accordingly deleted the addition to the extent of Rs. 2,77,00,342/-. However, the CIT(A) upheld the validity of the reassessment proceedings. Thus, the appeal filed by the assessee was partly allowed by the CIT(A). 5. Being aggrieved by that part of the order

Deputy Commissioner of Income Tax, Central Circle, Kollam vs. Arun Raj Pillai, Pathanamthitta

In the result, the cross objection filed by the assessee company stands allowed

ITA 314/COCH/2024[2018-19]Status: DisposedITAT Cochin09 Jun 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)

r.w.s. 147 of the Act. 4. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court and challenging the action ... LakmaniMewal Das, 1976 103 ITR 437 (SC), and SheoNath Singh v. AACIT, 972 SCR (1) 175 (SC). 11.2 Reassessment proceedings were initiated merely on the basis of 'reason to suspect' and not 'reason to believe' for the purpose of making fishing and roving enquiries in connection with the various items

Sreevalsam Hotels and Resorts Private Ltd, Rajavalsam vs. ACIT, Central Circle, Kollam

In the result, assessee’s appeal in ITA No

ITA 115/COCH/2024[2017-2018]Status: DisposedITAT Cochin09 Jun 2025AY 2017-2018

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

r.w.s. 147 of the Act. 4. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court and challenging the action ... placed on Chhugamal Rajpal vs. S.P. Chaliha [1971] 79 ITR 603 (SC); Bakulbhai Ramanlal Patel vs. Income Tax Officer (2011) 79 CCH 0204 (Guj). Reassessment proceedings initiated by the Ld. A.O on the basis of the satisfaction borrowed from the unverified information received from the Investigation Wing without any independent

Income Tax Officer, Parwanoo, H.P vs. Deyem Industry, Nalagarh Solan

In the result, appeal of the Revenue is dismissed

ITA 708/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh09 Jun 2025AY 2012-13

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 708/Chd/2023 निर्धारण वर्ष / Assessment Year : 2012-13 The ITO Parwanoo, Himachal Pradesh बनाम DEYEM INDUSTRY Nalagarh, Ropar Road Near Hazat Khana, Nalagarh, H.P.- 174101 स्थायी लेखा सं./ PAN NO: AAGFD0437L अपीलार्थी/ Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Ankit Awal, Ms. Khushbu Sood, Advocates राजस्व की ओर से/ Revenue by : Shri Rohit Sharma, CIT DR (Virtual) सुनवाई की ता

For Appellant: Shri Ankit Awal & Ms. Khushbu Sood, AdvocatesFor Respondent: Shri Rohit Sharma, CIT DR (Virtual)
Section 143(3)Section 147Section 2(47)Section 271(1)(c)Section 53A

Escrow amount was received by the assessee in April 2012, i.e., at the beginning of the next financial year. 3.2 The AO initiated reassessment proceedings under Section 147/148, contending that the assessee had under-declared the taxable LTCG by not including the Escrow amount

Jaiambay Commercial Pvt. Ltd., Kolkata vs. I.T.O., Ward - 60(2), Kolkata

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

ITA 2623/KOL/2024[2012-2013]Status: DisposedITAT Kolkata09 Jun 2025AY 2012-2013

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 249(2)Section 250

appears that some confusion had arisen because the assessment order u/s 143(3) of the Act was made on 25.02.2015 and subsequently the reassessment proceedings were initiated and the order u/s 147 r.w.s 143(3) dated 28.12.2019 was passed (which is claimed to be received on 31/12/2019 and the appeal

Hmg Engineering Private Limited, Mumbai vs. Income-Tax Officer, Ward 1(1)(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3012/MUM/2024[2012-13]Status: DisposedITAT Mumbai09 Jun 2025AY 2012-13

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सुं./Ita No. 3012/Mum/2024 (नििाारण वर्ा / Assessment Year :2012-13) Hmg Engineering Pvt. Ltd. V/S. Ito, Ward (1)(1)(4) 1St Floor, Bandukwala बिाम Income Tax Department, Building, 14 British Hotel 531A 5Th Floor, Aayakar Lane, Off B S Marg, Fort, Bhawan, Maharishi Karve Maharashtra-400023 Road, Maharashtra- 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach3226L Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Krutarth K. Desai राजस्व की ओर से /Revenue By: Shri Hemanshu Joshi

For Appellant: Shri Krutarth K. DesaiFor Respondent: Shri Hemanshu Joshi
Section 143(3)Section 147Section 148Section 41(1)

assessee is that the CIT(A) erred in confirming the reopening of the assessment as per law, as the AO erred in initiating reassessment proceedings on the same set of facts which were available to the AO at the time of original assessment proceedings. 3. Representatives of both sides were

Arvindbhai Punabhai Patel, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

The appeal of the assessee is partly allowed for statistical purposes

ITA 1998/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad06 Jun 2025AY 2013-14

Bench: Ms.Suchitra R. Kamble

Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

assessee. Accordingly, a notice under section 148 of the Act was issued on 27.05.2016 and served by RPAD. During the course of reassessment proceedings, the Assessing Officer issued several notices under section 142(1) of the Act along with detailed questionnaires, but the assessee failed to respond to most ... Ground Nos. 1 and 2 raised by the assessee are dismissed. 10. Ground No. 3 raises a legal issue regarding the jurisdictional validity of reassessment proceedings initiated under section 147 of the Act. The grievance of the assessee is that the Assessing Officer reopened the case for a specific reason

Vanaraj Wood Industries Private Ltd, Chennai vs. Income Tax Officer, Delhi

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

ITA 115/CHNY/2025[2013-14]Status: DisposedITAT Chennai06 Jun 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:115/Chny/2025 िनधा"रण वष" / Assessment Year: 2013-14

For Appellant: Shri. A.Srinivasan, C.AFor Respondent: Shri. R.Clement Ramesh Kumar, C.I.T
Section 144Section 148

been passed without considering the any of the submissions. Further, the assessee has not participated before the AO also at the time of reassessment proceedings and hence prayed for one more opportunity before the AO in the interest of natural justice. 9. Per contra, the ld.DR submitted that the assessee

ACIT- 4 2 1, Mumbai City vs. Hathway Investments Pvt Ltd, Mumbai

In the result, both the revenue’s appeals are dismissed, whereas the cross objections filed by the Assessee’s are allowed, for statistical purposes

ITA 1482/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Jun 2025AY 2014-15

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankar & Co No. 90/Mum/2025 {Assessment Year: 2014-15} A N D & Co No. 91/Mum/2025 {Assessment Year: 2017-18}

For Appellant: Shri Priyesh Vora (Virtually)For Respondent: Shri Himanshu Joshi (SR DR)
Section 10(34)Section 115Section 142(1)Section 14ASection 250

Private Limited (1992) 198 ITR 297(SC) was in context of re-assessment proceedings initiated u/s 147 wherein Hon’ble Supreme Court held that reassessment proceedings initiated u/s 147 are for the benefit of revenue and not the assessee, wherein the mandate is to bring to tax income which

Assistant Commissioner of Income Tax, Mumbai City vs. Hathway Investments Pvt Ltd, Mumbai

In the result, both the revenue’s appeals are dismissed, whereas the cross objections filed by the Assessee’s are allowed, for statistical purposes

ITA 1481/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Jun 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankar & Co No. 90/Mum/2025 {Assessment Year: 2014-15} A N D & Co No. 91/Mum/2025 {Assessment Year: 2017-18}

For Appellant: Shri Priyesh Vora (Virtually)For Respondent: Shri Himanshu Joshi (SR DR)
Section 10(34)Section 115Section 142(1)Section 14ASection 250

Private Limited (1992) 198 ITR 297(SC) was in context of re-assessment proceedings initiated u/s 147 wherein Hon’ble Supreme Court held that reassessment proceedings initiated u/s 147 are for the benefit of revenue and not the assessee, wherein the mandate is to bring to tax income which

Ashok Kumar Jain, Meerut vs. PCIT, Ghaziabad

In the result, both the appeals filed by appellant/assessee are allowed

ITA 2627/DEL/2024[2013-14]Status: DisposedITAT Delhi06 Jun 2025AY 2013-14

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singhita No. 2627/Del/2024 Assessment Year: 2013-14 Ita No.2628/Del/2024 Assessment Year: 2014-15 Ashok Kumar Jain, Vs. Principal Cit, Prop. Mange Lal Prakash Ghaziabad Chand, 45-B Gupta Colony, (Uttar Pradesh) T.P. Nagar, Meerut Pin: 250002 Pan: Aeipj3089E (Appellant) (Respondent) Assessee By: Shri Piyush Agarwal, Ca Department By: Mr. Javed Akhtar, Cit (Dr) Date Of Hearing: 20.03.2025 Date Of Pronouncement: 06.06.2025 O R D E R Per Vimal Kumar: The Appeals Filed By The Appellant/Assessee Are Against Separate Orders Dated 27.03.2024 Of Learned Principal Commissioner Of Income-Tax(Appeals), Ghaziabad (Hereinafter Referred As ‘Ld. Pcit’ ) Under Section 263 Of The Income-Tax Act, 1961 (Hereinafter Referred As “The Act”) Arising Out Of Separate Assessment Orders, Both Dated 29.03.2022 Of National Faceless Appeal Centre(Nfac), Delhi (Hereinafter Referred As “Ld. Ao”) Under Section 147 R.W.S. 144B Of The Act For Assessment Years 2013-14 & 2014-15 Respectively.

For Appellant: Shri Piyush Agarwal, CAFor Respondent: Mr. Javed Akhtar, CIT (DR)
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 263Section 40Section 40A(3)

Even in case of violation of 40A(3) only profit element can be added to the income, relied on various case laws provided during reassessment proceedings. 5. Immediately previous AY 2012-13 was also under scrutiny assessment u/s 143(3) and trading results are near to Immediately previous scrutiny assessment ... relied on various case laws provided during reassessment proceedings for law of consistency. 9.1 From the above it is clear that Ld. AO made proper inquiries and Appellant has made all the reply and Reassessment order was passed after due verification so Explanation 2(a) of sub section

Kundarnad Janata Shikshan Sangh Ankalgi, Ankalgi Gokak vs. Income Tax Officer, Gokak

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

ITA 57/PAN/2025[2018-19]Status: DisposedITAT Panaji05 Jun 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.57/Pan/2025 (A.Y.2018-19 ) Kundarnad Janta Shikshan Vs National E – Sangh Ankalgi, Assessment Centre, . Ankalgi, Gokak, Delhi-110001 Belgaum-591101, Karnataka. Pan .No.Aadtk0333K (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 69A

bank accounts. The Ld.AR submitted that the assessee has filed the written submissions and details of sources of cash deposits in the reassessment proceedings u/sec147 of the Act on the ITBA E proceedings placed at page 7 of the paper book and the assessing officer has overlooked the material evidences

Nitta Gelatin India Limited, Kochi vs. DCIT, Corporate Circle 2(1), Kochi

In the result, both the appeals of the assessee stand allowed for statistical purposes

ITA 268/COCH/2025[2013-14]Status: DisposedITAT Cochin05 Jun 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Nitta Gelatin India Limited ..….……….Appellant 50/1002, Sbt Avenue, Panampilly Nagar, Kochi Kerala – 682036 [Pan:Aabck1582H] Vs. Dcit, Corporate Circle 2(1) , Kochi ..….……….Respondent

For Appellant: Shri. Gopi K,CA
Section 143(3)Section 147Section 148

formed a belief that income had escaped assessment and reopened the case under Section 147. A notice under Section 148 was issued, and reassessment proceedings followed. Despite multiple notices under Sections 143(2) and 142(1), the AO was not satisfied with the assessee’s submissions and completed the reassessment