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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

Shri. Sannappa Ramappa, Davangere vs. Income Tax Officer, Ward-1(3), Davangere

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

ITA 50/BANG/2025[2012-13]Status: DisposedITAT Bangalore30 Apr 2025AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2012-13

For Appellant: Ms. Richa Bakiwala, CAFor Respondent: Shri Subramanian .S, JCIT-DR
Section 133(6)Section 143Section 143(3)Section 147Section 148Section 250

valid assessment order was passed in the first instance. In the II absence of an assessment order, the very foundation for initiating reassessment proceedings is lacking, rendering the reassessment notice invalid and unsustainable. The learned NFAC passed the order against the principles of natural justice i.e. the order was passed ... distinct from the information based on which the VI notice under section 148 of the Act was issued. This fundamental deviation renders the reassessment proceedings invalid and unsustainable in law. The learned Assessing Officer erred in initiating assessment proceedings under Section 148 of the Act, though the time VII limit

Mahendra Kumar, Bangalore vs. Principal Commissioner of Income Tax-2, Bengaluru

In the result, the revisionary order passed u/s

ITA 812/BANG/2024[2017-18]Status: DisposedITAT Bangalore30 Apr 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2017-18

For Appellant: Shri Ravi Shankar, AdvocateFor Respondent: Smt. Srinandini Das, CIT(DR)(ITAT)
Section 142(1)Section 143(2)Section 147Section 148Section 263

assessee was accepted at Rs.13,76,300 as per return of income as well as the original assessed income. Therefore, in the reassessment proceedings, there was no addition made. 8. Subsequently on examination of the record, the ld. PCIT noted that as per financials, assessee’s turnover has increased substantially ... hence revisionary order is correctly passed. It was also submitted that in 263 proceedings, now assessee cannot challenge the validity of reassessment proceedings. She referred to para 6 of the order of the ld. PCIT, who states that there is no details of transportation and therefore the order

Devalbai Karsan Parmar, Mumbai vs. Income Tax Officer Ward 20(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1786/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Apr 2025AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2017-18 Devalbai Karsan Parmar, Income Tax Officer, Ward-20(1)(1), H9, B-401, Herumb Chs, 3Rd Floor, New Mhada Colony, Vs. Piramal Chambers, Kamgar Nagar, Lalbaugh, Near Tilak Nagar Mumbai-400012. Railway Station, Chembur, Mumbai-400024. Pan: Aispp0021A (Appellant) (Respondent) For Assessee : Shri Shashank Mehta For Revenue : Shri Asif Karmali, Sr.Dr

For Appellant: Shri Shashank MehtaFor Respondent: Shri Asif Karmali, Sr.DR
Section 147Section 148Section 148ASection 151Section 151ASection 56Section 56(2)Section 56(2)(vii)

letter dated 15/07/2022, we are of the considered view that the Revenue has not followed the mandatory provisions of the Act while initiating the reassessment proceedings and sanction of the Specified Authority is not in conformity with the law prevalent at the time of grant of sanction. 18. From

Smt Pranita Pankaj Thakur, Mumbai vs. Income Tax Officer. Ward 4(1), Mumbai

In the result, appeal of the assessee is accordingly allowed

ITA 1702/MUM/2025[2011-12]Status: DisposedITAT Mumbai30 Apr 2025AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2011-12 Smt. Pranita Pankaj Thakur Income Tax Officer, Ward 4(1), Thakur Niwas,C.S. Road, Qureshi Mansion, Gokhale Virar West,Tal. Vasai, Vs. Road, Dist-Thane. Mumbai- 400602 Mumbai- 401303 Pan No. Aaaupt 2294 F Appellant Respondent

For Appellant: Mr. Sanjeev MehtaFor Respondent: Mr. Akhatar Hussain Ansari, Sr. DR
Section 132Section 143(3)Section 148Section 68

recorded reasons to believe that income was escaped assessment and issued notice u/s 148 of the Act on 28.01.2016. During the course of reassessment proceedings, the assessee explained that source of the cash was from cash Pranita Pankaj Thakur 3 transactions with the Swastik groups, but said explanation

Bio- Care Technologies, Mumbai vs. ITO, Ward 32(1)(1), Mumbai

In the result, ground No. 4 of the appeal is partly allowed

ITA 6946/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 Apr 2025AY 2018-19

Bench: Shri Pawan Singh, Hon'Ble

Section 142Section 148Section 148ASection 234ASection 254(1)Section 50CSection 56(2)(x)

Commissioner of Income Tax (Appeals) (NFAC/ CIT(A)] has erred in dismissing the appeal and confirming the additions made by the Assessing officer. 2. Reassessment proceedings bad in law a) On the facts and circumstances of the case and in law, the Ld. AO and further Ld.NFAC / CIT(A) erred ... reopening the assessment; the reassessment proceedings are bad in law and liable to be quashed. b) Without prejudice to above, the notice u/s 148A(b), the order u/s 148A(d), and the reopening notice u/s 148 has been issued by the Jurisdictional Assessing officer instead of Faceless Assessing officer

DCIT(Exemp)-2(1), Mumbai vs. Tata Education and Development Trust, Mumbai

ITA 5954/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Apr 2025AY 2013-14

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Biswanath Das
Section 11(1)(c)Section 143(3)Section 147Section 250

subject to verification during course of assessment proceedings and that the assessee has failed to bring it on record during the reassessment proceedings?” 2.1. The Assessee has filed application under Rule 27 of the Income Tax (Appellate Tribunal) Rules, 1963 [for short ’ITAT Rules’] On the issue of validity ... reassessment proceeded decided against the Assessee by the CIT(A): “On the facts and in the circumstances of the case and in law, the Learned commissioner of Income-tax (Appeals) ought to have held that reassessment proceedings are without jurisdiction and bad in law in terms of sections

Asst.Commissioner of Income-Tax - Circle 41-1-1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5503/MUM/2024[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 250

Foreign Asset came from JSY’s saving in the Foreign Bank Account. The Foreign Asset was, thereafter, sold in July 2007. 3.5. Reassessment proceedings were initiated in the case of JSY, BSY and Assessee for a number of assessment years within the time limit of 16 years from ... that income liable to tax had escaped assessment since various credits in the Foreign Bank Account were not offered to tax in India. The reassessment proceedings for the various assessment years culminated into passing of the assessment orders under Section 143(3)/147 of the Act. Penalty under Section

Dy. Commissioner of Income-Tax- 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5502/MUM/2024[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09
Section 250

Foreign Asset came from JSY's saving in the Foreign Bank Account. The Foreign Asset was, thereafter, sold in July 2007. 3.5. Reassessment proceedings were initiated in the case of JSY, BSY and Assessee for a number of assessment years within the time limit of 16 years from ... that income liable to tax had escaped assessment since various credits in the Foreign Bank Account were not offered to tax in India. The reassessment proceedings for the various assessment years culminated into passing of the assessment orders under Section 143(3)/147 of the Act. Penalty under Section

DCIT 41.1.1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5311/MUM/2024[1997-98]Status: DisposedITAT Mumbai30 Apr 2025AY 1997-98
Section 250

purchase of the Foreign Asset came from JSY’s saving in the Foreign Bank Account. The Foreign Asset was, thereafter, sold in July 2007. Reassessment proceedings were initiated in the case of JSY, BSY and Assessee for a number of assessment years within the time limit of 16 years from ... that income liable to tax had escaped assessment since various credits in the Foreign Bank Account were not offered to tax in India. The reassessment proceedings for the various assessment years culminated into passing of the assessment orders under Section 143(3)/147 of the Act. Penalty under Section

Deputy Commissioner of Income Tax - 41(1)(1), Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5309/MUM/2024[1997-98]Status: DisposedITAT Mumbai30 Apr 2025AY 1997-98

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 250

Foreign Asset came from JSY’s saving in the Foreign Bank Account. The Foreign Asset was, thereafter, sold in July 2007. 3.5. Reassessment proceedings were initiated in the case of JSY, BSY and Assessee for a number of assessment years within the time limit of 16 years from ... that income liable to tax had escaped assessment since various credits in the Foreign Bank Account were not offered to tax in India. The reassessment proceedings for the various assessment years culminated into passing of the assessment orders under Section 143(3)/147 of the Act. Penalty under Section

DCIT 41.1.1, Kautilya Bhawan, Mumb vs. Satya Kim Yashpal, Mumbai

ITA 5138/MUM/2024[2001-02]Status: DisposedITAT Mumbai30 Apr 2025AY 2001-02
For Appellant: NoneFor Respondent: Dr. Kishor Dhule; Shri Bhangepatil
Section 250

Foreign Asset came from JSY's saving in the Foreign Bank Account. The Foreign Asset was, thereafter, sold in July 2007. 3. 5. Reassessment proceedings were initiated in the case of JSY, BSY and Assessee for a number of assessment years within the time limit of 16 years from ... that income liable to tax had escaped assessment since various credits in the Foreign Bank Account were not offered to tax in India. The reassessment proceedings for the various assessment years culminated into passing of the assessment orders under Section 143(3)/147 of the Act. Penalty under Section

DCIT 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5137/MUM/2024[2001-02]Status: DisposedITAT Mumbai30 Apr 2025AY 2001-02

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 250

Foreign Asset came from JSY’s saving in the Foreign Bank Account. The Foreign Asset was, thereafter, sold in July 2007. 3.5. Reassessment proceedings were initiated in the case of JSY, BSY and Assessee for a number of assessment years within the time limit of 16 years from ... that income liable to tax had escaped assessment since various credits in the Foreign Bank Account were not offered to tax in India. The reassessment proceedings for the various assessment years culminated into passing of the assessment orders under Section 143(3)/147 of the Act. Penalty under Section

Assistant Commissioner of Income Tax-42(1)(1), Mumbai vs. Jekin Enterprise, Mumbai

In the result, the appeals of the revenue are dismissed, and the cross objections of the assessee are allowed

ITA 3111/MUM/2024[2011-12]Status: DisposedITAT Mumbai30 Apr 2025AY 2011-12

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 3111/Mum/2024 (निर्धारण वर्ा / Assessment Year :2011-12) आयकर अपील सं./Ita No. 3110/Mum/2024 (निर्धारण वर्ा / Assessment Year :2012-13) आयकर अपील सं./Ita No. 3105/Mum/2024 (निर्धारण वर्ा / Assessment Year :2013-14) आयकर अपील सं./Ita No. 3109/Mum/2024 (निर्धारण वर्ा / Assessment Year :2014-15) आयकर अपील सं./Ita No. 3107/Mum/2024 (निर्धारण वर्ा / Assessment Year :2015-16) Acit-42(1), Mumbai V/S. Jekin Enterprise Room No. 732, 7Th Floor, बिधम A 604, Prem Nagar, Kautilya Bhavan, G. Block, Building No. 5, Bkc, Bandra East, Mandepeshwar Road, Mumbai-400051 Boriwali (W.), Mumbai, Maharashtra-400092 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaafj0648R Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी प्रनि आपत्ति सं./ Co No. 177/Mum/2024 (Arising Out Of Ita No. 3111/Mum/2024) (निर्धारण वर्ा / Assessment Year :2011-12) प्रनि आपत्ति सं./ Co No. 176/Mum/2024 (Arising Out Of Ita No. 3110/Mum/2024) (निर्धारण वर्ा / Assessment Year :2012-13) प्रनि आपत्ति सं./ Co No. 173/Mum/2024 (Arising Out Of Ita No. 3105/Mum/2024)

For Appellant: Shri Anant paiFor Respondent: Ms. Kavitha Kaushik
Section 147Section 250Section 68

cash deposits. Aggrieved with the order, the assessee preferred an appeal before Ld. CIT(A). Vide order dated 10.04.2024, Ld. CIT(A) quashed the reassessment proceedings holding it is to be illegal on account of change of opinion, and also deleted the addition on account of cash deposits on merits

Assisstant Commissioner of Income Tax-42(1)(1), Mumbai vs. Jekin Enterprise, Mumbai

In the result, the appeals of the revenue are dismissed, and the cross objections of the assessee are allowed

ITA 3110/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 Apr 2025AY 2012-13

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 3111/Mum/2024 (निर्धारण वर्ा / Assessment Year :2011-12) आयकर अपील सं./Ita No. 3110/Mum/2024 (निर्धारण वर्ा / Assessment Year :2012-13) आयकर अपील सं./Ita No. 3105/Mum/2024 (निर्धारण वर्ा / Assessment Year :2013-14) आयकर अपील सं./Ita No. 3109/Mum/2024 (निर्धारण वर्ा / Assessment Year :2014-15) आयकर अपील सं./Ita No. 3107/Mum/2024 (निर्धारण वर्ा / Assessment Year :2015-16) Acit-42(1), Mumbai V/S. Jekin Enterprise Room No. 732, 7Th Floor, बिधम A 604, Prem Nagar, Kautilya Bhavan, G. Block, Building No. 5, Bkc, Bandra East, Mandepeshwar Road, Mumbai-400051 Boriwali (W.), Mumbai, Maharashtra-400092 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaafj0648R Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी प्रनि आपत्ति सं./ Co No. 177/Mum/2024 (Arising Out Of Ita No. 3111/Mum/2024) (निर्धारण वर्ा / Assessment Year :2011-12) प्रनि आपत्ति सं./ Co No. 176/Mum/2024 (Arising Out Of Ita No. 3110/Mum/2024) (निर्धारण वर्ा / Assessment Year :2012-13) प्रनि आपत्ति सं./ Co No. 173/Mum/2024 (Arising Out Of Ita No. 3105/Mum/2024)

For Appellant: Shri Anant paiFor Respondent: Ms. Kavitha Kaushik
Section 147Section 250Section 68

cash deposits. Aggrieved with the order, the assessee preferred an appeal before Ld. CIT(A). Vide order dated 10.04.2024, Ld. CIT(A) quashed the reassessment proceedings holding it is to be illegal on account of change of opinion, and also deleted the addition on account of cash deposits on merits

Assistant Commissioner of Income Tax-42(1)(1), Mumbai vs. Jekin Enterprise, Mumbai

In the result, the appeals of the revenue are dismissed, and the cross objections of the assessee are allowed

ITA 3109/MUM/2024[2014-15]Status: DisposedITAT Mumbai30 Apr 2025AY 2014-15

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 3111/Mum/2024 (निर्धारण वर्ा / Assessment Year :2011-12) आयकर अपील सं./Ita No. 3110/Mum/2024 (निर्धारण वर्ा / Assessment Year :2012-13) आयकर अपील सं./Ita No. 3105/Mum/2024 (निर्धारण वर्ा / Assessment Year :2013-14) आयकर अपील सं./Ita No. 3109/Mum/2024 (निर्धारण वर्ा / Assessment Year :2014-15) आयकर अपील सं./Ita No. 3107/Mum/2024 (निर्धारण वर्ा / Assessment Year :2015-16) Acit-42(1), Mumbai V/S. Jekin Enterprise Room No. 732, 7Th Floor, बिधम A 604, Prem Nagar, Kautilya Bhavan, G. Block, Building No. 5, Bkc, Bandra East, Mandepeshwar Road, Mumbai-400051 Boriwali (W.), Mumbai, Maharashtra-400092 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaafj0648R Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी प्रनि आपत्ति सं./ Co No. 177/Mum/2024 (Arising Out Of Ita No. 3111/Mum/2024) (निर्धारण वर्ा / Assessment Year :2011-12) प्रनि आपत्ति सं./ Co No. 176/Mum/2024 (Arising Out Of Ita No. 3110/Mum/2024) (निर्धारण वर्ा / Assessment Year :2012-13) प्रनि आपत्ति सं./ Co No. 173/Mum/2024 (Arising Out Of Ita No. 3105/Mum/2024)

For Appellant: Shri Anant paiFor Respondent: Ms. Kavitha Kaushik
Section 147Section 250Section 68

cash deposits. Aggrieved with the order, the assessee preferred an appeal before Ld. CIT(A). Vide order dated 10.04.2024, Ld. CIT(A) quashed the reassessment proceedings holding it is to be illegal on account of change of opinion, and also deleted the addition on account of cash deposits on merits

Assistant Commissioner of Income Tax, 42(1)(1), Mumbai vs. Jekin Enterprise, Mumbai

In the result, the appeals of the revenue are dismissed, and the cross objections of the assessee are allowed

ITA 3107/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Apr 2025AY 2015-16

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 3111/Mum/2024 (निर्धारण वर्ा / Assessment Year :2011-12) आयकर अपील सं./Ita No. 3110/Mum/2024 (निर्धारण वर्ा / Assessment Year :2012-13) आयकर अपील सं./Ita No. 3105/Mum/2024 (निर्धारण वर्ा / Assessment Year :2013-14) आयकर अपील सं./Ita No. 3109/Mum/2024 (निर्धारण वर्ा / Assessment Year :2014-15) आयकर अपील सं./Ita No. 3107/Mum/2024 (निर्धारण वर्ा / Assessment Year :2015-16) Acit-42(1), Mumbai V/S. Jekin Enterprise Room No. 732, 7Th Floor, बिधम A 604, Prem Nagar, Kautilya Bhavan, G. Block, Building No. 5, Bkc, Bandra East, Mandepeshwar Road, Mumbai-400051 Boriwali (W.), Mumbai, Maharashtra-400092 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaafj0648R Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी प्रनि आपत्ति सं./ Co No. 177/Mum/2024 (Arising Out Of Ita No. 3111/Mum/2024) (निर्धारण वर्ा / Assessment Year :2011-12) प्रनि आपत्ति सं./ Co No. 176/Mum/2024 (Arising Out Of Ita No. 3110/Mum/2024) (निर्धारण वर्ा / Assessment Year :2012-13) प्रनि आपत्ति सं./ Co No. 173/Mum/2024 (Arising Out Of Ita No. 3105/Mum/2024)

For Appellant: Shri Anant paiFor Respondent: Ms. Kavitha Kaushik
Section 147Section 250Section 68

cash deposits. Aggrieved with the order, the assessee preferred an appeal before Ld. CIT(A). Vide order dated 10.04.2024, Ld. CIT(A) quashed the reassessment proceedings holding it is to be illegal on account of change of opinion, and also deleted the addition on account of cash deposits on merits

Assistant Commissioner of Income Tax-42(1)(1), Mumbai vs. Jekin Enterprise, Mumbai

In the result, the appeals of the revenue are dismissed, and the cross objections of the assessee are allowed

ITA 3105/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Apr 2025AY 2013-14

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 3111/Mum/2024 (निर्धारण वर्ा / Assessment Year :2011-12) आयकर अपील सं./Ita No. 3110/Mum/2024 (निर्धारण वर्ा / Assessment Year :2012-13) आयकर अपील सं./Ita No. 3105/Mum/2024 (निर्धारण वर्ा / Assessment Year :2013-14) आयकर अपील सं./Ita No. 3109/Mum/2024 (निर्धारण वर्ा / Assessment Year :2014-15) आयकर अपील सं./Ita No. 3107/Mum/2024 (निर्धारण वर्ा / Assessment Year :2015-16) Acit-42(1), Mumbai V/S. Jekin Enterprise Room No. 732, 7Th Floor, बिधम A 604, Prem Nagar, Kautilya Bhavan, G. Block, Building No. 5, Bkc, Bandra East, Mandepeshwar Road, Mumbai-400051 Boriwali (W.), Mumbai, Maharashtra-400092 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaafj0648R Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी प्रनि आपत्ति सं./ Co No. 177/Mum/2024 (Arising Out Of Ita No. 3111/Mum/2024) (निर्धारण वर्ा / Assessment Year :2011-12) प्रनि आपत्ति सं./ Co No. 176/Mum/2024 (Arising Out Of Ita No. 3110/Mum/2024) (निर्धारण वर्ा / Assessment Year :2012-13) प्रनि आपत्ति सं./ Co No. 173/Mum/2024 (Arising Out Of Ita No. 3105/Mum/2024)

For Appellant: Shri Anant paiFor Respondent: Ms. Kavitha Kaushik
Section 147Section 250Section 68

cash deposits. Aggrieved with the order, the assessee preferred an appeal before Ld. CIT(A). Vide order dated 10.04.2024, Ld. CIT(A) quashed the reassessment proceedings holding it is to be illegal on account of change of opinion, and also deleted the addition on account of cash deposits on merits

Income Tax Officer, Ward-1, Faridkot, Bsnl Building vs. M/S Vohra Solvex Pvt. Ltd, Sadiq Road

In the result, C.O. filed by the assessee is allowed

ITA 588/ASR/2024[2014-15]Status: DisposedITAT Amritsar29 Apr 2025AY 2014-15

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: Sh. Sudhir Sehgal, A.R
Section 143(3)Section 148Section 250(6)Section 69C

course of re-assessment proceedings. However, the AO has refused to give any cognizance to such documentary evidences produced and filed in course of reassessment proceeding due to the absence of any purchase agreements and details of transportation in respect of the said purchases and as such the same ... which according to the assessee is an identical case. 18. The ld. AR of the assessee submitted that when the reassessment proceedings are commenced by issue of notice u/s 148, beyond four years the same should be based on some tangible materials available with the AO, but in the instant

Mammayil Thekkepurayil Manshoor, Kannur vs. DCIT (International Taxation), Kochi

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

ITA 681/COCH/2023[2007-08]Status: DisposedITAT Cochin29 Apr 2025AY 2007-08

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

For Appellant: Shri Surendranath Rao, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 139(1)Section 144CSection 148Section 149Section 27Section 5(2)

Being aggrieved, the appellant is in appeal before us in the present appeal. 7. The learned counsel for the assessee submits that the reassessment proceedings were barred by limitation as the reassessment proceedings were initiated after expiry of a period of 6 years and also for the reason that ... rival contentions and perused the material available on record. The grounds of appeal 2 to 3 challenge the very validity of the initiation of reassessment proceedings on the ground that the reassessment proceedings are barred by limitation and also there was no reason to believe that income escaped assessment

Mammayil Thekkepurayil Manshoor, Kannur vs. DCIT (International Taxation), Kochi

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

ITA 679/COCH/2023[2006-2007]Status: DisposedITAT Cochin29 Apr 2025AY 2006-2007

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

For Appellant: Shri Surendranath Rao, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 139(1)Section 144CSection 148Section 149Section 27Section 5(2)

Being aggrieved, the appellant is in appeal before us in the present appeal. 7. The learned counsel for the assessee submits that the reassessment proceedings were barred by limitation as the reassessment proceedings were initiated after expiry of a period of 6 years and also for the reason that ... rival contentions and perused the material available on record. The grounds of appeal 2 to 3 challenge the very validity of the initiation of reassessment proceedings on the ground that the reassessment proceedings are barred by limitation and also there was no reason to believe that income escaped assessment