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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

Ramesh Dandumal Chachlani, Ulhasnagar vs. Income Tax Officer Ward 2(2), Kalyan, Mumbia

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

ITA 4874/MUM/2024[2015-16]Status: DisposedITAT Mumbai03 Apr 2025AY 2015-16

Bench: Shri B R Baskaran & Shri Raj Kumar Chauhan

Section 144BSection 147Section 148Section 149Section 149(1)Section 149(1)(b)Section 234ASection 274

issued within the period of six years from the end of the relevant assessment year, which was expiring on 31st March 2022, the reassessment proceedings are within the period of limitation prescribed in Section 149 of the Act. It is not acceptable. Section 149 of the Act sets out, inter

Sns Constructions P.Ltd, Panipat vs. ITO, Ward-4, Panipat

In the result, the appeal of the revenue is dismissed and the CO of the 7

ITA 4013/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Apr 2025AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganeshincome Tax Officer, Vs. Anil Kumar, Ward-1(1), J-10, South City-1, Gurgaon Gurgaon, Haryana (Appellant) (Respondent) Pan: Aampk9521G Co No. 88/Del/2024 (Ita No. 4013/Del/2024) (Assessment Year: 2014-15) Anil Kumar, Vs. Income Tax Officer, J-10, South City-1, Ward-1(1), Gurgaon, Haryana Gurgaon (Appellant) (Respondent) Pan: Aampk9521G

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 10(38)Section 115BSection 133ASection 143(3)Section 144Section 147Section 148Section 44ASection 69

dated 25.03.2022. The assessee preferred an appeal against this reassessment order before the ld NFAC. The ld NFAC quashed the entire reassessment proceedings by observing as under:- “Finding & Decision 7.1 The appellant in the grounds of appeal has contested that the re-opening of assessment proceeding is not valid, even

Mascot Fastners Private Limited, Uttarakhand vs. National Faceless Assessment Centre, Delhi

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

ITA 46/DDN/2024[2013-14]Status: DisposedITAT Dehradun02 Apr 2025AY 2013-14

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) M/S. Mascot Fastners Pvt. Vs. National Faceless Ltd, Assessment Centre, Plot No. B-155, Eldeco, Sidcul, Delhi Industrial Park, Sitarganj, Udham Singh Nagar, 262 403 (Appellant) (Respondent) Pan: Aabcm4504H Assessee By : Shri Atul Ninawat, Partner Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 18/03/2025 Date Of Pronouncement 02/04/2025

For Appellant: Shri Atul Ninawat, PartnerFor Respondent: Shri A. S. Rana, Sr. DR
Section 115JSection 143(3)Section 147Section 80Section 80I

explanation given by the assessee, the Learned AO had indeed formed an opinion in the original scrutiny assessment proceedings. The Learned AO in the reassessment proceedings had merely sought to re-examine the very same materials already on record and had tried to change his opinion. This clearly tantamounts ... change of opinion on the part of the Learned AO in the reassessment proceedings on the materials already on record. It is trite law that no reopening of assessment could be made based on change of opinion. Reliance in this regard is placed on the decision of Hon‟ble Supreme

Satish Kumar Saini, Jaipur vs. Income Tax Officer, Alwar

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

ITA 1526/JPR/2024[2012-13]Status: DisposedITAT Jaipur02 Apr 2025AY 2012-13
For Appellant: Shri Vishal Kalra, C.A. (Thr. V.C.)For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 127Section 144Section 148Section 151Section 69A

Considering the above facts and discussion, the objections raised by the appellant are without substance and do not undermine the legitimacy of the reassessment proceedings initiated by the AO. Accordingly, the appellant's contentions are dismissed, and the reopening of the assessment is confirmed. 5. 2. Now come to addition ... NFAC, dated 22.10.2024 .We note that the primary contention raised by the Ld AR for the assessee pertains to the validity of the reassessment proceedings initiated under Section 147 and the issuance of notice under Section 148 of the Act. The assessee has alleged procedural lapses, including absence of valid

Shri Salasar Balaji Developers Pvt. Ltd, Jaipur vs. Income Tax Officer, Ward 2(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1186/JPR/2024[2012-13]Status: DisposedITAT Jaipur02 Apr 2025AY 2012-13

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Saurav Harsh, Adv., Ld. ARFor Respondent: Mr. Manoj Kumar, JCIT, Ld. DR
Section 132Section 143(3)Section 148Section 250Section 68Section 69C

appeal:- 1. That on the facts and in the circumstances of the case and in law, the Ld. Assessing Officer grossly erred in initiating reassessment proceedings u/s.148 of the Income Tax Act, 1961 against the assessee appellant. 2. That on the facts and in the circumstances of the case ... Bill, 2009. [Para 6] The memorandum states that some of the Courts have held that the Assessing Officer has to restrict the reassessment proceedings only to issues in respect of which reasons have been recorded for reopening the assessment, and that it is not open to him to touch upon

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Meenakshi Mercantiles Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2489/KOL/2024[2022-23]Status: DisposedITAT Kolkata02 Apr 2025AY 2022-23

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dcit, Circle-11(1), Meenakshi Mercantiles Limited Kolkata Room No 504, Woodburn Aayakar Bhawan, 6Thfloor, P-7, Central, 5A,Bibhabati Bose, Vs. Chowringhee Square, Kolkata, Sarani Kolkata, West Bengal, 700069 Westbengal-700020 (Appellant) (Respondent) Pan No. Aadcm1113E Assessee By : Shri S.K. Tulsiyan & Smt. Lata Goyal, Ars Revenue By : Shri Sailen Samadder, Dr Date Of Hearing: 19.03.2025 Date Of Pronouncement : 02.04.2025

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Sailen Samadder, DR
Section 48

against him. The Appellant - assessee, as a Respondent before the ITAT was entitled to agitate the jurisdictional issue relating to the validity of the reassessment proceedings. We are, therefore, of the considered opinion that the impugned order passed by the ITAT suffers from perversity in so far as it refused ... additional grounds, under Rule 27 of the ITAT Rules, pertaining to issues relating to the assumption of jurisdiction and the validity of the reassessment proceedings under section 153C of the Act.” 08. We also note that the facts relating to the above said issue as raised by the assessee under

ACIT, New Delhi vs. M/S. Bhushan Steel Ltd., New Delhi

In the result, appeal of the assessee is allowed

ITA 1470/DEL/2016[2009-10]Status: DisposedITAT Delhi02 Apr 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2006-07] S. C. Johnson Pvt. Ltd., Vs Dcit, 5Th Floor, Plot No.68, Circle-7(1), Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent [Assessment Year : 2007-08] S. C. Johnson Pvt. Ltd., Vs Acit, 5Th Floor, Plot No.68, Circle-22(2), Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent [Assessment Year : 2008-09] S. C. Johnson Pvt. Ltd., Vs Add.Cit, 5Th Floor, Plot No.68, Special Range-8, Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent Appellant By Shri K. M. Gupta, Adv. & Ms. Shruti Khimta, Ar Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 02.06.2025 Date Of Pronouncement 28.08.2025

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 250Section 80I

dated 24.12.2009 wherein certain additions were made however, the same were claimed as allowed u/s 80IB & 80IC of the Act. Thereafter, reassessment proceedings were initiated in the case of assessee u/s 147 of the act and notice u/s 148 was issued on 17.11.2011. In response assessee filed return of income ... failed to appreciate and has also erred in law in approving the action of the Ld. AO of initiating and completing the reassessment proceedings despite there being no escapement of income for the year under consideration as per the alleged reasons recorded by the Ld. AO, either

Neetesh Kumar Gupta, Shamshabad, Agra vs. Income Tax Officer WD 2(1)(3), Agra

In the result, the appeal is allowed for statistical purposes

ITA 107/AGR/2025[2012-13]Status: DisposedITAT Agra01 Apr 2025AY 2012-13

Bench: : Shri Sunil Kumar Singh & Shri Brajesh Kumar Singhassessment Year: 2012-13

Section 144Section 147Section 148Section 250(6)

deposited cash of Rs.10,67,965/- in his saving bank account maintained with State Bank of India, Shamsabad, Agra, the Assessing Officer initiated reassessment proceedings u/s. 147 of the Act by issuing a notice u/s. 148 of the Act on 31.03.2019, which stood un-responded on behalf of the assessee

Ramdas Singh Tomar, Rajasthan vs. Income Tax Officer, Ward 1(1), Jaipur

ITA 1092/JPR/2024[2018-19]Status: DisposedITAT Jaipur01 Apr 2025AY 2018-19

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपील सं. / ITA No. 1092/JP/2024 निर्धारण वर्ष / Assessment Year : 2018-19 Ramdas Singh Tomar M/s Om Sai Construction, Harikand Ka Pura Faraspura, Dholpur बनाम Income Tax Officer, Ward 1(1), Jaipur स्थायीलेखा सं. / जीआईआर सं./PAN/GIR No.: AMZPT4728R अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Rahul Pandya, Adv. राजस्व की ओर से / Revenue by: Sh. Anup Singh, Addl. CIT सुनवा

For Appellant: Sh. Rahul Pandya, AdvFor Respondent: Sh. Anup Singh, Addl. CIT
Section 115BSection 139(1)Section 142(1)Section 147Section 148Section 148ASection 2Section 271ASection 69A

appellant has taken a plea against the addition of Rs.1,10,52,000/- u/s 69A of the Act. The appellant during the reassessment proceedings contended that cash withdrawn amounting to Rs.1,10,52,000/- was for the purchase of materials and to meet out business expenses but could not substantiate

Malkiat Agro Industries 01, Cantt Road, Nabha 147201, Punjab vs. Lovish Shelley the DCIT Circle Mandigobind Garh Jao Income Tax Officer Nabha, Punjab

In the result, assessee’s appeal is allowed

ITA 485/CHANDI/2024[2012-2013]Status: DisposedITAT Chandigarh01 Apr 2025AY 2012-2013

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri K.K. Singla, C.AFor Respondent: Smt. Kusum Bansal, CIT DR
Section 133Section 133(6)Section 143(1)Section 148

taken:- "1. That the Ld. CIT(A), NFAC, Delhi has erred in confirming the order of the Assessing Officer, Circle Mandi Gobindgarh in the reassessment proceedings as initiated by the ITO, Ward Nabha u/s 148 and also confirming the addition of Rs. 12,39,90,680/- against the returned income ... assessment was framed originally u/s 143(1) and lateron, the assessment was sought to be reopened by way of notice u/s 148 and such reassessment proceedings were quashed as per following judgments:- i). Shiva Exports Vs ITO, 27 CCH 742 (Chd. Trib.) ii). CIT Vs Orient Crafts Ltd. reported

Vishal Infraglobal Pvt. Ltd., Mehsana vs. The Dy.CIT, Gandhinagar Circle, Gandhinagar

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 2081/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad01 Apr 2025AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.2080/Ahd/2024 & 2081/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Vishal Infraglobal Pvt.Ltd. The Dcit बनाम/ Plot No.42, 2Nd Floor Gandhinagar Circle V/S. Apple Avenue Gandhinagar B/H. Dharti Flats Gayatri Temple, Highway Mehsana – 384 002 "थायी लेखा सं./Pan: Aaecv 2187 J अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri S.N. Divatia, Ar Revenue By : Shri A.P. Singh, Cit-Dr & Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 27 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 01 /04/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri S.N. Divatia, ARFor Respondent: Shri A.P. Singh, CIT-DR &
Section 144Section 147Section 148Section 250Section 270A

assessee. Needless to add, the Assessing Officer shall re-examine the issue of penalty in light of the final outcome of the reassessment proceedings. 7.3. The assessee is directed to co-operate fully in the set-aside proceedings and furnish all relevant details and explanations as may be called

Vishal Infraglobal Pvt. Ltd., Mehsana vs. The Dy.CIT, Gandhinagar Circle, Gandhinagar

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 2080/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad01 Apr 2025AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.2080/Ahd/2024 & 2081/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Vishal Infraglobal Pvt.Ltd. The Dcit बनाम/ Plot No.42, 2Nd Floor Gandhinagar Circle V/S. Apple Avenue Gandhinagar B/H. Dharti Flats Gayatri Temple, Highway Mehsana – 384 002 "थायी लेखा सं./Pan: Aaecv 2187 J अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri S.N. Divatia, Ar Revenue By : Shri A.P. Singh, Cit-Dr & Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 27 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 01 /04/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri S.N. Divatia, ARFor Respondent: Shri A.P. Singh, CIT-DR &
Section 144Section 147Section 148Section 250Section 270A

assessee. Needless to add, the Assessing Officer shall re-examine the issue of penalty in light of the final outcome of the reassessment proceedings. 7.3. The assessee is directed to co-operate fully in the set-aside proceedings and furnish all relevant details and explanations as may be called

Aristocrat Residences LLP, Kolkata vs. Income Tax Officer Ward 34 (1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1118/KOL/2024[AY-2013-2014]Status: DisposedITAT Kolkata01 Apr 2025

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Income Tax Officer, Ward Aristocrat Residences Llp 34(1) 2 Oswal Chambers Church Lane Aaykar Bhavan, Bbd Bagh, Kolkata-700001 Vs. Kolkata-700107 West Bengal West Bengal (Appellant) (Respondent) Pan No. Aavfa9997R Assessee By : Dr. Kapil Goel, Ar Revenue By : H. Robindro Singh, Dr Date Of Hearing: 06.02.2025 Date Of Pronouncement : 01.04.2025

For Appellant: Dr. Kapil Goel, ARFor Respondent: H. Robindro Singh, DR
Section 132Section 139Section 142(1)Section 147Section 148Section 149Section 151Section 153Section 153ASection 153C

search no incriminating material is found, in case of completed/anak assessment, the only remedy available to the Revenue would be to initiate the reassessment proceedings under Sections 147/148 of the Act, subject to fulfillment of the conditions mentioned in sections 147/148, as in such a situation, the Revenue cannot

Annapurna Infratech, Mumbai vs. DCIT, Central Circle 1, Thane

ITA 252/MUM/2025[2016-2017]Status: DisposedITAT Mumbai01 Apr 2025AY 2016-2017

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Shri Tarang MehtaFor Respondent: Dr. K.R. Subhash, CIT-DR
Section 132Section 143(3)Section 153ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “A” BENCH : MUMBAI BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SHRI NARENDER KUMAR

ACIT, Circle-4(1)(1), Aligarh vs. Mohd. Intzar, Aligarh

The appeal stand dismissed

ITA 318/AGR/2024[2014-15]Status: DisposedITAT Agra28 Mar 2025AY 2014-15

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.318/Agr/2024 (िनधा"रणवष" / Assessment Year: 2014-15) Acit Circle 4(1)(1) Mohd. Intzar बनाम/ Aligarh 202001 140, Sarai Mitan Vs. Delhi Gate, Aligarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aagpi-7161-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Dr. Arun Kumar Yadav – Ld. Cit-Dr ""थ"कीओरसे/Respondent By : Shri Deepak Singh (Advocate) – Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025

For Appellant: Dr. Arun Kumar Yadav – Ld. CIT-DRFor Respondent: Shri Deepak Singh (Advocate) – Ld. AR
Section 143(3)Section 147Section 148Section 69C

remained unverified. Accordingly, 12.5% of these purchases was disallowed and added as unexplained income u/s 69C. 3. The assessee challenged the validity of reassessment proceedings by placing reliance on various judicial decisions. The quantum additions on merits were also contested. The Ld. CIT(A), in para 4.3, noted that during ... income which was duly verified during scrutiny assessment proceedings. There was no tangible material to reopen the case of the assessee and accordingly, the reassessment proceedings were quashed and legal grounds as raised by the assessee were allowed. 4. The Ld. CIT(A) also rendered findings on merits and noted

Anil Kumar Yadav Legal Heir Smt. Long Shree, Mainpuri vs. Income Tax Officer-4(2)(4), Mainpuri

ITA 258/AGR/2024[2011-12]Status: DisposedITAT Agra28 Mar 2025AY 2011-12
For Appellant: Shri Anurga Sinha (Advocate) – Ld. ARFor Respondent: Shri Shailendra Shrivastava - Ld. Sr. DR
Section 143(3)Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL “DB” BENCH, AGRA BEFORE HON'BLE SHRI SATBEER SINGH GODARA, JM AND HON'BLE

Subhash Chandra Gupta, Mainpuri vs. ITO Ward-2(5), Mainpuri

The appeal stand allowed in terms of our above order

ITA 216/AGR/2024[2011-12]Status: DisposedITAT Agra28 Mar 2025AY 2011-12

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.216/Agr/2024 (िनधा"रणवष" / Assessment Year: 2011-12) Shri Subhash Chandra Gupta Ito-2(5) बनाम/ Kharagjeet Nagar, Mainpuri Mainpuri Vs. Up 205001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adjpc-7010-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Rajiv Kulshreshtha (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Shailendra Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025

For Appellant: Shri Rajiv Kulshreshtha (Advocate) – Ld. ARFor Respondent: Shri Shailendra Shrivastava – Ld. Sr. DR
Section 143(3)Section 44A

selling vegetables. However, Ld. AO noted discrepancies in original return of income filed on 31-03-2012 and revised return of income filed during reassessment proceedings. The assessee was required to prove business activities and the assessee filed affidavit on 16-10-2018 in support of its contentions. However

Santhanalakshmi Babu Satishkumar, Chennai vs. ITO, Central Circle-1(4), Chennai

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

ITA 3187/CHNY/2024[2016-17]Status: DisposedITAT Chennai28 Mar 2025AY 2016-17

Bench: SHRI DUVVURU RL REDDY (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)

For Appellant: Shri Abhishek Murali, CAFor Respondent: Ms. Gauthami Manivasagam, JCIT
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 250

decision of the Hon’ble Supreme Court in the case of Union of India v. Ashish Agarwal (supra), the Assessing Officer validly initiated the reassessment proceedings and completed the assessment under section 147 of the Act and pleaded to confirm the reassessment order passed by the Assessing Officer ... under section 148 of the Act dated 25.07.2022 and served on the assessee. Thus, we find that the Assessing Officer has legally initiated the reassessment proceedings as per amended provisions of section 147 of the Act and completed the assessment under section 147 dated 25.03.2023 and the same stands confirmed

Smt. Jasmine Shah Srivastava, Bengaluru vs. Assistant Commissioner of Income-Tax, (International Taxation), Circle-2(2), Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 615/BANG/2023[2011-12]Status: DisposedITAT Bangalore28 Mar 2025AY 2011-12

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2011-12

For Appellant: Shri. V. Chandrashekar, AdvocateFor Respondent: Shri. Subramanian S, Addl. CIT(DR)(ITAT), Bangalore
Section 131Section 132Section 132(4)Section 143(3)Section 147Section 148Section 153C

Considering the rival submissions, materials available on record and Order of the lower authorities, we notice that it is an undisputed fact that the reassessment proceedings were initiated under section 147 of the Act based on documents found and seized in search proceedings under section 132 of the Act which

Pratap Nagnaji Rajgor, Mumbai vs. ITO Ward 19(3) (1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 865/MUM/2025[2009-2010]Status: DisposedITAT Mumbai28 Mar 2025AY 2009-2010

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(1)Section 148Section 271(1)(c)Section 274

eight parties. (Subsequently, the assessment was reopened by issuing of notice u/s. 148 r.w.s. 147 of the Act after recording reasons.) 2.2. During the reassessment proceedings, the Ld. AO called upon assessee to provide details of sales and purchases with full details of suppliers and purchasers along with their