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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

Amina Aslam Qureshi, Mumbai vs. Income Tax Officer Ward 22(1)(1) Mumbai, Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 769/MUM/2025[2017-2018]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-2018

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

Section 148Section 148ASection 151Section 234BSection 251(1)Section 274Section 56(2)(vii)

circumstances of the case and in law, the Ld CIT(A) erred in not considering the fact that Ld. AO erred in initiating reassessment proceedings under section 148 which is bad in law and required to be quashed. 2 ITA No.769/Mum/2025; A.Y. 2017-18 Amina Aslam Qureshi

ACIT-19(1), Mumbai vs. M Nalin & Co, Mumbai

In the result, the assessee’s cross objection No

ITA 684/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Mar 2025AY 2012-13

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeeacit-19(1), Mumbai Vs M Nalin & Co 5Th 805,8Th Floor, Prasad Chambers, 506, Floor, Piramal Chambers, Parel, Mumbai-400 Tata Road No.02, Opera House 012 Mumbai-400 004 Pan: Aaafm3223H Appellant Respondent

For Appellant: Shri Dharan GandhiFor Respondent: Shri. R.R Makwana, Addl.CIT
Section 14Section 143(1)Section 143(3)Section 147Section 148Section 250

communicated to the assessee, who filed objections challenging the reopening. These objections were considered, rebutted, and disposed of vide order dated 08/11/2019. During the reassessment proceedings, multiple notices under Sections 143(2) and 142(1) of the Act were issued, to which the assessee submitted responses and supporting documents from ... revenue has preferred an appeal before the Tribunal, whereas the assessee has filed a cross-objection, challenging the legal validity of the reassessment proceedings before the Tribunal. 3. The Ld.AR argued and filed a paper book containing pages 1 to 341. The Ld.AR first initiated argument related to Cross Objection

Vidhi Electronics LLP, Bhayandar vs. PCIT, Thane

In the result, the appeal is allowed for statistical purposes

ITA 6861/MUM/2024[2019-20]Status: DisposedITAT Mumbai28 Mar 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarvidhi Electronics Llp, V/S. Principal Commissioner Of A-102, Sudama Tower, बनाम Income Tax, Ashar It Park, 6Th Prakash Market Road, Floor, Road No. 16Z, Wagle Bhayander West, Thane- Industrial Estate, Thane 401101, Maharashtra (West), Thane – 400 604, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Appfv4987Q .. Appellant/अपीलार्थी Respondent/प्रतिवादी

For Appellant: NoneFor Respondent: Ms Kavitha Kaushik,(Sr. DR)
Section 133(6)Section 147Section 148Section 148ASection 69C

providing goods or services. The assessee was allegedly found to be one of the beneficiaries availing bogus purchases from the entity for this year. Reassessment proceedings were initiated by the ld.AO. However, during the entire proceedings under clause (d) of section 148A of the Act, the assessee remained non-responsive

Nilesh Satish Shingte, Mumbai vs. ITO, Ward-41(3)(3), Mumbai

In the result of the file by the assessee stands partly allowed as indicated hereinabove

ITA 6145/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Mar 2025AY 2016-17

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

Section 132Section 142(1)Section 147Section 148Section 148ASection 151Section 4Section 69A

from jurisdictional errors. It is also noted that, these are 5 ITA No.6145/Mum/2024; A.Y. 2016-17 Nilesh Satish Shingte directly connected with validity of reassessment proceedings and no new facts needs to be investigated for adjudicating the same. Issues alleged by the assessee being legal issue does not require investigation

Ambaji Avenues Private Limited, Mumbai vs. Income Tax Officer, Ward - 9(1) (2), Mumbai

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

ITA 5216/MUM/2024[2012-13]Status: DisposedITAT Mumbai28 Mar 2025AY 2012-13

Bench: Shri Narender Kumar Choudhryassessment Year: 2012-13

For Appellant: Shri Ramesh Malpani, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R
Section 133(6)Section 142(1)Section 143(1)Section 147Section 148Section 250Section 68

Assessee is given an opportunity to point out that the reasons to believe as recorded in the reasons do not warrant reopening before the reassessment proceedings are commenced. The Assessing Officer disposes of these objections and if satisfied with the objections, then the impugned reopening notice under section ... given an opportunity to point out that the reasons to believe as recorded in the reasons do not warrant reopening before the reassessment proceedings are commenced. Further where the jurisdictional issue such as reopening of the case is involved, the same must be strictly complied with by the authority concerned

Dmsons Metal Pvt Ltd, Mumbai vs. DCIT, Central Circle-4(1), Mumbai

In the result, appeal of the assessee bearing ITA 762/Mum/2023 is partly allowed

ITA 762/MUM/2023[2015-16]Status: DisposedITAT Mumbai28 Mar 2025AY 2015-16

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeedm Sons Metal Pvt Ltd Vs Dcit, Central Circle-4(1), Mumbai 19Th Floor, Air India Building 502, Peninsula Heights, Juhu Lane, Andheri (West), Mumbai- Nariman Point, Mumbai-400 021 400058 Pan: Aaccd6037D Appellant Respondent

For Appellant: Shri Prayag JhaFor Respondent: Shri. R.R Makwana, Addl.CIT
Section 139(1)Section 147Section 148Section 250

view of the Bench and have raised no objections. Needless to say, the assessee shall be afforded a reasonable opportunity of hearing during the reassessment proceedings. At the same time, the assessee is expected to act diligently and cooperate with the assessment process to ensure expeditious disposal of the matter

The Indian Hotels Company Ltd, Mumbai vs. Asst CIT Cir 2(2), Mumbai

Accordingly, Ground No.1 and 4 raised by the Assessee is allowed while all the other grounds raised by the Assessee are dismissed as having being rendered infructuous

ITA 5653/MUM/2011[1998-99]Status: DisposedITAT Mumbai28 Mar 2025AY 1998-99

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

For Appellant: Shri V. Sridharan, Sr. AdvocateFor Respondent: Shri Hemanshu Joshi
Section 143(3)Section 147Section 234BSection 250Section 68

Section 147 of the Act. In the present case assessment was framed on the Assessee under Section 143(3) of the Act. Thereafter, the reassessment proceedings were again initiated under Section 147 of the Act for the Assessment Year 1998- 1999 after the expiry of 4 years from ... proceedings under Section 143(3) read with Section 147 of the Act on 25/03/2004 and therefore, there was no new tangible material to initiate reassessment proceedings. 3 Assessment Year 1998-1999 4. Per contra the Learned Departmental Representative placed reliance upon reasons recorded as reproduced in Paragraph

Rakesh Bhatt, New Delhi vs. ACIT Central Circle-18, New Delhi

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

ITA 1181/DEL/2023[2016-17]Status: DisposedITAT Delhi28 Mar 2025AY 2016-17

Bench: Shris.Rifaur Rahmanbhl Forex & Finlease Limited, Vs. Dcit, Central Circle - 2, 6, Mohan Singh Place, New Delhi. Connaught Place, New Delhi – 110 001. (Pan : Aabcb8886H) (Appellant) (Respondent) Assessee By : Ms. Gini Gandhi, Advocate Ms. Anu Bajaj, Advocate Revenue By : Shri Sanjay Kumar, Sr. Dr Date Of Hearing : 13.03.2025 Date Of Order : 14.05.2025 O R D E R 1. The Assessee Has Filed This Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short] Dated 11.07.2023 For The Assessment Year 2014-15. 2. At The Time Of Hearing, Ld. Ar Of The Assessee Submitted That The Appeal Filed By The Assessee Is Against Imposition Of Penalty Under Section 271(1)(C) Of The Income-Tax Act, 1961 (For Short ‘The Act’). In This Regard, He Submitted That Assessee Has Filed Its Original Return Of Income U/S 139(4) Of The Act Which Was Belated Return & Declared The Loss. As Per The Provisions Of The Act, The Losses Declared In The Belated Returns

For Appellant: Ms. Gini Gandhi, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 139Section 139(4)Section 147Section 148Section 14ASection 271(1)(c)

years. However, while completing the assessment, he considered the unclaimed carried forward of loss and reduced the voluntary disallowance of expenses for which the reassessment proceedings were initiated on the behest of audit objection. We observed that when the assessee has chose not to carry forward the 4 returned losses

India Luxco Retail Private Limited, New Delhi vs. ACIT, Circle-10(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 2406/DEL/2022[2018-19]Status: DisposedITAT Delhi28 Mar 2025AY 2018-19

Bench: SHRI PRADIP KUMAR KEDIA (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

For Appellant: S/Shri Ravi Sharma & Jaskaran SinghFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 147Section 148Section 80I

authorities below examined. The limited issue that has been raised before us in the instant appeal is with respect to validity of reassessment proceedings u/s.148 r.w.s. 147 of the Act. Undoubtedly, assessment has been reopened in the instant case after more than four years from the end of relevant assessment ... Kelvinator of India Ltd. 187 Taxman 312 (SC)]. Thus, in light of facts of the case and settled legal principle, we hold reassessment proceedings are without jurisdiction, hence, is quashed. 8. Thus, the assesssee succeeds on ground no. 2 of appeal. 9. In the result, appeal of the assessee

Shahul Hameed, Mananthavady vs. ITO, Ward-2, Kalpetta

In the result, the appeal by the assessee is allowed

ITA 355/COCH/2024[2014-2015]Status: DisposedITAT Cochin27 Mar 2025AY 2014-2015

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Sr.AR
Section 115Section 133ASection 143(3)Section 147Section 148Section 154Section 250Section 69

section 148 of the Act was issued to the assessee on 30/03/2017 and proceedings under section 147 of the Act were initiated. During the reassessment proceedings, it was observed on the verification of the cash flow statement and statement of income filed by the assessee, it 3 ITA No.355/Coch/2024. Sri.Sahul

Firdos Shahnawazuddin Siddiqui, Mumbai vs. Commissioner of Income-Tax (Appeals), National Faceless Appeals Centre

In the result the appeal filed by the assessee stands allowed

ITA 823/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Mar 2025AY 2017-18

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

Section 2(47)Section 250Section 56(2)(vii)Section 56(2)(viib)

Bank Statement on 25/05/2016. A copy of bank statement that formed part of the paper book as Annexure 2. 2.3 The Ld.AO initiated the reassessment proceedings under Section 148 of the Act dated 30//06/2021. Assessee filed requisite details. The Ld.AO after considering submissions of the assessee passed order dated

Ajay Multi Projects Private Limited, Mumbai vs. DCIT, Circle 4(1)(1), Mumbai, Aaykar Bhawan

In the result, the appeal of the assessee is allowed

ITA 587/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Mar 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Ajay Multi Projects Pvt. Ltd., Dcit, Circle-4(1)(1), 2Nd Floor, C.J. House, 285 Aayakar Bhavan, Vs. Princess Street, Marine Lines, Mumbai-400020. Mumbai-400002. Pan No. Aadca 0338 H Appellant Respondent

For Appellant: Mr. Ram Krishn Kedia, Sr. DRFor Respondent: Mr. Dharan Gandhi
Section 147Section 148Section 148ASection 151Section 234ASection 271(1)(c)Section 69A

provisions of section 148A have not been followed 4. The provisions of section 148A have not been followed and as a result, the reassessment proceedings are bad in law. as a result, the reassessment proceedings are bad in law. as a result, the reassessment proceedings ... result, the The sanction u/s 151 is bad in law and as a result, the reassessment proceeding is bad in law. reassessment proceeding is bad in law. 6. The Ld. CIT(A) has erred in confirming the reopening 6. The Ld. CIT(A) has erred in confirming the reopening

ACIT Circle-4(3)(1), Mumbai vs. Jmp Securities Pvt Ltd, Mumbai

In the result, the appeal filed by the revenue is dismissed and the cross objection filed by the assessee is allowed

ITA 3792/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Mar 2025AY 2017-18

Bench: Shri. Amarjit Singh, Am & Ms. Kavitha Rajagopal, Jm Acit, Circle-4(3)(1) Jmp Securities Pvt. Ltd. Aayakar Bhavan, M. K. Road, 801/806, 8Th Floor, Elite Square, 274, Churchgate, Mumbai – 400020. Vs. Perin Nariman St. Bazar Gate, Fort, Mumbai – 400001. Pan/Gir No. Aaacj8850C (Appellant) : (Respondent) C. O. No. 182/Mum/2024 (Arising Out Of Ita No. 3792/Mum/2024) (Assessment Year: 2017-18) Jmp Securities Pvt. Ltd. Acit, Circle-4(3)(1) 801/806, 8Th Floor, Elite Square, 274, Aayakar Bhavan, M. K. Road, Perin Nariman St. Bazar Gate, Fort, Vs. Churchgate, Mumbai – 400020. Mumbai – 400001. Pan/Gir No. Aaacj8850C (Appellant) : (Respondent) : Shri. Omkandalkar Assessee By Respondent By : Shri. Hemankumar Chimanlal Leuva Cit Dr. Date Of Hearing : 05.02.2025 Date Of Pronouncement : 27.03.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Revenue & Cross Objection Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short)

For Respondent: Shri. Hemankumar Chimanlal Leuva
Section 147Section 148Section 151Section 151ASection 250Section 68Section 69

Bombay) [25-08-2023] and therefore, unsustainable and bad in law. 3. The NFAC is not justified in upholding the validity of the reassessment proceedings without appreciating the fact that the notice dated 30.07.2022 issued under section 148 of the Act has been issued by the Jurisdictional Assessing Officer ... that the impugned notice which was sanctioned in violation to the provisions of Section 151(ii) is bad in law and hereby quash the reassessment proceeding as invalid. Therefore, ground no. 1 and 2 raised by the assessee in its cross objection is hereby allowed. As we have held

ITO Ward 41(1)(1), Mumbai, Kautilya Bhavan, Bkc vs. Arvind Velji Gada, Mumbai

In the result, both the appeals of the assessee and Revenue

ITA 2026/MUM/2024[2016-17]Status: DisposedITAT Mumbai27 Mar 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Arvind Velji Gada, Ito Ward 41(1)(1), 1704 12Th Floor, Bellezza Tower, Kautilya Bhavan, Avenue 3, Near Vs. 420, Bhavani Shankar Road, Videsh Bhavan, G Block Bkc, Dadar (West) Bandra Kurla Complex, Bandra Mumbai-400028. East, Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent Assessment Year: 2016-17 Ito Ward 41(1)(1), Arvind Velji Gada, Kautilya Bhavan, Avenue 3, 1704 12Th Floor, Bellezza Tower, 420, Vs. Near Videsh Bhavan, G Block Bhavani Shankar Road, Dadar Bkc, Bandra Kurla Complex, (West) Bandra East, Mumbai-400028. Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent

For Respondent: Mr. Ajay R Singh/
Section 68

after 29/03/2022 same can be done in a faceless 30/07/2022 as after 29/03/2022 same can be done in a faceless manner, therefore the reassessment proceed manner, therefore the reassessment proceedings is bad in law. ings is bad in law. 7. The learned CIT (A) failed to appreciate that ... after 29/03/2022 same can be done in a faceless 30/07/2022 as after 29/03/2022 same can be done in a faceless manner, therefore the reassessment proceedings is bad in law. manner, therefore the reassessment proceedings is bad in law. manner, therefore the reassessment proceedings is bad in law. 2. The learned

Arvind Velji Gada, Mumbai vs. ITO Ward 41(1)(1), Mumbai

In the result, both the appeals of the assessee and Revenue

ITA 1582/MUM/2024[2016-17]Status: DisposedITAT Mumbai27 Mar 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Arvind Velji Gada, Ito Ward 41(1)(1), 1704 12Th Floor, Bellezza Tower, Kautilya Bhavan, Avenue 3, Near Vs. 420, Bhavani Shankar Road, Videsh Bhavan, G Block Bkc, Dadar (West) Bandra Kurla Complex, Bandra Mumbai-400028. East, Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent Assessment Year: 2016-17 Ito Ward 41(1)(1), Arvind Velji Gada, Kautilya Bhavan, Avenue 3, 1704 12Th Floor, Bellezza Tower, 420, Vs. Near Videsh Bhavan, G Block Bhavani Shankar Road, Dadar Bkc, Bandra Kurla Complex, (West) Bandra East, Mumbai-400028. Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent

For Respondent: Mr. Ajay R Singh/
Section 68

after 29/03/2022 same can be done in a faceless 30/07/2022 as after 29/03/2022 same can be done in a faceless manner, therefore the reassessment proceed manner, therefore the reassessment proceedings is bad in law. ings is bad in law. 7. The learned CIT (A) failed to appreciate that ... after 29/03/2022 same can be done in a faceless 30/07/2022 as after 29/03/2022 same can be done in a faceless manner, therefore the reassessment proceedings is bad in law. manner, therefore the reassessment proceedings is bad in law. manner, therefore the reassessment proceedings is bad in law. 2. The learned

Anil Agrawal, Muzaffarpur vs. DCIT/ACIT, Cir-1, Muzzaffarpur, Muzaffarpur

In the result, the appeal filed by the assessee is allowed on this issue

ITA 511/PAT/2024[2015-16]Status: DisposedITAT Patna26 Mar 2025AY 2015-16

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 147(1)Section 148Section 148A

April 1 2021 at 3 a.m. thereby treating the 1st April 2021 as issuance of impugned notice u/s 148 of the Act, quashed the reassessment proceedings holding that the provisions of Finance Act 2021 would be applicable from 01.04.2021 and therefore, before issuance any notice ... contention of the ld. counsel that the issue of notice u/s 143(2) of the Act within the prescribed period in relation to the reassessment proceedings u/s 147/148 was not mandatory, we find that the issue has been settled by the various High Courts holding that even in the case

Prerna Agency Pvt Ltd, Kolkata vs. Income Tax Officer, Ward 2(1), Patna

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

ITA 285/PAT/2023[2013-2014]Status: DisposedITAT Patna26 Mar 2025AY 2013-2014

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 143(3)Section 147Section 148Section 151

beyond four years. The original return had already been assessed u/s 143(3) of the Act. It is pertinent to mention herein that reassessment proceedings u/s 147 can only be initiated if income chargeable to tax has escaped assessment due to the assessee’s failure to fully and truly disclose

Bedico Automotives, Ludhiana vs. Income Tax Officer Ward- 7(1), Ludhiana

In the result, the appeal is dismissed

ITA 207/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh26 Mar 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 147Section 148Section 250Section 69C

given to the assessee. The Ld. DR had drawn our attention the following findings of the Ld.CIT(A) which read as under: During the reassessment proceedings, the assessee raised objections for the reopening and the AO duly disposed off the objections. The submissions made by the assessee were considered

Govindbhai Bhavandas Patel, Ahmedabad vs. ITO Ward 4(2)(2), Ahmedabad (Existing ITO Ward 4(2)(1), Ahmedabad)

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 256/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad26 Mar 2025AY 2011-12

Bench: Ld. Cit(A) Who Has Set Aside The Exparte Assessment Order Invoking Section 251(1)(A) Of The Act By Observing As Follows:

Section 143(2)Section 144Section 147Section 148Section 234ASection 251(1)(a)Section 271FSection 69A

file the Return of Income within 30 days. The assessee requested for time but also to drop the reassessment proceedings without furnishing necessary documents and details. Therefore final show cause notice was issued. Assessee failed to file any explanation or reply, therefore the cash deposits made in Vijaya Bank ... full and therefore the learned AO is to be directed to accept the returned income and the submission made during the course of the reassessment proceedings. 2. That the learned National faceless Appeal Centre has erred in law and facts by not quashing the assessment order as notice under section

Dy.Commissioner of Income Tax, Central Circle-1, Aurangabad vs. Parth Multitrade Pvt Ltd, Jalna

In the result, the appeal filed by the Revenue and the CO filed by the assessee are allowed for statistical purposes

ITA 1345/PUN/2024[2008-2009]Status: DisposedITAT Pune26 Mar 2025AY 2008-2009

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2008-09

For Appellant: Shri Anand PartaniFor Respondent: Shri Ajay Kumar Keshari - CIT
Section 143(1)Section 143(3)Section 147Section 148Section 151Section 151(1)Section 68

been fulfilled and therefore the notice issued under section 148 of the Act without proper approval is invalid, without jurisdiction and the reassessment proceedings are therefore, liable to be quashed. 4.5 On the other hand, in the remand report, the Add. CIT has also accepted that the AO has taken