“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 Parasram Commodities Pvt Ltd., Delhi vs. DCIT, Circle-23(1), Delhi

In the result the appeal of the assessee is allowed

ITA 4630/DEL/2025[2012-13]Status: DisposedITAT Delhi18 Mar 2026AY 2012-13

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2012-13

Section 143(3)Section 147Section 148Section 68

made in respect of issues recorded by Assessing Officer for re-opening assessment, Assessing Officer cannot make addition on any other issue in reassessment proceedings. 6. The Ld. AR submitted that the re-opening is not justified, hence the assessment order is liable to be quashed ... transaction was not genuine.Thus the addition is made on the suspicion. The Assessing Officer cannot make any addition on the other issue in reassessment proceedings. Respectfully following the decision of the Hon’ble High Court and ITAT we find that the Assessing Officer made the addition without mentioning the proper

Shailesh Kumar, New Delhi vs. Central Circle- 27, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3641/DEL/2025[2015-16]Status: DisposedITAT Delhi18 Mar 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Amitabh Shuklashailesh Kumar Vs Acit W-82/1, Eastern Avenue, Sainik Central Circle-27 Farms, New Delhi Jhandewalan, New Delhi Pan: Afppk1645B (Applicant) (Respondent) Appellant By Sh. R. P. Mall, Adv Respondent By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 26.02.2026 Date Of Pronouncement 18.03.2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-29, (‘Ld. Cit (A)’ For Short), New Delhi Dated 28/03/2025 For The Assessment Year 2015-16. 2. Brief Facts Of The Case Are That, Assessee Filed Its Return Of Income For The Year Under Consideration Declaring Income Of Rs. 18,18,380/-. An Assessment Order Came To Be Passed U/S 147 Of The Act On 30/05/2023 By Computing The Income Of The Assessee At Rs. 72,84,905/- As Against The Returned Income Of Rs. 18,18,380/-. Aggrieved By The Assessment Order Dated 30/05/2023, Assessee Preferred Appeal Before The Ld. Cit(A). The Ld. Cit(A) Vide Order Dated 28/03/2025, Dismissed The Appeal Of The Assessee.

Section 147Section 148Section 148ASection 149Section 149(1)Section 149(1)(b)Section 3(1)

Assessee. 2 Shailesh Kumar Vs. ACIT 3. The Ld. Counsel for the Assessee addressing on the additional grounds of Appeal submitted that the reassessment proceedings for year under consideration is time-barred. Further submitted that the notice u/s 148 was issued on 05/04/2021, followed bythe notice u/s 148A(b) dated ... could not validly be issued for Assessment Year 2015- 16 in view of the limitation prescribed u/s 149 of the Act, rendering the entire reassessment proceedings void and without jurisdiction. The Ld. Counsel for the Assessee relying on the Judgment of Hon'ble Supreme Court Union of India Vs. Rajeev

Vandana Singh, Noida vs. ITO 5(2)(5) Noida, Noida

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

ITA 2816/DEL/2024[2015-16]Status: DisposedITAT Delhi18 Mar 2026AY 2015-16

Bench: Shri Ramit Kochar & Shri Sudhir Kumarvandana Singh, Ito, 5(2)(5), 302, Abhinav Apartments, Noida, U.P. Vasundhra Enclave V. Delhi-110096 Pan-Dcrps8979A (Appellant) (Respondent)

Section 144Section 147Section 148Section 249(4)(b)Section 250Section 69

assessee was reopened for framing reassessment by invoking provisions of section 147. The AO issued notices to the assessee from time to time during reassessment proceedings u/s 148 as well 142(1) and 6 Vandana Singh v. ITO SCN u/s 144 of the Act, but the same were not complied ... with by the assessee before the AO during reassessment proceedings, which led to an ex-parte reassessment order wherein additions to the time of Rs. 1,36,45,500/- were made by the AO.We have detailed additions in preceding para’s of this order and the same are not repeated

Shree Mallikarjun Shipping Private Limited, Vasco vs. Deputy Commissioner of Income Tax, Circle - 1(1), Panaji

ITA 8/PAN/2025[2007-08]Status: DisposedITAT Panaji17 Mar 2026AY 2007-08

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshali

Section 143(3)Section 69A

considered the grounds of appeal, submissions of the assessee and findings of the A.O but has sustained the validity of reassessment proceedings u/sec147 of the Act and addition of unexplained money u/sec69A of the Act and the CIT(A)has granted relief in other grounds of appeal and partly allowed ... disputed issues in the grounds of appeal of the assessee that that the CIT(A) has erred in sustaining the validity of initiation of reassessment proceedings u/sec147 of the Act and sustaining the addition u/sec69A of the Act without providing proper opportunity and overlooking the facts and material evidences

Mohammed Usman, Bhilai, Durg vs. Income Tax Officer-2(1), Bhilai, Durg

In the result, appeal of the assessee is allowed

ITA 180/RPR/2026[2011-12]Status: DisposedITAT Raipur17 Mar 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.180/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 Mohammed Usman C/25, Nandini Road, Power House, Bhilai-490 011, Dist. Durg Pan: Aafpu9292H

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 148

Society for Worldwide Inter Bank Financial, Tele-2023 SCC OnLine Del 7382 communications', this court invalidated a reassessment proceeding after noting that the notice under section 143(2) of the Act was not issued to the assessee pursuant to the filing of the return. In other words, it was held ... complied with or that on placing the objection the assessee had waived the notice for further processing of the reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the 7 Mohammed Usman Vs. ITO-2(1), Bhilai (C.G.) assessee had placed its objection

Dindayal Agarwal, Berhampur vs. The Income Tax Officer, Ward-1, Berhampur.

In the result, the appeal of the assessee is allowed

ITA 471/CTK/2025[2017-18]Status: DisposedITAT Cuttack16 Mar 2026AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2016-17 Dindayal Agarwal Ito, Ward-1, Berhampur

For Appellant: Shri Pranaya Ku. Mishra, Prashant KumarFor Respondent: Shri Shakeer Ahamed, Sr. DR

Section 148Section 148ASection 151

revenue and upheld the decision of the Hon’ble Bombay High Court wherein it was held that where approval for initiation of reassessment proceedings was granted by Commissioner after expiry of 3 years from end of relevant assessment year, said approval should have been granted by Principal Chief Commissioner, thus

Income Tax Officer Ward 6 (1), Mohali vs. Skycity Builders and Promoters Private Limited, Khrar Punjab

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1217/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)

Section 143(3)Section 148Section 68

since formation of belief of escapement of income as well as approval for reopening of the case proceeded on wrong foundation of facts, the reassessment proceedings could not be sustained in law. The Ld. CIT-DR, in the written submissions, has stated that the case was reopened on specific, reliable

Skycity Builders and Promoters Private Limited, Kharar, Rupnagar vs. DCIT Ward 6(1), Chandigarh Jao ITO 6(1) Mohali, Chandigarh

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1066/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)

Section 143(3)Section 148Section 68

Rupinder Singh Duggal, Ahmedabad vs. The ITO, Ward-5(3)(2), Ahmedabad

In the result the appeal filed by the assessee is allowed

ITA 1921/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 147Section 148Section 148ASection 149Section 151Section 192Section 54Section 80C

disallowance of deduction under section 80C of the Act amounting to Rs.1,00,000/-, though such issue was not the subject-matter of reassessment proceedings. 5. The appellant craves leave to add, alter or delete any ground either before or in the course of hearing of the appeal ... which is below the monetary limit of Rs.50 lakhs as prescribed u/s.149(1)(b) of the Act and requested to drop the reassessment proceedings. However, the Ld AO in the reassessment order confined the additions to salary income of Rs.8,98,920/=; LTCG of Rs. 20,93,414/= and denial

ACIT, Circle -20(1), Mumbai vs. Utkarsha Vivek Parkar, Mumbai

In the result appeal filed by the Revenue is dismissed

ITA 6513/MUM/2025[2011-12]Status: DisposedITAT Mumbai16 Mar 2026AY 2011-12

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokaracit Circle-20(1), Utkarsha Vivek Mumbai Parkar, Room No. 305, 3Rd Vs. 108, A-Wing, Byculla Floor, Piramal Service Industrial Chambers, Parel, Estate, D. K. Cross Mumbai – 400 012. Road, Byculla, Mumbai-400 027 Pan/Gir No. Agjpp4377J (Applicant) (Respondent) Revenue By Shri Nayanjyoti Nath, Ld. Dr Assessee By Ms. Dinkle Hariya, Ld. Ar Date Of Hearing 11.03.2026 Date Of Pronouncement 16.03.2026

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 69C

response to the said notice. The assessee subsequently filed the return electronically on 14.08.2018 declaring income of Rs. 27,38,940/- 5. During the reassessment proceedings, the Assessing Officer issued statutory notices under sections 143(2) and 142(1) and called for details regarding the alleged purchases from the aforesaid ... assessee challenged both the validity of reopening as well as the addition made by the Assessing Officer. The assessee contended that the reassessment proceedings were initiated merely on the basis of information received from the Sales Tax Department without independent application of mind by the Assessing Officer. It was further

Poreddy Sambasiva Reddy, Kadiri vs. ITO, Ward-1, Hindupur

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

ITA 1862/HYD/2025[2018-19]Status: DisposedITAT Hyderabad13 Mar 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1862/Hyd/2025 ("नधा"रणवष"/ Assessment Year: 2018-19) Poreddy Sambasiva Reddy, Vs. Income Tax Officer, Kadiri. Ward-1, Pan: Bibpr4972G Hindupur. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Nvv Gopalal Krishna, Ca Assessee Represented By राज"वका""त"न"ध"व/ : Dr. Sachin Kumar, Sr.Ar Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 09/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 13/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Poreddy Sambasiva Reddy, Kadiri (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 22/10/2025 For The Assessment Year (“A.Y.” 2018-19. Poreddy Sambasiva Reddy Vs. Ito 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 142(1)Section 144Section 147Section 148Section 250Section 69A

issuance of notice under section 148 of the Act and consequently issued notice under section 148 of the Act on 03.04.2022. During the reassessment proceedings, the assessee neither filed the return of income in response to the notice issued under section 148 of the Act nor complied with the various ... file any return of income for the Assessment Year 2018–19 and also did not respond to the notices issued during the reassessment proceedings. Consequently, the Ld. AO completed the assessment ex-parte and treated the entire deposits of Rs.5,67,57,068/- in the bank account of the assessee

Veera Reddy Posham, Nalgonda vs. ACIT, Central Circle-1(1), Hyderabad

ITA 1829/HYD/2025[2020-21]Status: DisposedITAT Hyderabad13 Mar 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita.Nos.1829 & 1830/Hyd/2025

For Appellant: -None-For Respondent: Dr. Sachin Kumar, Sr. AR

Section 10Section 132Section 143(3)Section 147Section 148Section 234FSection 250(6)Section 270ASection 80CSection 80C(2)(xvii)

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO

Dandeboina Ramesh, Warangal vs. ITO, Ward-(1), Warangal

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

ITA 1661/HYD/2025[2015-16]Status: DisposedITAT Hyderabad13 Mar 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

Section 115Section 139Section 144Section 147Section 148Section 148ASection 149Section 69A

Rs.2,07,420/-. However, thereafter the assessee did not comply with the subsequent notices issued by the Ld. AO during the course of reassessment proceedings. Consequently, the Ld. AO called for the bank statement of the assessee from the concerned bank and on verification of the same found that

C 2062 Kaveripakkam Primary Agricultural Coop Crdeit Society, Vellore vs. ITO, Ward-1, Vellore

ITA 3998/CHNY/2025[2019-20]Status: DisposedITAT Chennai13 Mar 2026AY 2019-20

Bench: Shri Inturi Rama Rao & Shri Manu Kumar Giriआयकर अपील सं. / Ita No.3998/Chny/2025 िनधा"रण वष" / Assessment Year: 2019-20 C 2062 Kaveripakkam Primary Vs Income-Tax Officer, Agricultural Coop Credit Society, Ward-1, No.2, Barracks 320, Theradi Street, Cross Street, Officers Kaveripakkam, Arakkonam, Lane, Vellore-632001. Vellore – 632505. Pan: Aahfc5813C Appellant/ Assessee Respondent /Revenue Assessee By Shri J. Saravanan – Advocate Revenue By Ms. R Anitha, Addl.Cit(Dr) Date Of Hearing 18/02/2026 Date Of Pronouncement 13/03/2026 आदेश/ Order Per Inturi Rama Rao, Am : This Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Delhi Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2019-20 Dated 08.08.2025. The Assesseeraised The Following Grounds Of Appeal :

Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 148ASection 151ASection 250Section 69A

that the issue of notice u/s 148 of the Act by the Jurisdictional Assessing Officer (JAO) after 29.03.2022, are invalid, and consequentially the whole reassessment proceedings are liable to be quashed. 6. For these and other additional grounds that may be adduced before or at the time of hearing

Witmer Enterprises Pvt. Ltd., Chennai vs. ITO, Corporate Ward-3(3), Chennai

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

ITA 3840/CHNY/2025[2013-14]Status: DisposedITAT Chennai13 Mar 2026AY 2013-14

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3840/Chny/2025 िनधा"रण वष"/Assessment Year: 2013-14 Witmer Enterprises Pvt. Ltd., Vs. The Income Tax Officer, No. 86, Vasanth Business Centre, Corporate Ward 3(3), Ttk Road, Alwarpet, Chennai 600 018. Chennai. [Pan: Aaacw6606P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.02.2026 घोषणा की तारीख /Date Of Pronouncement : 13.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 06.11.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2013-14. 2. The Ld. Ar Shri Y. Sridhar, C.A. Requested To Take Up Ground No. 3 As Preliminary Issue For Adjudication As It Goes To The Root Of The Matter. Having No Objection From The Ld. Dr Ms. Gouthami

For Appellant: Shri Y. Sridhar, F.C.AFor Respondent: Ms. Gouthami Manivasagam, Addl. CIT

Section 143(2)Section 148Section 4

under section 143(2) of the Income Tax Act, 1961 [“Act” in short] was issued or served on the assessee, which is mandatory in reassessment proceedings. The ld. AR drew our attention to para 10 of the impugned order and argued that the ld. CIT(A) without considering the statutory

Shilpa Shetty Kundra, Mumbai vs. DCIT, CC-5(2), Mumbai

In the result, Assessee’s appeal is allowed for statistical purposes, in the above terms

ITA 996/MUM/2025[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2020-21

For Appellant: Ms. Simran Dhawan, Adv. & RaviFor Respondent: Shri Leyaqat Ali Aafaqui, (SR. D.R.)

Section 133(6)Section 194CSection 250

Acknowledgement of Income Tax Return of Doner for AY 2020-21. 8. In view of the aforesaid evidences filed during the course of reassessment proceedings, the appellant has fully discharged the burden u/s 68 of the Act and the burden has shifted on to the department and the Assessing Officer

Bharat Thakarshi Mamania, Mumbai vs. ITO 22(1)(6), Mumbai

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

ITA 8510/MUM/2025[2012-2013]Status: DisposedITAT Mumbai13 Mar 2026AY 2012-2013

Bench: Smt. Beena Pillai ()

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 69C

above, the said order passed should be quashed and assessment be annulled. 2. On the facts and circumstances and judicial pronouncements; the reassessment proceedings in pursuance to the notice u/s. 148 of The Income Tax Act, 1961 is in violation of provisions of section 151 of Income

Veer Sawarkar Katyal, Delhi vs. ITO Ward -43 (6), Delhi

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

ITA 8834/DEL/2025[2007-08]Status: DisposedITAT Delhi13 Mar 2026AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shuklaassessment Year: 2007-08 Veer Sawarkar Katyal, Vs Ito, 329, Sainik Vihar, Ward 43(6), Pitampura, Delhi. Rani Bagh, New Delhi – 110 034. Pan: Abdpk7569E

For Appellant: Shri Ved Jain, Advocate &For Respondent: Shri Ravi Kant Chaudhary, Sr. DR

Section 142(1)Section 147Section 148Section 250Section 254

Developers Ltd. for Rs.1,05,55,375/- in cash, made the addition of the same to the total income of the assessee in the reassessment proceedings initiated u/s 147 of the Act. We find, the ld.CIT(A) sustained an amount of Rs.35,18,458/- being 1/3 of the total investment ... assessee was not given any opportunity to confront the persons whose statement was recorded and which is the basis of initiation of reassessment proceedings and for making the addition. It is also the submission of the ld. counsel that if the so-called documents/statements, which are the basis of initiation

Sarit Gupta (HUF), New Delhi vs. Income Tax Officer, Ward 43(6), New Delhi

In the result the appeal of the assessee is allowed

ITA 6662/DEL/2025[2015-16]Status: DisposedITAT Delhi13 Mar 2026AY 2015-16

Bench: the NFAC who vide order dated 28-08-2025 dismissed the appeal. Being, aggrieved the order of the Ld. NFAC, the assessee is in appeal before the Tribunal.

Section 10(38)Section 147Section 148Section 148ASection 149Section 149(1)Section 3

issued on 26-07-2022 the said notice is to be treated as time barred by limitation and consequentially reassessment proceedings would be liable to be quashed as void ab initio. Respectfully following the decision of the Hon’ble Supreme Court, we hold that the notice issued

Bmr Overseas Limited, Delhi vs. Deputy Commissioner of Income Tax Circle 4(2), C.R. Building Delhi 110002, Delhi

In the result the appeal of the assessee is allowed

ITA 6646/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Bmr Overseas Limited, Vs. Dcit, Circle 4(2), Zb-33/487, Plot No. 4 & 5, C.R. Building, Dilshad Garde New Delhi Industrial Area, Shahdara, Delhi – 110 095 [Pan No. Aafcb8509D) (Appellant) (Respondent)

Section 115BSection 143Section 147Section 148Section 151Section 156Section 157ASection 68

facts and in law in confirming the reopening of the assessment proceedings u/s. 147 of the Act without having valid information. (ii) that the reassessment proceedings have been initiated on the basis of information without there being any independent application of mind. (iii) That the reassessment order passed