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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

Graceunited Developes Private Limited, Mumbai vs. Income Tax Officer 12(2)(1), Mumba

In the result, both the appeals by the assessee are allowed

ITA 2048/MUM/2024[2013-14]Status: DisposedITAT Mumbai13 Mar 2025AY 2013-14

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Suchek Anchaliya, C.A. & Vaishali More, C.AFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 143(2)Section 147Section 148

claim of the assessee that the assumption of jurisdiction is bad in law as the conditions laid down for initiating reassessment proceedings u/s 147 of the Act have not been fulfilled. With other grounds, the assessee has challenged the addition on merits of the case. 2 आयकर अपीलीय अधिकरण INCOME ... stated, the facts of the case are that vide notice dated 31/03/2021 issued u/s 148 of the Act, the AO assumed jurisdiction for initiating reassessment proceedings within the meaning of Section 147 of the Act. The reasons recorded for reopening of assessment is identical in both the years

Shree Auro Iron Limited, Jaipur vs. Principal Commissioner of Income Tax-I, Jaipur

In the result, this appeal of the assessee is allowed

ITA 788/JPR/2024[2016-17]Status: DisposedITAT Jaipur12 Mar 2025AY 2016-17
For Appellant: Shri Pravin Saraswant, CAFor Respondent: Mrs. Alka Gautam, CIT DR
Section 142(1)Section 143Section 145ASection 147Section 148Section 151Section 263Section 48

assessee vide assessment order dated 30.03.2022 passed u/s 147 r.w.s.144B of the Income tax Act, 1961. Meaning thereby that the reason for which reassessment proceedings were taken up did not subsist any more as the AO was satisfied about the matter which prompted him to initiate reassessment proceedings. Thereafter ... cost claimed and the AO did not apply his mind on such claim of the assessee. It was also claimed by ld. AR that reassessment proceedings were carried as per Faceless Scheme wherein separate verification unit, review unit are also available and in such mechanism it cannot be said that

ACIT, Ncr Building, Jaipur vs. Hans Raj Agarwal, Vidhyadhar Nagar Jaipur

39. In view of the above discussion and findings, memorandum of cross objections No 1/JP/2025 filed by the assessee is allowed

ITA 1253/JPR/2024[2016-17]Status: DisposedITAT Jaipur12 Mar 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Aditya Vijay, Adv. &For Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132Section 142(1)Section 143(1)(a)Section 147Section 148Section 250

11/12/2018 accepting the return of income of the assessee, thus the impugned assessment order passed dated 17.05.2023 is merely a review under garb of reassessment proceedings. Thus, the impugned assessment order dated 17.05.2023 deserved to be quashed.” 11. As is available from page 14 to 17 of the impugned order ... income of the assessee by passing the order u/s143(3) dated 11/12/2018(PB Pg No. 157-163). 2. Thus, Ld.AO by initiating the present reassessment proceedings are merely reviewing its own decision which is not permissible in law. 3. Because it is merely a fresh application of mind

Himasagar Krishna Muthappagari, Tirupati vs. ITO., Ward-2(3), Tirupati

ITA 687/HYD/2024[2016-17]Status: DisposedITAT Hyderabad12 Mar 2025AY 2016-17

Bench: Us.

For Appellant: Shri M. Uday Teja, C.AFor Respondent: Ms. M. Narmada, CIT-DR
Section 143(3)Section 147Section 148Section 263

based on the fact that the Long-Term Capital Gains (for short “LTCG”) was computed short while framing the original assessment, initiated the reassessment proceedings u/s 147 of the Act. Reassessment 5 Himsagar Krishna Vs. Pr. CIT, Tirupati order u/s 147 r.w.s. 144B of the Act, dated 22.03.2022 was thereafter

Eurofins Peenya Resources Private Limited (Formerly Known As Eurofins Advinus Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle2(1)(1), Bangalore

In the result, the appeal for AY 2013-14 is partly allowed

ITA 1115/BANG/2023[2015-16]Status: DisposedITAT Bangalore12 Mar 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Smt. Nandini Das - CIT (DR)
Section 143(3)Section 147Section 148Section 40

every right to assess or reassess such income and also any other income which has escaped assessment and comes to his notice during the reassessment proceedings. However, there is one fetter to his right, i.e., if any action has to be taken after the expiry of four years from ... disclose fully and truly all material facts necessary for his assessment for that assessment year. 21. Therefore, in the case of reassessment proceedings initiated after the expiry of four years, the AO can assume jurisdiction for reassessment only after the above conditions are satisfied. Satisfaction of the above conditions

Cane Development Council Anoopshahr, Bulandshahr vs. ITO, Ward-3(1), Bulandshahr

In the result, Appeal of the Assessee in ITA Nos

ITA 5756/DEL/2019[2015-16]Status: DisposedITAT Delhi12 Mar 2025AY 2015-16

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.I.T.A. No. 5755/Del/2024 (A.Y 2013-14) I.T.A. No. 5756/Del/2024 (A.Y 2014-15) I.T.A. No. 5761/Del/2024 (A.Y 2015-16)

Section 148Section 148oSection 149Section 149(1)

noted above, by virtue of TOLA, the AO had period of twenty-nine days limitation left on the date of commencement of the reassessment proceedings, which began on 01.06.2021, to issue a notice under Section 148 of the Act. The said notice was required to be accompanied by an order ... obtained only from Pr. Chief Commissioner of Income Tax and not from Pr. Commissioner of Income Tax. The Hon’ble High Court quashed the reassessment proceedings in the absence of proper approval obtained by the AO and the ratio to this judgment squarely applies to the facts of the Assessee

Shanvaj Hussin, Khargone vs. ITO, Khargone

ITA 504/IND/2024[2014-15]Status: HeardITAT Indore11 Mar 2025AY 2014-15

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshimember Assessment Year: 2014-15 Shanvaj Hussain, Income Tax Officer, 5, New Sabji Mandi, Khargone बनाम/ Khargone Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Afkph8029P Assessee By Shri S.N. Agrawal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.03.2025 Date Of Pronouncement 11.03.2025

Section 139Section 143(3)Section 147Section 246Section 250Section 253Section 271BSection 44A

ICICI Bank, Khargone. On merits the Page 2 of 11 Shanvaj Hussain ITA No. 504/Ind/2024 – AY 2014-15 assessee submitted during the course of reassessment proceedings that he was merely a commission agent who earned the commission income and offered it for tax in his Income Tax Return. The assessee ... audit. Once board has advised the said circular is binding on revenue then Revenue cannot contend otherwise. 3.2 The Ld. AR also contended that reassessment proceedings u/s 147/148 after original assessment proceedings u/s 143(3) too were set aside by CIT(A) vide order dated 01.01.2024 Page 44 Page

Income Tax Officer, Indore vs. Sewa Sahkari Sanstha Maryadit Tillor Khurad, Indore

ITA 327/IND/2024[2015-16]Status: DisposedITAT Indore11 Mar 2025AY 2015-16

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshimember

Section 246ASection 250Section 253Section 269TSection 271E

reference made by the DCIT to ACIT on 01.08.2024 shall not enhance case of the department as the reference was after the conclusion of reassessment proceedings by the DCIT. 8. The satisfaction dated 24.09.2024 recorded by the ACIT cannot be equated with the satisfaction to be recorded in the reassessment

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 901/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

material fact necessary for assessment. It is seen that this fact was brought to the notice of the AO through objections filed during the reassessment proceedings, the AO vide order dt. 25.11.2019 disposing the objections raised, stating that the assessment u/s 143(3) of the Act is completed ... through a detailed speaking order in compliance with the Hon’ble Supreme Court’s directives in GKN Driveshafts. 3. Participation in Reassessment Proceedings o After the AO disposed of the objections, the assessee participated in the reassessment proceedings without raising further objections. 4. Challenge Before CIT(A) o Despite procedural

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 875/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Mar 2025AY 2016-17
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

material fact necessary for assessment. It is seen that this fact was brought to the notice of the AO through objections filed during the reassessment proceedings, the AO vide order dt. 25.11.2019 disposing the objections raised, stating that the assessment u/s 143(3) of the Act is completed ... through a detailed speaking order in compliance with the Hon’ble Supreme Court’s directives in GKN Driveshafts. 3. Participation in Reassessment Proceedings • After the AO disposed of the objections, the assessee participated in the reassessment proceedings without raising further objections. 4. Challenge Before CIT(A) • Despite procedural compliance

Income Tax Officer (Gopal Lal Kansotia), Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 874/JPR/2024[2015-16]Status: DisposedITAT Jaipur11 Mar 2025AY 2015-16
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

material fact necessary for assessment. It is seen that this fact was brought to the notice of the AO through objections filed during the reassessment proceedings, the AO vide order dt. 25.11.2019 disposing the objections raised, stating that the assessment u/s 143(3) of the Act is completed ... through a detailed speaking order in compliance with the Hon'ble Supreme Court's directives in GKN Driveshafts. 3. Participation in Reassessment Proceedings o After the AO disposed of the objections, the assessee participated in the reassessment proceedings without raising further objections. 4. Challenge Before CIT(A) o Despite procedural

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

ITA 873/JPR/2024[2013-14]Status: DisposedITAT Jaipur11 Mar 2025AY 2013-14
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

material fact necessary for assessment. It is seen that this fact was brought to the notice of the AO through objections filed during the reassessment proceedings, the AO vide order dt. 25.11.2019 disposing the objections raised, stating that the assessment u/s 143(3) of the Act is completed ... through a detailed speaking order in compliance with the Hon’ble Supreme Court’s directives in GKN Driveshafts. 3. Participation in Reassessment Proceedings o After the AO disposed of the objections, the assessee participated in the reassessment proceedings without raising further objections. 4. Challenge Before CIT(A) o Despite procedural

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 872/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Mar 2025AY 2012-13
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

material fact necessary for assessment. It is seen that this fact was brought to the notice of the AO through objections filed during the reassessment proceedings, the AO vide order dt. 25.11.2019 disposing the objections raised, stating that the assessment u/s 143(3) of the Act is completed ... through a detailed speaking order in compliance with the Hon’ble Supreme Court’s directives in GKN Driveshafts. 3. Participation in Reassessment Proceedings - After the AO disposed of the objections, the assessee participated in the reassessment proceedings without raising further objections. 4. Challenge Before CIT(A) Despite procedural compliance

Ram Kishor Soni, Ahmedabad vs. National Faceless Assessment Centre, Delhi Present AO: the ITO, Ward-4(2)(1), Ahmedabad

The appeals of the assessee are allowed for statistical purposes

ITA 1282/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad11 Mar 2025AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita Nos.1281&1282/Ahd/2024 निर्धारण वर्ष / Assessment Years: 2013-14 & 2014-15 Ram Kishor Soni, 626, Sector No.3, Chankyapuri, Ghatlodiya, Ahmedabad-380061 स्थायी लेखा सं./Pan: Blips8712B बनाम/ V/S. National Faceless Assessment Centre, Delhi Present A.O.: Income Tax Officer, Ward-4(2)(1), Ahmedabad अपीलार्थी/ (Appellant) प्रत्यर्थी / (Respondent) Assessee By: Shri P. F. Jain, Ar Revenue By: Shri Rignesh Das, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 10/03/2025 घोषणा की तारीख / Date Of Pronouncement: 11/03/2025 आदेश/Order Per Makarand V. Mahadeokar, Am: Both These Appeals Filed By The Assessee Pertain To Assessment Years 2013-14 & 2014-15 Against The Respective Orders Of Commissioner Of Appeal, National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)"], Confirming The Additions Made By The Assessing Officer [Hereinafter Referred To As "Ao"] Under Section 69A Of The Income-Tax Act, 1961[Hereinafter Referred To As "The Act"], On Account Of Unexplained Cash Deposits In The Assessee'S Bank Accounts. Since The Issues Involved In Both The Appeals Are Identical, They Are Disposed Of By This Consolidated Order.

For Appellant: Shri P. F. Jain, ARFor Respondent: Shri Rignesh Das, Sr. DR
Section 115BSection 132Section 142(1)Section 144Section 147Section 148Section 154Section 234ASection 69A

accordance with the law, after affording the assessee a reasonable opportunity to present its case. The assessee is directed to fully cooperate in the reassessment proceedings and furnish all necessary details to substantiate its claim. 9. The learned AR has relied on the decision of the Co-ordinate Bench

Ram Kishor Soni, Ahmedabad vs. National Faceless Assessment Centre, Delhi Present AO: the ITO, Ward-4(2)(1), Ahmedabad

The appeals of the assessee are allowed for statistical purposes

ITA 1281/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad11 Mar 2025AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita Nos.1281&1282/Ahd/2024 निर्धारण वर्ष / Assessment Years: 2013-14 & 2014-15

For Appellant: Shri P. F. Jain, ARFor Respondent: Shri Rignesh Das, Sr. DR
Section 115BSection 132Section 142(1)Section 144Section 147Section 148Section 154Section 234ASection 69A

accordance with the law, after affording the assessee a reasonable opportunity to present its case. The assessee is directed to fully cooperate in the reassessment proceedings and furnish all necessary details to substantiate its claim. 9. The learned AR has relied on the decision of the Co-ordinate Bench

Pravin Babanrao Tambe, Pune vs. Principal Commissioner of Income Tax-4, Pune

In the result, the appeal filed by the assessee is dismissed as not maintainable

ITA 692/PUN/2023[2013-14]Status: DisposedITAT Pune11 Mar 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.692/Pun/2023 िनधा"रण वष" / Assessment Year : 2013-14 Pravin Babanrao Tambe, Vs. Pcit, Pune-4. Sr. No.14, Shree Datta Colony, Akashwani, Hadapsar, Pune- 411028. Pan : Aimpt5087G Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri Ajay Kumar Keshari Date Of Hearing : 12.12.2024 Date Of Pronouncement : 11.03.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31.03.2021 Passed By Ld. Pr.Cit, Pune- 4 [‘Ld. Pcit’] U/S 263 Of The It Act For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. Ld Cit Erred In Law & On Facts In Invoking Jurisdiction Under Section 263 & Setting Aside Assessment Order For Fresh Assessment On The Ground That Assessment Has Been Framed

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 143(2)Section 143(3)Section 148Section 263Section 48

order u/s 147 r.w.s. 263 was passed on 24.03.2022. It was specifically pointed out by Ld. DR that the assessee participated in this consequential reassessment proceedings through qualified representative wherein written submissions were furnished by the 9 assessee and after considering the contentions of the assessee, the orders were passed

Raziulla Syed, Hyderabad vs. ITO (Int Taxn)-2, Hyderabad

In the result, appeal of the Assessee is allowed

ITA 986/HYD/2024[2017-18]Status: DisposedITAT Hyderabad11 Mar 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P Murali Mohan RaoFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 142(1)Section 144C(5)Section 147Section 148Section 148ASection 195

with effective from 01.04.2021 prescribed under the same provisions (Sections 147-151), including a new provision Section 148A prescribing the procedure for reopening and reassessment proceedings. In pursuance to the Judgment of the Hon’ble Supreme Court the CBDT vide it’s instruction No.1/2022 dated 11.05.2022, 5 ITA.No.986/Hyd./2024 ... 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." 7.4. In this

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

In the result, all the five appeals filed by the assessee are allowed

ITA 552/CHNY/2024[2018-19]Status: DisposedITAT Chennai11 Mar 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

search no incriminating material is found, in case of completed/unabated assessment, the only remedy available to the Revenue would be to initiate the reassessment proceedings under sections 147/48 of the Act, subject to fulfilment of the conditions mentioned in sections 147/148, as in such a situation, the Revenue cannot ... assessee u/s.153A of the Act, despite no incriminating material found in the case of direct search would justify such proceedings as akin to reassessment proceedings u/s.147 of the Act. In this context, we are of the view that reassessment and its conditions are completely different and distinct for the conditions

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

In the result, all the five appeals filed by the assessee are allowed

ITA 551/CHNY/2024[2017-18]Status: DisposedITAT Chennai11 Mar 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

search no incriminating material is found, in case of completed/unabated assessment, the only remedy available to the Revenue would be to initiate the reassessment proceedings under sections 147/48 of the Act, subject to fulfilment of the conditions mentioned in sections 147/148, as in such a situation, the Revenue cannot ... assessee u/s.153A of the Act, despite no incriminating material found in the case of direct search would justify such proceedings as akin to reassessment proceedings u/s.147 of the Act. In this context, we are of the view that reassessment and its conditions are completely different and distinct for the conditions

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

ITA 550/CHNY/2024[2016-17]Status: DisposedITAT Chennai11 Mar 2025AY 2016-17
For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्न IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH, CHENNAI श्री जॉर्ज जॉर्ज के, उपाध्यक्ष एवं