“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

Samir Navin Shah, Mumbai vs. Income Tax Officer, Circle 19(3), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 5421/MUM/2024[2012-23]Status: DisposedITAT Mumbai06 Mar 2025AY 2012-23

Bench: Shri Anikesh Banerjee & Omkareshwar Chidarasamir Navin Shah Vs Income-Tax Officer, Circle 19(3) Shreeji Arcade, Shreeji Matru Mandir, Mumbai Chambers, Tata Road No.1 & 2 Opera House, Mumbai-400 004 Pan : Aazps9084M Appellant Respondent Assessee By : Shriv.P. Kothari Respondent By : Ms. Kavitha Kaushik,(Sr Dr)

For Appellant: ShriV.P. KothariFor Respondent: Ms. Kavitha Kaushik,(SR DR)

Section 143(3)Section 147Section 148Section 250

original assessment under Section 143(3), the Ld. AO had applied an 8% addition in respect of purchases from Mayur Exports, whereas in the reassessment proceedings under Sections 147/143(3), the entire amount of alleged bogus purchases was added. This, the Ld. AR argued, amounts to a complete change ... opinion, which is not permissible in reassessment proceedings. Aggrieved by the reassessment order, the assessee filed an appeal before the Ld. CIT(A), who upheld the assessment order. Dissatisfied with the order, the assessee has now preferred the present appeal before us. 4. We have heard the rival submissions

Visible Chits (Maharashtra) Private Limited, Thane vs. Income Tax Officer, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 410/MUM/2024[2017-18]Status: DisposedITAT Mumbai06 Mar 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Omkareshwar Chidaravisible Chits (Maharashtra) Vs Income-Tax Officer, Private Limited, Thane Ward15(3)(2),Mumbai F/49, Eternity Mall, Teen Hath Aayakar Bhavan, M.K. Road, Naka, Thane-400 604 Mumbai-400 020 Pan: Aadcv1633L Appellant Respondent Assessee By : Shri Kartik Natarajan Respondent By : Ms. Kavitha Kaushik,(Sr Dr)

For Appellant: Shri Kartik NatarajanFor Respondent: Ms. Kavitha Kaushik,(SR DR)

Section 143(3)Section 250Section 40Section 68

remand the matter to the file of the Ld. AO for fresh adjudication. We refrain from expressing any opinion that may prejudice the reassessment proceedings. It is, however, imperative that the assessee is afforded a reasonable opportunity of being heard during the reassessment proceedings and is allowed to submit

Income Tax Officer 10(1)(1), Aayakar Bhavan vs. Kunal Comtrade Private Limited, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 3731/MUM/2024[2013-14]Status: DisposedITAT Mumbai06 Mar 2025AY 2013-14

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Mani JainFor Respondent: Shri Biswanath Das, CIT-DR

addition, the assessee explained as under before Ld CIT(A):- “43. At the outset, it is submitted that the appellant during the course of reassessment proceedings itself submitted documents/clarifications with respect to the said issue. However, the Id.AO arbitrarily rejected the same and made an addition of Rs.6.43

Income Tax Officer 10(1)(1), Aayakar Bhavan vs. Kunal Comtrade Private Limited, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 3730/MUM/2024[2014-15]Status: DisposedITAT Mumbai06 Mar 2025AY 2014-15

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Mani JainFor Respondent: Shri Biswanath Das, CIT-DR

Kuber Khaini Pvt. Ltd., Delhi vs. ACIT, Central Circle- 30, New Delhi

In the result, the cross objection filed by the assessee in AY 2006-07 is allowed and

ITA 885/DEL/2019[2014-15]Status: DisposedITAT Delhi06 Mar 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shris.Rifaur Rahman

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Javed Akhtar, CIT DR

Section 143(3)Section 271(1)(c)Section 274

No.6053 /DEL/2016 ITA Nos.884 to 886/DEL/2022 CO No.18/Del/2017 CO Nos.186 to 188/Del/2022 that no proper opportunity was granted to the assessee and further reassessment proceedings were taken up only on 19.03.2014 and completed on 28.03.2014 within 9 days. It clearly shows that assessee was not extended proper time and proper ... opportunity to produce various records as called for by the Assessing Officer. It is also fact on record that reassessment proceedings were initiated beyond four years and Assessing Officer has not brought on record any failure on the part of the assessee to disclose fully and truly all material facts

Assistant Commissioner of Income Tax, Central Circle, Vapi vs. Radha Madhav Eco Industrial Park, Vapi

ITA 626/SRT/2024[2019-20]Status: DisposedITAT Surat05 Mar 2025AY 2019-20

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) Vs. The Acit, Radha Madhav Eco-Industrial Park, Central Circle - 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp - Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp - Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

Section 139Section 250

IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT

Assistant Commissioner of Income Tax, Central Circle, Vapi vs. Radha Madhav Eco Industrial Park, Vapi

ITA 625/SRT/2024[2018-19]Status: DisposedITAT Surat05 Mar 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023

Section 139Section 250

IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT

DCIT, Jaipur vs. Pramod Chand Mahnot, Jaipur

In the result, the appeal of the Department and C

ITA 162/JPR/2023[2012-13]Status: DisposedITAT Jaipur05 Mar 2025AY 2012-13

For Appellant: Shri Rohan Sogani, CAFor Respondent: Shri Anup Singh, Addl. CIT-DR fu/kZkfjrh dh vksj ls@

Section 10(38)Section 147Section 148Section 151Section 153CSection 68Section 69C

illegal, unjustified, arbitrary and against the facts of the case and without jurisdiction. Relief may be please be granted by quashing the entire reassessment proceedings initiated by the Id. AO and confirmed by the id CIT(A)/NFAC 2. In the facts and circumstances of the case ... without jurisdiction. Relief may be please be granted by 3 DCIT , CIRCLE-6, JAIPUR VS SHRI PRAMOD CHAND MAHNOT, JAIPUR quashing the entire reassessment proceedings initiated by the ld. AO and confirmed by the ld. CIT(A)/NFAC 3. In the facts and circumstances of the case

Kamlesh Gupta and Sons HUF, Mumbai vs. The Income Tax Officer Ward 19(2)(2), Mumbai

ITA 4080/MUM/2024[2012-13]Status: DisposedITAT Mumbai05 Mar 2025AY 2012-13

Bench: Shri Sandeep Gosain (Jm) & Shri Omkareshwar Chidara (Am) Kamlesh Gupta & Sons Huf Ito-19(2)(2) 95-C, Mittal Towers Piramal Chamber Nariman Point, Churchgate Vs. Lalbaug, Lower Mumbai-400 021. Parel, Mumbai-12. Pan : Aaehk4734K Appellant Respondent

For Appellant: Shri Asif KarmaliFor Respondent: Shri Sumit Mantri

Section 143(1)Section 143(3)Section 147Section 148Section 151Section 250

assessee of the furnishing all material facts fully and truly to the assessing officer; and therefore, does not do away with any further reassessment proceedings that may arise upon availability of any fresh material facts. Therefore, in this case, the time limit of issuance of notice under section

Rahul Jabarmal Jain, Mumbai vs. Assistant. Commissioner of Income Tax -19(3), Mumbai

In the result, the appeal is accordingly partly allowed for statistical purposes in the above terms

ITA 3525/MUM/2024[2008-09]Status: DisposedITAT Mumbai05 Mar 2025AY 2008-09

Bench: Shri B R Baskaran & Shri Raj Kumar Chauhanrahul Jabarmal Jain Vs. Acit 19(3) 1204/B 12 Floor, Pratiksha Tower, R. 5Th Floor, Piramal Chamber, S. Nimkar Marg, Mumbai Central, Lalbaug, Mumbai-400 012 Mumbai-400 008 Pan: Aempj8236K (Appellant) (Respondent)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 37

That on fact and circumstances of the case and in law the ld. C.I.T. (Appeals), NFAC, Delhi has erred in upholding the validity of reassessment proceeding initiated under section 147 of the Income Tax Act, 1961 by the ld. Assessing Officer to reopen the already concluded assessment earlier u/s.143 ... merely on change of opinion and borrowed satisfaction. In view of the same appellant prays that reassessment proceeding initiated to reopen the concluded assessment u/s.143(3) by issue of impugned notice u/s.148 dated 16-03-2015 and consequent reassessment order passed u/s.143(3) r.w.s.147 on 28-03-2016 being

Impressions Services Private Limited, Delhi vs. ADIT Circle 10(1), Delhi

In the result, the Assessee’s appeal is allowed in the aforesaid manner

ITA 3275/DEL/2023[2018-19]Status: DisposedITAT Delhi05 Mar 2025AY 2018-19

Bench: Shri Mahavir Singha.Yr. : 2012-13 Jaivir, Vs. Ito, Ward-1, Sonipat, H.No. 1399, Sector-23, Haryana Sonipat, Haryana (Pan: Amgmpj7567H) (Appellant) (Respondent)

For Appellant: Shri Suresh Gupta, CAFor Respondent: Shri Manoj Kumar, Sr. DR

Section 142(1)Section 147Section 148Section 151

argued only the following legal ground:- “On facts and in the circumstances of the case, the authorities below have erred in upholding the reassessment proceedings ignoring the fact that impugned assessment is invalid and without jurisdiction as the reassessment proceedings has been initiated without application of mind and therefore ... time of hearing, Ld. AR has reiterated the aforesaid ground and also the submissions made before the authorities below, more particularly that invocation of reassessment proceedings based on non-existing provision of law. He relied upon the recent Coordinate Bench decision dated 04.08.2025 in the case of Sumit Suneja

Rajendra Maganbhai Patel, Mumbai vs. The Asstt. Commissioner of Income Tax, Circle International Taxation, Vadodara

ITA 106/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad04 Mar 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita Nos.105/Ahd/2023 & 106/Ahd/2023 निर्धारण वर्ष / Assessment Years : 2013-14 & 2015-16 Respectively Rajendra Maganbhai Patel C-1/8, Bhadran Nagar S.V. Road, Malad West Mumbai - 400 064 Maharashtra स्थायी लेखा सं./Pan: Asipp 5675 N बनाम / V/S. The Asstt.Commissioner Of Income Tax, Circle International Taxation, Vadodara (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) Assessee By: Shri Tushar Hemani, Sr.Advocate & Revenue By : Shri Parimalsinh N. Parmar, Ar Shri Prathvi Raj Meena, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 26/02/2025 घोषणा की तारीख / Date Of Pronouncement: 04/03/2025 आदेश/Order Per Makarand V. Mahadeokar, Am: Both These Appeals By The Assessee Pertain To Assessment Years (Ays) 2013-14 & 2015-16 & Are Directed Against The Final Assessment Orders Passed By The Assessing Officer [Hereinafter Referred To As “Ao"] Under Section 147 R.W.S.144C(13) Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act"], Pursuant To The Directions Of The Dispute Resolution Panel [Hereinafter Referred To As “Drp”]. The Core Issue In Both The Appeals Concerns The Addition Made By The Ao On Account Of Credits In The Assessee'S Non- Resident External (Nre) Bank Accounts.

For Appellant: Shri Tushar Hemani, Sr.Advocate &For Respondent: Shri Parimalsinh N. Parmar, AR

Section 143(2)Section 147Section 148

assessee establish that foreign remittances into NRE accounts are not taxable under Indian law. However, all three cases involved quashing of reassessment proceedings under Section 148A, whereas the present case involves a completed assessment under Section 147 r.w.s.144C(13) of the Act after a full-fledged inquiry. Therefore, while

Rajendra Maganbhai Patel, Mumbai vs. The Asstt. Commissioner of Income Tax, Circle International Taxation, Vadodara

ITA 105/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad04 Mar 2025AY 2013-14

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.105/Ahd/2023 & 106/Ahd/2023 िनधा"रण वष" /Assessment Years : 2013-14 & 2015-16 Respectively Rajendra Maganbhai Patel The Asstt.Commissioner Of बनाम/ C-1/8, Bhadran Nagar Income Tax, Circle V/S. S.V. Road, Malad West International Taxation, Mumbai – 400 064 Vadodara Maharashtra "थायी लेखा सं./Pan: Asipp 5675 N (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Tushar Hemani, Sr.Advocate & Shri Parimalsinh N. Parmar, Ar Revenue By : Shri Prathvi Raj Meena, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 26 /02/2025 घोषणा की तारीख /Date Of Pronouncement: 04 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: Both These Appeals By The Assessee Pertain To Assessment Years (Ays) 2013-14 & 2015-16 & Are Directed Against The Final Assessment Orders Passed By The Assessing Officer [Hereinafter Referred To As “Ao”] Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act"], Pursuant To The Directions Of The Dispute Resolution Panel [Hereinafter Referred To As “Drp”]. The Core Issue In Both The Appeals Concerns The Addition Made By The Ao On Account Of Credits In The Assessee’S Non- Resident External (Nre) Bank Accounts.

For Appellant: Shri Tushar Hemani, Sr.Advocate &For Respondent: Shri Prathvi Raj Meena, CIT-DR

Section 143(2)Section 147Section 148

assessee establish that foreign remittances into NRE accounts are not taxable under Indian law. However, all three cases involved quashing of reassessment proceedings under Section 148A, whereas the present case involves a completed assessment under Section 147 r.w.s. 144C(13) of the Act after a full-fledged inquiry. Therefore, while

Assistant Commissioner of Income Tax, Central Circle 3(2), Kolkata, Aayakar Bhawan Poorva vs. M/S. Delightful Estate Developers LLP, Kolkata

In the result, the CO of the assessee is allowed and the appeal of the Revenue is dismissed as infructuous

ITA 2309/KOL/2024[2017-18]Status: DisposedITAT Kolkata04 Mar 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm M/S Delightful Estate Developers Llp Acit, Cc 3(2), Kolkata Hasting Chamber, 5 Th Floor, Acit, Central Circle 3(2), Aaykar Room No.5C, 7C, Kiran Bhavan Poorva, 5Th Floor, 110, Vs. Shanti Pally, Kolkata-700107, Shankar Roy Road Kolkata West Bengal G.P.O. Kolkata-700001, West Bengal (Respondent) (Appellant) Pan No. Aamfd0344A Co No.04/Kol/2025 (Assessment Year: 2017-18) M/S Delightful Estate Developers Llp Acit, Cc 3(2), Kolkata Hasting Chamber, 5 Th Floor, Acit, Central Circle 3(2), Aaykar Room No.5C, 7C, Kiran Bhavan Poorva, 5 Th Floor, 110, Vs. Shankar Roy Road Kolkata Shanti Pally, Kolkata-700107, West Bengal G.P.O. Kolkata-700001, West Bengal (Appellant) (Respondent) Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Rajat Datta, Dr Date Of Hearing: 28.01.2025 Date Of Pronouncement : 04.03.2025

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Rajat Datta, DR

Section 144BSection 147Section 148Section 37Section 47Section 68

adjudicated. Hence, the Revenue’s appeal before us is against the deletion of addition while the assessee has challenged the validity of reassessment proceedings based on the vague and scanty reasons. 05. After hearing the rival contentions and perusing the materials available on record, we find that the case

Income Tax Officer Ward 4 1 Kolkata, Kolkata vs. Panel Commerce Pvt Ltd, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1292/KOL/2023[2013-14]Status: DisposedITAT Kolkata04 Mar 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Panel Commerce Pvt. Ltd. Income Tax Officer, Ward 4(2) 4 Synagogue Street, Aaykar Bhavan, P-7, 8Th Floor, Room No. 814, Chowringhee Square, Kolkata- Vs. Kolkata-700001, 700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aagcp4413P Co No. 1/Kol/2024 (Arising In Ita No.1929/Kol/2023 For A.Y. 2013-14) Panel Commerce Pvt. Ltd. Income Tax Officer, Ward 4(2) 4 Synagogue Street, Aaykar Bhavan, P-7, 8Th Floor, Room No. 814, Chowringhee Square, Kolkata- Vs. Kolkata-700001, 700069, West Bengal West Bengal (Appellant) (Respondent) Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Raghuveer Madanappa, Dr Date Of Hearing: 30.01.2025 Date Of Pronouncement : 04.03.2025

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Raghuveer Madanappa, DR

Section 147Section 148Section 68

Tribunal raising multiple grounds. Ground no. 1 & 2 are connected on which the ld. AR of the assessee stating before the bench that the reassessment proceeding initiated by the ld. AO is bad in law as the same has been done only on the basis of information received from Investigation ... situation, the statements were ITA No.1292/KOL/2023 & CO No. 01/KOL/2024 Panel Commerce Pvt. Ltd; A.Y. 2013-14 never confronted to the assessee in the entire reassessment proceedings to find out whether the assessee was named as beneficiary of accommodation entry made by them. In this context, the submission of the assessee

Shah Rukh Khan, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, the appeal by the assessee is allowed

ITA 6312/MUM/2024[A. Y. 2012-13 ]Status: DisposedITAT Mumbai04 Mar 2025

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalshah Rukh Khan, 44, Mannat, Bj Road, Bandstand, Bandra, Mumbai - 400050 Pan: Aahpk3293L ……………. Appellant V/S Dcit, Central Circle – 4(2) Kautilya Bhavan, Bandra Kurla Complex, Bandra East, ……………. Respondent Mumbai - 400050 Maharashtra

For Appellant: Shri Aditya AjgaonkarFor Respondent: Ms. Kavitha Kaushik, Sr. DR

Section 148Section 250

assessment. 7. In the facts of the matter and in law, the Learned Commissioner Income Tax (Appeal) erred in upholding the validity of the reassessment proceedings and the denial of the double taxation relief of Rs.1,40,00,000/- withheld at source in the UK. Infact, for the same Assessment

Udaylal Hiralal Jain, Mumbai vs. Income Tax Officer, Ward 20(3)(1), Mumbai

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

ITA 6306/MUM/2024[2016-17]Status: DisposedITAT Mumbai04 Mar 2025AY 2016-17

Bench: Shri Sandeep Singh Karhail & Shri Girish Agrawalassessment Year: 2016-17 Udaylal Hiralal Jain Income-Tax Officer, Ward – Shop No.8, Bmc Bldg., 20(3)(1), R A Kidwai, Wadala, Vs. Mumbai Mumbai – 400 031

For Appellant: Shri Shashank Mehta, CAFor Respondent: Ms. Kavitha Kaushik, Sr. DR

Section 147Section 148Section 151

Learned National Faceless Appeal Centre (NFAC) CIT (Appeals has erred in upholding the action of the ld. Assessing Officer of proceeding with reassessment proceedings without waiting for the statutory period of four week, after serving of order disposing of the appellant's objection on initiation of reassessment proceedings, thereby violating ... Learned National Faceless Appeal Centre (NFAC) CIT (Appeals) has erred in upholding the action of the Ld. Assessing Officer of initiating the reassessment proceedings u/s 147 merely on surmises and conjectures without being in possession of any tangible material 4. In the facts and circumstances of the case

Dy. Commissioner of Income-Tax-1(1)(1), Mumbai, Aayakar Bhawan vs. Aver Software Technologies Limited, Mumbai

ITA 4333/MUM/2024[2009-10]Status: DisposedITAT Mumbai04 Mar 2025AY 2009-10

For Appellant: Shri Ram Krishn Kedia

Section 143(1)Section 143(3)Section 147Section 148Section 24Section 250Section 69

case of the Assessee was reopened under Section 147 of the Act by issuing notice, dated 26/03/2014, under Section 148 of the Act. The reassessment proceedings culminated into passing of the Assessment Order, dated 30/03/2015 under 143(3) read with Section 147 of the Act assessing taxable income

Ankit Dilip Sethi, Aurangabad vs. ITO Ward 1(1), Aurangabad

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

ITA 2000/PUN/2024[2016-17]Status: DisposedITAT Pune03 Mar 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajiv ThakkarFor Respondent: Shri Ramnath P Murkunde - DR

Section 132Section 143(2)Section 144Section 147Section 148Section 69A

assessee that in view of the various decisions of Co-ordinate Benches of the Tribunal and Hon'ble Jurisdictional High Court, the reassessment proceedings initiated by the Assessing Officer are not in accordance with law. 8.1 We do not want to decide the appeal at present, since the assessee

Ankit Dilip Sethi, Aurangabad vs. ITO, Ward-1(1), Aurangabad

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

ITA 1999/PUN/2024[2014-15]Status: DisposedITAT Pune03 Mar 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajiv ThakkarFor Respondent: Shri Ramnath P Murkunde - DR

Section 132Section 143(2)Section 144Section 147Section 148Section 69A