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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

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

In the result, the captioned appeals by the revenue are dismissed and the cross-objections filed by the assessee are allowed

ITA 3164/MUM/2023[2013-14]Status: DisposedITAT Mumbai05 Feb 2025AY 2013-14

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

For Appellant: Shri Rakesh Joshi, A/RFor Respondent: Shri Mahesh Akhade, CIT D/R
Section 1Section 115JSection 143(3)Section 147Section 148Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

light of Rule 18(6) of the ITAT Rules, 1963. 6. Vide notice dated 26/03/2021 issued u/s 148 of the Act, the AO initiated reassessment proceedings. The reasons for reopening are as under:- “In this case, return of income was filed on 28.09.2013 declaring total income

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

In the result, the captioned appeals by the revenue are dismissed and the cross-objections filed by the assessee are allowed

ITA 3161/MUM/2023[2014-15]Status: DisposedITAT Mumbai05 Feb 2025AY 2014-15

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

For Appellant: Shri Rakesh Joshi, A/RFor Respondent: Shri Mahesh Akhade, CIT D/R
Section 1Section 115JSection 143(3)Section 147Section 148Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

light of Rule 18(6) of the ITAT Rules, 1963. 6. Vide notice dated 26/03/2021 issued u/s 148 of the Act, the AO initiated reassessment proceedings. The reasons for reopening are as under:- “In this case, return of income was filed on 28.09.2013 declaring total income

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

In the result, the captioned appeals by the revenue are dismissed and the cross-objections filed by the assessee are allowed

ITA 3157/MUM/2023[2017-18]Status: DisposedITAT Mumbai05 Feb 2025AY 2017-18

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

For Appellant: Shri Rakesh Joshi, A/RFor Respondent: Shri Mahesh Akhade, CIT D/R
Section 1Section 115JSection 143(3)Section 147Section 148Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

light of Rule 18(6) of the ITAT Rules, 1963. 6. Vide notice dated 26/03/2021 issued u/s 148 of the Act, the AO initiated reassessment proceedings. The reasons for reopening are as under:- “In this case, return of income was filed on 28.09.2013 declaring total income

Ravi Kumar, Hyderabad vs. Income Tax Officer, Ward 4(4), Hyderabad

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

ITA 167/HYD/2024[2011-12]Status: DisposedITAT Hyderabad04 Feb 2025AY 2011-12

Bench: Shri Laliet Kumar & Shri Manjunatha G.आ.अपी.सं /Ita No.167/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2011-12) Ravi Kumar Vs. Income Tax Officer Hyderabad Ward-4(4) [Pan : Adopk6597R] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri A.Srinivas, Ar रधजस् व द्वधरध/Revenue By: Dr.Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 20/01/2025 घोर्णध की तधरीख/Date Of 04/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.01.2024 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre (Nfac), Delhi, Pertaining To A.Y.2011-12. 2. The Brief Facts Of The Case Are That, The Assessee, An Individual Entered Into A Development Agreement Cum General Power Of Attorney Vide Document Number 560/2011 Dated 24.03.2011 With M/S Gayathri Construction Company For Joint Development Of A Property. The Assessee Had Not Disclosed The Transaction In His Return Of Income. Therefore, The Assessment

For Appellant: Shri A.Srinivas, ARFor Respondent: Dr.Sachin Kumar, DR
Section 147Section 148Section 54F

neither the Assessing Officer nor the Ld.CIT(A) examined the eligibility of the assessee to claim deduction u/s 54F of the Act in the reassessment proceedings and further, none of the authorities below have examined the fact with regard to one of the conditions for claiming deduction

Madhucon Projects Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-2(1), Hyderabad

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

ITA 762/HYD/2020[2014-15]Status: DisposedITAT Hyderabad04 Feb 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

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

Madhucon Projects Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-2(1), Hyderabad

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

ITA 761/HYD/2020[2013-14]Status: DisposedITAT Hyderabad04 Feb 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

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

ACIT Central Circle-2(1), Hyderabad vs. Madhucon Projects Limited, Hyderabad

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

ITA 723/HYD/2020[2013-14]Status: DisposedITAT Hyderabad04 Feb 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

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

Asst. Commissioner of Income Tax, Central Circle-2(1), Hyderabad vs. Madhucon Projects Limited, Hyderabad

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

ITA 13/HYD/2020[2010-11]Status: DisposedITAT Hyderabad04 Feb 2025AY 2010-11

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

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

Asst. Commissioner of Income Tax, Central Circle-2(1), Hyderabad vs. Madhucon Projects Limited, Hyderabad

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

ITA 12/HYD/2020[2009-10]Status: DisposedITAT Hyderabad04 Feb 2025AY 2009-10

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

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

Madhucon Projects Limited, Hyderabad vs. DCIT, Central Circle-3, Hyd, Hyderabad

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

ITA 1328/HYD/2017[2008-09]Status: DisposedITAT Hyderabad04 Feb 2025AY 2008-09

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

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

M/S. Shroff Properties Pvt. Ltd., Kolkata vs. I.T.O., Ward - 1(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1951/KOL/2024[2010-2011]Status: DisposedITAT Kolkata04 Feb 2025AY 2010-2011

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1951/Kol/2024 Assessment Year : 2010-11

For Appellant: Shri Abhishek Bansal, ARFor Respondent: Shri Kapil Mondal, Addl. CIT
Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

about some accommodation entry received by the assessee from M/s. Canary Tradecom Pvt. Ltd. which is alleged to be a Jama Kharchi Company. The reassessment proceedings were carried out after issuance of notice u/s.148 of the Act and after validly serving of notices u/s.143(2)/142 ... During the course of reassessment proceedings, assessee stated that the alleged sum received from M/s. Canary Tradecom Pvt. Ltd. had already been returned on the very same day for purchasing Equity Shares. Evidence and support thereof was also furnished. Ld. AO was not satisfied and concluded the assessment making addition

Natthi Singh, Dehtora vs. Income Tax Officer, Ward

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

ITA 196/AGR/2023[2010-11]Status: DisposedITAT Agra03 Feb 2025AY 2010-11

Bench: Shri M. Balaganesh(Through Virtual Hearing) Natthi Singh, Vs. Ito, Mohhamadpur, Dehtora, Up Ward (Appellant) (Respondent) Pan: Jfqps8274N Assessee By : None Revenue By: Shri Shailendra Srivastava, Sr. Dr Date Of Hearing 03/02/2025 Date Of Pronouncement 03/02/2025

For Appellant: NoneFor Respondent: Shri Shailendra Srivastava, Sr. DR
Section 144Section 148Section 292B

assessment order and had also stated that the authorized representative of the assessee had indeed cooperated and participated in the reassessment proceedings and hence the objection of the assessee was dismissed. In our considered opinion, this is not the proper way of disposing of the ground. The assumption of jurisdiction

Lalita Ramesh Jain, Pune vs. Income Tax Officer, Pradhikaran Pune

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

ITA 1876/PUN/2024[2010-11]Status: DisposedITAT Pune03 Feb 2025AY 2010-11

Bench: SHRI MANISH BORAD (Accountant Member)

For Appellant: NoneFor Respondent: Shri Sanjay Dhivare
Section 147Section 148Section 68Section 69

information about the transaction of immovable property in the name of the assessee, the assessee was served with the notice u/s 148 and thereafter reassessment proceedings u/s 147 r.w.s. 143(3) were carried out. Ld. Assessing Officer noticed that during the year assessee had made investments for purchase of immovable ... credits including cash deposits amounting to Rs.5,43,000/-. The assessee furnished certain 3 details but failed to satisfy the Assessing Officer and the reassessment proceedings were concluded fastening addition of Rs.33,09,800/- to the income declared by the assessee at Rs.1,81,890/- in the return of income

Manju Devi Daftari, Kolkata vs. I.T.O., Ward - 36(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1571/KOL/2024[2011-2012]Status: DisposedITAT Kolkata03 Feb 2025AY 2011-2012

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1571/Kol/2024 Assessment Year : 2011-12

For Appellant: Shri Sunil Surana, ARFor Respondent: 26.11.2024
Section 143(1)Section 144Section 147Section 148Section 250

alleged to a penny stock company in the Writ filed before the Hon’ble Bombay High Court and Hon’ble Court has quashed the reassessment proceedings and the same was subsequently followed by the Tribunal in the case of Tanuj Properties Pvt. Ltd. Vs. ITO (supra) dealing with the very ... Tribunal decided the issue in favour of the assessee holding that the notice u/s.148 of the Act was bad in law and reassessment proceedings deserves to be quashed. 9. Respectfully following the judgment of Hon’ble Bombay High Court in the case of South Yarra Holdings (supra) and the consistent

Ms. Natasha Chopra, Delhi vs. DCIT, Circle-16(1), Delhi

In the result, the appeal of the Assessee for assessment year 2016-17

ITA 2292/DEL/2024[2020-21]Status: HeardITAT Delhi03 Feb 2025AY 2020-21

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri V. K. Agarwal, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 131Section 133Section 143(1)Section 147Section 148Section 68

reopening the assessment was based on incorrect facts recorded by the Learned AO in the reasons. Accordingly, the Assessee prayed for dropping of the reassessment proceedings per se. However, the Learned AO did not heed to this contention of the Assessee and proceeded to frame the reassessment by adding ... terms of section 151 of the Act, though sought for, was not provided to the Assessee. Accordingly, the learned AR pleaded that the reassessment proceedings should be treated as void ab initio. 5. As regards the amount received in the sum of Rs 1.90 crores towards share capital from Sridhar

Vandna Gandhi, Patna vs. ACIT, Cir-5, Patna

The appeal of the assessee is allowed for statistical purposes

ITA 431/PAT/2024[2001-02]Status: DisposedITAT Patna31 Jan 2025AY 2001-02

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.431/Pat/2024 Assessment Year: 2001-02 Vandna Gandhi………………….....…..…………………....Appellant W/O Sri Azad Gandhi Kila Road, Patna City, Patna- 800008. [Pan: Ainpg4871E] Vs. Acit, Circle-5, Patna…….….…….…............................…..…..... Respondent Appearances By: Shri Mahindra Chowdhary, Advocate Appeared On Behalf Of The Appellant. Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 30, 2025 Date Of Pronouncing The Order : January 31, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 22.05.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Was Partner In The Firm Namely M/S Raj Construction With 5.43% Share. At The Time Of Firm’S Assessment For The Assessment Year 2001-02, It Was Noted That The Capital Introduced By The Assessee Was Rs.5,00,000/-. This Was The First Year Of The Firm’S Existence Since The Source Of The Capital Introduced Was Not Properly Explained, Therefore, The Assessing Officer Treated The Same As Unexplained Income Of The Firm U/S 68 Of The Act. Based On The Information, The Reassessment Proceedings Were Initiated

Section 142(1)Section 147Section 148Section 250Section 68

explained, therefore, the Assessing Officer treated the same as unexplained income of the firm u/s 68 of the Act. Based on the information, the reassessment proceedings were initiated I.T.A. No.431/Pat/2024 Assessment Year: 2001-02 Vandna Gandhi u/s 147 of the Act by issuing a notice u/s 148 to the assessee

The DCIT, Circle-4(1) (1), Ahmedabad vs. M/S. Shah Foils Pvt. Ltd., Ahmedabad

Appeal is partly allowed and the Revenue’s appeal is dismissed

ITA 1922/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 Jan 2025AY 2011-12

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar1. आयकर अपील सं /Ita No.1852/Ahd/2019 2. आयकर अपील सं /Ita No.1922/Ahd/2019 िनधा"रण वष" /Assessment Year : 2011-12 1. M/S.Shah Foils Ltd. 1. The Ito, Ward-4(1)(3) बनाम/ 26, Block-B, Galaxy Ahmedabad-380 015 V/S. Signature, Science City Rd Sola, Ahmedabad-380 060 2. The Ito, 2. M/S.Shah Foils Ltd. Ward-4(1)(3) 26, Block-B, Galaxy Ahmedabad-380 015 Signature, Science City Rd Sola, Ahmedabad-380 060 "थायी लेखा सं./Pan: Aaics 0490 F (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri K.C. Thaker, Ar Revenue By : Shri A.P. Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 28/01/2025 घोषणा की तारीख /Date Of Pronouncement: 31/01/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: These Cross-Appeals By The Assessee & The Revenue Are Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad [Hereinafter Referred To As “Cit(A)”], Dated 23.10.2019, Arising Out Of The Assessment Order Dated 29.12.2017 Passed Under Section 143(3) Read

For Appellant: Shri K.C. Thaker, ARFor Respondent: Shri A.P. Singh, CIT-DR
Section 143(1)Section 143(3)Section 147Section 69A

when the assessee has failed to demonstrate that corresponding purchases were accounted for against the unaccounted sales made. Ground relating to challenging the reassessment proceedings u/s 147 of the Act: 5. Based on incriminating evidence obtained during the search, the DGCEI concluded that M/s. Shah Foils Ltd. had made unaccounted ... assessee’s submissions and correspondence with the AO (letter dated 28.08.2017). It was concluded that the assessee had NOT formally objected to the reassessment proceedings but instead filed submissions on merits of the case. The CIT(A) observed that the AO had relied on multiple pieces of evidence, including seized

M/S. Shah Foils Ltd., Ahmedabad vs. The ITO, Ward-4(1)(3), Ahmedabad

Appeal is partly allowed and the

ITA 1852/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 Jan 2025AY 2011-12
For Appellant: Shri K.C. Thaker, ARFor Respondent: Shri A.P. Singh, CIT-DR
Section 143(1)Section 143(3)Section 147Section 69A

when the assessee has failed to demonstrate that corresponding purchases were accounted for against the unaccounted sales made. Ground relating to challenging the reassessment proceedings u/s 147 of the Act: 5. Based on incriminating evidence obtained during the search, the DGCEI concluded that M/s. Shah Foils Ltd. had made unaccounted ... assessee's submissions and correspondence with the AO (letter dated 28.08.2017). It was concluded that the assessee had NOT formally objected to the reassessment proceedings but instead filed submissions on merits of the case. The CIT(A) observed that the AO had relied on multiple pieces of evidence, including seized

Pixel Commercial Pvt. Ltd., Kolkata vs. I.T.O., Ward - 9(3), Kolkata

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

ITA 1601/KOL/2024[2009-2010]Status: DisposedITAT Kolkata31 Jan 2025AY 2009-2010

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1601/Kol/2024 Assessment Year : 2009-10

For Appellant: Shri Amit Agrawal, AdvFor Respondent: Smt. Madhumita Das, Addl. CIT
Section 143(2)Section 143(3)Section 147Section 148Section 250Section 69

initio. 3. That the Ld. Commissioner of Income Tax (Appeals), erred in partly dismissing the appeal of the Assessee although the initiation of reassessment proceedings, in the case of the Appellant Assessee, by issue of Notice u/s 148 of the Act and continuation of the same culminating into the impugned ... assessee has raised as many as Nine grounds of which Grounds of appeal No.1 to 6 have been raised challenging the validity of reassessment proceedings. Grounds of Appeal No. 7 and 8 are against addition u/s.69 of the Act at Rs.8.00 lakh made by the AO and affirmed

M/S. Rosewood Mercantile Pvt. Ltd.., Kolkata vs. I.T.O., Ward-3(2), Kolkata

In the result, the appeals of the assessee are allowed

ITA 582/KOL/2022[2010-2011]Status: DisposedITAT Kolkata31 Jan 2025AY 2010-2011

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri C. Roy, ARFor Respondent: Shri Praveen Kishore, CIT DR
Section 133(6)Section 143(1)Section 147Section 263

tune of ₹44,50,000/- and share premium ₹ 10,44,00,000/- by issue of equity shares. The PCIT also noticed that during the reassessment proceedings, the ld. AO issued notice u/s 133(6) of the Act to the 9 out of 20 subscribers and completed the assessment vide order