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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

Integrated Core Strategies (Asia) Pte Ltd, Mumbai vs. The Deputy Commissioner of Income Tax (International Taxation)Circle 2(2)(1), Mumbai

Appeal of the assessee is partly allowed

ITA 2608/MUM/2024[2015-16]Status: DisposedITAT Mumbai14 Jan 2025AY 2015-16

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

For Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 147Section 148Section 148ASection 149Section 68Section 90

During the course of hearing, the ld. AR present the arguments with regard to Ground No.2 wherein the assessee has challenged the validity of reassessment proceedings for the reason that notice under section 148 of the Act dated 28.07.2022 is barred by limitation. 2. The assessee is a company incorporated ... notice issued in assessee's case on 28.07.2022 is beyond time limit specified under the Act. Accordingly, the ld. AR submitted that the consequent reassessment proceedings would be rendered void and liable to be quashed. The ld. AR placed reliance on the decision of the Hon'ble Supreme Court

ITO(It)-2(3)(1), Mumbai vs. Subramania Sreenivasan Ganeshnath, Mumbai

In the result, the appeal of the Revenue is dismissed in terms of paragraph 8 and 9 above

ITA 2439/MUM/2024[2017-18]Status: DisposedITAT Mumbai14 Jan 2025AY 2017-18

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Hiren CFor Respondent: Shri Swapnil Savant
Section 142(1)Section 144C(3)Section 147Section 250Section 68Section 69C

Muscat and deriving salary income. During the relevant previous year, the Assessee filed return of income on 19/05/2021 declaring income at INR.52,04,970/-. Reassessment proceedings under Section 147 of the Act were initiated in the case of the Assessee on the ground that the Assessee

Shital Dhorda, Mumbai vs. ITO-22(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 4625/MUM/2023[2012-13]Status: DisposedITAT Mumbai14 Jan 2025AY 2012-13

Bench: Shri Sandeep Gosainvs. Ito – 22(3)(3) Shital Dhorda 408, Piramal Chambers 1002, 10Th Floor, Lalbaug, Mumbai – Vibgyor, S.V. Road, 400012. Santacruz (W), Mumbai – 400054. Pan/Gir No. Ajvpd0456H (Applicant) (Respondent) Assessee By Shri Snehal Shah Revenue By Shir Vithal Machindra Bhosale, Sr. Dr सुनवाई क" तारीख/Date Of Hearing 16.12.2024 घोषणा क" तारीख/Date Of Pronouncement 14.01.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 04.07.2023, Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The Learned Commissioner Of Income Tax (Appeals) / National Faceless Appeal Centre, Delhi (‘Ld. Cit(A)’), For The Assessment Year 2012-13. The Assessee Has Raised The Following Grounds Of Appeal:

Section 131Section 132Section 143(3)Section 250

statement on oath nor the appellant has received any such "incriminating evidences" such as "pen-drive" till date on the basis of which such reassessment proceedings was initiated at any point of time during the reassessment proceedings. iii. No link between the material and the formation of belief ... some positive material to establish that income chargeable to tax has escaped assessment. The law does not permit an Assessing Officer to initiate reassessment proceedings with a view to embark upon enquiries to gather material to come to a conclusion that income has escaped assessment. The duty cast upon

Saroj Tilakraj Juneja, Surat vs. DCIT Circle-1(1)(1), Surat

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

ITA 1048/SRT/2024[2014-15]Status: DisposedITAT Surat13 Jan 2025AY 2014-15

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1048/Srt/2024 Assessment Year: (2014-15) (Physical Hearing) Saroj Tilakraj Juneja, Vs. The Dcit, 3, Subhas Nagar Society, Ghod Dod Road, Circle - 1(1)(1), Surat - 395007 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abbpj5634M (Appellant) (Respondent) Appellant By Shri Kiran K. Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 08/01/2025 Date Of Pronouncement 13/01/2025

Section 147Section 148Section 250Section 253(3)Section 253(5)Section 69

ground of delay. ITA No.1048/SRT/2024/AY.2014-15 Saroj Tilakraj Juneja 3. the learned CIT(A) grossly erred in not appreciating the ground regarding stay of reassessment proceedings by the Hon’ble Gujarat High Court for this particular year. 4. The appellant reserves right to add, alter and withdraw any grounds of appeal

Anish Garg, Patiala vs. ITO Ward-4, Patiala

In the result, the appeal of the assessee is allowed

ITA 739/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh13 Jan 2025AY 2012-13
For Appellant: Shri Rajiv Saldi, C.AFor Respondent: Shri Vivek Vardhan, Addl.CIT
Section 133ASection 142(1)Section 143(3)Section 147Section 148Section 151Section 250(4)

hereby set-aside as the same doesn't satisfy the conditions so specified u/s 147 r/w 149 of the Act. 17. Consequently, reassessment proceedings are also liable to be set-aside and the other grounds raised on merits of the additions have therefore become academic and are dismissed as infructious

Mustasq Ahmad, Chennai vs. ITO, Intl Tax Ward 1(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 1351/CHNY/2023[2013-14]Status: DisposedITAT Chennai13 Jan 2025AY 2013-14

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.1351/Chny/2023 िनधा"रण वष"/Assessment Year: 2013-2014. Mustaq Ahmad, The Income Tax Officer, No.160, Mustafa Centre, Vs. International Taxation, Usman Road, Ward 1(1) T. Nagar, Chennai. Chennai 600 017. Pan: Adepa 1181B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Lekha, C.A, ""यथ" क" ओर से/Respondent By : Mr. Nilay Baran Som, Cit. सुनवाई क" तारीख/Date Of Hearing : 30.10.2024 घोषणा क" तारीख/Date Of Pronouncement : 13.01.2025 आदेश /O R D E R Per Manu Kumar Giri () This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (A), Chennai-16 [‘Cit(A)’ Short] Dated 27.09.2023 For Assessment Year 2013-14. 2. In This Appeal, The Assessee Has Raised Five (5) Grounds Of Appeal. However, The Counsel For The Assessee Has Vehemently Pressed A Ground No.2 That There Was No Fresh Material On Which The Ao Has Issued Notice Dated 31.03.2021 U/S 148 Of The Income Tax Act, 1961 (‘Act’ In Short). G.No.2 Is As Under: ‘’2. At The Outset, The Ao Has No Jurisdiction To Reopen The Assessment, As All The Material Facts Were With The Ao Even At The Time Of Completing The Original Assessment & There Was No Fresh Material On Which The Ao Has Issued Notice. The Notice Issued By The Ao U/S.148 Of The Act Is Ab Initio Void & On This Ground Alone The Reassessment Deserves To Be Cancelled’’.

For Appellant: Ms. Lekha, C.AFor Respondent: Mr. Nilay Baran Som, CIT
Section 143(3)Section 147Section 148Section 2(22)(e)

truly, the jurisdictional condition has not been satisfied by the AO. Failure to disclose all material facts were not mentioned anywhere in the reassessment proceedings and therefore, held to be invalid. It is necessary for the AO to first state that there is a failure to disclose fully and truly ... tangible material evidence to initiate the re-assessment proceedings. Had there been any material evidence, which prompted the assessing officer to initiate reassessment proceedings, he ought to have atleast indicated it in the order of reassessment proceedings. But the re-assessment proceedings was concluded only on the basis

Janak Texturisers Pvt Ltd, Mumbai vs. Income Tax Officer, Ward 4(2)(1), Mumbai

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

ITA 472/MUM/2024[2010-11]Status: DisposedITAT Mumbai13 Jan 2025AY 2010-11

Bench: Smt. Beena Pillaiassessment Year: 2010-11

For Appellant: Shri G.P. Mehta, Ld. A.RFor Respondent: Ms. Kavitha Kaushik, Ld. Sr. D.R
Section 142(1)Section 148Section 24Section 3

notice u/s 148 of the Act on 31.03.2017. 2.1. In response to the notice, assessee filed its reply on 28.04.2017 requesting to drop the reassessment proceedings, however, no return of income was filed in response to the notice u/s 148 of the Act. 2.2. Subsequently, notice ... notice issued. Summon u/s 3 M/s. Janak Texturisers Pvt. Ltd. 131 of the Act was issued calling upon the assessee to appear for the reassessment proceedings. Subsequently, one more letter was issued asking upon assessee to furnish the details as called for. In compliance, assessee vide letter dated 12.12.2017 filed

Siddharth Suryakant Deshmukh, Mumbai vs. Income Tax Officer 4(2)(1), Mumbai

ITA 3318/MUM/2024[2011-12]Status: DisposedITAT Mumbai13 Jan 2025AY 2011-12

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

For Appellant: Shri Ashish A. ThakurdesaiFor Respondent: Shri Kiran Unavekar
Section 144Section 147Section 148Section 234ASection 250Section 69

Assessment Year 2011-12.Since the Assessee had made deposits exceeding INR.2,00,000/- with the banking company and had entered into transactions at commodity exchange, reassessment proceedings were initiated against the Assessee under Section 147 of the Act by issuance of Notice Under Section 148 of the Act on 15/03/2018. Since ... case. As was the case for Assessment Year 2012-13, the Assessee had failed to file return of income and participate in the reassessment proceedings for the Assessment Year 2011-2012. We note that notice under Section 148 of the Act was issued on 15/03/2018 and the assessment was framed

Davos International Fund, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-2(1)(1), Mumbai

Appeal of the assessee is partly allowed

ITA 1190/MUM/2024[2018-19]Status: DisposedITAT Mumbai13 Jan 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

For Appellant: Shri Vijay Mehta / Shri DhavalFor Respondent: Shri Krishna Kumar, Sr. DR
Section 132Section 147Section 148Section 148ASection 149Section 149(1)Section 151Section 68

assessee also raised the following additional ground of appeal, raising legal contentions with regard to notice issued u/s. 148. “1. The initiation of reassessment proceedings by the Assessing Officer is illegal and bad in law in as much as the approval of the PCCIT has not been obtained as required

Railroad Logistics India Pvt. Ltd., Mumbai vs. Pr Commissioner of Income Tax-3, Mumbai

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

ITA 2564/MUM/2023[2012-2013]Status: DisposedITAT Mumbai13 Jan 2025AY 2012-2013

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Girish Agarwal, Am Railroad Logistics India Pvt. Ltd. The Principal Commissioner Of C/O Metal Trim, Gala No.1, Tankiwala Income Tax Pcit, Mumbai-3 Room No. 612, 6Th Floor, Aayakar Indl. Estate, Steel Made Compound, Marol Vs. Maroshi Road, Marol, Andheri (E) , Bhavan, Maharishi Karve Road, Mumbai – 400 059. Mumbai-400020 Pan/Gir No. Aaccr3484J (Assessee) : (Respondent) Assessee By : Shri. Satish R. Mody Respondent By : Shri. Tushar Mohite Sr. Ar Date Of Hearing : 18.10.2024 Date Of Pronouncement : 13.01.2025 O R D E R Per Kavitha Rajagopal, J M:

For Appellant: Shri. Satish R. ModyFor Respondent: Shri. Tushar Mohite Sr. AR
Section 143(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 263

PCIT invoked the revisionary powers u/s. 263 of the Act for the reason that since the assessee was non compliant during the reassessment proceedings the ld. AO ought to have added the entire unexplained expenditure amounting to Rs. 5,85,10,996/- as bogus transaction and also interest u/s. 234A ... other hand controverted the said fact and contended that the assessee has failed to furnish any documentary evidences before the ld. AO in the reassessment proceeding, in failure of which the ld. DR stated that the ld. PCIT was right in invoking the revisionary powers

J. P. Marketing Mehsana, Mehsana vs. The ITO, Ward-1, Mehsana

ITA 985/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad10 Jan 2025AY 2014-15

Bench: Smt.Annapurna Gupta & Ms. Suchitra Raghunath Kamble

For Appellant: Shri S.N. Divetia, andFor Respondent: Shri Sudhendu Das, CIT-DR
Section 147Section 250(6)

आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ ‘D' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT

The Asstt. Commissioner of Income Tax, Central Circle-1(2), Ahmedabad vs. Shri Kailash Ramavatar Goenka, Ahmedabad

ITA 67/AHD/2023[2019-20]Status: DisposedITAT Ahmedabad10 Jan 2025AY 2019-20

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

For Appellant: Shri Tushar Hemani, Sr.Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 132Section 153A

highlighted those entities within the group, such as Sujan Infrastructure Pvt. Ltd. and Sankalp Inn, had already offered the relevant unaccounted income during reassessment proceedings. Thus, taxing the same amount in the hands of the assessee individually would result in double taxation, which is impermissible under the law. In response

Sadbhav Engineering Ltd., Ahmedabad vs. DCIT, Central Circle 1(3), Ahmedabad

ITA 235/AHD/2021[2018-19]Status: DisposedITAT Ahmedabad10 Jan 2025AY 2018-19

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarsr. No. Appellant Respondent 1-7 It(Ss)A.No./ Asstt.Year 170 To 175 & 235/Ahd/2021 Asst. Year 2012- 13 To 2018-19 Sadbhav Engineering Ltd. Nr. Havmour Restaurant Navrangpura Ahmedbad. Dcit, Cent.Cir.1(3) Ahmedabad. 8-14 183 To 189/Ahd/2021 Asst. Year 2012- 14 To 2018-19 Pan : Aadcs 0852 Q Dcit, Cent.Cir.1(3) Ahmedabad. Sadbhav Engineering Ltd. Nr. Havmour Restaurant Navrangpura Ahmedabad. (Applicant) (Responent) Assessee By Shri Dhinal Shah, Ar Revenue By: Shri H. Phani Raju, Cit-Dr सुनवाई की तारीख /Date Of Hearing : 18/10/2024 घोषणा की तारीख / Date Of Pronouncement: 10/01/2025 आदेश/Order Per Bench: The Above Cross-Appeals Of The Assessee & The Revenue Are Against The Consolidated Order Of The Ld. Commissioner Of Income Tax(Appeals) 11, Ahmedabad All Dated 04.08.2021 Passed Under Section 250(6) Of The Income Tax Act, 1961 (“The Act" For Short) For The

For Respondent: Shri H. Phani Raju, CIT-DR
Section 115BSection 132Section 139(1)Section 143(3)Section 153ASection 250(6)Section 69ASection 80I

आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ 'A' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT

Minal Shroff, Rs Puram Tamilnadu vs. ITO, Non Corp Ward -2(3), Coimbatore

ITA 2424/CHNY/2024[2014-15]Status: DisposedITAT Chennai10 Jan 2025AY 2014-15
For Appellant: Mr.S.K.Tulsiyan, AdvocateFor Respondent: Ms.T.M.Suganthamala
Section 143(2)Section 143(3)Section 147Section 148Section 2(40)

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH: CHENNΑΙ श्री एबी टी. वर्की, न्यायिक

Income Tax Officer-28(3)(1), Mumbai, Vashi vs. Shekhar Shivaji Desai, Navi Mumbai

In the result, the appeal filed by the Revenue is dismissed

ITA 3986/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Jan 2025AY 2014-15

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhanassessment Year : 2014-15 Income Tax Officer-28(3)(1), Shekhar Shivaji Desai, Room No. 316, 301, C 37 1, Shiv Kurpa Building, Tower No. 6, 3Rd Floor, Vs. Sector-20, Nerul Gaon, Vashi Railway Station, Navi Mumbai. Navi Mumbai. Pan : Ajipd4083F (Appellant) (Respondent)

For Appellant: Shri Prakash JhunjhunwalaFor Respondent: Shri Pushkaraj Bhangepatil, Addl.CIT
Section 10(38)Section 144Section 147Section 148Section 2Section 68

addition on the basis of report given by the Investigation Wing. We noticed earlier that the impugned assessment proceeding is the second round of reassessment proceedings. The AO had already assessed the income of the assessee in the first reassessment, wherein he had conducted enquiries with regard to share transactions ... surrendering the membership license on 31-07-2015. The AO had also examined the ledger account copies and global reports in the first reassessment proceedings. The AO had also examined the bank accounts of the assessee and assessed the entire credits found in the bank account, which was Rs.25

Pehal, Chhatarpur vs. ITO (Exemption), Gwalior

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

ITA 46/AGR/2024[2010-11]Status: DisposedITAT Agra09 Jan 2025AY 2010-11

Bench: SHRI RAMIT KOCHAR (Accountant Member)

For Appellant: Sh. Sanjay Parekh, CAFor Respondent: Sh. Shailendra Srivastava, Sr. DR
Section 11Section 11(1)(a)Section 12ASection 12A(2)Section 143(3)Section 144Section 147Section 148Section 250

file the requisite details/documents to support his contentions. The assessee also did not comply with the notices issued by the Assessing Officer during reassessment proceedings. Thus, the assessee is equally responsible for its woes. Under these circumstances and fairness to both the parties, in the interest of justice, the appellate

Income Tax Officer, Chennai vs. Sanguine Media Limited, Chennai

The appeal stand allowed for statistical purposes

ITA 480/CHNY/2024[2011]Status: DisposedITAT Chennai09 Jan 2025

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.1594/Chny/2023 (िनधा9रण वष9 / Assessment Year: 2011-12) M/S. Sanguine Media Limited Ito बनाम/ Plot No.135A, 1St Floor, Non-Corporate Ward-20(5) Chandran Nagar Main Road, Chennai Vs. Chrompet, Chennai-600 044. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecs-2217-C (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.480/Chny/2024 (िनधा9रण वष9 / Assessment Year: 2011-12) Ito M/S. Sanguine Media Limited बनाम/ Plot No.135A, 1St Floor, Non-Corporate Ward-10(6) Chennai Chandran Nagar Main Road, Vs. Chrompet, Chennai-600 044. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecs-2217-C (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri Neeraj Mangla (Ca) (Virtual)- Ld.Ar " थ" की ओर से/Revenue By : Shri Nilay Baran Som (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 10-12-2024 घोषणा की तारीख /Date Of Pronouncement : 09-01-2025 आदेश / O R D E R

For Appellant: Shri Neeraj Mangla (CA) (Virtual)- Ld.ARFor Respondent: Shri Nilay Baran Som (CIT)-Ld. DR
Section 147Section 271(1)(c)Section 68

perusal of case records, our adjudication would be as under. Proceedings before lower authorities 2.1 The assessee being resident corporate assessee was subjected to reassessment proceedings and an assessment was framed u/s 147 r.w.s. 143(3) on 26.12.2018. In the assessment order, Ld. AO made certain addition

Sanguine Media Limited, Chennai vs. ITO, Chennai

The appeal stand allowed for statistical purposes

ITA 1594/CHNY/2023[2011-12]Status: DisposedITAT Chennai09 Jan 2025AY 2011-12

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.1594/Chny/2023 (िनधा9रण वष9 / Assessment Year: 2011-12) M/S. Sanguine Media Limited Ito बनाम/ Plot No.135A, 1St Floor, Non-Corporate Ward-20(5) Chandran Nagar Main Road, Chennai Vs. Chrompet, Chennai-600 044. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecs-2217-C (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.480/Chny/2024 (िनधा9रण वष9 / Assessment Year: 2011-12) Ito M/S. Sanguine Media Limited बनाम/ Plot No.135A, 1St Floor, Non-Corporate Ward-10(6) Chennai Chandran Nagar Main Road, Vs. Chrompet, Chennai-600 044. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecs-2217-C (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri Neeraj Mangla (Ca) (Virtual)- Ld.Ar " थ" की ओर से/Revenue By : Shri Nilay Baran Som (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 10-12-2024 घोषणा की तारीख /Date Of Pronouncement : 09-01-2025 आदेश / O R D E R

For Appellant: Shri Neeraj Mangla (CA) (Virtual)- Ld.ARFor Respondent: Shri Nilay Baran Som (CIT)-Ld. DR
Section 147Section 271(1)(c)Section 68

perusal of case records, our adjudication would be as under. Proceedings before lower authorities 2.1 The assessee being resident corporate assessee was subjected to reassessment proceedings and an assessment was framed u/s 147 r.w.s. 143(3) on 26.12.2018. In the assessment order, Ld. AO made certain addition

Hewlett-Packard (India) Software Operation Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-(1)(1), Bangalore

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

ITA 405/BANG/2024[2014-15]Status: DisposedITAT Bangalore09 Jan 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2014-15

For Appellant: Sri P.C. Kincha, A.RFor Respondent: Sri A. Sreenivasa Rao, D.R
Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 250Section 92C

return of income and disclosed fully and truly all material materials necessary for the assessment. c) The issues which are raised during the reassessment proceedings were already examined during the regular assessment proceedings u/s 143(3) of the Act and hence this is merely a change of opinion. 3.3 Thereafter ... after considering the submission against the various notices issued by the AO during the reassessment proceedings and considering the requisite clarification and Hewlett-Packard (India) Software Operation Pvt. Ltd., Bangalore Page 7 of 19 explanation, the AO/NFAC passed an order dated 25.3.2022 served on 29.3.2022 u/s 147 r.w.s. 144B

Ari Healthcare Pvt Ltd, Pune vs. DCIT CC-2(2), Mumbai

In the result, appeals are allowed as indicated above

ITA 6079/MUM/2024[2021-22]Status: DisposedITAT Mumbai09 Jan 2025AY 2021-22

Bench: Shri Saktijit Dey, V.P. & Smt Renu Jauhri, A.M. A.Y.2022-23 A.Y.2021-22

accepting assessee’s claim of market development expenses. Therefore, principle of consistency would have been maintained by following the position taken in the reassessment proceedings for A.Ys 2019-20 and 2020-21 rather than following the non-existent orders of the First Appellate Authority in A.Ys