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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

Smt Neha Prasanna Ghotage, Belagavi vs. Assistant Commissioner of Income Tax, Central Circle - 2, Belagavi

Appeals are DISMISSED

ITA 260/PAN/2025[2007-08]Status: DisposedITAT Panaji11 Feb 2026AY 2007-08

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

Further, we also find that, for the subsequent assessment years commencing from AY 2011-12 to AY 2015-16 reassessment proceedings in the case of the assessee vide notice issued u/s 148 of the Act were initiated and pursuant thereto a return of income for each of such assessment years ... also oblivious on records that, without the help of such or similar working staff or consultant the appellant not only represented herself in reassessment proceedings for former years but continued to file regular returns from AY 2017-18 to 2024-25 u/s 139(4)/139(1) of the Act which

Smt Neha Prasanna Ghotage, Belagavi vs. Assistant Commissioner of Income Tax, Central Circle, 2, Belagavi

Appeals are DISMISSED

ITA 259/PAN/2025[2006-07]Status: DisposedITAT Panaji11 Feb 2026AY 2006-07

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

Further, we also find that, for the subsequent assessment years commencing from AY 2011-12 to AY 2015-16 reassessment proceedings in the case of the assessee vide notice issued u/s 148 of the Act were initiated and pursuant thereto a return of income for each of such assessment years ... also oblivious on records that, without the help of such or similar working staff or consultant the appellant not only represented herself in reassessment proceedings for former years but continued to file regular returns from AY 2017-18 to 2024-25 u/s 139(4)/139(1) of the Act which

Jain Enterprises, Bhilai, Durg vs. PCIT, Raipur-1, Raipur

In the result, appeal of the assessee is dismissed as above

ITA 187/RPR/2025[2018-19]Status: DisposedITAT Raipur11 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 187/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Jain Enterprises, Vs Pr. Commissioner Of Income Tax, 87-B, Light Industrial Area, Raipur-1, Central Revenue Building, Bhilai-490026, C.G. Civil Lines, Raipur, 492001, C.G. Pan: Aagfj3469G (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri S. R. Rao, Advocate राज" की ओर से / Revenue By : Shri Ram Tiwari, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख / Date Of : 11/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2018-19 Filed By The Assessee Is Directed Against The Order Dated 24.03.2025 Of The Principal Commissioner Of Income Tax, Raipur-1 (‘Pcit’) Passed Under Section 263 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: Shri S. R. Rao, AdvocateFor Respondent: Shri Ram Tiwari, CIT-DR
Section 142(1)Section 147Section 148Section 263

order dated 27.03.2023, it is not evident that the Ld. AO has gone through various details, documents, etc. furnished by the assessee during the reassessment proceedings and carried out any enquiry/investigation/verification, which should have been made before concluding the reassessment. 14. The Hon'ble Supreme Court, in the case

ACIT Central Circle 1 Guwahati, Guwahati vs. Ds Systems Private Limited, Guwahati

In the result, appeal of the revenue is dismissed

ITA 284/GTY/2025[2016-17]Status: DisposedITAT Guwahati11 Feb 2026AY 2016-17

Bench: the Hon'ble

For Appellant: Sandeep Goel, Advocate
Section 133ASection 143(1)(a)Section 143(2)Section 147Section 148Section 151Section 250Section 69C

were disposed of through speaking order which was served to the assessee. Thereafter, detailed questionnaire was issued to the assessee. During the course of reassessment proceedings, the assessee furnished reply time to time. 3. A survey u/s 133A of the Act was conducted in the case of DS Systems ... Assessing Officer under the unamended Section 148 of the Act dated 29.06.2021 for the impugned A.Y.2016-17, is considered to be invalid and the reassessment proceedings quashed for want of valid notice issued under the amended Section 148 of the Act by the Assessing Officer.” 6. The Ld. CIT(A) further

Anil Tuteja, Fatehabad vs. Pr. Commissioner of Income Tax, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 780/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Karan Pratap Singh, Sirsa, Haryana vs. ITO, Ward-1, Sirsa, Haryana

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 761/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Munish Kumar Legal Heir Late Sh Gurdeep Singh, Vill Manakpur, Yamunanagar vs. ITO, Ward 5, Yamunanagar

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 754/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Home Construction Co, Ludhiana vs. DCIT Central Circle 1, Ludhiana

In the result, appeal of the Assessee is allowed

ITA 615/CHANDI/2025[2022-2023]Status: DisposedITAT Chandigarh11 Feb 2026AY 2022-2023

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 132Section 139(1)Section 271A

section 148 (as amended by the Finance Act, 2021) mandates prior approval from the Principal Commissioner of Income Tax (PCIT) before initiating reassessment proceedings on the basis of such material. The failure to comply with such requirement would render the assessment legally untenable." 6.3 The Ld. Counsel also relied upon

Gopal Krishan Bansal, Mandi Gobindgarh, Punjab vs. ITO Ward -1, Mandi Gobindgarh, Sirhind

In the result, appeal of the Assessee is allowed and cross appeal filed by the Revenue is dismissed

ITA 614/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh11 Feb 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 148Section 149

Kanwaljit Kaur reported in 171 taxmann 174, that the notice u/s 148, was held to be without jurisdiction and bad in law and reassessment proceedings initiated in pursuance to that was quashed. 10.1 In the present case, the chart as reproduced in the 'Brief Synopsis of the assessee as above

Income Tax Office, Ward-I Mandi Gobindgarh Hq Sirhind vs. Gopal Krishan Bansal, Aggarwal Steel Tubes

In the result, appeal of the Assessee is allowed and cross appeal filed by the Revenue is dismissed

ITA 478/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh11 Feb 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 148Section 149

Kanwaljit Kaur reported in 171 taxmann 174, that the notice u/s 148, was held to be without jurisdiction and bad in law and reassessment proceedings initiated in pursuance to that was quashed. 10.1 In the present case, the chart as reproduced in the 'Brief Synopsis of the assessee as above

Madhu Grewal, Chandigarh vs. Principal Commissioner of Income Tax, Chandigarh-1, Chandigarh

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 603/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh11 Feb 2026AY 2019-20

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Parveen Kumar, 229, Village Manakpur-II, Tehsil Jagadhri, Haryana vs. Prabhjot Kaur, PCIT Panchkula, Chandigarh

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 576/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-2019

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Maninder Jeet Singh V.P.O. Udhamgarh, Jagadhri, Haryana vs. Prabhjot Kaur, PCIT, Panchkula

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 575/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-2019
For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Ram Niwas, Fatehabad vs. Income Tax Officer, Income Tax Office, Sirsa Road, Industrial Area, Fatehabad

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 498/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Rakesh Kumar, Jagadhri vs. The Principal Commissioner of Income Tax, Panchkula

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 456/CHANDI/2024[2015-16 ]Status: DisposedITAT Chandigarh11 Feb 2026

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Ashok Kumar Thakral, Jagadhri vs. Principal Commissioner of Income Tax, Panchkula

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 455/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Feb 2026AY 2015-16

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Kartar Singh, Fatehabad vs. Pr. Commissioner of Income Tax, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 335/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Sh. Ram Lal, Fatehabad vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 332/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Bimla Devi, Jagadhri vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 328/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition

Paramjit Singh, Sirsa vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 327/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issuance of notice under section 148. 35. It was contended that despite such approval and reopening, the Assessing Officer, upon completion of the reassessment proceedings, neither disagreed with the reasons forming the basis of approval nor made any addition in the hands of the assessee and ultimately accepted the returned ... reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening, the Ld. AO conducted reassessment proceedings and examined the sole issue for which jurisdiction u/s 148 was assumed, namely the taxability of interest received u/s 28 of the Land Acquisition