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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

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Avinash Singla, Khanna

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

ITA 814/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh06 Jan 2025AY 2013-14
For Appellant: Sh. Rohit Kapoor, Advocate andFor Respondent: Smt. Kusum Bansal, CIT DR
Section 249Section 253Section 3Section 5

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

Nandi Sahakari Sakkare Karkhane Niyamit, Vijayapur vs. Income Tax Officer Appeal, Vijayapur

In the result, appeal filed by the assessee is allowed

ITA 447/BANG/2024[2013-14]Status: DisposedITAT Bangalore06 Jan 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2013-14

For Appellant: Sri. Chetan V Chougale & Sri Praveen P Ghali, CAFor Respondent: Sri. A. Sreenivasa Rao, CIT - DR
Section 115JSection 132ASection 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

furnish the names of the parties to whom sugar and other byproducts is sold along with invoice if needed. 3.3 During the course of reassessment proceedings, the following observations are made by the AO: i. The assessee could not reconcile the payments received from M/s. Renuka Mata Multi State Urban ... total income of the assessee at Rs. 9,02,82,885/- Before us, the counsel for the assessee challenged the initiation of the reassessment proceeding u/s. 147 on the ground that notice u/s. 148 of the Act dated 31.03.2021 is barred by limitation due to the fact that the regular

Pallavi Pal, Noida vs. Ward 5(2)(1), Noida, Aayakar Bhawan, Gautam Budh Nagar

Accordingly, Revenue’s appeal in this case is dismissed

ITA 4657/DEL/2024[2012-13]Status: DisposedITAT Delhi06 Jan 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayita No.4657/Del/2019 (Assessment Year 2008-09) Income Tax Officer, Shri Vijay Shankar Ward-66(4), Bajpai, New Delhi. Vs. 104, Riico Ind. Area, School Of Aeronautics Delhi Jaipur Highway, Neemrana, Rajsthan-301705. Pan-Aeppb6550D (Appellant) (Respondent) Assessee By Shri Rahul Bardia, Ca Department By Ms. Harpreet Kaur, Sr. Dr Date Of Hearing 19/08/2025 Date Of Pronouncement 25/08/2025

Section 147Section 148Section 253(2)Section 271Section 271(1)(c)

conclusion that since no proper service of notice had been effected under Section 148 (1) of the Act on the Assessee, the reassessment proceedings were liable to be quashed. Consequently, the question framed is answered in the affirmative, le, in favour of the Assessee and against the Revenue. 6.1.8 Further ... above appeal has been adjudicated by the undersigned in appeal No. 10572/2016-17 dated 19.03.2019 wherein the reassessment proceedings u/s 147 initiated by the appellant have been held to be vitiated, void ab initio and bad in law and have been quashed. 6.1.1 Considering the factual matrix of the case

Horizon Dwellings Private Limited, Bareilly vs. PCIT, Bareilly

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

ITA 77/LKW/2022[2017-2018]Status: DisposedITAT Lucknow06 Jan 2025AY 2017-2018

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriahorizon Dwellings Pvt Ltd V. Pcit, Bareilly, Navjeevan Appartments, Income Tax Department, Opposite Parag Factory, Bareilly (Up)-243001. Badaun Road, Kargaina, Bareilly-243001. Pan:Aacch6839F (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Adv. Respondent By: Shri Sunil Kumar Rajwanshi, Addl. Cit(Dr) O R D E R

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Sunil Kumar Rajwanshi, Addl
Section 143(3)Section 263

taxmann.com 799 (SC) Where Assessing Officer after making due enquiries found assesee’s claim for exemption of income as correct and, thus, dropped reassessment proceedings, since view taken by him was one of possible views, impugned revisional order passed under section 263 was to be set aside CIT Vs. Honda

Shri Chetan Sharma, Kanpur vs. Principal Commissioner of Income Tax (Central), Kanpur

The appeal of the assessee stands partly allowed for statistical purposes

ITA 344/LKW/2019[2015-16]Status: DisposedITAT Lucknow06 Jan 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Hari Singh Chouhan V. The Income Tax Officer 3(5) 1, Naramau Kanpur Kanpur Nagar (U.P) Tan/Pan:Askpc3749A (Appellant) (Respondent) Appellant By: Srhi Rakesh Garg, Advocate Respondent By: Shri Sunil Kumar Rajwanshi, D.R. O R D E R

For Appellant: Srhi Rakesh Garg, AdvocateFor Respondent: Shri Sunil Kumar Rajwanshi, D.R
Section 147Section 148Section 271(1)(c)Section 50CSection 55A

framed thereafter is all without jurisdiction, the order passed u/s 147/143(3) as upheld by the CIT(A) be quashed. 2. Because the entire reassessment proceedings have been initiated on the basis of borrowed satisfaction and there being no inquiry or independent satisfaction of the AO, approval accorded being mechanical ... after giving a proper opportunity to the assessee, re-examine and adjudicate the issue de novo. 5.1 The assessee has also challenged initiation of reassessment proceedings in its grounds of appeal. However, no arguments were advanced by either of the sides on the validity of reassessment proceedings. Accordingly, these grounds

ACIT, Circle-7(1), Kolkata vs. Hi Tech Systems and Services Limited, Kolkata

In the result, both the appeals of the assessee are allowed and both the appeals of the revenue are dismissed

ITA 1318/KOL/2024[2022-2023]Status: DisposedITAT Kolkata06 Jan 2025AY 2022-2023

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri J.P. Khaitan &For Respondent: Shri Subhendu Datta, DR
Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153Section 80H

745/KOL/2024 02. At the time of hearing the ld. Counsel for the assessee pressed ground no.1 which read as under:- “1. Section 153: Reassessment Proceedings barred by law as per the provisions of section 153 of the Act Tax Impact - Not Applicable] a) That on the facts ... That on the facts and in the circumstances of the case, the learned CIT(A) erred in not appreciating the fact that the instant reassessment proceedings were already time barred on 01 May 2021 and that the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions

Krishan Dev Verma, Jaipur vs. ITO Ward - 1, Bhiwani

ITA 1147/DEL/2020[2014-15]Status: DisposedITAT Delhi06 Jan 2025AY 2014-15

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Gaurav Jain, Advocate &For Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 14Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 238Section 30(4)Section 31

commenced and its completion thereof on approval of the Resolution Plan by the order dated 14.12.2020 passed by the NCLT, the AO initiated the reassessment proceedings under section 147 through issue of notice dated 19.03.2020 under section 148 of the Act for AY 2016-17 and vide notice dated

Sms Concast Ag, New Delhi vs. ACIT, (International Taxation), Circle- 3(1)(2), New Delhi

In the result, all the three appeals of AYs 2015-16, 2016-17 & 2017-18

ITA 2695/DEL/2018[2014-15]Status: DisposedITAT Delhi06 Jan 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri S.Rifaur Rahmanddit, Circle 2 (2), Vs. Sms Siemag Ag, New Delhi. C/O Mohinder Puri & Co., 1A-1D, Vandhna, 11, Tolstoy Marg, New Delhi – 110 01. (Aadcs1173J) Sms Siemag Ag, Vs. Ddit, Circle 2 (2), C/O Mohinder Puri & Co., New Delhi. 1A-1D, Vandhna, 11, Tolstoy Marg, New Delhi – 110 01. (Aadcs1173J)

For Appellant: Shri Percy Pardiwalla, Sr. AdvocateFor Respondent: Shri Vijay B Vasanta, CIT DR
Section 142(1)Section 143(1)Section 148

appeal before the ld. CIT(A)-XXIV, New Delhi. Before ld. CIT (A), assessee has raised various grounds including jurisdictional issues for initiating reassessment proceedings in the case of the assessee and also on merit, assessee has ITA No.3071/DEL/2019 ITA No.1443 & 1444/DEL/2022 submitted before the ld. CIT (A) as under ... laid down that reassessment jurisdiction is available only to the AO and not to the assessee and the assessee in reassessment proceedings cannot claim that certain incomes originally declared as taxable are not taxable. Therefore, the AO has rightly considered the income returned in the revised return as starting point

Sureshbhai Raghubhai Thorat, Valsad vs. ITO, Ward-7, Vapi

In the result, the appeal of the assessee is dismissed

ITA 426/SRT/2024[2017-18]Status: DisposedITAT Surat03 Jan 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.426/Srt/2024 (Assessment Year: 2017-18) (Physical Hearing) Sureshbhai Raghubhai Thorat, Vs. The Ito, Siddharth Villa, At Post Ozar, Ward – 7, Mota Pondha B.O., Valsad – Vapi 396191 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acapt3507F (Appellant) (Respondent) Appellant By None Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 02/01/2025 Date Of Pronouncement 03/01/2025

Section 115BSection 133ASection 139Section 144Section 147Section 148Section 250Section 270ASection 69

erred in law and on facts in upholding, without adjudication, the action of the ld. ITO of commencing and completing the reassessment proceedings u/s 147 r.w.s. 144 of the Act on the basis of invalid notice issued u/s 148 of the Act. 4) The ld. CIT(A) has erred

K K Spun India Limited, Delhi vs. DCIT Central Circle-2 New Delhi, Jhandewalan Delhi

The appeals of the assessee are allowed

ITA 2006/DEL/2024[2019-20]Status: DisposedITAT Delhi03 Jan 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the reopening of the reassessment proceedings despite the fact that notice under section 148 has been issued beyond three years without there being any books of accounts, evidence or other ... case, the learned CIT(A) has erred both on facts and in law in confirming the reassessment, despite the fact that the reassessment proceedings initiated and consequent reassessment order passed by A0 are bad in the eye of law as the information on the basis of which notice under Section

K K Spun India Limited, Delhi vs. DCIT, Jhandewalan Delhi

The appeals of the assessee are allowed

ITA 2005/DEL/2024[2018-19]Status: DisposedITAT Delhi03 Jan 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the reopening of the reassessment proceedings despite the fact that notice under section 148 has been issued beyond three years without there being any books of accounts, evidence or other ... case, the learned CIT(A) has erred both on facts and in law in confirming the reassessment, despite the fact that the reassessment proceedings initiated and consequent reassessment order passed by A0 are bad in the eye of law as the information on the basis of which notice under Section

Power Links Transmission Ltd., New Delhi vs. Addl. CIT, Special Range- 7, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4599/DEL/2019[2012-13]Status: DisposedITAT Delhi03 Jan 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumarassessment Year: 2012-13 Powerlinks, Transmission Ltd. Vs Additional 10Th Floor, Dlf Tower-A, Commissioner Of District Centre, Jasola, Income Tax, Spl. Range New Delhi. 7 New Delhi Pan No. Aabct7775M (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 147Section 271(1)(c)Section 274Section 3ASection 80I

wrong. Hence, it is clear that section 147 of the Act does not postulate conferment of power upon the Assessing Officer to initiate reassessment proceedings upon a mere change of opinion". 10. Ld. DR has supported the order of the below authorities and ought the dismissal of the appeal

Vgu-Technology Business Incubator Trust, Jaipur vs. CIT Exemption Jaipur, Jaipur

28. In view of the above finding, the appeal is allowed and the impugned order passed by Learned CIT(A) confirming the impugned assessment framed by the Assessing Officer is hereby set aside

ITA 799/JPR/2024[2024-2025]Status: DisposedITAT Jaipur03 Jan 2025AY 2024-2025

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Mahendra Gargieya, AdvFor Respondent: MS. Alka Gautam, CIT
Section 132Section 143(2)Section 148Section 148ASection 153Section 153ASection 153CSection 68

required to be assessed. 14 Kavita Samtani vs DCIT 20. The necessary corollary of the above second proviso is that the assessment or reassessment proceedings, which have already been 'completed' and assessment orders have been passed determining the assessee's total income and, such orders are subsisting at the time

M/S Skyline E Tech, Kochi vs. ACIT Circle 2(2), Kochi

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

ITA 269/COCH/2023[2005-06]Status: DisposedITAT Cochin03 Jan 2025AY 2005-06

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Radhesh Bhatt, CAFor Respondent: Shri Sanjit Kumar Das, CIT(DR)
Section 143(2)Section 143(3)Section 250Section 263Section 32Section 32(1)Section 47

quash the reassessment order passed by the ld. AO. Accordingly ground no.2 of the appeal is allowed. 20. As we have already quashed the reassessment proceedings, the other grounds on merits are not required to be adjudicated and hence these are dismissed. 21. There is also another aspect to both ... r.w.s. 263 passed by AO 26.12.2011 ITA Nos.268 & 269/COCH/2023 Page 9 of 9 Whether issues involved in 263 order are No. connected to reassessment proceedings Order which could have been revised is order 26.12.2008 u/s. 143(3) r.w.s. 147 of the Act dated If reassessment is quashed, revisionary Yes. proceedings

M/S Skyline E Tech, Kochi vs. ACIT Circle 2(2), Kochi

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

ITA 268/COCH/2023[2005-06]Status: DisposedITAT Cochin03 Jan 2025AY 2005-06

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Radhesh Bhatt, CAFor Respondent: Shri Sanjit Kumar Das, CIT(DR)
Section 143(2)Section 143(3)Section 250Section 263Section 32Section 32(1)Section 47

quash the reassessment order passed by the ld. AO. Accordingly ground no.2 of the appeal is allowed. 20. As we have already quashed the reassessment proceedings, the other grounds on merits are not required to be adjudicated and hence these are dismissed. 21. There is also another aspect to both ... r.w.s. 263 passed by AO 26.12.2011 ITA Nos.268 & 269/COCH/2023 Page 9 of 9 Whether issues involved in 263 order are No. connected to reassessment proceedings Order which could have been revised is order 26.12.2008 u/s. 143(3) r.w.s. 147 of the Act dated If reassessment is quashed, revisionary Yes. proceedings

Ramad Ventures Private Limited, Chennai vs. ACIT Non Corporate Circle 20, Chennai

The appeal stand allowed in terms of our above order

ITA 408/CHNY/2024[2013-14]Status: DisposedITAT Chennai02 Jan 2025AY 2013-14

Bench: Hon’Ble Shri S.S. Viswanethra Ravi, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.408/Chny/2024 (िनधा)रण वष) / Assessment Year: 2013-14) M/S. Ramad Ventures Private Ltd. Dcit बनाम Old No.23, New No.18, Corporate Circle-5(1) Chellammal Street, Shenoy Nagar, Chennai. / Vs. Chennai-600 030. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecr-7531-C (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri K.G. Raghunath (Advocate) - Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Raghupathy (Addl.Cit) - Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 16-12-2024 घोषणा की तारीख /Date Of Pronouncement : 02-01-2025 आदेश / O R D E R

For Appellant: Shri K.G. Raghunath (Advocate) - Ld.ARFor Respondent: Shri R. Raghupathy (Addl.CIT) - Ld. Sr. DR
Section 143(3)Section 147Section 148Section 156Section 250

hearing on appeals, on the issues raised, hereinabove and in the assessment order concerned. 2. The Ld. AR advanced arguments and assailed the reassessment proceeding on legal grounds. The Ld. AR also advance argument on merits and submitted that the business had already commenced and therefore interest expenditure was allowable ... assessee’s submissions, Ld. AO framed impugned assessment and disallowed business expenditure in toto. 3.3 During first appeal, the assessee assailed the validity of reassessment proceedings and also assailed the disallowance of business expenditure by relying upon various judicial decisions. On legal ground, it was submitted that the case

Income Tax Officer, Piramal Chambers vs. Dibya Trading Co LLP, Mumbai, Maharashtra

In the result, appeal of the revenue is dismissed and cross- objection of the assessee is also dismissed

ITA 4330/MUM/2024[2015-16]Status: DisposedITAT Mumbai02 Jan 2025AY 2015-16

Bench: Shri Amarjit Singh & Shri Sunil Kumar Singhassessment Year: 2015-16 Income Tax Officer Dibya Trading Co. Llp

For Appellant: Shri Madhur Agrawal & Shri Jay BhahsaliFor Respondent: Shri R.R. Makwana, Sr. DR
Section 10(35)Section 250

No.4330/Mum/2024 & C.O. No. 191/Mum/2024 Dibya Trading Co. LLP A.Y. 2015-16 5.1.5 It is noticed from the record that during the course of reassessment proceedings, the appellant has furnished all the relevant documents in respect of purchase & sale of mutual funds in its submissions furnished on various dates & sales also

Oxford University Press, Mumbai vs. DCIT, International Taxation Circle -3(2)(2), Mumbai

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

ITA 4743/MUM/2023[2021-22]Status: HeardITAT Mumbai02 Jan 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI AMARJIT SINGH (Accountant Member)

Section 131Section 133ASection 153ASection 153C

properly disclosed the said transaction in his books of account, where it can no more remain incriminating in his hands. In such case, no reassessment proceedings can be initiated under the provisions of the section 153C of the Act of the non-searched person. Thus, Section 153C clearly envisages ... period for which the incriminating information was found and not for the period of six years, and secondly, there can be more than one reassessment proceedings for the same assessment year by taking recourse to the provisions of the section 153C of the Act as the action may follow

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2024[2017-18]Status: DisposedITAT Delhi02 Jan 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

assessee has challenged the action of the Ld. CIT(A) in rejecting the assessee’s legal issue with respect to initiation of reassessment proceedings u/s 148 of the Act. In support of prayer under Rule 27 of the Rules, the Ld. AR of the assessee has made following submissions ... detail: “Initiation of Reassessment proceedings wholly without jurisdiction As stated above, the original assessment was completed vide order dated 29.03.2016 passed under section 143(3) of the Act/pages 119 to 128 of the paper book), assessing the income of the assessee at Rs. 38,50,02,139, after making disallowance

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2024[2013-14]Status: DisposedITAT Delhi02 Jan 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

assessee has challenged the action of the Ld. CIT(A) in rejecting the assessee’s legal issue with respect to initiation of reassessment proceedings u/s 148 of the Act. In support of prayer under Rule 27 of the Rules, the Ld. AR of the assessee has made following submissions ... detail: “Initiation of Reassessment proceedings wholly without jurisdiction As stated above, the original assessment was completed vide order dated 29.03.2016 passed under section 143(3) of the Act/pages 119 to 128 of the paper book), assessing the income of the assessee at Rs. 38,50,02,139, after making disallowance