← All Phrases

“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

DCIT Circle-28(1), Civic Centre New Delhi vs. Ashwani Khurana, New Delhi

ITA 4534/DEL/2024[2016-17]Status: DisposedITAT Delhi11 Feb 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwaldcit, Circle 28(1) Vs. Ashwani Khurana Room No. 1001, 10Th Floor 5, Green Avenue Vasant E-2, Block Civic Centre, Kunj, New Delhi – 110002 New Delhi – 110070 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaepk3731G Appellant .. Respondent

For Appellant: Sh. A.K. Khurana, CAFor Respondent: Sh. Jitender Singh, CIT, DR
Section 147Section 148Section 148ASection 151Section 151A

raised following grounds: “1. That on facts and circumstances of the case and in law, the CIT(A) has erred in quashing/invalidating the reassessment proceedings u/s 147 of the Act by ignoring that the Instruction No. 1/2022 dated 11/05/2022 was Issued by the CBDT in compliance of the judgement

Kuldip Singh, Ranchi vs. DCIT/ACIT, Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 180/RAN/2025[14-15]Status: DisposedITAT Ranchi10 Feb 2026

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.180/Ran/2025 Assessment Year: 2014-15 Kuldip Singh…………………….……….……...................……….……Appellant The Avenue Vishnupuri Marg, Upper Burdwan Compound, Lalpur, Ranchi- 834001. [Pan: Agjps6921P] Vs. Dcit/Acit, Circle-1, Ranchi…...…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kailash Gautam, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2026 Date Of Pronouncing The Order : February 10, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 06.03.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

details of which were not reflected in records and, thus, said income escaped assessment- Assessee filed instant petition challenging validity of reassessment proceedings - It was noted that assessee had filed complete details of its share transactions in case of 'S' Ltd. at time of completion of assessment under section ... Whether since there was no failure on part of assessee to disclose all material facts at time of assessment, initiation of reassessment proceedings based on mere change of opinion was not justified - Held, yes [Paras 36 and 37] [In favour of assessee] iii. Madras High Court in the case

Gulmohar Towers Private Limited, Kolkata vs. Income Tax Officer, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 976/KOL/2025[2011-12]Status: DisposedITAT Kolkata10 Feb 2026AY 2011-12

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

For Appellant: Shri S. Jhajharia, ARFor Respondent: Shri P.N. Barnwal, DR
Section 143(1)Section 147Section 148Section 148(2)

facts and circumstances as stated above and the ratio laid down in the various decision as discussed above, we are inclined to quash the reassessment proceedings. 4.2. In view of the facts and circumstances as stated above and the ratio laid down in the various decisions as discussed above ... inclined to quash the reassessment proceedings 4.3. So far as the merits of the case are concerned, we find that these shares were held since earlier assessment years (since A.Y. 2007-08) and have been shown in the balance sheets in the successive assessment years. We note that during

Palanisamy Shankarganesh, Erode vs. ITO Ward 1, (1), Erode

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

ITA 3544/CHNY/2025[2018-19]Status: DisposedITAT Chennai10 Feb 2026AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./Ita No.: 3544/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Shri Palanisamy Shankarganesh The Income Tax Officer, Prop: Universal Communication, Vs. Ward-1(1), No.56, Mettur Road, Erode, Erode. Tamil Nadu-638 001. [Pan: Azsps4331D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr.Bhupendran, Advocate ""यथ" क" ओर से/Respondent By : Mr.Sbr Kumar Laghimsetti, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 20.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 10.02.2026

For Appellant: Mr.Bhupendran, AdvocateFor Respondent: Mr.SBR Kumar Laghimsetti
Section 142(1)Section 143(1)Section 147Section 148Section 148ASection 151

hereby file the present application before the Hon'ble Tribunal, seeking to raise the following Additional Grounds of Appeal: Additional Ground No.1: The Impugned Reassessment Proceeding is null and void, as the Assessing Officer did not obtain the approval of the Specified Authority as per Section ... Taxman 420 (Madras), Telangana HC Order in 481 ITR 175 (Telangana) & Chennai ITAT Order in ITA No.895/Chny/2025 dated 19.09.2025] Additional Ground No.2: The Impugned Reassessment Proceeding is null and void, as the Assessing Officer, vide Show Cause Notice u/s.148A(b) dated 23/03/2022 required the Appellant to respond on or before

Abraham Kurian, Dindigul vs. ITO, Ward-1, Dindigul

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

ITA 2775/CHNY/2025[2013-14]Status: DisposedITAT Chennai10 Feb 2026AY 2013-14

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2775/Chny/2025 िनधा$रण वष$ /Assessment Year: 2013-14

For Appellant: Mr. A. Venkatesh, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 143(3)Section 148Section 250Section 69A

Subsequently, the A.O noticed that there is a cash credit which is not explained and therefore the A.O initiated reassessment proceedings by issue of notice u/s. 148 of the Act. The assessee submitted that the source for the cash deposit is from the advance received towards sale of property, from ... orders of the lower authorities. 6. We have heard the parties, and perused the material available on record. The A.O during the course of reassessment proceedings called on the assessee to furnish the source for cash deposits to the tune of Rs.1,71,14,000/. Based on the various details

Mrs. Jeanette Dsouza Legal Representative of Late Shri. Vinod Dsouza), Mangalore vs. Income Tax Officer, Ward-1(1), Mangalore

In the result, with above direction to the learned assessing officer, the ground No

ITA 2348/BANG/2025[2016-17]Status: DisposedITAT Bangalore10 Feb 2026AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubeyassessment Year : 2016-17 Mrs. Jeanette Dsouza, Lr Of Late Shri Vinod Dsouza, Flat No. San F 10, The Income Tax Officer, Holy Family Apartments, Ward – 1(1), Vs. Lalbagh, Mangalore, Mangalore. Karnataka – 575 003. Pan: Adhpd4076H Appellant Respondent

For Appellant: Shri Prasanna Shenoy, CA
Section 139Section 142Section 144Section 144BSection 147Section 148Section 148ASection 149Section 159Section 55

assessment order dated 22 March 2023. 6. Assessee preferred an appeal before the learned CIT – A. The assessee objected to the reassessment proceedings, as well as the computation of undisclosed income. The learned CIT – A dismissed Page 3 of 5 the appeal of the assessee. Therefore, the assessee

Mr. Saurabh Anil Gandhi, Mumbai vs. Income Tax Officer Ward 42(3)(3), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 8437/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Feb 2026AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailmr. Saurabh Anil Gandhi A-502 Chanakya Chs Ltd. Mahavir Nagar, Opp. Ekta Nagar, New Link Road, Kandivali West, Mumbai- 400067 ............... Appellant Pan: Aelpg7302J

For Appellant: Shri Nikhil Tiwari a/wFor Respondent: Shri Pravin Salunkhe, Sr. DR
Section 132Section 147Section 148Section 153CSection 250Section 35Section 80Section 80G

requested to treat the return filed on 25/06/2010 as filed in compliance with the notice issued under section 148 of the Act. During the reassessment proceedings, notice was issued to the assessee to show cause as to why the donation of INR 1 lakh given to the Navjeevan Charitable Trust

DCIT Circle 2(3)(1), Mumbai vs. Tata Steel Limited, Mumbai

The appeal of the Revenue is dismissed

ITA 6471/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Feb 2026AY 2010-11

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokardcit Circle-2(3)(1) Tata Steel Limited 552, 5Th Floor, Aayakar Bombay House, 24, Bhavan, M. K. Road, Vs. Homi Mody Street, Mumbai-400 020 Fort, Mumbai, Gpo, Mumbai-400 001 Pan/Gir No. Aaacb1247M (Applicant) (Respondent) Revenue By Shri Ritesh Misra, Ld. Dr Assessee By Ms. Jasmin Amalasadvala, Ld. Ar Date Of Hearing 27.01.2026 Date Of Pronouncement 10.02.2026

Section 115JSection 131Section 133(6)Section 147Section 148Section 153ASection 250Section 268ASection 68

Subsequently, assessment was completed under section 153A r.w.s. 143(3) on 30.12.2016 determining total income at Rs. 636,97,12,178/-.Thereafter, reassessment proceedings were initiated under section 148 on 29.03.2017 based on information received from the Investigation Wing alleging that the assessee was beneficiary of accommodation entries from

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6211/MUM/2025[1996-97]Status: DisposedITAT Mumbai10 Feb 2026AY 1996-97

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC Bank. The modus operandi of the investment made by the appellant has been

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6209/MUM/2025[1998-99]Status: DisposedITAT Mumbai10 Feb 2026AY 1998-99

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC Bank. The modus operandi of the investment made by the appellant has been

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6195/MUM/2025[1996-97]Status: DisposedITAT Mumbai10 Feb 2026AY 1996-97

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC Bank. The modus operandi of the investment made by the appellant has been

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6194/MUM/2025[2000-01]Status: DisposedITAT Mumbai10 Feb 2026AY 2000-01

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC Bank. The modus operandi of the investment made by the appellant has been

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6193/MUM/2025[1997-98]Status: DisposedITAT Mumbai10 Feb 2026AY 1997-98

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC Bank. The modus operandi of the investment made by the appellant has been

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

ITA 6192/MUM/2025[1999-00]Status: DisposedITAT Mumbai10 Feb 2026AY 1999-00

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

Section 143(3)Section 144Section 250Section 271(1)(c)

with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC Bank. The modus operandi of the investment made by the appellant has been discussed

Deputy Commissioner of Income Tax Central Circle - 5(3), Mumbai vs. Unify Texturisers Private Limited, Mumbai

ITA 5055/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Feb 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawaldcit Central Circle-5(3), Vs Unify Texturisers Private Limited Mumbai 3Rd Floor, Astral Centre, Nm Joshi Kautilya Bhawan, Bandra Marg, Opp. Chinchpokli Railway Kurla Complex, Bandra (East) Station, Mumbai-400011 Mumbai 400051 Pan: Aaacu8565F Appellant Respondent C.O. No.241/Mum/2025 (Arising Out Of I.T.A. No.5055/Mum/2025 A.Y. :2017-18)

For Appellant: Shri Jay BhansaliFor Respondent: Ms. Kavita Kaushik (SR DR)
Section 139(1)Section 147Section 148Section 148ASection 151Section 151(1)Section 250

beyond the prescribed period of three years from the end of the relevant assessment year was contrary to law and, therefore, vitiated the entire reassessment proceedings. 4. In furtherance of his submissions, the Ld. AR placed reliance on the judgment of the Hon’ble Bombay High Court in the case ... notice dated 29.06.2021 and the subsequent order passed under section 148A(d) of the Act, it is evident that the approval for initiation of reassessment proceedings beyond three years from the end of the relevant assessment year was granted by the Ld. Principal Commissioner of Income Tax-8, Mumbai

Kabel Metal Power Cables Ltd, Thane vs. Dy. Commissioner of Income Tax, Circle-5(2)(1), Mumbai

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

ITA 4789/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Feb 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarita No.4789/Mum/2025 (Assessment Year: 2014-15)

For Appellant: Shri Prakash Jhujhunwala a/w Shri Saiprasad GhoshFor Respondent: Shri Ritesh Misra (CIT DR)
Section 139(1)Section 143(2)Section 147Section 148Section 250

additional grounds before the Bench. By way of Additional Ground No. 4, the assessee specifically challenged the jurisdiction of the Ld. AO to initiate reassessment proceedings without issuance of notice under section 143(2) of the Act. On facts, it is admitted by the Ld. AO that no notice under ... section 143(2) of the Act was served upon the assessee prior to initiation of the reassessment proceedings. The Ld. AO, in his letter dated 22.01.2026 bearing No. ACIT-5(2)(1)/ITAT Report/2026-27, noted that the return in response to notice issued under section

Kabel Metal Power Cables Ltd, Thane vs. Dy. Commissioner of Income Tax, Circle-5(2)(1), Mumbai

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

ITA 4788/MUM/2025[2013-14]Status: DisposedITAT Mumbai10 Feb 2026AY 2013-14

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarita No.4789/Mum/2025 (Assessment Year: 2014-15)

For Appellant: Shri Prakash Jhujhunwala a/w Shri Saiprasad GhoshFor Respondent: Shri Ritesh Misra (CIT DR)
Section 139(1)Section 143(2)Section 147Section 148Section 250

additional grounds before the Bench. By way of Additional Ground No. 4, the assessee specifically challenged the jurisdiction of the Ld. AO to initiate reassessment proceedings without issuance of notice under section 143(2) of the Act. On facts, it is admitted by the Ld. AO that no notice under ... section 143(2) of the Act was served upon the assessee prior to initiation of the reassessment proceedings. The Ld. AO, in his letter dated 22.01.2026 bearing No. ACIT-5(2)(1)/ITAT Report/2026-27, noted that the return in response to notice issued under section

Nagpal, Uttar Pradesh vs. ITO Ward -2 (5), Chandausi

ITA 179/DEL/2026[2018-19]Status: DisposedITAT Delhi10 Feb 2026AY 2018-19

Bench: Sh. Satbeer Singh Godara

For Appellant: Sh. V. Rajkumar, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH `SMC', NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No

Krishna, Delhi vs. ITO Ward 36(1), Delhi

Appeal is allowed in above terms

ITA 166/DEL/2026[2017-18]Status: DisposedITAT Delhi10 Feb 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 166/Del/2026 : Asstt. Year: 2017-18 Mrs. Krishna, Vs Income Tax Officer, G-2/57, Sector-11, Rohini, Ward-36(1), New Delhi-110085 New Delhi-110001 (Appellant) (Respondent) Pan No. Aijpd1120H Assessee By: Sh. Manish Kumar, Ca & Sh. Gaurav Bhujel, Ar Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082534866(1) Dated 12.11.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Manish Kumar, CA &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

Income Tax Officer Ward 25 3 Delhi & Ors.(supra), a Coordinate Bench of this court examined the validity of initiation of reassessment proceedings, in cases where the income 5 Krishna alleged to have escaped assessment was Rs.50,00,000/- or less. In the aforesaid context, this court also considered ... amended 1961 Act, the issue concerning limitation is inextricably intertwined with two aspects: (a) First, the rank of the authority granting approval/sanction for triggering reassessment proceedings. (b) Second, the quantum of income which has escaped assessment.” (Emphasis is ours) 12. Clearly, the Revenue advanced the argument of interlinkage between limitation

Aftab Siddique, Raipur vs. DCIT-1(1), Raipur

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

ITA 633/RPR/2025[2018-19]Status: DisposedITAT Raipur09 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 633/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Aftab Siddique, Near Sunni Maszid, Vs Deputy Commissioner Of Income Nayapara, Tatyapara, Raipur, Tax, Circle-1(1), Aaykar Bhawan, Civil Lines, Raipur Pan: Ajgps3624K (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : None (Petition Filed) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 05/02/2026 घोषणा की तारीख / Date Of : 09/02/2026 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 11.08.2025 Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [‘Cit(A)’] Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: None (Petition filed)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 127Section 148Section 250Section 250(6)Section 251(1)(a)Section 251(2)Section 68

illegal. The assessment order is liable to be quashed. Ld. CIT(A) erred in confirming addition based on illegal assessment order. 5. Initiation of reassessment proceedings Nil and consequent reassessment order passed is illegal without jurisdiction, ab initio vold. The reassessment order is liable to be quashed