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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

Seema Sinha, Indore vs. ITO-4(4), Bhopal

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

ITA 499/IND/2023[2011-12]Status: HeardITAT Indore18 Mar 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanismt. Seema Sinha Ito-3(4) C-508, Shehnai Residency Bhopal Vs. A.B. Road, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Alups4142A Assessee By Shri S.N. Agrawal, Ar Revenue By Shri Harshit Bari , Sr. Dr Date Of Hearing 18.03.2024 Date Of Pronouncement 18.03.2024

Section 147Section 148

That on the facts and in the circumstances of the case and in law, the Ld CIT(A) erred in upholding the validity of reassessment proceedings initiated under section 147 of the Income-Tax Act, 1961 even when reopening was done in absence of any tangible material and live link

Kamal Panjwani, Indore vs. The ACIT 3 (1), Indore

ITA 85/IND/2014[1992-93]Status: DisposedITAT Indore18 Mar 2024AY 1992-93

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant that reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in maintaining ... appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant and reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in sustaining

Kamal Panjwani, Indore vs. The ACIT 3 (1), Indore

ITA 84/IND/2014[1991-97]Status: DisposedITAT Indore18 Mar 2024AY 1991-97

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant that reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in maintaining ... appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant and reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in sustaining

Kamal Panjwani, Indore vs. The ACIT 3 (1), Indore

ITA 83/IND/2014[1990-91]Status: DisposedITAT Indore18 Mar 2024AY 1990-91

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant that reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in maintaining ... appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant and reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in sustaining

Kamal Panjwani, Indore vs. The ACIT 3 (1), Indore

ITA 82/IND/2014[1989-90]Status: DisposedITAT Indore18 Mar 2024AY 1989-90

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant that reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in maintaining ... appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant and reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in sustaining

Kamal Panjwani, Indore vs. The ACIT 3 (1), Indore

ITA 81/IND/2014[1988-89]Status: DisposedITAT Indore18 Mar 2024AY 1988-89

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant that reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in maintaining ... appellant submits that the Ld. CIT(A)-I, Indore, was not justified to reject the contention of the appellant and reassessment proceedings so initiated by the AO was invalid, void and bad in law. 2. The appellant submits that the Ld. CIT(A)-I, Indore, has erred in sustaining

Pragati Power Corporation Ltd., New Delhi vs. ACIT, Special Range-7, New Delhi

In the result, the appeal of the assessee is allowed

ITA 3583/DEL/2019[2011-12]Status: DisposedITAT Delhi18 Mar 2024AY 2011-12

Bench: Shri Shamim Yahya & Shri Yogesh Kumar Uspragati Power Corporation Ltd., Vs. Acit, Spl. Range 7, Himadari Rajghat Power House Office Complex, New Delhi. Rajghat, New Delhi – 110 002. (Pan : Aaccp8035F) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate Revenue By : Shri Vivek Vardhan, Sr. Dr Date Of Hearing : 14.03.2024 Date Of Order : 18.03.2024

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 139Section 142Section 143Section 143(2)Section 143(3)Section 147Section 148

pursuant to assessment proceedings u/s 143(3) that the income was alleged to have escaped assessment. 3.4 He further submitted that the reassessment proceedings itself are illegal and liable to be quashed because of the following factors :- (i) There is no allegation of the AO that the assessee had failed

Gujarat Industries Power Co.Ltd., Baroda vs. The ACIT., Circle-1(1), Baroda

In the result, the appeal filed by the assessee is hereby dismissed

ITA 3049/AHD/2010[1998-99]Status: DisposedITAT Ahmedabad15 Mar 2024AY 1998-99

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 3049 & 3050/Ahd/2010 धििाधरणवरध/Asstt. Years: (1998-1999 & 1999 & 2000) Gujarat Industries Power Company The Asst. Commissioner Of Ltd., Vs. Income Tax, P.O Petrochemicals, Circle-1(1), Baroda-391346. Baroda.

For Appellant: Shri Yogesh Shah, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 115JSection 147Section 148

record and the provisions of the statute and in case in earlier proceedings no such opinion is formed It cannot be contended that the reassessment proceedings were initiated on mere change of opinion. Mere assessment in routine manner did not lead to inference that the opinion was formed in respect

Late Krishna Gopal Gupta (Thr. Son and Legal Heir Shri Mahendra Kumar Gupta), Jaipur vs. I.T.O. Ward 2 (1), Jaipur

In the result, the appeal of the assesee is allowed

ITA 2/JPR/2024[A.Y. 2007-08]Status: DisposedITAT Jaipur14 Mar 2024

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri G.M. Mehta, CAFor Respondent: Smt. Monisha Choudhary, Addl CIT-DR
Section 148Section 250

case of the assessee was reopened and notice u/s.148 of the Act was issued and served upon the assessee. During the course of reassessment proceedings, the ld. AR of the assessee informed that the assessee died on 29.03.2014. Further, the ld. AR of the assessee filed written submission vide letter ... served on the assessee. Burden on Revenue to prove service. Notice sent by speed post to wrong address is no service of notice. Reassessment proceedings are not valid." 10.1 The AO on the above submission of the appellant in a report has submitted that on perusal of the record/AST/AIS

Sri. Panati Vikramdeva Reddy, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-4(3)(1), Bengaluru

In the result, the appeals of the assessee are dismissed

ITA 121/BANG/2024[2014-15]Status: DisposedITAT Bangalore14 Mar 2024AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahu

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 132Section 142(1)Section 147Section 148Section 271Section 271(1)(b)Section 274Section 44A

further submitted that the assessee failed to demonstrate any reasonable cause for not complying notices u/s. 142(1) of the Act during the reassessment proceedings. Before the CIT(Appeals) he could have furnished reasonable cause for not complying the notices. After passing the penalty order, he filed the appeal before

Sri. Panati Vikramdeva Reddy, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-4(3)(1), Bengaluru

In the result, the appeals of the assessee are dismissed

ITA 120/BANG/2024[2013-14]Status: DisposedITAT Bangalore14 Mar 2024AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahu

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 132Section 142(1)Section 147Section 148Section 271Section 271(1)(b)Section 274Section 44A

further submitted that the assessee failed to demonstrate any reasonable cause for not complying notices u/s. 142(1) of the Act during the reassessment proceedings. Before the CIT(Appeals) he could have furnished reasonable cause for not complying the notices. After passing the penalty order, he filed the appeal before

Raghav Petrochem Pvt Ltd, New Delhi vs. Income Tax Officer Ward 20(3), New Delhi

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

ITA 3437/DEL/2023[2012-13]Status: DisposedITAT Delhi14 Mar 2024AY 2012-13

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year: 2012-13 Raghav Petrochem Pvt. Vs. Income Tax Officer, Ltd., Ward 20(3), Delhi. Delhi. Pan Aaacr4540H (Appellant) (Respondent)

For Appellant: Shri Nirbhay Mehta, AdvFor Respondent: Shri Vivek Vardhan, Sr.DR
Section 131Section 133(6)Section 147Section 148

filed its return on 21.05.2019 declaring income of Rs. 7,03,900/-. Statutory notice(s) were issued/served upon the assessee during the course of reassessment proceedings. On asking for the reasons recorded it was provided on Page 2 of 5 ITA No.-3437/Del/2023 Raghav Petrochem ... vide letter dated 12.11.2019 to notice u/s 148 was disposed of vide order dated 19.11.2019 by the Ld. Assessing Officer (“AO”). 4. During the reassessment proceedings, the assessee filed ledger account, sale bills and bank statement in support of transactions with the aforesaid two concerns. With a view to verifying

M/S.Va Tech Wabag Ltd, Chennai vs. ACIT Central Circle 3(2), Chennai

The appeal stand allowed in terms of our above order

ITA 503/CHNY/2023[2006-07]Status: DisposedITAT Chennai13 Mar 2024AY 2006-07

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

For Appellant: Shri R. Vijayaraghavan (Advocate)-Ld. ARFor Respondent: Shri P. Sajit Kumar (JCIT) – Ld. Sr. DR
Section 143(3)Section 147Section 41(1)Section 80ISection 80l

Court. This issue, thus, has attained finality. The first appellate order got merged with the orders of high authorities. By revisiting this issue in reassessment proceeding, in our opinion, would tantamount to disturbing the already concluded issue which could not be permitted. Therefore, the reassessment proceedings could not be upheld ... computation u/s 115JB is concerned, mere omission on the part of Ld. AO to consider the same could not trigger reassessment proceedings unless there was any failure on the part of the assessee to make full disclosure thereof. The complete details, in this regard, was made available by the assessee

M/S Ramani Timber Corporation, Trichy vs. ACIT-Circle-3(1), Trichy

The appeal stand partly allowed in terms of our above order

ITA 1476/CHNY/2023[2012-13]Status: DisposedITAT Chennai13 Mar 2024AY 2012-13

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1476/Chny/2023 (िनधा*रण वष* / Assessment Year: 2012-13) M/S. Ramani Timber Corporation Acit बनाम 3/132A. Tanjore Road, Opp.Udc Circle-3(1) / Vs. Kattur, Trichy-620 019. Trichy. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaefr-9407-J (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Mrs. T.V. Muthu Abirami (Advocate)-Ld. Ar " थ"कीओरसे/Respondent By : Shri D. Hema Bhupal (Jcit)- Ld. Sr. Dr सुनवाईकीतारीख/Date Of Final Hearing : 13-03-2024 घोषणाकीतारीख /Date Of Pronouncement : 13-03-2024 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2012-13 Arises Out Of An Order Passed By Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] On 17-10-2023 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S 147 Of The Act On 31-12-2018. This Is Second Round Of Litigation. Earlier, The Tribunal Vide Its Order In Ita No.125/Chny/2020 Dated 09-11-2021 Had Set Aside The Appeal To Ld. Cit(A) For Fresh Consideration. Pursuant To The Same, Impugned Order

For Appellant: Mrs. T.V. Muthu Abirami (Advocate)-Ld. ARFor Respondent: Shri D. Hema Bhupal (JCIT)- Ld. Sr. DR
Section 143(3)Section 147Section 234ASection 68

appellant objects to the levy of interest u/s.234A and 2348 of the Income Tax Act, 1961. As is evident, the assessee is challenging the reassessment proceedings on legal grounds. The assessee is also challenging quantum addition on merits. 2. The Ld. AR advanced arguments assailing the assumption of reassessment jurisdiction

M/S. Smb Constructions, Mangaluru vs. Income Tax Officer, Ward-1(1), Mangaluru

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

ITA 46/BANG/2024[2015-16]Status: DisposedITAT Bangalore13 Mar 2024AY 2015-16

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

For Appellant: Ms.Sunaina Bhatia, AdvocateFor Respondent: Sri.V.Parithivel, JCIT-DR
Section 144Section 147Section 148Section 194Section 194ISection 234A

completed u/s 144 r.w.s. 147 of the Act, and assessed the income at Rs.53,82,000 u/s.144 of the Act, and completed the reassessment proceedings. 4. Aggrieved from the above order, the assessee filed appeal before the first appellate authority. During the course of appellate proceedings, the CIT(A) also

M/S Concise Exim Pvt Ltd, Thane vs. ITO Ward 2 (1), Thane

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

ITA 3170/MUM/2023[2011-12]Status: DisposedITAT Mumbai13 Mar 2024AY 2011-12

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S Concise Exim Private Limited V. Income Tax Officer, Ward 2(1) Thane- 400614 B-426, 4Th Floor, Nbc Complex Plot No. 43, Sector- 11 Cbd Belapur, Thane- 400614 Pan: Aadcc5668A (Appellant) (Respondent) Assessee Represented By : None Department Represented By : Shri H.M. Bhatt

Section 148Section 250Section 68

facts on the file in as much as he has not justified to uphold the action of the Ld. Assessing Officer in resorting the reassessment proceedings and issuing notice under section 148 of the Act since the notice issued under section 148 is bad in law. 2. That the order

Bharat Vanmalibhai Modiya, Mumbai vs. Income Tax Officer 25(2) (2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 125/MUM/2022[2010-11]Status: DisposedITAT Mumbai13 Mar 2024AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2010-11 Bharat Vanmalibhai Modiya, Income Tax Officer 25(2)(2), 503, Shree Krishna Bhuvan, Kautilya Bhavan, Dgit Vs. Dixit Road, Vile Parle (E), (Vigilance) (West) Avenue 3, Mumbai-400057. Near Videsh Bhavan, G Block Bkc, Bandra Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aawpm 1067 D Appellant Respondent Assessee By : Mr. Bharat Kumar : Mr. Ashok Kumar Ambastha, Dr Revenue By Date Of Hearing : 12/03/2024 Date Of Pronouncement : 13/03/2024

For Appellant: Mr. Bharat Kumar
Section 143(1)Section 148

file compliance to notice to notice u/s 148 of the Act. The Assessing Officer u/s 148 of the Act. The Assessing Officer completed the reassessment proceedings on 28.03.2016 wherein he completed the reassessment proceedings on 28.03.2016 wherein he completed the reassessment proceedings on 28.03.2016 wherein he made addition ... upheld the addition and he Ld. CIT(A) also upheld the addition and he Ld. CIT(A) also upheld the addition and justified the reassessment proceedings u/147 of the Act. justified the reassessment proceedings u/147 of the Act. justified the reassessment proceedings u/147 of the Act. 3. Aggrieved, the assessee

Dinesh Shah (HUF), Mumbai vs. DCIT Central Circle -3(4), Mumbai

In the result, all four appeals of the assessee are allowed

ITA 1150/MUM/2020[2010-11]Status: DisposedITAT Mumbai13 Mar 2024AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dinesh Shah (Huf), Dy. Cit, Central Circle-3(4), Flat No. 434, Shabri Shikhar, Mumbai. Vs. R.C. Marg, Chembur (W), Mumbai-400071. Pan No. Aadhs 0544 N Appellant Respondent Assessee By : Mr. Rasesh Shah : Ms. Sanyogita Nagpal, Cit-Dr Revenue By Date Of Hearing : 15/02/2024 Date Of Pronouncement : 13/03/2024 Order

For Appellant: Mr. Rasesh Shah
Section 143(3)Section 153CSection 68

additional ground in all the appeals challenging the validity of the reassessment challenging the validity of the reassessment challenging the validity of the reassessment proceedings completed u/s 153C of the Act. The relevant additional proceedings completed u/s 153C of the Act. The relevant additional proceedings completed u/s 153C

Dinesh Shah (HUF), Mumbai vs. DCIT Central Cir-3(4), Mumbai

In the result, all four appeals of the assessee are allowed

ITA 1149/MUM/2020[2011-12]Status: DisposedITAT Mumbai13 Mar 2024AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dinesh Shah (Huf), Dy. Cit, Central Circle-3(4), Flat No. 434, Shabri Shikhar, Mumbai. Vs. R.C. Marg, Chembur (W), Mumbai-400071. Pan No. Aadhs 0544 N Appellant Respondent Assessee By : Mr. Rasesh Shah : Ms. Sanyogita Nagpal, Cit-Dr Revenue By Date Of Hearing : 15/02/2024 Date Of Pronouncement : 13/03/2024 Order

For Appellant: Mr. Rasesh Shah
Section 143(3)Section 153CSection 68

additional ground in all the appeals challenging the validity of the reassessment challenging the validity of the reassessment challenging the validity of the reassessment proceedings completed u/s 153C of the Act. The relevant additional proceedings completed u/s 153C of the Act. The relevant additional proceedings completed u/s 153C

Dinesh Shah (HUF), Mumbai vs. DCIT Central Cir -3(4), Mumbai

In the result, all four appeals of the assessee are allowed

ITA 1148/MUM/2020[2012-13]Status: DisposedITAT Mumbai13 Mar 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dinesh Shah (Huf), Dy. Cit, Central Circle-3(4), Flat No. 434, Shabri Shikhar, Mumbai. Vs. R.C. Marg, Chembur (W), Mumbai-400071. Pan No. Aadhs 0544 N Appellant Respondent Assessee By : Mr. Rasesh Shah : Ms. Sanyogita Nagpal, Cit-Dr Revenue By Date Of Hearing : 15/02/2024 Date Of Pronouncement : 13/03/2024 Order

For Appellant: Mr. Rasesh Shah
Section 143(3)Section 153CSection 68

additional ground in all the appeals challenging the validity of the reassessment challenging the validity of the reassessment challenging the validity of the reassessment proceedings completed u/s 153C of the Act. The relevant additional proceedings completed u/s 153C of the Act. The relevant additional proceedings completed u/s 153C