← 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

Narmada Concast Private Limited, Bhavnagar vs. The Dy. Commissioner of Income Tax, Central Circle-1(1), Ahmedabad

In the result, the appeal filed by the Assessee is hereby allowed

ITA 33/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad03 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(3)Section 148

I.T.A No. 33/Ahd/2023 A.Y. 2013-14 Page No 6 Narmada Concast Pvt. Ltd. vs. DCIT recorded by the Assessing Officer before initiating the reassessment proceedings. Thus it is to be held that the reopening of assessment is merely on the basis of “borrowed satisfaction” which is not justified under ... done on borrowed satisfaction by observing as follows: “On the basis of the information received from another agency, there cannot be any reassessment proceedings However, after considering the information/material received from other source, the Assessing Officers required to consider the material on record in case of the assessee and thereafter

Goldiam Jewellery Limited, Mumbai vs. DCIT-CC 1(2), Mumbai

The appeals of the assessee are allowed partly

ITA 3219/MUM/2023[2016-17]Status: DisposedITAT Mumbai03 Jan 2024AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Goldiam International Limited Plot No.16/17 Gems & Dcit, Central Circle 1(2) Vs. Jewelry Complex Seepz Sez Mumbai Andheri East, Mumbai-400 096 (Appellant) (Respondent) Pan No. Aaacg2271J

For Appellant: Shri Mani Jain, CAFor Respondent: Shri Mirza Azhar, DR
Section 10(35)Section 133ASection 143Section 147Section 148

beneficiary of sham dividend declared by the company. This information was received from inside total on record of AO on the basis of which reassessment proceedings are initiated. After analyzing several judicial precedents, he upheld the reassessment holding that AO had valid reasons to initiate reassessment proceedings which were duly ... assessment year. Accordingly, respectfully following the decision of the honourable Bombay High Court we allow ground number 1 and 2 of the appeal quashing reassessment proceedings. 017. Even on the merits of the case, the facts clearly shows that assessee purchased JM balanced fund mutual fund on 17/6/2015

M/S. Jet Speed Real Tors, Mumbai vs. ACIT Cir 32(1), Mumbai

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

ITA 77/MUM/2022[2014-15]Status: DisposedITAT Mumbai03 Jan 2024AY 2014-15

Bench: Shri Amit Shukla, Hon'Ble

Section 131Section 133ASection 143(2)Section 143(3)Section 147Section 148

well as the lender (page 180, 181 and 267 of PB for AY 2014-15) during the course of reassessment proceedings. AY 2014-15 Amount Name of of loan Amount Date of accepted 5 Remark the party in AY repaid repayment 2014-15 Frontline

M/S. Jet Speed Realtors, Mumbai vs. ACIT Cir 32(1), Mumbai

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

ITA 109/MUM/2022[2015-16]Status: DisposedITAT Mumbai03 Jan 2024AY 2015-16

Bench: Shri Amit Shukla, Hon'Ble

Section 131Section 133ASection 143(2)Section 143(3)Section 147Section 148

well as the lender (page 180, 181 and 267 of PB for AY 2014-15) during the course of reassessment proceedings. AY 2014-15 Amount Name of of loan Amount Date of accepted 5 Remark the party in AY repaid repayment 2014-15 Frontline

Jet Spped Realators, Mumbai vs. ACIT Cir 32(1), Mumbai

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

ITA 108/MUM/2022[2016-17]Status: DisposedITAT Mumbai03 Jan 2024AY 2016-17

Bench: Shri Amit Shukla, Hon'Ble

Section 131Section 133ASection 143(2)Section 143(3)Section 147Section 148

well as the lender (page 180, 181 and 267 of PB for AY 2014-15) during the course of reassessment proceedings. AY 2014-15 Amount Name of of loan Amount Date of accepted 5 Remark the party in AY repaid repayment 2014-15 Frontline

Sd Propcon Pvt. Ltd., Noida vs. ITO Ward 22(4), New Delhi

ITA 2503/DEL/2023[2012-13]Status: DisposedITAT Delhi01 Jan 2024AY 2012-13

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri Sandeep Sapra, AdvFor Respondent: Shri Anuj Garg, Sr. DR
Section 147Section 234BSection 282Section 68

147/143(3) of I.T Act by ITO, Ward 22(4), New Delhi (in short AO) is also bad in law as initiation of reassessment proceedings u/s 147/148 of I.T. Act is illegal. 4. That without prejudice to Ground No. 3 above, the impugned reassessment order as passed u/s 147/143

Shalin Star, Mumbai vs. ITO-Ward 19(3)(1), Mumbai

Appeal is allowed for statistical purposes

ITA 3154/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Dec 2023AY 2012-13
For Appellant: Shri Himanshu Gandhi
Section 143(1)Section 143(3)Section 145(3)Section 147Section 148Section 234ASection 271(1)(c)Section 69C

adjudicating grounds of appeal on merit. 3. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming reassessment proceeding initiated through notice under section 148 which is bad in law and require to be quashed. 4. On the facts and circumstances ... case and law, the Ld. CIT(A) erred in confirming reassessment proceeding even though the signed copy of reason recorded for reopening was not provided to appellant. 5. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming addition of Rs.3

M/S Rama Enterprises, Mumbai vs. ITO Ward 27 (3) (1), Mumbai

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

ITA 2992/MUM/2023[2009-10]Status: DisposedITAT Mumbai29 Dec 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Smt. Mahita Nair
Section 133(6)Section 143(3)Section 144Section 147Section 148Section 250

20/12/2011 determining the total income of the assessee at Rs. 1,90,320 against the returned income of Rs. 1,50,950. Subsequently, reassessment proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 27/01/2015. During the reassessment proceedings, notice ... behalf of the assessee. Since the assessee failed to discharge the onus cast on him, the Assessing Officer proceeded to complete the reassessment proceedings under section 144 of the Act on the basis of material available on record. Accordingly, vide order dated 08/12/2015 passed under section 144 read with section

Leelaben Kantilal Parekh, Mumbai vs. Income Tax Officer Ward 20(2)(1), Piramal Chamber, Mumbai

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

ITA 2926/MUM/2023[2011-12]Status: DisposedITAT Mumbai29 Dec 2023AY 2011-12

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Piyush Chhajed a/wFor Respondent: Shri Nagnath B. Pasale
Section 133(6)Section 147Section 148Section 151Section 151(2)Section 250Section 69C

whether it was passed otherwise] and how much period has elapsed between the passing of the original assessment order and initiation of reassessment proceedings under section 147. The law as it presently stands, therefore, has to be pressed into aid to apply the aforesaid procedural requirements for invoking section ... income filed by the assessee was not selected for scrutiny. The AO based on the information received from the DGIT (Investigation), Mumbai initiated the reassessment proceedings. The reasons recorded by the AO, while reopening the assessment, are as under: “Reason for reopening recorded

Ravindra K Reshamwala, Mumbai vs. The Income Tax Officer Ward 17(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 2925/MUM/2023[2010-11]Status: DisposedITAT Mumbai29 Dec 2023AY 2010-11

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Piyush ChhajedFor Respondent: Smt. Mahita Nair
Section 143(1)Section 143(3)Section 147Section 148Section 151(2)Section 250Section 35Section 35A

erred in confirming the action of assessing officer i,e. not disposing of the complete objections raised by the assessee during the course of reassessment proceedings as required u/s.147 as laid down by Honourable Supreme Court in case of GKN Driveshafts (India) Ltd, 251 ITR 19. 3. On the facts ... Trust, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 24/03/2017. During the reassessment proceedings, the assessee was Ravindra K. Reshamwala ITA no.2925/Mum./2023 asked to show cause as to why the donations made by it to Navjeevan Charitable

Omkar Metal and Alloys Corporation, C P Tank Mumbai vs. Income Tax Officer 19. 2. 4, Matru Mandir

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

ITA 2838/MUM/2023[2009-2010]Status: DisposedITAT Mumbai29 Dec 2023AY 2009-2010

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2009-10 Omkar Metal & Alloys Ito 19.2.4, Corporation, C P Tank Matru Mandir, Opp Bhatia Room No. 47, Balakrishna Vs. Hospital, Grant Road (West), Niwas, 2Nd Floor, 2Nd Mumbai-400007. Panjarapole Lane, Mumbai-400004. Pan No. Aaafo 4997 N Appellant Respondent

For Appellant: Mr. Vimal PunmiyaFor Respondent: Mr. H.M. Bhatt, Sr. DR
Section 143(3)Section 145(3)Section 147Section 148

notice u/s 148 of the Act on 08.03.2014. During the course notice u/s 148 of the Act on 08.03.2014. During the course of the reassessment proceedings, the Assessing Officer observed reassessment proceedings, the Assessing Officer observed reassessment proceedings, the Assessing Officer observed that 19 parties from whom the assessee

Dr Batras Positive Health Clinic Private Limited, Mumbai vs. CIT(A), National Faceless Appeal Centre

In the result, all the appeals of the assessee

ITA 2748/MUM/2023[2011-12]Status: DisposedITAT Mumbai29 Dec 2023AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Ita Nos. 2748, 2747 & 2761/Mum/2023 Assessment Year: 2011-12, 2012-13 & 2013-14 Dr Batras Positive Health Clinic Cit(A), National Faceless Pvt. Ltd., Appeal Centre, Delhi. 2Nd Floor, H Kantilal Compound, Vs. Andheri Kurla Road, Sakinaka Andheri East-400072 Pan No. Aabcd 3857 G Appellant Respondent

For Appellant: Mr. Yogesh A. Thar, Mr. ChaitanyaFor Respondent: Mr. Ashok Kumar Ambastha, Sr
Section 143(2)Section 147Section 16(2)

assessment order is out of ‘Public Relation E ‘Public Relation Expenses’ of ₹37,52,470/-, whereas in the , whereas in the reassessment proceeding reassessment proceeding, the Assessing Officer has disallowed the Assessing Officer has disallowed expenses of ₹3,72,89, 3,72,89,606/- out of ‘advertisement and business advertisement ... information,' justifying the objection in this case qualifies as 'information,' justifying t objection in this case qualifies as 'information,' justifying t initiation of reassessment proceedings initiation of reassessment proceedings 7.1.9 In conclusion, In conclusion, we do not find merit in the argument we do not find merit in the argument

Dr Batras Positive Health Clinic Private Limited, Mumbai vs. CIT(A), NFAC, National Faceless Appeal Centre

In the result, all the appeals of the assessee

ITA 2747/MUM/2023[AY 2012-13]Status: DisposedITAT Mumbai29 Dec 2023

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Ita Nos. 2748, 2747 & 2761/Mum/2023 Assessment Year: 2011-12, 2012-13 & 2013-14 Dr Batras Positive Health Clinic Cit(A), National Faceless Pvt. Ltd., Appeal Centre, Delhi. 2Nd Floor, H Kantilal Compound, Vs. Andheri Kurla Road, Sakinaka Andheri East-400072 Pan No. Aabcd 3857 G Appellant Respondent

For Appellant: Mr. Yogesh A. Thar, Mr. ChaitanyaFor Respondent: Mr. Ashok Kumar Ambastha, Sr
Section 143(2)Section 147Section 16(2)

assessment order is out of ‘Public Relation E ‘Public Relation Expenses’ of ₹37,52,470/-, whereas in the , whereas in the reassessment proceeding reassessment proceeding, the Assessing Officer has disallowed the Assessing Officer has disallowed expenses of ₹3,72,89, 3,72,89,606/- out of ‘advertisement and business advertisement ... information,' justifying the objection in this case qualifies as 'information,' justifying t objection in this case qualifies as 'information,' justifying t initiation of reassessment proceedings initiation of reassessment proceedings 7.1.9 In conclusion, In conclusion, we do not find merit in the argument we do not find merit in the argument

+DCIT CC- 7(2), Mumbai vs. Sahebrao Deshmukh Co.Op. Bank Ltd., Mumbai

Accordingly, Ground No. 1 and 2 raised by the Revenue are dismissed, while Ground No

ITA 2478/MUM/2021[2014-15]Status: DisposedITAT Mumbai29 Dec 2023AY 2014-15

Bench: The Tribunal.

For Appellant: Shri Satish ModiFor Respondent: Ms. Shreekala Pardeshi
Section 143(3)Section 147Section 148

Miscellaneous Application preferred by the Revenue [MA No. 174/Mum/2023] the aforesaid order, dated 27/02/2022, was recalled in view of the fact that the reassessment proceedings in the present case were initiated on account of a revenue audit objection accepted by the Assessing Officer and therefore, the case fell under ... disallowance made on merits. The CIT(A), vide order dated 26/10/2021, deleted the disallowance of INR 90,72,553/- holding that the reassessment proceedings were void-ab-initio and therefore, the order dated 28/12/2019, passed by the Assessing Officer under Section 143(3) read with Section

Shrifal Impex Private Limited, Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 250/SRT/2023[2014-15]Status: DisposedITAT Surat29 Dec 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

books of accounts and are audited by a qualified chartered accountant. The assesses company In the original assessment proceedings as well as reassessment proceedings has submitted Audit Report and Audited Balance Sheet and Trading Profit & loss A/c along with all the annexures, Party wise details of purchases along with their ... provisions of Finance Act 2008 where Note No. 29 concerns amendment in respect ITA Nos. 190 - 191 &250/SRT/2023 Shrifal Impex Pvt. Ltd. of reassessment proceedings. It is meant to clarify the correct legislative intention in respect of the amendment relating to Section 151 which has been applicable w.e.f 1st October

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 191/SRT/2023[2012-13]Status: DisposedITAT Surat29 Dec 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

books of accounts and are audited by a qualified chartered accountant. The assesses company In the original assessment proceedings as well as reassessment proceedings has submitted Audit Report and Audited Balance Sheet and Trading Profit & loss A/c along with all the annexures, Party wise details of purchases along with their ... provisions of Finance Act 2008 where Note No. 29 concerns amendment in respect ITA Nos. 190 - 191 &250/SRT/2023 Shrifal Impex Pvt. Ltd. of reassessment proceedings. It is meant to clarify the correct legislative intention in respect of the amendment relating to Section 151 which has been applicable w.e.f 1st October

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 190/SRT/2023[2011-12]Status: DisposedITAT Surat29 Dec 2023AY 2011-12

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

books of accounts and are audited by a qualified chartered accountant. The assesses company In the original assessment proceedings as well as reassessment proceedings has submitted Audit Report and Audited Balance Sheet and Trading Profit & loss A/c along with all the annexures, Party wise details of purchases along with their ... provisions of Finance Act 2008 where Note No. 29 concerns amendment in respect ITA Nos. 190 - 191 &250/SRT/2023 Shrifal Impex Pvt. Ltd. of reassessment proceedings. It is meant to clarify the correct legislative intention in respect of the amendment relating to Section 151 which has been applicable w.e.f 1st October

Assistant Commissioner of Income Tax Chandrapur Circle, Chandrapur vs. M/S Chadda Transport, Chandrapur

Appeal is dismissed

ITA 363/NAG/2019[2009-10]Status: DisposedITAT Nagpur27 Dec 2023AY 2009-10

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.363/Nag/2019 िनधा"रण वष" / Assessment Year : 2009-10 The Assistant M/S.Chadda Transport, Commissioner Of V Kosara Road, Padoli, Income Tax, S Chandrapur, Chandrapur Circle, Maharashtra – 442401. Chandrapur. Pan: Aaafc8556F Appellant / Revenue Respondent / Assessee Cross Objection No.01/Nag/2020 (Arising Out Of Ita No.363/Nag/2019) िनधा"रण वष" / Assessment Year : 2009-10 M/S.Chadda Transport, The Assistant Kosara Road, Padoli, V Commissioner Of Income Chandrapur, S Tax, Maharashtra – 442401. Chandrapur Circle, Chandrapur. Pan: Aaafc8556F Appellant / Assessee Respondent / Revenue Assessee By Shri Mukesh Agrawal – Ar Revenue By Shri Abhay Y. Mrathe – Sr.Dr Date Of Hearing 30/11/2023 Date Of Pronouncement 27/12/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am:

Section 143(3)Section 147Section 148Section 50Section 68

that he has all the powers to go beyond the remand report given by the AO and could have considered the issues raised in reassessment proceedings afresh and upheld the addition made by the AO. 6. Any other ground that may be raise during the proceedings.” 2. The assessee filed

Ajay Malshi Dedhia, Mumbai vs. ACIT 31(1), Mumbai

In the result, all these three appeals filed by the assessee are allowed for statistical purposes

ITA 3057/MUM/2023[2010-11]Status: DisposedITAT Mumbai21 Dec 2023AY 2010-11

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 3055 To 3057/Mum/2023 (A.Ys.2010-11, 2013-14 & 2015-16)

For Appellant: Mandar VaidyaFor Respondent: Milind Chavan
Section 143(3)Section 148Section 69A

details were available or record. e. Your appellant prays that the notice u/s 148 be treated as an invalid notice ad therefore the entire reassessment proceedings be quashed. P a g e | 3 ITA Nos.3055 to 3057/Mum/2023 Ajay Malshi Dedhia Vs. ACIT 31(1) 4. Invalid Reassessment Proceedings ... erred in law and on facts in confirming the action of the Id. A.O. c. Your appellant prays that the entire reassessment proceedings be treated as invalid and illegal and therefore the reassessment order passed u/s 143(3) r.w. s 147 be quashed. 5. Addition of Unexplained Money

Ajay Malshi Dedhia, Mumbai vs. ACIT 31(1), Mumbai

In the result, all these three appeals filed by the assessee are allowed for statistical purposes

ITA 3056/MUM/2023[2013-14]Status: DisposedITAT Mumbai21 Dec 2023AY 2013-14

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 3055 To 3057/Mum/2023 (A.Ys.2010-11, 2013-14 & 2015-16)

For Appellant: Mandar VaidyaFor Respondent: Milind Chavan
Section 143(3)Section 148Section 69A

details were available or record. e. Your appellant prays that the notice u/s 148 be treated as an invalid notice ad therefore the entire reassessment proceedings be quashed. P a g e | 3 ITA Nos.3055 to 3057/Mum/2023 Ajay Malshi Dedhia Vs. ACIT 31(1) 4. Invalid Reassessment Proceedings ... erred in law and on facts in confirming the action of the Id. A.O. c. Your appellant prays that the entire reassessment proceedings be treated as invalid and illegal and therefore the reassessment order passed u/s 143(3) r.w. s 147 be quashed. 5. Addition of Unexplained Money