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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, Jaipur vs. Rdb Cars Private Limited, Jaipur

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

ITA 140/JPR/2023[2012-13]Status: DisposedITAT Jaipur24 Jul 2023AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Ms Nupur Khandelwal (C.A)For Respondent: Ms Runi Pal (Addl.CIT)
Section 143(2)Section 143(3)Section 148Section 201(1)Section 249(2)Section 40

income at loss of (-) Rs. 1,65,98,229/-and the case of the assessee was assessed u/s 143(3) of the Act. Thereafter reassessment proceedings were initiated by issuing notice u/s 148 of the Act on 28.09.2016 after taking necessary approval on the pretext that the assessee has paid

Surajkumar & Sons, Mumbai vs. ITO 21 (3)(4), Mumbai

In the result ground no. 2 raised by the assessee is partly allowed for statistical purpose

ITA 258/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 Jul 2023AY 2010-11

Bench: Shri O.P. Kant, Accountant, Member & Ms. Kavitha Rajagopalm/S Surajkumar & Sons 302,-C, Shivshakti Chs Ltd., Kashinath Dhuru Marg, Agar Bazar, Prabhadevi, Mumbai-400025. Pan: Aaqfs4464G ...... Appellant Vs. Ito – 21(3)(4), 206, Piramal Chambers, Parel, Lalbaug, Mumbai-400012 ..... Respondent

For Appellant: Sh. Dalpat Shah, ARFor Respondent: Sh. Kishor Dhule- CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 148(2)Section 250Section 4

duly complied with by the Ld. AO and when the assessee has no grievance on this the same will not vitiate the reassessment proceedings. With regard to the contention that the reasons recorded for re-opening was wrong as the assessee did not make any purchase during the year under

Sky Gem, Mumbai vs. DCIT, CC-1(1), Mumbai

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

ITA 786/MUM/2023[2008-09]Status: DisposedITAT Mumbai19 Jul 2023AY 2008-09

Bench: Shri Pavan Kumar Gadale, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blesky Gem V. Dcit, Central Circle-1(1) Cc – 2081, G Block Room No. 905, 9Th Floor Bharat Diamonds Bourse Pratishtha Bhavan Bandra Kurla Complex Maharishi Karve Road Bandra (E), Mumbai -400051 Mumbai - 400020 Pan: Aayfs8765J (Appellant) (Respondent) Assessee Represented By : Shri Suchek Anchaliya & Shri Tushar Nagori Department Represented By : Ms. Kavita Kaushik

Section 143(1)Section 143(2)Section 147Section 148Section 68

availed accommodation entries from Laxmi Trading Co. who are said to be providing accommodation entries without there being transportation of any goods. In the reassessment proceedings, the assessee was asked to prove the Page No. 2 Sky Gem genuineness of the purchases made from Laxmi Trading Co. In response, assessee ... that the assumption of jurisdiction by the Ld. Assessing Officer is bad in law as the conditions laid down under the Act for initiating reassessment proceeding u/s 147 of the Act have not been fulfilled. 2. On the facts and circumstances of the case

M/S Atul Projects India Private Limited, Mumbai vs. DCIT-9(1)(2)(Now Jurisdiction With Dc CC-(2)(4), Mumbai

In the result appeal filed by the Assessee is allowed

ITA 111/MUM/2023[2011-12]Status: DisposedITAT Mumbai19 Jul 2023AY 2011-12

Bench: Shri B R Baskaran, Am & Shri N. K. Choudhry, Jm

For Appellant: Sh. Naresh Jain & ShFor Respondent: Sh. Manoj Kumar Sinha, Ld
Section 143(3)Section 147Section 148Section 250Section 68

Atul Projects India Pvt. Ltd. assessment year under consideration and therefore the AO while recording the reasons and initiating the reassessment proceedings u/s 147 r.w.s. 148 of the Act, has not followed the first proviso of section 147 of the Act. 6.10 As we have noted above that two different

ACIT, Central Circle-2(1), Mumbai vs. Fancy Devi., Mumbai

In the result, the appeal filed by Revenue is dismissed

ITA 3245/MUM/2022[2017-18]Status: DisposedITAT Mumbai19 Jul 2023AY 2017-18

Bench: Shri Pavan Kumar Gadale & Ms. Padmavathy Sacit, C. Circle-2(1), Fancy Devi, Room No.804,8Thfloor, B-502, Oberoi Sky बनाम/ Oldcgoannexbuilding, Heights, Cross Road, Vs. M.K.Road, Lokhandwala, Mumbai-400020. Andheri (W), Mumbai-400053. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aegpj5895J (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Shri.Ankush Kapoor.DRFor Respondent: Shri.Mahaveer Jain.AR
Section 131Section 143(2)Section 143(3)Section 153ASection 68

first proviso. It also means that only one assessment will be made under the aforesaid provisions as the two proceedings i.e. assessment or reassessment proceedings and proceedings under this provision merge into one. If assessment made under sub-section (1) is annulled in appeal or other legal proceedings, then

Narendra Kumar, New Delhi vs. ITO, Ward- 44(2), New Delhi

In the result, Ground No. 1 of the assessee is allowed

ITA 1218/DEL/2019[2012-13]Status: DisposedITAT Delhi19 Jul 2023AY 2012-13

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

For Appellant: & Sh. Anchit Jain, CAFor Respondent: Sh. Arvind Kumar Bansal
Section 132Section 132(4)Section 147Section 148Section 153CSection 68

said fact has been admitted by the Chairman of the Group in a concession recorded u/s 132(4) of the Act. The A.O. initiated reassessment proceedings u/s 147 of the Act on the basis of information received based on material qua, the assessee found during the search conducted on 27/06/2013

Mrs Sunita Shyam Malpani, Mumbai vs. Income Tax Officer, Ward 25(1)(3), Mumbai

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

ITA 344/MUM/2023[2010-2011]Status: DisposedITAT Mumbai18 Jul 2023AY 2010-2011

Bench: Shri Pavan Kumar Gadalesunita Shyam Malpani, Vs. Ito 25(1)(3), 701,Plot No.117, Room No.703, Karanapartment, Kautilyabhavan, Lokhandwalacomplex, Bandra Bkc, Andheri (W), Mumbai-400051. Mumbai-400053. "थायी लेखा सं./जीआइआर सं.Pan/Gir No.Acppm8552J (अपीलाथ"/Applicant) (""यथ"/Respondent)

Section 10Section 143Section 144ASection 148Section 250Section 68Section 69C

Since, the grounds of appeal on merits are decided in favour of the asssessee, hence the grounds of appeal with respect to validity of reassessment proceedings raised by the assessee becomes academic and are left open. 14. In the result, the appeal filed by the assessee is allowed. Order pronounced

M/S Super Emirates Exports, Mumbai vs. ITO -Ward 28(3)(3), Mumbai

In the result, both the appeal of the assessee are allowed for statistical purposes

ITA 1314/MUM/2023[2012-2013]Status: DisposedITAT Mumbai18 Jul 2023AY 2012-2013

Bench: Shri Aby T Varkey & Shri Amarjit Singhita Nos.1312 & 1314/Mum/2023 (A.Ys. 2011-12 To 2012-13)

For Appellant: Dinkle HariaFor Respondent: Suresh D. Gaikwad
Section 145Section 147

called for. WITHOUT PREJUDICE TO THE ABOVE 3. REASSESSMENT 3.1 The Ld. CIT (A) erred in confirming the action of the AO. in initiating reassessment proceedings and framing the assessment of the Appellant by invoking the provisions of section 147 r.ws 148 of the Income

M/S Super Emirates Exports, Mumbai vs. ITO-Ward 28(3)(3), Mumbai

In the result, both the appeal of the assessee are allowed for statistical purposes

ITA 1312/MUM/2023[2011-2012]Status: DisposedITAT Mumbai18 Jul 2023AY 2011-2012

Bench: Shri Aby T Varkey & Shri Amarjit Singhita Nos.1312 & 1314/Mum/2023 (A.Ys. 2011-12 To 2012-13)

For Appellant: Dinkle HariaFor Respondent: Suresh D. Gaikwad
Section 145Section 147

called for. WITHOUT PREJUDICE TO THE ABOVE 3. REASSESSMENT 3.1 The Ld. CIT (A) erred in confirming the action of the AO. in initiating reassessment proceedings and framing the assessment of the Appellant by invoking the provisions of section 147 r.ws 148 of the Income

M/S. Steecon Infrastructure, Jodhpur vs. ITO, Ward-1(4), Jodhpur

In the result, the appeal of the assessee is dismissed

ITA 61/JODH/2019[2012-13]Status: DisposedITAT Mumbai18 Jul 2023AY 2012-13

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2012-13 M/S Steecon Infrastructure Income Tax Officer 1(4) 85, Subhash Nagar, Pal Road, Paota Jodhpur- 242008 Vs. Jodhpur- 342008 Pan No. Acdfs3423Q Appellant Respondent

For Appellant: Mr. Piyush Chajed and Mr SumitFor Respondent: Mr. Virabhadra S. Mahajan, AR
Section 131Section 142(1)Section 143(3)Section 147Section 148

name of the firm M/s Devidayal & Sons and it was served on Shri Amirchand, one of the erstwhile partners. In the said reassessment proceeding, the Income tax officer made an addition of ₹ 3,00,926/- to the original assessed income. On appeal, learned first appellate authority upheld the order ... discontinuance of the business? The notice for the imposition of the penalty under section 28 was issued on the day on which the reassessment proceedings in respect of the escaped pre-dissolution income was completed and the said escaped income was brought to tax. In that case, the reassessment

ITO, Ward-24(1), New Delhi vs. Soumya Tradecom Pvt Ltd (Erst. Soumya Infratech (P)Ltd.), Aligarh

In the result, the appeal of revenue is dismissed

ITA 1095/DEL/2021[2011-12]Status: DisposedITAT Delhi18 Jul 2023AY 2011-12

Bench: Shri Chandra Mohan Garg & M.Balaganeshassessment Year: 2011-12 Ito, Ward-24(1), New Delhi M/S Soumya Tradecom Pvt. Ltd., (Erst. Soumya Infratech (P) Ltd.,) Vs. Room No. 91, Devika Tower, Nehru Place, South Delhi, Delhi 110019 Pan Aalcs 1040 G (Appellant) (Respondent) For Assessee : Shri Sunil Kuamr Gupta, Ca Revenue For : Shri Raghunath, Sr. Dr Date Of Hearing : 04.05.2023 Date Of Pronouncement : 18.07.2023 Order Per Chandra Mohan Garg, J.M. This Appeal Has Been Filed Against The Order Cit(A)-28, New Delhi Dated 07.07.2020 For A.Y. 2011-12. 2. The Grounds Have Been Raised By The Revenue Are As Follows:- 1. "Whether, On The Facts & Circumstances Of The Case & Law, The Ld. Cit(A) Is Justified In Deleting The Addition Of Rs. 4,97,14,844/- Made On Account Of Share Application Mony & Share Capital." 2. "The Ld. Cit(A) Has Failed To Take Notice Of The Reason Recorded Wherein The Then Ao Had Mentioned Amount Of Rs. 4,43,84,8441- & While Framing Of Reason, The Ao Had Mentioned Escapement Of Income At Least Of Rs. 1,00,000/- Which Has Broader Prospective. 3. "The Ld. Cit(A) Has Failed To Appreciate That "Approved" Connotes That Competent Authority Has Read & Understood Fully The Proposal Proposed By Ao & He Is Satisfied That The Case Is Fir For Reopening Us 148 Of The I.T. Act." 4. "The Ld. Cit(A) Has Failed To Appreciate The Bogus Nature Of Transactions As The Assessee Company Did Not Provide Relevant Documents Before A To Establish The Genuineness Of The Transactions So Undertaken." 5. The Ld. Cit(A) Has Failed To Appreciate That Onus Of Proving Transaction As Bogus Nature On Ao Comes Only After Discharge Of Onus By Assessee By Giving All Relevant Documents Which Assessee Failed To Discharge During Assessment Proceedings. Application Of Revenue Seeking Condonation Of Delay Of 255 Days.

For Appellant: Shri Sunil Kuamr Gupta, CA
Section 151

drawing our attention towards paras 4 to 4.7 of first appellate order submitted that the ld. CIT(A) has quashed initiation of reassessment proceedings and consequent reassessment order by rightly following the preposition of Hon’ble jurisdictional High Court of Delhi in the case of CIT vs. N C Cables ... therefore, respectfully following the decision of the Apex Court & Jurisdictional High Court in the case of N C Cables (supra), we hold that the reassessment proceedings are bad in law. Accordingly, the same was rightly quashed by the ld. CIT(A). We are unable to see any valid reason

Aruna Tiwari, Raipur vs. Principal Commissioner of Income Tax-1, Raipur

ITA 90/RPR/2022[2015-16]Status: DisposedITAT Raipur18 Jul 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 90/Rpr/2022 "नधा"रण वष" / Assessment Year : 2015-16 Smt. Aruna Tiwari 762, Sundar Nagar, Raipur (C.G.)-492 001 Pan: Adbpt4977B .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax-1, Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Nikhilesh Begani, CAFor Respondent: Shri V.K Singh, CIT-DR
Section 142(1)Section 143(3)Section 263

आयकर अपील"य अ"धकरण "यायपीठ रायपुर म"। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI RAVISH

Milan Shantilal Mehta, Mumbai vs. The Income Tax Officer Ward 2 (5), Thane

In the result, the appeal by the assessee is allowed

ITA 1199/MUM/2023[2010-2011]Status: DisposedITAT Mumbai17 Jul 2023AY 2010-2011

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri G.P. MehtaFor Respondent: Smt. Mahita Nair
Section 142(1)Section 143(1)Section 143(2)Section 144Section 147Section 148Section 250Section 271Section 271(1)(b)Section 274

section 142(1) of Milan Shantilal Mehta ITA no.1199/Mum./2023 the Act were issued to the assessee with a request to attend the reassessment proceedings. However, the assessee could not comply with the same. The assessee also did not comply with the notices issued thereafter. Accordingly, the Assessing Officer

M/S Blue City Township & Colonizers, Amritsar vs. The Income Tax Officer, Amritsar

ITA 90/ASR/2017[2009-10]Status: DisposedITAT Amritsar14 Jul 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 147Section 148Section 151Section 234ASection 69

Income Tax Act, 1961 are illegal, bad in law, without jurisdiction. 2. That on the facts and in the circumstances of the case, reassessment proceeding cannot be initiated under section 147 for the purpose of enquiry and verification. 3. That on the facts and in the circumstances of-the case ... Ground No. 1 and 2, the assessee has challenged the validity of the notice issued u/s 148 of the Act and the reassessment proceedings u/s 147 cannot be done for the purpose of enquiry or verification is bad in law and without jurisdiction. 4. The appellant assessee company’s case

Spectrum Infonet Pvt. Ltd., Raigarh vs. Pr. Commissioner of Income Tax (Central), Bhopal

In the result, appeal filed by the assessee in ITA No

ITA 34/RPR/2022[2011-12]Status: DisposedITAT Raipur14 Jul 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 33 & 34/Rpr/2022 "नधा"रण वष" / Assessment Years : 2010-11 & 2011-12 Spectrum Infonet Private Limited 601, South Gajanandpuram Colony, Kotra Road, Raigarh (C.G.)-496001 Pan : Aalcs5656E .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax (Central), Bhopal ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri V.K Singh, CIT-DR
Section 147Section 263

Cherry Vintrade Pvt Ltd. Nor any such details are available on record which show that such details were filed before the AO during the reassessment proceedings. 3. It is further seen that M/s Cherry Vintrade Pvt. Ltd. (vide SI. No. 10608) is an identified paper/bogus/shell company having director Shri Ashis

Spectrum Infonet Pvt. Ltd., Raigarh vs. Pr. CIT (Central), Bhopal

In the result, appeal filed by the assessee in ITA No

ITA 33/RPR/2022[2010-11]Status: DisposedITAT Raipur14 Jul 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 33 & 34/Rpr/2022 "नधा"रण वष" / Assessment Years : 2010-11 & 2011-12 Spectrum Infonet Private Limited 601, South Gajanandpuram Colony, Kotra Road, Raigarh (C.G.)-496001 Pan : Aalcs5656E .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax (Central), Bhopal ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri V.K Singh, CIT-DR
Section 147Section 263

Cherry Vintrade Pvt Ltd. Nor any such details are available on record which show that such details were filed before the AO during the reassessment proceedings. 3. It is further seen that M/s Cherry Vintrade Pvt. Ltd. (vide SI. No. 10608) is an identified paper/bogus/shell company having director Shri Ashis

Satya Pal, Gurgaon vs. ITO, Gurgaon

In the result all the three appeals of the assessees are partly allowed, as indicated above

ITA 3024/DEL/2017[2010-11]Status: DisposedITAT Delhi13 Jul 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadआ.अ.सं .I.T.A No. 3024/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satya Pal, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aabpy6152A A N D आ.अ.सं .I.T.A No. 3022/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satyabir Singh, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aacpy7890A A N D आ.अ.सं .I.T.A No. 3023/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Rati Ram, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aaopy3440Q अपीलाथ"/ Appellants ""थ"/ Respondents

For Appellant: Shri K. Sampath, Advocate; &
Section 143(3)Section 147Section 234ASection 253Section 54B

various other grounds on merit are not being adjudicated being academic in nature. Since the legal ground raised by the assessee challenging the reassessment proceedings are decided in favour of the assessee, the grounds raised by the Revenue in its appeal become infructuous and the same is accordingly dismissed

Rati Ram, Gurgaon vs. ITO, Gurgaon

In the result all the three appeals of the assessees are partly allowed, as indicated above

ITA 3023/DEL/2017[2010-11]Status: DisposedITAT Delhi13 Jul 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadआ.अ.सं .I.T.A No. 3024/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satya Pal, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aabpy6152A A N D आ.अ.सं .I.T.A No. 3022/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satyabir Singh, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aacpy7890A A N D आ.अ.सं .I.T.A No. 3023/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Rati Ram, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aaopy3440Q अपीलाथ"/ Appellants ""थ"/ Respondents

For Appellant: Shri K. Sampath, Advocate; &
Section 143(3)Section 147Section 234ASection 253Section 54B

various other grounds on merit are not being adjudicated being academic in nature. Since the legal ground raised by the assessee challenging the reassessment proceedings are decided in favour of the assessee, the grounds raised by the Revenue in its appeal become infructuous and the same is accordingly dismissed

Satyabir Singh Yadav, Gurgaon vs. ITO, Gurgaon

In the result all the three appeals of the assessees are partly allowed, as indicated above

ITA 3022/DEL/2017[2010-11]Status: DisposedITAT Delhi13 Jul 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadआ.अ.सं .I.T.A No. 3024/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satya Pal, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aabpy6152A A N D आ.अ.सं .I.T.A No. 3022/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satyabir Singh, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aacpy7890A A N D आ.अ.सं .I.T.A No. 3023/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Rati Ram, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aaopy3440Q अपीलाथ"/ Appellants ""थ"/ Respondents

For Appellant: Shri K. Sampath, Advocate; &
Section 143(3)Section 147Section 234ASection 253Section 54B

various other grounds on merit are not being adjudicated being academic in nature. Since the legal ground raised by the assessee challenging the reassessment proceedings are decided in favour of the assessee, the grounds raised by the Revenue in its appeal become infructuous and the same is accordingly dismissed

ITO, 20(2)(1), Mumbai vs. M/S J S Jube Traders, Mumbai

In the result, appeal filed by the Revenue is dismissed and cross objection filed by the assessee is partly allowed

ITA 410/MUM/2023[2011-12]Status: DisposedITAT Mumbai12 Jul 2023AY 2011-12

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Ble & Income Tax Officer-20(2)(1) V. M/S. J.S Tube Traders Room No. 216, 2Nd Floor 337, Signal Hill Piramal Chambers, Lalbaug Opp Vihar Hotel, Avenue Road Darukhana, Mumbai- 400010 Parel, Mumbai- 400012 Pan: Aaafj2901K (Appellant) (Respondent)

Section 133(6)Section 143(1)Section 143(2)Section 147Section 148

assessee. In response Authorised Representative of the assessee attended and submitted the relevant information as called for. 3. During the course of reassessment proceedings, the assessee was asked to prove the genuineness of the purchases made from various dealers as referred at Page No. 2 of the Assessment Order