← 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- 17(2), New Delhi vs. National Fertilizers Ltd., New Delhi

In the result, the appeal of the assessee is allowed and that of the Revenue is dismissed

ITA 5547/DEL/2017[2006-07]Status: DisposedITAT Delhi01 Mar 2023AY 2006-07

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Ved Jain, AdvFor Respondent: Sh. Atiq Ahmad, Sr. DR
Section 143(3)Section 148

facts and circumstances of the case, the learned CIT(A) has erred in rejecting the contention of the assessee that the reassessment proceedings initiated by the learned A.O. are bad in the eye of law as the reasons recorded for the issue of notice under Section

National Fertilizers Ltd., New Delhi vs. ACIT, Circle-13(1), New Delhi

In the result, the appeal of the assessee is allowed and that of the Revenue is dismissed

ITA 4723/DEL/2017[2006-07]Status: DisposedITAT Delhi01 Mar 2023AY 2006-07

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Ved Jain, AdvFor Respondent: Sh. Atiq Ahmad, Sr. DR
Section 143(3)Section 148

facts and circumstances of the case, the learned CIT(A) has erred in rejecting the contention of the assessee that the reassessment proceedings initiated by the learned A.O. are bad in the eye of law as the reasons recorded for the issue of notice under Section

Narayan Securities Ltd, New Delhi vs. DCIT Circle-17(2), New Delhi

In the result, this appeal is treated as partly allowed

ITA 7768/DEL/2019[2011-12]Status: DisposedITAT Delhi28 Feb 2023AY 2011-12
Section 143(3)Section 147Section 148

appeal are as under: “1. That the Commissioner of Income Tax Appeals[‘CIT(A)’]erred on facts and in law in upholding validity of reassessment proceedings initiated under section 147 through the issuance of notice under section 148 of the Page 1 of 5 Narayan Securities Ltd. Vs DCIT Income ... That the CIT(A) erred on facts and in law in holding that the appellant was precluded from raising objections to assumption/validity of reassessment proceedings in view of provisions of 292BB of the Act without appreciating that the said provision only precluded the assessee from raising objections relating to service

Sh. Joginder Singh S/O. Sh. Gurdial Singh, Bathinda vs. Income Tax Officer, Bathinda

Appeal of the assessee is disposed of in the terms indicated as above

ITA 198/ASR/2019[2009-10]Status: DisposedITAT Amritsar28 Feb 2023AY 2009-10

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

For Appellant: Sh. P. N. Arora, AdvFor Respondent: Mrs. Kanchan Garg, Sr. DR
Section 147Section 148Section 149Section 150Section 153(3)

sustained. 7 Joginder Singh v. ITO 5. Next issue is regarding addition of Rs.38,59,220/- made by the Assessing Officer in the reassessment proceedings being unaccounted investment in purchase of land. 6. The Ld. CIT(A) has although granted relief to the appellant in the terms indicated here under

Shreenathji Infrastructure P.Ltd., Pipariya vs. Assistant Commissioner of Income Tax, Itarsi

ITA 314/IND/2018[2014-15]Status: DisposedITAT Indore28 Feb 2023AY 2014-15

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

Section 147Section 80Section 80I

assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case ... assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case

Shreenathji Infrastructure P.Ltd., Pipariya vs. Assistant Commissioner of Income Tax, Itarsi

ITA 313/IND/2018[2013-14]Status: DisposedITAT Indore28 Feb 2023AY 2013-14

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

Section 147Section 80Section 80I

assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case ... assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case

Shreenathji Infrastructure P.Ltd., Pipariya vs. Deputy Commissioner of Income Tax, Itarsi

ITA 312/IND/2018[2012-13]Status: DisposedITAT Indore28 Feb 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

Section 147Section 80Section 80I

assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case ... assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case

Shreenathji Infrastructure P.Ltd., Pipariya vs. Assistant Commissioner of Income Tax, Itarsi

ITA 311/IND/2018[2010-11]Status: DisposedITAT Indore28 Feb 2023AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

Section 147Section 80Section 80I

assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case ... assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case

Shreenathji Infrastructure P.Ltd., Pipariya vs. Assistant Commissioner of Income Tax, Itarsi

ITA 310/IND/2018[2009-10]Status: DisposedITAT Indore28 Feb 2023AY 2009-10

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

Section 147Section 80Section 80I

assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case ... assessment. Further, there being no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, the reassessment proceedings are bad in law. (2) That on the facts and in the circumstances of the appellant’s case

ACIT Central Circle-19, New Delhi vs. Chanchal Taneja, New Delhi

In the result, appeal of Revenue is dismissed

ITA 1874/DEL/2019[2010-11]Status: DisposedITAT Delhi24 Feb 2023AY 2010-11

Bench: Sh. Anil Chaturvedi & Sh. Yogesh Kumar Usacit Vs. Chanchal Taneja Central Circle – 19, F-19/89, Sec-15, New Delhi Rohini, New Delhi Pan No. Acspt 2316 F (Appellant) (Respondent) Assessee By Shri Ravi Pratap, Adv. Revenue By Shri T. James Singson, Cit-D.R. Date Of Hearing: 16.02.2023 Date Of Pronouncement: 24.02.2023 Order Per Anil Chaturvedi, Am : This Appeal Filed By The Revenue Is Directed Against The Order Dated 27.12.2018 Of The Commissioner Of Income Tax (Appeals)-24, New Delhi Relating To Assessment Year 2010-11. 2. Brief Facts Of The Case As Culled Out From The Material On Record Are As Under :-

Section 132Section 139Section 148Section 153ASection 68

premises on 30.03.2016. So it is very clear that on the date of the initiation of search i.e. 30.03.2016, no assessment or reassessment proceedings in the case of appellant was pending and therefore in view of the second proviso to section 153A of the Act, there cannot be any case ... assessment or reassessment proceedings for A.Y. 2010-11 getting abated. 5.4 Since the search was conducted at the premises of the appellant, therefore, as per the provisions of section 153A of the ACIT Vs. Chanchal Taneja 5 Act, the AO was required to issue notice u/s 153A

Subhash Gujar, Jhajjar vs. ITO, Ward-4, Rohtak

Appeal is dismissed

ITA 6053/DEL/2018[2007-08]Status: DisposedITAT Delhi24 Feb 2023AY 2007-08

Bench: Shri Kul Bharat

Section 142(1)Section 143(2)Section 143(3)Section 148

case on the issue of 292BB is covered by following judgments:- 383 ITR 455 (Del) Silver Line:- The failure of the Assessing Officer, in reassessment proceedings, to issue notice under section 143(2) of the Act, prior to finalizing the reassessment order, cannot be condoned by referring to section 292BB

Sri.John Mathew N, Alappuzha vs. The ITO, WD-2, Alappuzha

In the result, the appeal by the assessee is dismissed

ITA 81/COCH/2018[2001-02]Status: DisposedITAT Cochin24 Feb 2023AY 2001-02

Bench: Shri Sanjay Arora & Shri Sandeep Gosainshri John Mathew N. The Income Tax Officer Neroth House Ward - 2, Alleppey Vs. No. 1, Jubilee Road Alappuzha [Pan: Acupm8885D] Appellant Respondent Appellant By: Shri Anil D. Nair & Shri P.K. Biju, Advocates Respondent By: Smt. J.M. Jamuna Devi, Sr. D.R. Date Of Hearing: 03.02.2023 Date Of Pronouncement: 24.02.2023 O R D E R Per Bench This Appeal By The Assessee Challenges The Validity Of The Reassessment Under Section 147 Read With Section 143(3) Of The Income Tax Act, 1961 (‘The Act’ Hereinafter) Dated 20.11.2007 For Assessment Year (Ay) 2001-02, Since Upheld In First Appeal Vide Order Dated 24.01.2018 By The Commissioner Of Income Tax (Appeals), Kottayam (‘Cit(A)’ For Short). 2.1 At The Outset, Shri Anil D. Nair, The Ld. Counsel For The Assessee-Appellant, Would Submit That The Basis Of The Assessee’S Challenge Is Two-Fold: (A) Non-Supply Of The Reasons Recorded; & (B) True & Full Disclosure Of All Material Facts Relating To The Income Escaping Assessment By The Assessee Per His Return Of Income.

For Appellant: Shri Anil D. Nair &For Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(2)Section 143(3)Section 147Section 148(2)Section 230ASection 234B

much so, he claims that in view of the said disclosure, the claim ought to be deemed to have been accepted, failing the reassessment proceedings. How we wonder, it then lies in the assessee’s mouth to contend that he was not aware of the reasons recorded. The two reasons ... which the assessee seeks to assail the reassessment proceedings are in fact contradictory. 4 M/s. Kunnummakkara Service/Income Tax Officer, W(2)(2) 3.2 The second reason, i.e., as to true and full disclosure, is, again, not valid inasmuch as the time limitation of four years (from

Kishorbhai Chhaganbhai Andipara, Rajkot vs. ITO, Ward-1(2)(1), Rajkot

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

ITA 199/RJT/2022[2011-12]Status: HeardITAT Rajkot24 Feb 2023AY 2011-12

Bench: The Income Tax Officer, Rajkot. As The Net Taxable Income For The Assessment Year 2011-12 Was Below The Basic Exemption Limit, The Assessee Has Not Filed The Return Of Income U/S. 139 Of The Act.

Section 139Section 144Section 147Section 148

Saving Bank Account with Rajkot Nagrik Sahakari Bank Ltd. However no Return of Income was filed by the assessee. Therefore the Assessing Officer initiated reassessment proceedings u/s. 147 of the Act by issuing a notice u/s. 148 of the Act dated 21.03.2018. The assessee has not responded to the above

Shiv Kumar Sharma, New Delhi vs. ACIT, Circle-57(1), New Delhi

In the result, appeal of Assessee is allowed

ITA 4329/DEL/2019[2012-13]Status: DisposedITAT Delhi23 Feb 2023AY 2012-13

Bench: Shri Anil Chaturvedi & Shri C.M. Garg

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Ms Kirti Sankratyayan, Sr. DR
Section 131Section 132Section 132(4)Section 147Section 148

aside the Orders of the authorities below and delete the addition of Rs.19,75,000/-. 8. Both the parties also argued on initiation of reassessment proceedings and have also cited various case Laws and Ld. D.R. also submitted written submissions. However, in view of the fact that addition on merit

ACIT, Circle-64(1), New Delhi vs. Gurnihal Singh Pirzada, Chandigarh

ITA 3952/DEL/2019[2013-14]Status: DisposedITAT Delhi23 Feb 2023AY 2013-14

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No. 3947/Del/2019, A.Y. 2008-09 Ita No.3952/Del/2019, A.Y. 2013-14

Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

impugned order had sustained the contention on behalf of the assessee that mandatory notice u/s 143(2) at the time of reassessment proceedings was not issued and served upon the assessee subsequent to filing of return by it. 3. Relevant here is to state that Ld. CIT(A) vide letter ... available record on assessment file.” 4. Consequently concluding that no notice u/s 143(2) was issued or served subsequently to initiation of reassessment proceedings and taking notice of various judicial pronouncements submitted on behalf of the appellant assessee the Ld. CIT(A) held the reassessment proceedings were invalid and accordingly

ACIT, Circle-64(1), New Delhi vs. Gurnihal Singh Pirzada, Chandigarh

ITA 3947/DEL/2019[2008-09]Status: DisposedITAT Delhi23 Feb 2023AY 2008-09

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No. 3947/Del/2019, A.Y. 2008-09 Ita No.3952/Del/2019, A.Y. 2013-14

Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

impugned order had sustained the contention on behalf of the assessee that mandatory notice u/s 143(2) at the time of reassessment proceedings was not issued and served upon the assessee subsequent to filing of return by it. 3. Relevant here is to state that Ld. CIT(A) vide letter ... available record on assessment file.” 4. Consequently concluding that no notice u/s 143(2) was issued or served subsequently to initiation of reassessment proceedings and taking notice of various judicial pronouncements submitted on behalf of the appellant assessee the Ld. CIT(A) held the reassessment proceedings were invalid and accordingly

Sumangal Techpark (P) Ltd, New Delhi vs. ITO Ward - 24(3), New Delhi

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

ITA 3840/DEL/2019[2010-11]Status: DisposedITAT Delhi23 Feb 2023AY 2010-11

Bench: Shri Anil Chaturvedi & Shri C.M. Gargassessment Year: 2010-11 Sumangal Techpark (P) Ltd., Vs. Ito, 117, Hans Bhawan, Ward-24(3), 1 Bsz Marg, New Delhi. New Delhi. Pan: Aalcs4760R (Appellant) (Respondent) Assessee By : Shri S.K. Gupta, Ca Revenue By : Ms Kirti Sankratyayan, Sr. Dr Date Of Hearing : 19.12.2022 Date Of Pronouncement : 23.02.2023 Order Per C.M. Garg, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.02.2019 Of The Cit(A)-8, New Delhi, Relating To Assessment Year 2010-11. 2. First Of All, We Have Heard The Arguments Of Both The Representatives On Legal Ground No.1 Of The Assessee Which Reads As Under:- “3. The Initiation Of The Proceedings U/S 148 & The Consequent Order Us 147 Are Bad In Law As A) The Initiation Of Proceedings U/S 148 Are Contrary To Provisions Of Law B) The Mandatory Procedure Laid Down In The Act Has Not Been Followed. C) The Notice Issued U/S 148 Is Time Barred As Issued After 4 Years From The End Of The Relevant Assessment Year Where The Case Has Already Been Assessed U/S 143(3). D) The Approval Of Addl. Cit & Pcit Is Bad In Law & Mechanical Without Application Of Mind & Has Been Taken Without Bringing To Their Notice Material Facts Of The Case. E) The Information Has Been Collected Behind The Back Of The Assessee & The Assessee Was Never Confronted With The Same Nor An Opportunity Provided For Cross-Examination Of Jain Brothers, Alleged Intermediary & The Relevant Seized Material Relied Upon Has Not Been Provided To The Assessee.”

For Appellant: Shri S.K. Gupta, CAFor Respondent: Ms Kirti Sankratyayan, Sr. DR
Section 143(3)Section 147Section 148Section 151Section 292B

12360/2018 td: 21.05.2019 in para 23. Further, the Hon'ble Bench of Delhi ITAT in the following cases has quashed the reassessment proceedings for initiation of proceeding by invoking repealed provision of sec 147(b) of IT Act: • M/s VRC Township P Ltd ITA No. 1503/Del/2017 dt: 14.10.2020; • M/s Maheshwari ... authority have acted mechanically in granting sanction u/s 151 of the Act. Such mechanical approval was found to be fatal for validity of the reassessment proceedings as decided by the co-ordinate Hon’ble Delhi Bench in the RMP Holdings P Ltd ITA No.7243/Del/2019 dt: 31.07.2020 wherein it was held

The ACIT-Central Circle-2, Rajkot vs. Shri Vicky Balkrishna Mehta, Rajkot

The appeal of the Revenue is dismissed

ITA 130/RJT/2020[2004-05]Status: DisposedITAT Rajkot22 Feb 2023AY 2004-05

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2004-05 Assistant Commissioner Of Vs. Shri Vicky Balkrishna Mehta, Income-Tax, 7Th Floor, Mansrovar Central Circle-2, Apartment, Royal Park, Rajkot Kalawad Road, Rajkot Pan : Agqpm 6495 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 28.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 22.02.2023 आदेश/O R D E R Per Annapurna Gupta: This Appeal Is Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-13, Ahmedabad (Hereinafter Referred To As “Cit(A)”) Dated 22.01.2020 Passed U/S 250(6) Of The Income-Tax Act, 1961, (Hereinafter Referred To As “The Act”) For Assessment Year (Ay) 2004-05. 2. The Grounds Of Appeal Raised By The Revenue Read As Under:

For Appellant: Shri D.M. Rindani, ARFor Respondent: Shri Shramdeep Sinha, CIT-DR
Section 147Section 148Section 149Section 149(1)(c)Section 149(3)Section 250(6)

assessee under Section 147 of the Act to be not fulfilled. 4. As it transpires from the orders of the authorities below, reassessment proceedings were initiated on the assessee by issuing notice under Section 148 of the Act on 27.02.2015. The impugned year before ... held that the notice in the present case had been also issued beyond the limit prescribed under the Act. He accordingly quashed the reassessment proceedings and subsequently the order passed to be held as invalid. It is aggrieved by this order of the learned CIT(A) that the Department

Nya International, Surat vs. Principal Commissioner of Income Tax - 1, Surat

In the result, appeal filed by the assessee is allowed

ITA 57/SRT/2022[2012-13]Status: DisposedITAT Surat22 Feb 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.57/Srt/2022 "नधा"रणवष"/Assessment Year: (2012-13) (Physical Court Hearing) Nya International, Vs. The Pcit-1, Unit No.360, Plot No.239, Sez, Gidc Surat. Sachin, Suarat – 394230. (Assessee) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfn1681M

Section 10ASection 143(3)Section 148Section 263

147/148 of the Act and then after assessment order was framed under section 143(3) r.w.s 147 of the Act dated 28.12.2019. In the reassessment proceedings, the Assessing Officer has raised mainly two issues, first is undisclosed bank account and second is deduction under section 10AA of the Act. During ... reassessment proceedings, the assessee has submitted the information regarding the undisclosed bank account and the information regarding deduction under section 10AA of the Act. The Assessing Officer has examined both the issues which were the subject matter of reassessment proceedings and disallowed the deduction of the assessee under section 10AA

Income Tax Officer, Ward-2(3)(8), Surat vs. Sanjaykumar Devkishan Panwar, Surat

In the result the ground No

ITA 588/SRT/2019[2008-09]Status: DisposedITAT Surat22 Feb 2023AY 2008-09

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.569/Srt/2019 Assessment Year: (2008-09) (Physical Court Hearing) Sanjaykumar Devkishan Panwar, Vs. The Ito, Ward-2(3)(8), 207, 2Nd Floor, 6/2060/61 Vedant Surat. Building Bojabhai Ni Sheri, Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aovpp8989A (Revenue)/(Appellant) (Assessee)/(Respondent) आयकर अपील सं./Ita No.588/Srt/2019 Assessment Year: (2008-09) The Ito, Ward-2(3)(8), Vs. Sanjaykumar Devkishan Panwar, 207, 2Nd Floor, 6/2060/61 Vedant Surat. Building Bojabhai Ni Sheri, Mahidharpura, Surat – 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aovpp8989A (Revenue)/(Appellant) (Assessee)/(Respondent) Assessee By Shri Rohit Vijayvargia, Ca Shri Ritesh Mishra, Cit(Dr) Respondent By Date Of Hearing 03/02/2023 Date Of Pronouncement 20/02/2023

Section 143(3)Section 147Section 148

there is no failure on the part of the assessee to disclose fully and truly, all facts necessary for making the original assessment, therefore reassessment proceedings are bad in law and hence it should be quashed. 13. In respect of additional grounds raised by the assessee, the Ld. Counsel submitted ... failure on the part of the assessee to disclose fully and truly, all material facts necessary for making the original assessment, therefore reassessment proceedings should be quashed’ is not acceptable. We note that there was a fresh information with the AO that assessee made bogus purchases without taking delivery