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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

Amish Anantrai Modi, Mumbai vs. Central Circle 2(1), Mumbai

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

ITA 6282/MUM/2025[2013-2014]Status: DisposedITAT Mumbai21 Jan 2026AY 2013-2014

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 143(3)Section 147Section 148Section 153C

objections filed by the assessee against the reasons recorded for reopening were not disposed of by the Assessing Officer prior to completion of the reassessment proceedings, thereby rendering the assumption of jurisdiction itself vitiated in law. The challenge thus raised strikes at the root of the proceedings and goes ... framing of the said assessment. 4. It was further submitted that subsequent to the quashing of the said assessment, the Assessing Officer initiated reassessment proceedings under section 147 of the Act, not on the same footing as the earlier addition on alleged bogus long- term capital gains, but this time

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5375/MUM/2025[2013-14]Status: DisposedITAT Mumbai21 Jan 2026AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

For Appellant: Mr. Annavaram Kosuri, SR-DR a/wFor Respondent: Mr. Rajesh Shah
Section 147Section 68

return filed in response to the said notice. Thereafter, statutory return filed in response to the said notice. Thereafter, statutory notices were issued and reassessment proceedings were initiated. issued and reassessment proceedings were initiated. issued and reassessment proceedings were initiated. 4.4 During the reassessment proceedings, the assessee contested During ... reassessment proceedings, the assessee contested During the reassessment proceedings, the assessee contested the allegations on multiple grounds. It was submitted, inter alia, the allegations on multiple grounds. It was submitted, inter alia, the allegations on multiple grounds. It was submitted, inter alia, that the allegation of accommodation entries was based

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5374/MUM/2025[2011-12]Status: DisposedITAT Mumbai21 Jan 2026AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan()

For Respondent: Mr. Rajesh Shah
Section 147Section 250Section 68

return of income filed on 28.09.2009 be treated as the return filed in response to the said notice. Thereafter, statutory notices were issued and reassessment proceedings were initiated. 4.4 During the reassessment proceedings, the assessee contested the allegations on multiple grounds. It was submitted, inter alia, that the allegation ... assessment. All the grounds relating to reopening of assessment are hereby dismissed." It can be seen from the above that even though the reassessment proceedings were started in 30.3.2016, the documentary evidences were submitted at the eleventh hour ie. on 30.12.2016 on which day the AO completed the assessment

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5373/MUM/2025[2012-13]Status: DisposedITAT Mumbai21 Jan 2026AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan()

For Respondent: Mr. Rajesh Shah
Section 147Section 250Section 68

return of income filed on 28.09.2009 be treated as the return filed in response to the said notice. Thereafter, statutory notices were issued and reassessment proceedings were initiated. 4.4 During the reassessment proceedings, the assessee contested the allegations on multiple grounds. It was submitted, inter alia, that the allegation

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5372/MUM/2025[2010-11]Status: DisposedITAT Mumbai21 Jan 2026AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan()

For Respondent: Mr. Rajesh Shah
Section 147Section 250Section 68

return of income filed on 28.09.2009 be treated as the return filed in response to the said notice. Thereafter, statutory notices were issued and reassessment proceedings were initiated. 4.4 During the reassessment proceedings, the assessee contested the allegations on multiple grounds. It was submitted, inter alia, that the allegation

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5371/MUM/2025[2009-10]Status: DisposedITAT Mumbai21 Jan 2026AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

For Appellant: Mr. Annavaram Kosuri, SR-DR a/wFor Respondent: Mr. Rajesh Shah
Section 147Section 68

return filed in response to the said notice. Thereafter, statutory return filed in response to the said notice. Thereafter, statutory notices were issued and reassessment proceedings were initiated. issued and reassessment proceedings were initiated. issued and reassessment proceedings were initiated. 4.4 During the reassessment proceedings, the assessee contested During ... reassessment proceedings, the assessee contested During the reassessment proceedings, the assessee contested the allegations on multiple grounds. It was submitted, inter alia, the allegations on multiple grounds. It was submitted, inter alia, the allegations on multiple grounds. It was submitted, inter alia, that the allegation of accommodation entries was based

A.B. Exports Private Limited, New Delhi vs. Income Tax Officer Ward -9(1)(1), Mumbai

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

ITA 4760/MUM/2025[2008-09]Status: DisposedITAT Mumbai21 Jan 2026AY 2008-09

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 132Section 132(4)Section 143(3)Section 147Section 68

alleged unexplained expenditure by way of commission. 4. The factual matrix, in brief but in necessary detail, is that the Assessing Officer initiated reassessment proceedings under section 147 of the Act on the basis of information received from the Investigation Directorate, Mumbai, to the effect that a search and seizure ... Limited (Earlier known as Lexus Infotech Ltd) 5 Yash-V Jewels Private AAACY1119P 1,00,00,000 Limited 5. During the course of the reassessment proceedings, the Assessing Officer issued various statutory notices and show cause communications calling upon the assessee to explain as to why the aforesaid transactions should

Charanjit Kaur, New Delhi vs. Income Tax Officer, Civic Centre, New Delhi

In the result, the appeal is dismissed

ITA 8558/DEL/2025[2017-18]Status: DisposedITAT Delhi21 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Mrs. Charanjit Kaur, Vs. Income Tax Officer, F-Ic, Iind Floor, Tilak Nagar Ward-69(1), S.O. (West Delhi), Tilak New Delhi Nagar, West Delhi, New Delhi Pan: Aegpk6308F (Appellant) (Respondent) Assessee By None Department By Sh. Manoj Kumar, Sr. Dr

Section 147Section 148Section 69

meaning of section 147 of the Income Tax Act, 1961. Accordingly, a notice under section 148 was issued on 27.03.2021. During the course of reassessment proceedings, despite issuance of statutory notices and opportunities afforded, the appellant did not furnish any credible evidence explaining the source of the said cash investment

Sh. Mukesh Singla & Sons (HUF), Delhi vs. Deputy Commissioner of Income Tax, Delhi

In the result, the Assessee’s appeal is partly allowed

ITA 4836/DEL/2025[2014-15]Status: DisposedITAT Delhi21 Jan 2026AY 2014-15

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Bleasstt. Year : 2014-15 Sh. Mukesh Singla & Sons (Huf), Vs. Dcit, Circle 28(1), 64, Bhagwan Budha New Delhi Cooperative Society, Second Floor, Pitampura, Delhi – 110 034 (Pan: Aaihm2755E) (Appellant) (Respondent) Appellant By : Dr. Rakesh Gupta, Adv. & Sh. Saksham Agrawal, Ca Respondent By : Sh. A.K. Arora, Sr. Dr.

For Appellant: Dr. Rakesh Gupta, Adv. & Sh. SakshamFor Respondent: Sh. A.K. Arora, Sr. DR
Section 142(1)Section 271(1)(b)

failed to comply with the notices issued u/s. 142(1) dated 26.11.2021, 11.02.2022, 02.3.2022 and 9.3.2022 by the AO during the course of reassessment proceedings. It was further submitted that assessee could not make necessary compliance to the said notices for the reason that the Karta of the assessee

DCIT Central Circle 1 Delhi, Delhi vs. Sahara India Financial Corporation Ltd, Lucknow

ITA 4679/DEL/2025[2010-11]Status: DisposedITAT Delhi21 Jan 2026AY 2010-11
Section 142Section 250Section 269SSection 271D

ITA No.4679/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH "B"NEW DELHI BEFORE SHRI MAHAVIR SINGH, HON'BLE VICE

Mr. Abhishek Dixit, Gurugram vs. DDIT/ADIT( in Tax.), Noida

In the result, appeal of the assessee is allowed

ITA 414/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Jan 2026AY 2016-17

Bench: Shri Sudhir Pareek & Shri Brajesh Kumar Singh

Section 147Section 148Section 151

ACIT [(2024) 166 taxmann.com 61(Delhi)], it was submitted that it is a settled proposition that no addition can be sustained in the reassessment proceedings u/s 147 where the very ground forming the basis of reopening is ultimately dropped. The relevant extract of the AR’s submission in para ... assessing officer to make any further addition on any other ground(s). It is a settled proposition that no addition can be sustained in reassessment proceedings under section 147 where the very ground forming the basis of reopening is ultimately dropped. The jurisdiction of the Assessing Officer is confined

M/S. South West Pinnacle Exploration Limited, Gurugram vs. ACIT, Circle-24(1), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 4076/DEL/2025[2014-15]Status: DisposedITAT Delhi21 Jan 2026AY 2014-15

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarm/S. South West Pinnacle Exploration Limited, Vs. Acit, Circle 24 (1), Plot No.6, 4Th Floor, Sector 44, New Delhi. Gurugram – 122 003 (Haryana). (Pan : Aakcs3608R) (Appellant) (Respondent) Assessee By : Shri I.P. Bansal, Advocate Shri Vivek Bansal, Advocate Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 25.11.2026 Date Of Order : 21.01.2026 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-24, New Delhi [“Ld. Cit (A)”, For Short] Dated 17.06.2025 For The Assessment Year 2014-15. 2. At The Outset, Ld. Ar Of The Assessee Submitted That The Issues Involved In The Present Appeal Are Squarely Covered By Various Decisions & He Heavily Relied Upon The Decision Of The Coordinate Bench In The Case Of Real Innerspring Technologies Pvt. Ltd. Vs. Acit (2025) 174

For Appellant: Shri I.P. Bansal, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR
Section 131(1)(d)Section 142(1)Section 143(2)

order and held as under :- 16 “10. Considered the rival submissions and material placed on record. We observed that the AO has initiated reassessment proceedings on the basis of information received from the Investigation Wing and search proceedings in the case of Shri Verma. It is brought on record that

Dharamvir Khosla vs. DCIT CC-5, New Delhi

ITA 3977/DEL/2025[2020-21]Status: DisposedITAT Delhi21 Jan 2026AY 2020-21

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Sh. Rajiv Saxena, AdvFor Respondent: Sh. Mahesh Kumar, CIT, DR
Section 139Section 139(1)Section 143(1)Section 153CSection 32(1)(ii)

Page 1 ITA Nos. 3976 & 3977/Del/2025 DharamvirKhosla (AY: 2019-20 & 2020-21) IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH

Dharamvir Khosla vs. DCIT CC-5, New Delhi

ITA 3976/DEL/2025[2019-20]Status: DisposedITAT Delhi21 Jan 2026AY 2019-20

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Sh. Rajiv Saxena, AdvFor Respondent: Sh. Mahesh Kumar, CIT, DR
Section 139Section 139(1)Section 143(1)Section 153CSection 32(1)(ii)

Page | 1 ITA Nos. 3976 & 3977/Del/2025 DharamvirKhosla (AY: 2019-20 & 2020-21) IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH

Mamraj Aggarwal, Delhi Sadar Bazar, Delhi vs. Income Tax Officer Ward 47(1), Delhi

In the result the appeal of the assessee is allowed

ITA 3864/DEL/2025[2017-18]Status: DisposedITAT Delhi21 Jan 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

Section 115BSection 131(1)Section 139Section 144BSection 147Section 148Section 148ASection 151Section 250Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”, DELHI BEFORE SH. S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SH. SUDHIR

South West Pinnacle Exploration Limited, Delhi vs. Assistant Commissioner of Income Tax Circle 24(1), Delhi

In the result, appeal filed by the assessee is allowed

ITA 3834/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Jan 2026AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumarm/S. South West Pinnacle Exploration Limited, Vs. Acit, Circle 24 (1), A-4, Pushpanjali Farms, Bijwasan, New Delhi. New Delhi – 110 061. (Pan : Aakcs3608R) (Appellant) (Respondent) Assessee By : Shri I.P. Bansal, Advocate Shri Vivek Bansal, Advocate Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 06.01.2026 Date Of Order : 21.01.2026 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-24, New Delhi [“Ld. Cit (A)”, For Short] Dated 29.05.2025 For The Assessment Year 2016-17. 2. At The Outset, Ld. Ar Of The Assessee Submitted That The Issues Involved In The Present Appeal Are Squarely Covered By Various Decisions & He Heavily Relied Upon The Decision Of The Coordinate Bench In The Case Of Real Innerspring Technologies Pvt. Ltd. Vs. Acit (2025) 174

For Appellant: Shri I.P. Bansal, AdvocateFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 68

order and held as under :- “10. Considered the rival submissions and material placed on record. We observed that the AO has initiated reassessment proceedings on the basis of information received from the Investigation Wing and search proceedings in the case of Shri Verma. It is brought on record that these

DCIT, CC-14, New Delhi vs. A.P. Securitas Pvt. Ltd, Delhi

In the result, application for condonation of delay of 52 days in filing of appeal is allowed and appeal filed by the Department of Revenue is dismissed

ITA 3077/DEL/2025[2022-23]Status: DisposedITAT Delhi21 Jan 2026AY 2022-23

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumardcit, Vs. A. P. Securitas Pvt. Ltd, Central Circle-14, 10-Dda, Commercial Complex, New Delhi New Delhi (Appellant) (Respondent) Pan: Aaaca1315R

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 139Section 139(1)Section 139(4)Section 143(1)Section 143(1)(a)Section 250Section 80ASection 80J

failure to digitally upload Form 10CCB could not lead one to conclude that assessee had failed to make a full and true disclosure, impugned reassessment proceedings after four years from end of relevant year were to be set aside.” 10. In view of the above said materials facts and well

Gautam Chopra, New Delhi vs. DCIT, Jhandewallan Extension

ITA 2567/DEL/2025[2021-2022]Status: DisposedITAT Delhi21 Jan 2026AY 2021-2022

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 69C

Delhi) wherein the Hon'ble Court has held as under:- "48. In terms of the Second Proviso to Section 153A, all assessment or reassessment proceedings relating to the six AYs' or the "relevant assessment year" pending on the date of search are statutorily envisaged to abate. Abatement is envisioned

Dy. Commissioner of Income Tax, Central Circle-1, Noida vs. M/S Rudra Bulldwell Homes Pvt. Ltd., Delhi

ITA 1119/DEL/2025[2017]Status: DisposedITAT Delhi21 Jan 2026

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member

Section 143Section 143(2)Section 143(3)Section 147Section 148Section 148ASection 151

legally untenable, as the law mandates that such approval must be obtained from the Principal Chief Commissioner of Income-tax (PCCIT) u/s 151. The reassessment proceedings initiated on the basis of approval from an incompetent authority are invalid and liable to be quashed. 2. On the facts

Aditi Infrabuild and Services Ltd., Delhi vs. DCIT, Central Circle-30, Delhi

ITA 5970/DEL/2024[2019-20]Status: DisposedITAT Delhi21 Jan 2026AY 2019-20

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwal

Section 132Section 139(1)Section 153ASection 153CSection 153DSection 250Section 37

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "A" BENCH: NEW DELHI ITA No.5970/Del/2024 BEFORE SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER