“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

Niraj Pravinchandra Doshi, Mumbai vs. Income Tax Officer 19(2)(4), Mumbai

In the result, the appeal of assessee is partly allowed

ITA 4415/MUM/2025[2009-10]Status: DisposedITAT Mumbai20 Jan 2026AY 2009-10

Bench: Shri Pawan Singh(Physical Hearing) Niraj Pravinchandra Doshi Ito,Ward-19(2)(4), Mumbai Gr. Floor, Shreeji Kripa Building, Vs Room No. 609, Piramal 9, Kumbhar Tukda, Bhuleshwar, Chambers, Lalbaug, Mumbai, Maharashtra – 400004. Maharashtra – 400012. [Pan No. Aabpd1392D] Appellant / Assessee Respondent / Revenue

Section 133(6)Section 143(3)Section 147Section 254(1)

Learned CIT (Appeals), Addl/ JCIT(A)-1, Noida has erred in upholding the action of the Ld. Assessing Officer in initiating the reassessment proceedings under section 147 merely on the basis of borrowed satisfaction and without any tangible material. 2. In the facts and circumstances of the case

DCIT, CC 6(2), Mumbai vs. Hdfc Ergo General Insurance Company Limited, Mumbai

In the result, appeal filed by the assesse bearing ITA No

ITA 3282/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Jan 2026AY 2017-18

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: ShriAbdulla PettiwalaFor Respondent: Shri RiteshMisra(CIT DR)a/w Shri

Section 115Section 143(3)Section 194HSection 244ASection 250Section 37(1)Section 40Section 40(1)Section 43B

payments made to motor car dealers during the period 1 April 2016 to 31 December 2016 are enclosed. 2. In the past, assessment / reassessment proceedings were initiated based on the show cause Notice issued by the Additional Director General under the service tax law. Vide letter dated 15 March

Hdfc Ergo General Insurance Company Limited, Mumbai vs. The Assistant Commissioner of Income Tax, Central Circle 6(2), Mumbai

In the result, appeal filed by the assesse bearing ITA No

ITA 2842/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Jan 2026AY 2017-18

For Appellant: ShriAbdulla PettiwalaFor Respondent: Shri Ritesh Misra(CIT DR)a/w Shri

Section 115Section 143(3)Section 194HSection 244ASection 250Section 37(1)Section 40Section 40(1)Section 43B

Rohit Goel, Delhi vs. DCIT, CC-20, Delhi

Appeal is allowed in above terms

ITA 8320/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 8320/Del/2025 : Asstt. Year: 2017-18 Rohit Goel, Vs Dcit, The Tax Chambers, Central Circle-20, Advocates & Legal Advisors, New Delhi-110055 C-177, Defence Colony, Lgf, New Delhi-110024 (Appellant) (Respondent) Pan No. Amvpg5611Q Assessee By: Ms. Swati Talwar, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)-27, New Delhi’S Din & Order No. Itba/Apl/M/250/2024-25/1073465261(1) Dated 19.02.2025, In Proceedings U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Ms. Swati Talwar, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 147Section 148Section 148ASection 149(1)Section 151

Income Tax Officer Ward 25 3 Delhi & Ors.(supra), a Coordinate Bench of this court examined the validity of initiation of reassessment proceedings, in cases where the income alleged to have escaped assessment was Rs.50,00,000/- or less. In the aforesaid context, this court also considered the question ... amended 1961 Act, the issue concerning limitation is inextricably intertwined with two aspects: (a) First, the rank of the authority granting approval/sanction for triggering reassessment proceedings. (b) Second, the quantum of income which has escaped assessment.” (Emphasis is ours) 12. Clearly, the Revenue advanced the argument of interlinkage between limitation

Ajay Nagpal, Delhi vs. ITO, Ward-48(1), Delhi

Appeal is allowed in above terms

ITA 8145/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Jan 2026AY 2018-19

Bench: Sh. Satbeer Singh Godaraita No. 8145/Del/2025 : Asstt. Year: 2018-19 Ajay Nagpal, Vs Income Tax Officer, 15/10, East Patel Nagar, Ward-48(1), New Delhi-110008 New Delhi-110002 (Appellant) (Respondent) Pan No. Aabpn9871D Assessee By: Sh. Pranav Yadav, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2018-19 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081608419(1) Dated 09.10.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Pranav Yadav, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 147Section 148Section 148ASection 149(1)Section 151

Income Tax Officer Ward 25 3 Delhi & Ors.(supra), a Coordinate Bench of this court examined the validity of initiation of reassessment proceedings, in cases where the income 5 Ajay Nagpal alleged to have escaped assessment was Rs.50,00,000/- or less. In the aforesaid context, this court also considered ... amended 1961 Act, the issue concerning limitation is inextricably intertwined with two aspects: (a) First, the rank of the authority granting approval/sanction for triggering reassessment proceedings. (b) Second, the quantum of income which has escaped assessment.” (Emphasis is ours) 12. Clearly, the Revenue advanced the argument of interlinkage between limitation

Agarwal Finestate Pvt Ltd, Delhi vs. Income Tax Officer, Delhi

Appeal of the assessee are allowed

ITA 7450/DEL/2025[2015-16]Status: DisposedITAT Delhi20 Jan 2026AY 2015-16

Bench: Sh. Satbeer Singh Godara

For Appellant: Sh. Satyajeet Goel, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 147Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH `SMC', NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No

Shiv Shambhu Iron and Steel Private Limited, Jamshedpur vs. ACIT Circle 3(1), Jamshedpur

The appeal of the assessee is allowed for statistical purposes

ITA 286/RAN/2024[2011-12]Status: DisposedITAT Ranchi19 Jan 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.286/Ran/2024 Assessment Year: 2016-17 Shiv Shambhu Iron & Steel Pvt. Ltd.…….…............................……….……Appellant Dropadi Bhawan, Station Road, Jugsalai, Jharkhand- 831002. [Pan: Aalcs7663M] Vs. Acit, Circle-3(1), Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 12.04.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2011–12 Declaring A Total Income Of ₹30,17,990. The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Of The Act Was Completed Determining The Total Income At ₹39,08,910. Subsequently, Based On Information Received, It Was Noticed That The Assessee Company Had Shown Receipt Of ₹1,49,00,000 Comprising Share Capital Of ₹14,90,000 & Share Premium Of ₹1,34,10,000. On The Basis Of This Information, The Assessing Officer Issued Notice Under Section 148 Of The Act. In Response To The Notice, The

Section 143(3)Section 147Section 148Section 250

dismissed the appeal and sustained the order of the Assessing Officer. 4. Before the Tribunal, the assessee contended that the reassessment proceedings were bad in law, as the statutory notices were not properly served on the registered email ID of the assessee. It was submitted that the notices could

Jaiswal Steel Industries Private Limited, Jamshedpur vs. ITO Ward 2(1), Jamshedpur

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

ITA 284/RAN/2024[2016-17]Status: DisposedITAT Ranchi19 Jan 2026AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.284/Ran/2024 Assessment Year: 2016-17 Jaiswal Steel Industries Pvt. Ltd. ….…….…............................……….……Appellant Dropadi Bhawan, Station Road, Jugsalai, Jharkhand- 831006. [Pan: Aabcj4471C] Vs. Ito, Ward-2(1), Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 02.04.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(3)Section 147Section 250Section 69Section 69A

that the assessee is a company, filed its return of income for the assessment year 2016–17 declaring income as per return. Subsequently, reassessment proceedings were initiated and the assessment was completed by the Assessing Officer under section 147 read with section 143(3) of the Act. While completing

Amplex Projects Private Limited, Agartala vs. DCIT/ACIT, Circle Silchar, Silchar

In the result, appeal of the assessee is allowed in above terms

ITA 333/GTY/2025[2013-14]Status: DisposedITAT Guwahati19 Jan 2026AY 2013-14

Bench: the Ld. CIT(A).

For Respondent: Shri Santosh Kumar Karnani, Addl. CIT

Section 1Section 139(1)Section 143(3)Section 153ASection 245DSection 245D(4)Section 250

qualified by the words "on the date of initiation of the search", and makes it abundantly clear that only such assessment or reassessment proceedings are liable to abate. In other words, Assessments which are not pending 1.e. completed assessments as on the date of search would hold their base ... search no incriminating material o found in case of completed unabated assessment the only remedy available to the revenue would he to initiate the reassessment proceedings under section 147/148, subject to fulfilment of the conditions mentioned in section 147/148, as in such a situation, the revenue cannot be left with

Sanjeev Kumar, Muzaffarpur vs. Commissioner of Income Tax Appeal, Patna

Appeal of the assessee is allowed for statistical purpose,

ITA 458/PAT/2025[2015-16]Status: DisposedITAT Patna19 Jan 2026AY 2015-16

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 144Section 147Section 148Section 250Section 69A

National Faceless Appeal Centre (NFAC), Delhi [hereafter “the Ld. CIT(A)]. 2. Brief facts of the case are that the assessee is an individual. Reassessment proceedings were initiated against the assessee under section 147 of the Income-tax Act, 1961 for the assessment year 2015–16 on the basis ... merits. 4. Aggrieved, the assessee is in appeal before the Tribunal. 5. At the time of the hearing the learned AR submitted that the reassessment proceedings themselves are bad in law as the assessee has never maintained any bank account with SBI as alleged by the Assessing Officer

Deepak Shrawan Budhia, Mumbai vs. Pr. Commissioner of I.T., Patna-1, Patna

In the result, appeal of the assessee is dismissed

ITA 365/PAT/2025[2018-19]Status: DisposedITAT Patna19 Jan 2026AY 2018-19

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 147Section 263Section 40

payment is more than the specified limit but no TDS was deducted and submitted that entire documents were furnished during the course of reassessment proceeding and the AO had examined the records and completed the reassessment proceeding, therefore, the Ld. Pr.CIT cannot exercise his jurisdiction ... Pr.CIT after examination of the records noted that the assessee is liable for TDS on the freight charges paid. However, during the course of reassessment proceedings the detailed documents were furnished by the assessee as per submission made before the Ld. Pr. CIT. The ld. Counsel for the assessee during

Anand Bhausaheb Bhalekar, Aurangabad vs. ITO, Ward -1(5), Aurangabad

In the result, appeal of the assessee is allowed

ITA 1207/PUN/2025[2015-16]Status: DisposedITAT Pune19 Jan 2026AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1207/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Anand Bhausaheb Bhalekar, V The Income Tax Plot No.259/C, Gut No.126/2, S Officer, Shantiban Hariram Nagar, Ward-1(5), Aurangabad. Behind Nandini Hotel, Aurangabad – 431001. Pan: Aompb6314E Appellant/ Assessee Respondent /Revenue Assessee By Shri Shubham Rathi – Virtual Revenue By Smt Neha Thakkar – Virtual Date Of Hearing 19/01/2026 Date Of Pronouncement 19/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16Dated 12.03.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Read With Section 144B Of The Act, Dated

Section 144BSection 147Section 148Section 149Section 151ASection 250

CHALLENGE TO REASSESSMENT 1.1 The Learned Commissioner of Income Tax (Appeals) ('the Ld. CIT'] has erred in not considering the ground of challenge to reassessment proceedings. 1.2 On the facts and in the circumstances of the case, the Learned Income Tax Officer, Ward 1(5), Aurangabad ... initiated the reassessment proceedings without fulfilling the preconditions required to initiate the reassessment proceedings U/s 148-151 of the Act. 1.3 On the facts and in circumstances of the case, the notice u/s 148 issued by the Ld. AO is barred by limitation

P Pushpalatha, Chennai vs. ITO, Ncc-10(3), Chennai

In the result, the appeal of the assessee stands dismissed

ITA 2791/CHNY/2025[2010-11]Status: DisposedITAT Chennai19 Jan 2026AY 2010-11

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Raviassessment Years: 2010-11 P.Pushpalatha, Income Tax Officer, No.11, Vivek Nagar, Kolathur, Non-Corporate Circle-10(3) Chennai-600 099. Chennai. [Pan: Ainpp2985Q] Appellant Respondent Assessee By : Mr.K.Balasubramanian, Advocate Revenue By : Ms.R.Anitha, Addl.Cit Date Of Hearing : 13.01.2026 Date Of Pronouncement : 19.01.2026 O R D E R Per Inturi Rama Rao, A.M :

For Appellant: Mr.K.Balasubramanian, AdvocateFor Respondent: Ms.R.Anitha, Addl.CIT

Section 131(1)Section 133ASection 142(1)Section 143(2)Section 148

submissions. 4.0 We heard the rival submissions and perused the material on record. At the outset, we find that the CIT(A) quashed the reassessment proceedings for want of not issuing notice u/s. 143(2) of the Act. When the assessment order was quashed, the CIT(A) ought

Rama Sivaraman, Mumbai vs. AO Ward 3(2), Thane

ITA 6947/MUM/2025[2013-14]Status: DisposedITAT Mumbai19 Jan 2026AY 2013-14

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Mr. Rajeev N. LFor Respondent: Shri Annavaram Kosuri

Section 147

resultant income tax demand and interest accrued thereon.” 4. The facts relevant for adjudication of the present appeal in brief are that reassessment proceedings were initiate in the case of the Assessee for the Assessment Year 2013-2014 on the base of AIR- Information with the Assessing Officer

Rama Sivaraman, Mumbai vs. ITO Ward 3(2), Mumbai

ITA 6946/MUM/2025[2013-14]Status: DisposedITAT Mumbai19 Jan 2026AY 2013-14

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Mr. Rajeev N. LFor Respondent: Shri Annavaram Kosuri

Section 147

Income Tax Officer22(1)(1), Mumbai vs. All India Transport Agency, Mumbai

ITA 6612/MUM/2025[2013-14]Status: DisposedITAT Mumbai19 Jan 2026AY 2013-14

Bench: Shri Sandeep Gosain

For Respondent: Shri Surendra Mohan, (Sr. DR)

Section 147Section 148

under: 1. Whether on the facts and in the circumstances of the case and in law, the Ld.CIT(A) erred in holding that the reassessment proceedings initiated under section 147 read with section 148 of the Income Tax Act, 1961, in the name of M/s All India Transport Agency were ... assessee had not filed any return of income for A.Y. 2013-14 despite undertaking financial transactions exceeding Rs.25 crore, thereby justifying the initiation of reassessment proceedings under section 147. 3. Briefly stated facts of the case are that the assessee, a partnership firm is stated to be engaged

Nitin Harilal Shah, Mumbai vs. Income Tax Officer, Mumbai

ITA 6536/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Jan 2026AY 2016-17

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Leyaqat Ali Aafaqui, Sr. DR

Section 132Section 147Section 148Section 148ASection 151Section 153CSection 271(1)(c)Section 69A

erred in not appreciating that the approval granted is in mechanical manner. 4. The Ld. CIT(A) has erred in not appreciating that the reassessment proceedings ought to have been initiated u/s 153C of the Act and not u/s 148 of the Act. The consequential order dated

Bharat Harishchandra Purohit, Mumbai vs. DCIT CC-4(2), Mumbai

In the result, all the appeals filed by the assessee stands allowed

ITA 5832/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 153CSection 254(1)Section 69

pendrive are correct and authenticated to the extent assessee paid ‘onmoney’ in cash, no addition can be made and even otherwise during the entire reassessment proceedings the veracity and reliability of the data recorded in the pendrive was not checked or tested. Therefore, in such a scenario no addition

Bharat Harishchandra Purohit, Mumbai vs. DCIT CC4(2), Mumbai

In the result, all the appeals filed by the assessee stands allowed

ITA 5831/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 153CSection 254(1)Section 69

Maharashtra Corporation Limited, Mumbai vs. Income Tax Officer Ward 4(2)(1), Mumbai

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

ITA 4146/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

Section 131Section 143(1)Section 144BSection 147Section 148Section 69C

goods, the Assessing Officer formed a belief that income chargeable to tax had escaped assessment. After obtaining the necessary approval from the competent authority, reassessment proceedings were initiated by issuance of notice under section 148 of the Act dated 31.03.2021.In response to the notice under section 148, the assessee filed ... were issued and served upon the assessee, calling for details and explanations. 4 ITA No. 4146/Mum/2025 Maharashtra Corporation Limited 5. During the course of reassessment proceedings, the Assessing Officer sought information from the Jurisdictional Assessing Officer, who, in turn, furnished a copy of the statement of Shri Tilok Chand Kothari