“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

Income Tax Officer, Mumbai vs. Sunita Chaudhary, Mumbai

In the result, appeal by the assessee is allowed

ITA 2124/MUM/2024[2014-15]Status: DisposedITAT Mumbai19 Jan 2026AY 2014-15

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 147Section 260ASection 68Section 69C

also directed to be deleted. 13. As, relief has granted to the assessee on the merits itself, therefore, the grounds pertaining to invocation of reassessment proceedings under section 147 of the Act are rendered academic in nature in the present case. 14. In the result, appeal by the assessee

Atul Kumar Agrawal, Manpur Road, Kashipur vs. National E-Assessment Centre, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 19/DDN/2025[2018-19]Status: DisposedITAT Dehradun16 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year: 2018-19] Mr. Atul Kumar Agarwal Vs National Prop.M/S. R.K. Industries, E-Assessment Centre, Manpur Road, Kashipur, New Delhi U.S. Nagar, Uttarakhand- 244713 Pan-Aaopa9970H Appellant Respondent Assessee By Shri Deepak Joshi,Adv. & Shri Rudra Pratab, Adv. Revenue By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 13.11.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 04.12.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2017-18/10235798 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Filed His Return Of Income On 15.08.2018, Declaring Total Income At Inr 5,81,560/-. The Case Of The Assessee Was Re-Opened U/S 147 Of The Act. Accordingly, Notice U/S 148 Was Issued On 30.03.2022, In Response To Which The Assessee Filed Return Of Income On 03.05.2022, Declaring Same Income As Was Declared In The Return Filed U/S 139(1) Of The Act. Thereafter Notice U/S 143(2) Of The Act Was Issued Followed By Notices U/S 142(1) Alongwith Questionnaires. In Response Filed Replies From Time To Time. After Considering The Submissions Made By The Assessee, Ao Completed The Assessment Vide Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Wherein The Total Income Was Assessed At Inr 54,23,320/-.

Section 133ASection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69C

circumstances of the case and in law, the Ld. CIT(A) has erred in confirming the action of Ld. AO in completing the reassessment proceedings without providing any opportunity of cross examination of the witnesses/statements of the third party relied upon by the Ld. AO and thus violating the principle

Rakesh Kumar Singh, Patna vs. ITO Ward 5(1), Patna

Appeal of the assessee is allowed for statistical purpose

ITA 478/PAT/2025[2015-16]Status: DisposedITAT Patna16 Jan 2026AY 2015-16

Bench: The Cit(A). However, The Cit(A) Dismissed The Appeal On The Ground Of Delay Without Condoning The Same & Without Adjudicating The Issues On Merits.

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

Suresh Jat, Badnawar vs. The Income-Tax Officer, Dhar

Appeal is allowed for statistical purpose

ITA 693/IND/2025[2016-17]Status: DisposedITAT Indore16 Jan 2026AY 2016-17

Bench: Shri B.M. Biyani & Shri Paresh M Joshisuresh Jat, Ito, बनाम/ C/O S.V. Agrawal & Associate Dhar. Vs. Dadi Dham, 24-25, Joy Building Colony, Old Aplasia, Indore. (Pan: Anopj2666E) (Appellant) (Respondent) Assessee By Shri S.N. Agrawal, Ca Revenue By Shri Anup Singh, Cit-Dr Date Of Hearing 08.01.2026 Date Of Pronouncement 16.01.2026 आदेश/ O R D E R

Section 144(1)Section 147Section 148Section 148ASection 194ASection 194HSection 250Section 253Section 69A

source of cash deposits in the bank accounts which tantamounts to making roving and fishing inquiries which is not permissible within the garb of reassessment proceedings under section 147 of the Act 2.That on the facts and in the circumstances of the case and in law, the Ld. Assessing Officer

Neha Tamrakar, Bhopal vs. Income Tax Officer 5 (1), Bhopal

In the result, the “Impugned Order” is set aside as & by

ITA 175/IND/2025[2009-10]Status: DisposedITAT Indore16 Jan 2026AY 2009-10

Bench: Shri B.M. Biyani & Shri Paresh M Joshineha Tamrakar, Ito -5(1), बनाम/ 177 A Sector, Indrapuri Bhopal. Vs. Bhopal(M.P.) (Pan: Ajtpt6475G) (Appellant) (Respondent) Assessee By Shri Soumya Bumb, Ca Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 12.01.2026 Date Of Pronouncement 16.01.2026 आदेश/ O R D E R

Section 129Section 139Section 142(1)Section 144Section 147Section 148Section 148(2)Section 151Section 246Section 250

dismissal of the first appeal are as under:- “In the original grounds of appeal, the assessee has challenged the validity of the reassessment proceedings on the ground that the notice u/s. 148 was issued only on 16.12.2016 and hence, the same is barred by limitation and accordingly, the assessment order

Sunil Piyush Shah, Ahmedabad vs. NFAC, Delhi Present Juris. -the ITO, Ward-5(3)(2), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 1917/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kambleassessment Year 2019-20

For Appellant: Shri Sunil Piyush Shah, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R

Section 132Section 132(4)Section 144BSection 147Section 148ASection 244ASection 250Section 270ASection 270A(9)Section 29A

third-party statements, thereby violating the principles of natural justice and rendering the entire proceedings null and void. 3. That the initiation of reassessment proceedings itself is void ab initio, as the notice issued under section 148A(b) and the consequential order under section 148A(d) dated 02.05.2023 were passed

Tushar Vipinchandra Shukla, Ahmedabad vs. The ITO, Ward-5(3)(2), Ahmedabad

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 1654/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kambleassessment Year 2019-20

For Appellant: Shri Mehul Thakkar, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R

Section 132(4)Section 139(1)Section 147Section 148ASection 151Section 80G

present case, approval was accorded only by the Ld. Principal Commissioner of Income Tax (PCIT), rendering the entire proceedings invalid. 6. The initiation of reassessment proceedings is bad in law, as the Show Cause Notice was issued under section 148A(b) of the Act despite the fact that the provisions

Alang Steel Recycling Private Limited, Bhavnagar vs. The Pr. CIT-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1605/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

Section 263Section 37Section 69C

Bankey Bihari Industries, which were stated to be involved in issuance of accommodation bills without actual supply of goods. 7. During the reassessment proceedings, the Assessing Officer examined the issue of purchases and, in respect of transactions aggregating to ₹77,61,745/-, treated the same as non-genuine and disallowed ... provisions of section 69C read with section 115BBE of the Act. The Principal Commissioner observed that the assessee had remained non-compliant during the reassessment proceedings and had not furnished satisfactory evidence to establish the genuineness of the transactions or the source of expenditure, and therefore the entire amount ought

Alang Steel Recycling Private Limited, Bhavnagar vs. The Dy.CIT, Circle-1, Bhavnagar

The appeal of the assessee is allowed for statistical purposes

ITA 1604/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Dy. Cit-1, Private Limited Vs. Circle-1, Ground Floor, Bhavnagar – 364 001 Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri Abhijit, Sr.Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

Section 147Section 234ASection 270ASection 37

return of Alang Steel Recycling Private Limited vs. Dy.CIT A.Y: 2018-19 income again declaring the same income of ₹10,75,470/-. During the reassessment proceedings, the Assessing Officer asked the assessee to substantiate the genuineness of the purchase transactions, particularly those aggregating to ₹77,61,745/- with M/s Hamaalloys

Sunil Vasantrao Chokakkar, Kolhapur vs. Income Tax Officer, Ward, Kudal

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

ITA 2982/PUN/2025[2013-14]Status: HeardITAT Pune16 Jan 2026AY 2013-14

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2982/Pun/2025 Assessment Year : 2013-14

For Appellant: NoneFor Respondent: Date of hearing

Section 147Section 148Section 250Section 80C

return of income for A.Y. 2013-14 e-filed on 20.03.2020 Case reopened after issuance of notice u/s.148 of the Act and reassessment proceedings were carried out. However, in absence of proper details, ld. Assessing Officer made various additions amounting to ₹16,94,146 and assessed income

Pallapu Srinivasarao (HUF), Almasguda vs. ITO., Ward-9(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 1586/HYD/2025[2020-21]Status: DisposedITAT Hyderabad16 Jan 2026AY 2020-21

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 139(1)Section 144Section 147Section 148Section 148ASection 69A

have quashed the notice issued u/s 148 as invalid and hence the learned Commissioner of Income Tax (Appeals) ought to have quashed the reassessment proceedings as void-ab-Initio. 4. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have held that the assessing officer ... were set aside by the High Courts, the Hon'ble Supreme Court has only permitted the Union of India to proceed further with the reassessment proceedings under the amended provision of law, more particularly, as amended by the Finance Act, 2021. It never intended the authorities concerned to continue with

Mohd Shoaib Ur Rahman, Hyderabad vs. Income Tax Officer, Ward-4(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 1561/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad16 Jan 2026AY 2015-2016

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 149Section 69A

were set aside by the High Courts, the Hon'ble Supreme Court has only permitted the Union of India to proceed further with the reassessment proceedings under the amended provision of law, more particularly, as amended by the Finance Act, 2021. It never intended the authorities concerned to continue with

Sudheer Chirania, Mumbai vs. The Income Tax Officer, Ward - 23(3)(7), Mumbai

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

ITA 5263/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Jan 2026AY 2012-13

Bench: Shri Saktijit Dey & Shri Jagadishassessment Year: 2012-13

For Appellant: Ms. Simran Dhawan & Mr. RaviFor Respondent: Shri Arun Kanti Datta, CIT DR

Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 68Section 69C

circumstances of the case and in law, the Ld. Commissioner of Income Tax (Appeals) has erred in upholding and sustaining the initiation of reassessment proceedings by issue of notice u/s 148, which is not as per provisions of law, clearly outside the sanction of law, illegal, bad in law, barred ... facts and circumstances of the case and in law, the Ld. Commissioner of Income Tax (Appeals) has erred in upholding the initiation of reassessment proceedings by issue of notice u/s 148 merely on the cursory observation in paragraph 6.1 of his order that the reopening was warranted not only

Anil Kumar Jain, New Delhi vs. Dy. Commissioner of Income Tax, Central Circle-26, Jhandewalan, New Delhi

In the result, the appeal of the assessee is allowed

ITA 475/DEL/2025[2013-14]Status: DisposedITAT Delhi16 Jan 2026AY 2013-14

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(1)Section 143(3)Section 147Section 148Section 151

Seema Mehta vs. ITO in ITA No.2405/Del/2024 and requested that the notice issued u/s 148 deserves to be held as invalid and consequent reassessment proceedings deserves to be quashed. 5. On the other hand, ld. Sr. DR submits that a survey was carried on 17.12.2015 at the business premises ... technical reasons, and later notice was issued and assessments were taken up afresh-After considering submissions of assessee and documents produced in reassessment proceedings, AO added back a sum of Rs.1,35,00,000/- - CIT(A) held against assessee an legality of reassessment notice but allowed assessee's appeal

Horizon Buildmart Pvt Ltd, Gurgaon vs. ACIT, Circle-2, Faridabad

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

ITA 1250/DEL/2025[2011-12]Status: DisposedITAT Delhi16 Jan 2026AY 2011-12

Bench: Shri Sudhir Kumar & Shri Manish Agarwalhorizon Buildmart Pvt. Ltd., Asst. Cit, C-131, Ground Floor, Block-C, Central Circle-Ii, Sushant Shopping Arcade, Vs. Faridabad, Sushant Lok-1, Haryana-121001. Gurgaon-122002. Pan-Aacch4582P (Appellant) (Respondent) Shri S.S. Nagar, Ca Assessee By Department By Ms. Amisha S. Gupta, Cit Dr Date Of Hearing 03/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon (‘Ld. Cit(A)’ In Short) Dated 27.01.2025 In Appeal No.10581/Cit(A) Ggn-3/2018-19 For Assessment Year 2011-12 Arising Out Of The Order Passed U/S 147 R.W.S 144 Of The Income Tax Act, 1961 (‘The Act’ For Short) Dated 28.12.2018. 2. Brief Facts Of The Case Are That Assessee Is Private Limited Company Engaged In The Business Of Real Estate. The Assessee Filed Its Return Of Income On 30.09.2011 Declaring A Loss Of Rs.54,833/-. The Ao Had Information That Assessee Received Loan Horizon Buildmart Pvt. Ltd. Vs. Acit

Section 143(2)Section 147Section 148Section 153C

order of the Ld. AO without considering the fact, that the reasons to believe recorded by the Ld. AO for the initiation of reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances ... filing such details. Ld. AR submits that loan alleged as bogus was repaid in Financial Year 2013-14. He further submits that entire reassessment proceedings were based on the incriminating materials and documents found as a result of search carried in some other group and therefore, the action u/s 153C

Income Tax Officer, Ferozepur vs. Ms.Jatin Agro, Fort Road

In the result, the appeal of the revenue is dismissed

ITA 104/ASR/2024[2017-18]Status: DisposedITAT Amritsar15 Jan 2026AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

Section 143(3)Section 148Section 250Section 35A

matter was carried in appeal before the ld. first appellate authority, both, on the legal issue of initiation of reassessment proceedings u/s 147 of the Act and also on merits and the Ld CIT(A) has decided the legal issue u/s 147 / 148 , against the assessee, (for which the assessee

Income Tax Officer, Ward-3(1), Ferozepur vs. Ms.Jatin Agro, Fort Road

In the result, the appeal of the revenue is dismissed

ITA 103/ASR/2024[2014-15]Status: DisposedITAT Amritsar15 Jan 2026AY 2014-15

Section 143(3)Section 148Section 250Section 35A

Assistant Commissioner of Income Tax, Central Circle, Patiala vs. Satguru Foundation(Regd), Muktsar

In the result, all the four appeals are dismissed

ITA 494/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh15 Jan 2026AY 2013-14

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 491, 493 & 494/Chd/2023 "नधा"रण वष" / A.Y. : 2010-11, 2012-13 & 2013-14 The Acit, M/S Satguru Foundation (Regd.), Central Circle, Vs Desh Bhagat College & Hospital, Patiala. Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 492/Chd/2023 "नधा"रण वष" / A.Y. : 2011-12 The Acit, M/S Satguru Foundation (Regd.), Patiala. Vs Desh Bhagat College & Hospital, Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR

Section 147

charge of administration of a dental college run by the aforesaid Satguru Foundation. On the basis of the impounded documents, the Assessing Officer initiated reassessment proceedings by issue of notice under section 148 of Income Tax Act after taking mandatory approval of the Ld. PCIT in respect ... categorical admission of having earned income which has escaped assessment. The material is available with the Assessing Officer which is sufficient for initiation of reassessment proceedings. At the stage of issue of notice only prima facie belief is required to the extent that income has escaped assessment which was clearly

Asstt. Commissioner of Income Tax, Patiala vs. Satguru Foundation(Regd.), Muktsar

In the result, all the four appeals are dismissed

ITA 493/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh15 Jan 2026AY 2012-13

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR

Section 147

Assistant Commissioner of Income Tax, Patiala vs. Satguru Foundation(Regd), Muktsar

In the result, all the four appeals are dismissed

ITA 492/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh15 Jan 2026AY 2011-12

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR

Section 147