← 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

C-2480 Elayangaram Paccs, Tirupattur vs. ITO, Tirupathur

In the result, appeal of the Assessee stands partly allowed for statistical purpose

ITA 4037/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Mar 2026AY 2018-19

Bench: Shri George George K, Vice- & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.4037/Chny/2025 "नधा"रण वष" / Assessment Year: 2018-19 C-2480 Elayanagaram Assessment Unit, Primary Agricultural V Nfac, Income Tax Cooperative Credit Society, S. Department, Elayanagaram, Tirupattur. Ito-Che-W- Pan: Aahfc7142G (146)(2), Chennai. Appellant Respondent Assessee By Mr. Shyam Sundar – Ca Revenue By Ms. V Awasthay – Jcit Date Of Hearing 17/02/2026 Date Of Pronouncement 11/03/2026 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax(Appeals)[Nfac] Delhi [‘The Cit(A)’] Passed Under Section 250 Of The Income Tax Act

Section 115BSection 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 250(6)Section 69Section 80P(2)(a)

restoring the matter for fresh consideration or adjudicating the issues on merits, thereby causing grave prejudice to the Appellant. 8. The reassessment proceedings initiated and completed under section 147 read with section 144 are bad in law, having been framed without proper application of mind and without examining the nature

Kuruzu Russelian, Chennai vs. ITO, Ncc-22(1), Chennai

In the result, the appeal filed by the assessee is allowed and the penalty levied u/s

ITA 2830/CHNY/2025[2015-16]Status: DisposedITAT Chennai11 Mar 2026AY 2015-16

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. R. Subramanian, CAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 147Section 148Section 271(1)(c)

notice, the assessee filed his return of income on 02.05.2022 declaring a total income of Rs.2,82,69,370/-. During the course of the reassessment proceedings, the assessee clarified that he had not purchased any immovable property for Rs.10,00,00,000/- as reflected in the information available with ... have heard the rival submissions and carefully perused the material available on record. The undisputed factual position emerging from the records is that the reassessment proceedings initiated by the AO u/s.147 of the Act culminated in the assessment order dated 15.03.2023, wherein the AO accepted the return of income filed

Shanmuga Sundaram Govindaraj, Chennai vs. DCIT, Non Corporate Circle-19(1), Chennai

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

ITA 2203/CHNY/2025[2017-18]Status: DisposedITAT Chennai11 Mar 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.2203/Chny/2025 "नधा"रण वष"/Assessment Year: 2017-18 Shanmuga Sundaram Govindaraj, V. Dcit, 19 Al, Mudali Street, Non Corporate Circle 19(1), Nehru Nagar, Chennai. Velachery, Chennai – 600 042. [Pan:Aidpg 5262 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr. N. Arjun Raj, Advocate ""थ" की ओर से /Respondent By : Mr. Guru Prasad, Addl. Cit सुनवाईक"तार"ख/Date Of Hearing : 13.01.2026 घोषणाक"तार"ख /Date Of Pronouncement : 11.03.2026

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mr. Guru Prasad, Addl. CIT
Section 115BSection 142(1)Section 147Section 197Section 69

time prescribed under the scheme. Based on this information, the AO formed a belief that income chargeable to tax had escaped assessment and initiated reassessment proceedings u/s. 147 of the Income-tax Act, 1961. During the course of reassessment proceedings, notice u/s. 142(1) of the Income

Piyush Ashok Mehta, Mumbai vs. DCIT, Central Circle 6(4), Mumbai

Accordingly, Ground No. 2 raised by the Assessee in the present appeal in allowed

ITA 9092/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Mar 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Ms. Deepika Arora
Section 133ASection 143(1)Section 143(3)Section 147

declaring total income of INR.4,70,704/- and INR.2,36,116/-, respectively. The return was processed under Section 143(1) of the Act. Thereafter, reassessment proceedings were initiated for the Assessment Year 2009-2010 and 2010-2011 after recording the following reasons for reopening the assessment: “A survey u/s.133A ... Assessing Officer there was failure on the part of Assessee to disclose fully and truly all material facts necessary for assessment. Therefore, reassessment proceedings were initiated for the Assessment Year 2009-2010 and 2010-2011. The Assessee filed objections to the reopening of the assessment proceedings vide Letter, dated 23/03/2016

Piyush Ashok Mehta, Mumbai vs. DCIT, Central Circle 6(4), Mumbai

Accordingly, Ground No. 2 raised by the Assessee in the present appeal in allowed

ITA 9091/MUM/2025[2009-10]Status: DisposedITAT Mumbai11 Mar 2026AY 2009-10

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Ms. Deepika Arora
Section 133ASection 143(1)Section 143(3)Section 147

declaring total income of INR.4,70,704/- and INR.2,36,116/-, respectively. The return was processed under Section 143(1) of the Act. Thereafter, reassessment proceedings were initiated for the Assessment Year 2009-2010 and 2010-2011 after recording the following reasons for reopening the assessment: “A survey u/s.133A ... Assessing Officer there was failure on the part of Assessee to disclose fully and truly all material facts necessary for assessment. Therefore, reassessment proceedings were initiated for the Assessment Year 2009-2010 and 2010-2011. The Assessee filed objections to the reopening of the assessment proceedings vide Letter, dated 23/03/2016

Sumitra Devi, Gurgaon vs. ITO, Ward 4(1), Gurgaon

ITA 2499/DEL/2025[2013-14]Status: DisposedITAT Delhi11 Mar 2026AY 2013-14

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

For Appellant: Sh. M.R. Sahu, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR
Section 144Section 147Section 148Section 148(1)

appeal regarding service of notices. It was further submitted that the notice prescribed in section 148 of the Act for the purpose of initiating reassessment proceedings is not a mere procedural requirement but is a condition precedent to the validity of any reassessment made. Mere issuance of notice for income ... reopening of assessment. Reliance is placed on the following decisions wherein, it was held that mere issuance of notice u/s.148 is not enough for reassessment proceedings but is service upon the assessee is important for a valid reassessment proceedings. (i) Hon'ble Supreme Court in the case of V. Narayan

Kuldeep, Hapur vs. ITO, Ward 3(4), Hapur

ITA 2963/DEL/2023[2009-2010]Status: DisposedITAT Delhi11 Mar 2026AY 2009-2010

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshkuldeep, Vs. Cit(A), Village Kastala, Kasmabad, Nfac, New Delhi Tehsil & District Hapur, Uttar Pradesh (Appellant) (Respondent) Pan:Bumpk4317F Assessee By : None Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 11/03/2026

For Appellant: NoneFor Respondent: Shri Om Prakash, Sr. DR
Section 144Section 147Section 148Section 151

file any return of income in response to notice under Section 148 of the Act. The assessee merely stated during the course of reassessment proceedings that cash was deposited out of sale proceeds of agricultural land but did not provide any documentary evidence in support of his contentions. Accordingly

East Delhi Leasing P.Ltd, New Delhi vs. ITO, Ward-8(1), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 7917/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Mar 2026AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 147Section 148

funds transferred to other parties also remain unexplained. With these observations, the objections filed by the assessee were rejected by the Id. AO and reassessment proceedings were further proceeded with by the Id. AO. In the reassessment proceedings, the share application money received in the sum of Rs 5.42 crores ... reasons recorded by the AO would show that on the mere suggestion of the Investigation Wing of the rotation of funds escaping assessment the reassessment proceedings have been initiated by the AO in the belief of escapement of income of the Assessee. Apparently as between the information received

Shri Gandhi Maulana Azad Shramjivi Ashra, Kutch vs. Income Tax Officer, Exemption Ward 1, Rajkot

In the result, appeals of the assessee, are allowed

ITA 612/RJT/2025[2016-17]Status: DisposedITAT Rajkot10 Mar 2026AY 2016-17

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

Exemption Charge" of Income Tax Department and the notice u/s 148A(b) of the Act by the Ld. Other ITO is invalid and no reassessment proceedings can sustain on the basis of a foundational notice being issued by a Non-Jurisdictional AO. 7. Reliance is placed on: Nimir Kishore Mehta ... that, the Ld. PCCIT has failed to apply her mind judiciously and has accorded the approval mechanically and without application of mind and the reassessment proceedings initiated on the basis of such an approval is illegitimate and the assessment order is required to be quashed. 9. The Hon'ble Supreme

Shri Gandhi Maulana Azad Shramjivi Ashra, Kutch vs. Income Tax Officer, Exemption Ward 1, Rajkot

In the result, appeals of the assessee, are allowed

ITA 611/RJT/2025[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

Exemption Charge" of Income Tax Department and the notice u/s 148A(b) of the Act by the Ld. Other ITO is invalid and no reassessment proceedings can sustain on the basis of a foundational notice being issued by a Non-Jurisdictional AO. 7. Reliance is placed on: Nimir Kishore Mehta ... that, the Ld. PCCIT has failed to apply her mind judiciously and has accorded the approval mechanically and without application of mind and the reassessment proceedings initiated on the basis of such an approval is illegitimate and the assessment order is required to be quashed. 9. The Hon'ble Supreme

Mehal Singh, Jhallian Khurd, Rupnagar vs. ITO Ward-2(2), Ropar

In the result, the appeal is allowed for statistical purposes

ITA 806/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh10 Mar 2026AY 2015-16

Bench: The Cit(A), All The Notices & The Impugned Order Were Communicated At The Old Email Address Of The Earlier Counsel & Not At The Updated Email Address Furnished In The Income-Tax Records. Consequently, The Assessee Remained Unaware Of The Dismissal Of The Appeal & Came To Know About It Only When Recovery Proceedings Were Initiated. Immediately Thereafter He Consulted His Counsel & Steps Were Taken To File The Present Appeal. It Has Further Been Submitted That The Assessee Is A Senior Citizen Suffering From Hypertension & Diabetes & Due To Medical Complications

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 144Section 147Section 249Section 249(4)Section 249(4)(b)

relevant financial year. The assessee had not filed a return of income and had also not responded to the statutory notices issued during the reassessment proceedings. 5.1 Consequently, the Assessing Officer completed assessment ex-parte under section 147 read with section 144 determining income at Rs.75,54,200/- and raised

Kewal Krishan, Chandigarh vs. Joa DCIT/ACIT/JCIT(OSD)(Central Circle) 1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1275/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-24

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section ... context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section

Kewal Krishan Chandigarh, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) (Central Circle) 1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1274/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh10 Mar 2026AY 2021-22
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section ... context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section

Kewal Krishan, Chandigarh vs. Jao DCIT/ACIT JCIT (OSD)(Central Circle)-1, Chandigarh.

In the result, all the above appeals are partly allowed

ITA 1273/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh10 Mar 2026AY 2020-21
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section ... context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1272/CHANDI/2025[2023-2024]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-2024

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section ... context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1271/CHANDI/2025[2022-2023]Status: DisposedITAT Chandigarh10 Mar 2026AY 2022-2023
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section ... context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT (OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1270/CHANDI/2025[2021-2022]Status: DisposedITAT Chandigarh10 Mar 2026AY 2021-2022

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section ... context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1269/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh10 Mar 2026AY 2020-2021

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section ... context in para 11 of the order is against the facts and circumstances of the case. 5. Notwithstanding the above grounds of appeal, the reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section

Deputy Commissioner of Income Tax, Yamunanagar vs. M/S the Ved Parkash Mukand Lal, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 833/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the commencement of reassessment proceedings was valid, it has only to be seen whether there was, prima-facie, some material on the basis of which the department could reopen ... part of the assessee and the assessee had not disclosed fully and truly all the material facts necessary for the assessment. Finally, the reassessment proceedings were held to be justified for both the years. Aggrieved, the assessee is in further appeal before us. Our findings and Adjudication 4. The material

DCIT vs. M/S the Ved Parkash Mukand Lal, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 832/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the commencement of reassessment proceedings was valid, it has only to be seen whether there was, prima-facie, some material on the basis of which the department could reopen ... part of the assessee and the assessee had not disclosed fully and truly all the material facts necessary for the assessment. Finally, the reassessment proceedings were held to be justified for both the years. Aggrieved, the assessee is in further appeal before us. Our findings and Adjudication 4. The material