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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

Bijoy Kumar Agarwal, Ranchi vs. ACIT/DCIT Central Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 310/RAN/2025[11-12]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Shri Sonjoy Sarmaandshri Ratnesh Nandan Sahay, Accountantmember

Section 133(6)Section 143(2)Section 147Section 148Section 250

Notice under section 148 was issued, in response to which the assessee filed a return declaring the same income as originally returned. During the reassessment proceedings notice under section 143(2) was issued. The assessee filed detailed replies along with computation of income, contract notes, demat statements, bank statements,details

Smita, Ranchi vs. ITO Ward 3(4), Chaibasa

The appeal of the assessee is allowed

ITA 266/RAN/2025[2018-19]Status: DisposedITAT Ranchi06 Jan 2026AY 2018-19

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 144BSection 147Section 148Section 151

approval obtained under section 151 of the Act for issuance of notice under section 148 was never furnished to the assessee. Therefore, the reassessment proceedings are therefore bad in law. Further, the Assessing Officer adopted stamp duty valuation without referring the matter to the Departmental Valuation Officer (DVO), rendering ... section 151 of the Act was furnished or served upon the assessee. Non-supply of approval under section 151 of Act vitiates the entire reassessment proceedings. The Ld. AR reliance was placed on the decision of the Hon’ble Delhi High Court in TIA Enterprises

Income Tax Officer, Ranchi, Jharkhand vs. Amba Carbonisation Pvt. Ltd., Ranchi, Jharkhand

In the result, the appeal of the revenue is dismissed

ITA 61/RAN/2024[2013-14]Status: DisposedITAT Ranchi06 Jan 2026AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.61/Ran/2024 Assessment Year: 2013-14 Ito, Ranchi………..…………….…….…...................................……….……Appellant Vs. Amba Carbonisation Pvt. Ltd ……....….…..….........……........……...…..…..Respondent 21, Ashok Bhawan, Kali Asthan Road, Ranchi, Jharkhand. [Pan: Aadca7460J] Appearances By: Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Appellant. Shri Devesh Poddar, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Revenue Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 15.01.2024 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 Is A Company Incorporated Under The Provisions Of The Companies Act & Is Engaged In The Business Of Manufacturing & Trading Of Special Smokeless Coal/Coke. The Assessee Also Derives Income By Way Of Interest On Bank Deposits. As Per Information Available With The Income-Tax Department, It Was Noticed That The Assessee’S Bank Accounts Reflected Substantial Cash Deposits, Which Were Allegedly Withdrawn Immediately Through Rtgs/Neft Transactions. It Was Further Observed That There Existed A Difference Between The Turnover Disclosed By The Assessee In The Return Of Income & The Total Credits Appearing In The Bank Accounts. On The Basis Of The Above Information, The Assessing Officer (Ao) Initiated Reassessment Proceedings By Issuing A Notice Under Section 148 Of The

Section 139Section 142(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 250Section 270ASection 273B

return of income and the total credits appearing in the bank accounts. On the basis of the above information, the Assessing Officer (AO) initiated reassessment proceedings by issuing a notice under section 148 of the I.T.A. No.61/Ran/2024 Amba Carbonisation Pvt. Ltd Act dated 16.03.2021. Subsequently, without concluding or formally dropping ... earlier reassessment proceedings, the AO issued another notice under section 148 of the Act dated 31.03.2021 for the same assessment year and on identical reasons, thereby initiating parallel reassessment proceedings. In response to the notices issued under section 148 of the Act, the assessee filed its return of income

Naveen Singh, Jamshedpur vs. Deputy Commissioner of Income Tax, Circle - 1, Jamshedpur

In the result, the appeal of the assessee is allowed

ITA 413/RAN/2024[2017-18]Status: DisposedITAT Ranchi06 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.413/Ran/2024 Assessment Year: 2017-18 Naveen Singh………...…………….…….…............................……….……Appellant M-9 Old, Adityapur Jamshedpur, Jharkhand- 831013. [Pan: Adkps4229A] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri P. S. Paul, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 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 12.09.2024 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 Assessment Year 2017–18 Declaring A Total Income Of ₹43,99,340/- Under Section 139(1) Of The Act. The Return Was Processed Under Section 143(1) Accepting The Income As Declared. Subsequently, The Ao Issued A Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Sanction From The Competent Authority. The Assessee Did Not Respond To The Notice Under Section 148. Thereafter, Multiple Notices Under Section 142(1) Were Issued, Including Final Opportunity Notices, Which Were Duly Served But Remained Unanswered.

Section 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 56(2)(x)

income under section 56(2)(x) of the Act to the extent of ₹1,29,10,000, which was not offered to tax. Accordingly, reassessment proceedings were initiated, and the said amount was added to the income of the assessee. The total income was assessed ... enactment relating to reassessment is 'belief' and not 'suspicion'. These essential elements are obviously and glaringly missing in the instant case which renders the reassessment proceedings as well as the order passed ex-facie null in law. 7.1. It is settled that before an AO can be said to have

Bishnu Transport Company, Dhanbad vs. DCIT/ACIT, Circle-1, Dhanbad

In the result, the appeal of the assessee is allowed

ITA 401/RAN/2024[2011-12]Status: DisposedITAT Ranchi06 Jan 2026AY 2011-12

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 143(3)Section 147Section 148Section 151Section 151oSection 68

assessee is in appeal before this tribunal. Before us, the assessee filed an additional legal ground challenging the validity of the reassessment proceedings on the ground that the approval obtained under section 151 of the Act for issuance of notice under section 148 of the Act was granted ... material relied upon, and no justification recorded for reopening the assessment of the assessee. Such approval is purely mechanical, which vitiates the entire reassessment proceedings. Reliance was placed on judicial precedents including United Electrical Co. (P) Ltd. Vs. CIT (258 ITR 317) (Del), PCIT Vs. N.C. Cables

Income Tax Offier, Ward 6(1), Ludhiana vs. Balpreet Singh, Ludhiana

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

ITA 1022/CHANDI/2025[2016]Status: DisposedITAT Chandigarh06 Jan 2026

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Balpreet Singh, AssesseeFor Respondent: Shri Manav Bansal, CIT, DR
Section 133(6)Section 142(1)Section 143(1)(a)Section 144Section 148Section 151Section 251Section 69A

within the stipulated period of 30 days. 3.1 Thereafter, the case was assigned to the Faceless Assessment Unit on 11.11.2021. During the course of reassessment proceedings, the jurisdictional Assessing Officer as well as the FAU issued several statutory notices under section 142(1) and a show-cause notice under section

Sudhakar Bajirao Shisode, Nashik vs. Income Tax Officer, Nashik

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2780/PUN/2025[2018-19]Status: DisposedITAT Pune06 Jan 2026AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2780/Pun/2025 Assessment Year : 2018-19

For Appellant: Shri Bhagyesh DeshmukhFor Respondent: Shri Manish Sinha
Section 144BSection 147Section 2Section 250Section 69CSection 80C

declared in the return filed for A.Y. 2018-19. Subsequently, based on the information received from Risk Management Strategy, the reassessment proceedings in the case of assessee were carried out. Certain details were submitted by the assessee during the course of reassessment proceedings. However, ld. Assessing Officer concluded the proceedings

Income Tax Officer, Dhule vs. Santosh Jaynarayan Sharma, Dhule

In the result, the appeal filed by the Revenue is dismissed whereas the Cross Objection filed by the assessee is partly allowed

ITA 2324/PUN/2025[2017-18]Status: DisposedITAT Pune06 Jan 2026AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2324/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Sanjay DhivareFor Respondent: Shri Chinmayy Suhas
Section 133(6)Section 145(3)Section 147Section 148Section 148ASection 151Section 69

Finance (No. 2) Act, 2009, expressly empowers the Assessing Officer to assess or reassess any other income that comes to his notice during reassessment proceedings. 2. The learned CIT(A) erred in deleting the addition of ₹1,20,27,224 made by the Assessing Officer by rejecting the books

Sachin Ganpat Vadane, Solapur vs. ITO, Ward-1(1), Solapur

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

ITA 2073/PUN/2025[2019-20]Status: DisposedITAT Pune06 Jan 2026AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2073/Pun/2025 Assessment Year : 2019-20

For Appellant: Shri Deepak GadgilFor Respondent: Shri Harshit Bari
Section 147Section 148Section 148ASection 151Section 40A(3)Section 69C

Assessee has raised following grounds of appeal : “1. Learned JAO was not legally correct in proceeding further with the impugned reassessment proceedings as the order passed u/s 148A(d) as well as notice issued u/s 148 by the JAO was without proper jurisdiction. 2. Without prejudice to the above

Sunblaze Constructions Pvt. Ltd., Kolkata vs. I.T.O., Ward - 9(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1788/KOL/2025[2016-2017]Status: DisposedITAT Kolkata06 Jan 2026AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Ito, Ward 9(1) Sunblaze Constructions Pvt. Ltd. 164/1, Maniktala Main Road, Aaykar Bhawan, P-7, Kankurgachi, S.O. Kolkata- Chowringhee Square, Kolkata- Vs. 700054, West Bengal 700069, West Bengal (Appellant) (Respondent) Pan No. Aascs7903D Assessee By : Shri S.K. Tulsiyan & Ms. Puja Somani, Ars Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 17.11.2025 Date Of Pronouncement: 06.01.2026

For Appellant: Shri S.K. Tulsiyan &For Respondent: Shri S.B. Chakraborthy, DR
Section 148Section 148A

said notice having been issued beyond she permissible time limit is invalid and void ab initio, and consequently, the entire reassessment proceedings deserve to be quashed." 3.1. After hearing the rival contentions and perusing the material on record, we find that the assessee has raised an additional ground of appeal

Jigna Ashutosh Bhatt, Mumbai vs. Income Tax Officer Ward 33(2)(1), Mumbai

In the result the appeal of the assessee is partly allowed on merits

ITA 3639/MUM/2025[2011-12]Status: HeardITAT Mumbai06 Jan 2026AY 2011-12

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarito Ward-32(2)(1) Jigna Ashutosh Bhatt Kautilya Bhavan, I-1434, Govardhan Nagar Bandra Kurla Bldg. No. 4, Opp. Poinsur Vs. Complex, Bandra (E), Gymkhana, Kandivali Mumbai-400 051 (West), Mumbai-400 067 Pan/Gir No. Aiypb4411G (Applicant) (Respondent) Assessee By Shri Ketan L. Vajani, Ld. Ar Revenue By Shri Aditya Rai, Ld. Dr Date Of Hearing 05.01.2026 Date Of Pronouncement 06.01.2026

Section 132(4)Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68

original return of income for Assessment Year 2011–12 on 27.09.2011, declaring total income of Rs. 55,695/-. Subsequently, the Assessing Officer initiated reassessment proceedings by issuing notice under section 148 of the Act on 29.03.2018, after recording reasons and obtaining sanction under the Act. The reopening was based ... assessee filed a return of income on 12.11.2018, declaring the same income as returned originally. 3. During the course of reassessment proceedings, the Assessing Officer issued a show cause notice dated 24.12.2018, enclosing a copy of the statement of Shri Nilesh Bharani recorded under section 132(4), and required

ITO-26(2)(1), Mumbai, Kautilya Bhavan Bkc vs. Svadeshi Enterprises (Mumbai), Fort, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 5865/MUM/2024[2014-15]Status: DisposedITAT Mumbai06 Jan 2026AY 2014-15

Bench: Shri Rahul Chaudhary & Shri Prabhash Shankar

For Appellant: Mr. Akshay & Nishil Jain, ARsFor Respondent: Shri Swapnil Choudhary, (Sr. DR)
Section 143(3)

regard, he relied on the case of Ashok Devichand Jain v. Union of India (452 ITR 43) (Bom) ----------------- 7. Further, he submitted that the reassessment proceedings in the present case are to be treated as being initiated by non-jurisdictional assessing officer and, therefore, the reassessment proceedings and consequent assessment

ACIT-(CC)-7(3), Mumbai vs. Jay Jagannath Steel and Power Limited, Odisha

In the result, the appeal is allowed for statistical

ITA 5600/MUM/2024[2018-19]Status: DisposedITAT Mumbai06 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry

For Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 147Section 69C

reiterated the same contentions as made before the authorities below. It is claimed that during the course of the reassessment proceedings, the assessee sought from the AO the documents/materials relied upon against it including the copy of the alleged statement of the Director of M/s Hind Unitrade as also ... Hind Unitrade to appear from cross-examination but none appeared from M/s Hind Unitrade. Be that as it may, he proceeded to conclude the reassessment proceedings by holding that no cross-examination was warranted in the facts of the present case and made the addition u/s 69C. The AO made

Neptune Fincot Pvt Ltd, Mumbai vs. Assistant Commissioner of Income Tax, Circle 15(1)(2), Mumbai

In the result, the assessee succeeded ground no

ITA 3946/MUM/2024[2014-15]Status: DisposedITAT Mumbai06 Jan 2026AY 2014-15

Bench: Shri Pawan Singh& Shri Arun Khodpia(Physical Hearing)

Section 144BSection 147Section 148Section 254(1)Section 69A

assessee has raised following grounds of appeal: “1. On the facts and in the circumstances of the case, and in law, the reassessment proceedings u/s.147 of the Act is bad in law, having been initiated under the pre-amended law that existed prior to 1.4.2021 even though the relevant notice ... illegal. 2. On the facts and in the circumstances of the case, and in law, the Ld. CIT(A) erred in upholding the reassessment proceedings u/s.147 of the Act. The appellant submits that mandate of Section 147 of the Act was not satisfied by the Ld. AO before reopening

Chand Jewellers, Nakodar vs. Income Tax Officer, Jalandhar

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

ITA 574/ASR/2025[2017-18]Status: DisposedITAT Amritsar05 Jan 2026AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 574/Asr/2025 Assessment Year: 2017-18 Chand Jewellers, Bazar Sarafan Vs. Ito-Ward Nakodar, Distt. Jalandhar. Jalandhar. [Pan:-Aahfc5908J] (Appellant) (Respondent) Appellant By Sh. Amit Bajaj, Adv. Respondent By Sh. Charan Dass, Sr. Dr

Section 115BSection 147Section 148Section 250Section 69A

passed under section 147 r.w.s. 144B, is against the law, facts, and circumstances of the case and deserves to be quashed. 2. That the reassessment proceedings initiated under section 147 and the issuance of notice under section 148 of the Act are illegal, void ab initio, and unsustainable ... with Allahabad bank, during the demonetisation period and filed its regular return on 30th August, 2017, declaring total income at Rs.1,52,910/-. 3.1 Reassessment proceedings were initiated ( as per procedure ) vide notice u/s 148 dated 29/03/2021, and in course of scrutiny , books of accounts ( cash book , ledger, stock register

Pankaj Jindal Contractor, Mansa vs. The Deputy Commissioner of Income Tax, Circle-I, Bathinda

In the result the appeal of the assessee is allowed

ITA 695/ASR/2024[2014-15]Status: DisposedITAT Amritsar05 Jan 2026AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 695/Asr/2024 Assessment Year: 2014-15 M/S Pankaj Jindal Contractor, Vs. Dcit-Circle-1, Near Vidya Bharti School, Bathinda. Mansa. [Pan:-Aajfp8008L] (Appellant) (Respondent) Appellant By Sh. Sudhir Sehgal, Adv. Respondent By Sh. Charan Dass, Sr. Dr

Section 139(1)Section 143(3)Section 147Section 148Section 148aSection 250Section 282Section 40A(3)Section 68

regarding the legal issues taken up in the grounds No 1 and 3 , the Ld AR of the assessee submitted that the reassessment proceedings has been initiated on the basis of change of opinion because both the issues, firstly the issue of disallowance of expenditure being hit by the provisions ... cash payment of Rs.5,31,280/- (A/c machinery rent), and carriage of materials Rs. 16,43,302/- which has formed the basis of this reassessment proceedings , has already been examined in original proceedings and as evident from the ledger A/c of machine rent , payments to each individuals are less than

Nagarajan Jaya, Kancheepuram vs. ITO, Ward-1, Kanchipuram

In the result the appeal of the Assessee is allowed

ITA 1815/CHNY/2025[2011-12]Status: DisposedITAT Chennai05 Jan 2026AY 2011-12

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. P. Chidambaram, AdvocateFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 143(3)Section 147Section 148Section 264

short ‘the Act’) on 30.09.2021. 2. The main grievance of the assessee is in relation to jurisdiction assumed by the AO while initiating the reassessment proceedings and on merits in :-2-: ITA. No:1815/Chny/2025 relation to the addition towards unexplained cash deposit and estimation of business income. 3. The brief ... A.Y.2011-12 and therefore the AO was of the opinion that there is an escapement of income for the above assessment year. Later, the reassessment proceedings were completed on the basis that the gross receipts of the Assessee was in excess of Rs.60,00,000/-, and the Assessee has not maintained

Adhi Kumara Guru, Chennai vs. DCIT, Ncc-22(1), Chennai

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

ITA 120/CHNY/2025[2014-15]Status: DisposedITAT Chennai05 Jan 2026AY 2014-15

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaमाननीय "ी मनु कुमार िग"र, "ाियक सद" एवं माननीय "ी अिमताभ शु"ा, लेखा सद" के सम"

For Appellant: Mr. P.M. Kathir, Advocate for Mr.G.Baskar, AdvocateFor Respondent: Ms. R Anitha, Addl.CIT
Section 143(2)Section 143(3)Section 147Section 148Section 54F

claimed claimed u/s.54F of the Act. He further observed 54F of the Act. He further observed that it was not evident whether the first reassessment proceedings that it was not evident whether the first reassessment proceedings that it was not evident whether the first reassessment proceedings were initiated to examine ... date of transfer. This issue was duly residential house on the date of transfer. This issue was duly examined during the first reassessment proceedings, which examined during the first reassessment proceedings, which examined during the first reassessment proceedings, which culminated without any addition, as the deduction culminated without any addition

M/S. Bms Sales Pvt. Ltd., Purulia vs. DCIT, Central Circle 3(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1199/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Jan 2026AY 2019-2020

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Siddharth Jhajharia, ARFor Respondent: Shri Raja Sengupta, DR
Section 115JSection 132Section 132(1)Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 147Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRIPRADIP KUMAR CHOUBEY, JM ITA

DCIT, Central Circle-5(4), Mumbai vs. Sunil Bhagwatlal Dalal, Mumbai

In the result, both the Revenue’s appeals are partly allowed and

ITA 4047/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Jan 2026AY 2016-17

Bench: Shri Justice (Retd.) C. V. Bhadang&

Section 143(3)Section 69Section 69A

opinion ignoring the fact that Hon'ble Bombay High Court, while deciding the writ petition filed by the assessee, ordered to continue the reassessment proceedings with certain directions. On the facts and circumstances of case, the Ld. CIT(A) erred in deleting the addition ... loan transactions recorded under the above mentioned ledger accounts represent cash transactions executed by the Radius Group with the assessee. 4.2 The assessee against reassessment proceedings filed Writ petition vide No. 3378 of 2019 before Hon’ble Bombay High Court which was adjudicated with following directions by Hon’ble Bombay