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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

Sms Group Gmbh, New Delhi vs. ACIT Circle - 3(1)(2) Intl. Taxation, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 3297/DEL/2023[2021-22]Status: DisposedITAT Delhi24 Dec 2025AY 2021-22

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

appeal before the ld. CIT(A)-XXIV, New Delhi. Before ld. CIT (A), assessee has raised various grounds including jurisdictional issues for initiating reassessment proceedings in the case of the assessee and also on merit, assessee has submitted before the ld. CIT (A) as under:- ITA No. 1591-1592/Del/2022 ... laid down that reassessment jurisdiction is available only to the AO and not to the assessee and the assessee in reassessment proceedings cannot claim that certain incomes originally declared as taxable are not taxable. Therefore, the AO has rightly considered the income returned in the revised return as starting point

Sms Group Gmbh, New Delhi vs. ACIT, Circle-3(1)(2) Int. Taxation, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1592/DEL/2022[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

appeal before the ld. CIT(A)-XXIV, New Delhi. Before ld. CIT (A), assessee has raised various grounds including jurisdictional issues for initiating reassessment proceedings in the case of the assessee and also on merit, assessee has submitted before the ld. CIT (A) as under:- ITA No. 1591-1592/Del/2022 ... laid down that reassessment jurisdiction is available only to the AO and not to the assessee and the assessee in reassessment proceedings cannot claim that certain incomes originally declared as taxable are not taxable. Therefore, the AO has rightly considered the income returned in the revised return as starting point

Sms Group Gmbh, New Delhi vs. ACIT, Circle-3(1)(2), Int. Taxation, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1591/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

appeal before the ld. CIT(A)-XXIV, New Delhi. Before ld. CIT (A), assessee has raised various grounds including jurisdictional issues for initiating reassessment proceedings in the case of the assessee and also on merit, assessee has submitted before the ld. CIT (A) as under:- ITA No. 1591-1592/Del/2022 ... laid down that reassessment jurisdiction is available only to the AO and not to the assessee and the assessee in reassessment proceedings cannot claim that certain incomes originally declared as taxable are not taxable. Therefore, the AO has rightly considered the income returned in the revised return as starting point

Income Tax Officer, Ward-1(1)(3), Dehradun, Aaykar Bhawan, Subhash Road vs. Uttarakhand Purv Sainik Kalyan Nigam Limited, Station Sub Area

In the result, appeal of the assessee is allowed

ITA 92/DDN/2024[2015-16]Status: DisposedITAT Dehradun23 Dec 2025AY 2015-16

Bench: Sh. Yogesh Kumar U.S. & Sh. Manish Agarwal

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. Amar Pal Singh, JCIT-DR
Section 10Section 139Section 139(1)Section 139(4)Section 143(3)Section 148Section 149Section 617

assessee preferred an appeal before this Tribunal and this Tribunal vide its order passed in ITA No. 3070/Del/2016 dated 31.05.2021 had quashed the reassessment proceedings. Since, for assessment year 2014-15, i.e., the year under consideration, the learned CIT(A) had merely relied on the order of the predecessor ... forward the loss. 9. In view of the above, respectfully following the judicial precedents relied upon hereinabove, we have no hesitation to quash the reassessment proceedings framed by learned AO as void abinitio. Accordingly, ground no. 4 raised by the assessee on legal issue is allowed. 10. In the result

Hiteshbhai Rameshbhai Patel, Surat vs. ITO Ward, 2, Bardoli

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

ITA 484/SRT/2025[2012-13]Status: DisposedITAT Surat23 Dec 2025AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-13 Hiteshbhai Rameshbhai Patel Income Tax Officer, 466 Kanbivad, Goddha Mahuwa, Ward-2, Bardoli, Income Tax Taluka Valod, Dist. Surat 394630 Vs. Office, 2Nd Floor, Bsnl Gujarat, Building, Opp. Jalaram Temple, Station Road, Bardoli- 394601 Pan No. Avdpp 6788 Q Appellant Respondent Assessee By : Mr. Sakar Sharma, Ar Revenue By : Mr. J.K. Chandani, Sr-Dr

For Appellant: Mr. Sakar Sharma, ARFor Respondent: Mr. J.K. Chandani, Sr-DR
Section 143(3)Section 147Section 148Section 151(1)Section 68

claimed, and expenses incurred for earning such income. 2.3 Upon consideration of the submissions and material placed on record, the Assessing Officer completed the reassessment proceedings and passed an order dated 09.12.2019 under section 147 read with section 143(3) of the Act, making an addition ... Counsel for the assessee filed a paper book containing pages 1-101. 5. Ground No. 1 of the appeal challenges the validity of the reassessment proceedings initiated under section 147 of the Act. The learned counsel for the assessee contended that cash deposit per-se, by itself, does not constitute

Jastej Gorowara, Bhopal vs. Commissioner of Income-Tax (Appeals), Delhi

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

ITA 277/IND/2025[2015-16]Status: DisposedITAT Indore23 Dec 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR
Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

brief facts of the case are that the assessee, Shri Jastej Gorowara, proprietor of M/s Ranjit’s Golden Oak Resorts, Bhopal, was subjected to reassessment proceedings for A.Y. 2011–12. The Assessing Officer reopened the assessment by issuing notice under section 148 of the Income

Jastej Gorowara, Bhopal vs. CIT(A), Delhi

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

ITA 276/IND/2025[2011-12]Status: DisposedITAT Indore23 Dec 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR
Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

brief facts of the case are that the assessee, Shri Jastej Gorowara, proprietor of M/s Ranjit’s Golden Oak Resorts, Bhopal, was subjected to reassessment proceedings for A.Y. 2011–12. The Assessing Officer reopened the assessment by issuing notice under section 148 of the Income

Kunal Vyas, Indore vs. ITO 4(1), Ind, Main Building, Indore

The appeal of the assessee is allowed for statistical purposes

ITA 201/IND/2025[2018-19]Status: DisposedITAT Indore23 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Ankit Sijariya, AdvFor Respondent: Shri Ashish Porwal, Sr. DR
Section 144Section 144BSection 148Section 68Section 69

basis of this information, the Assessing Officer formed a belief that income chargeable to tax had escaped assessment and accordingly initiated reassessment proceedings by issuing notice under section 148 of the Act. During the reassessment proceedings, the Assessing Officer observed that the assessee had purchased the immovable property jointly with ... with section 144B was valid. Consequently, all the grounds of appeal were dismissed. 5. Before us, the Counsel for the assessee submitted that the reassessment proceedings are without jurisdiction as there was no valid information or live link to justify reopening under section issued notice

Shri Digamber Jain Yuvak Sangh, Indore, M.P vs. The NFAC, Delhi

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

ITA 566/IND/2024[2013-14]Status: DisposedITAT Indore23 Dec 2025AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri S. N. Agrawal C.A.& Shri Pankaj Mogra, C.AFor Respondent: Shri Ashish Porwal, Sr. DR
Section 1Section 143(2)Section 144Section 147Section 148Section 149Section 151

That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in upholding the validity of reassessment proceedings initiated under section 147 of the Income-Tax Act, 1961 for Assessment Year 2013-14 even when notice under section ... That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in upholding the validity of reassessment proceedings initiated under section 147 of the Income-Tax Act, 1961 even when reopening was done in absence of any tangible Shri Digamber Jain Yuvak

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 427/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

grounds of appeal: “1. In law and in the facts and circumstances of the appellant's case, the CIT(A) has erred considering the reassessment proceedings u/s 147 as valid which are initiated merely on the basis of information received from ADIT and statement of third party without appreciating that ... Assessing Officer. 3. In law and in the facts and circumstances of THE appellant's case, the CIT(A) has erred considering the reassessment proceedings u/s.147 as valid when reassessment proceedings cannot be conducted on the basis of search conducted in case of third party more particularly when no details

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby

ITA 426/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

grounds of appeal: “1. In law and in the facts and circumstances of the appellant's case, the CIT(A) has erred considering the reassessment proceedings u/s 147 as valid which are initiated merely on the basis of information received from ADIT and statement of third party without appreciating that ... Assessing Officer. 3. In law and in the facts and circumstances of THE appellant's case, the CIT(A) has erred considering the reassessment proceedings u/s.147 as valid when reassessment proceedings cannot be conducted on the basis of search conducted in case of third party more particularly when no details

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 425/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

grounds of appeal: “1. In law and in the facts and circumstances of the appellant's case, the CIT(A) has erred considering the reassessment proceedings u/s 147 as valid which are initiated merely on the basis of information received from ADIT and statement of third party without appreciating that ... Assessing Officer. 3. In law and in the facts and circumstances of THE appellant's case, the CIT(A) has erred considering the reassessment proceedings u/s.147 as valid when reassessment proceedings cannot be conducted on the basis of search conducted in case of third party more particularly when no details

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 424/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

grounds of appeal: “1. In law and in the facts and circumstances of the appellant's case, the CIT(A) has erred considering the reassessment proceedings u/s 147 as valid which are initiated merely on the basis of information received from ADIT and statement of third party without appreciating that ... Assessing Officer. 3. In law and in the facts and circumstances of THE appellant's case, the CIT(A) has erred considering the reassessment proceedings u/s.147 as valid when reassessment proceedings cannot be conducted on the basis of search conducted in case of third party more particularly when no details

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. Siddheshwari Vyapaar Private Limited, Kolkata

In the result, appeal of the revenue is dismissed

ITA 2280/KOL/2025[2012-13]Status: DisposedITAT Kolkata23 Dec 2025AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.2280/Kol/2025 (निर्धारणवर्ा/Assessment Years :2012-2013) Dcit, Central Circle-1(2), Vs Siddheshwarivyapaar Pvt Ltd Kolkata 2Nd Floor, 159, Ravindra Sarani Kolkata-700007 Pan No. :Aancs 2337 J (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) रधजस्वकीओरसे /Revenue By : Shri Sanat Kumar Raha, Cit-Dr निर्धाररतीकीओरसे /Assessee By : Shrisoumitra Choudhury & Rainak Jain, Advocates सुनवाई की तारीख / Date Of Hearing : 09/12/2025 घोषणा की तारीख/Date Of Pronouncement : 23.12.2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Revenueagainst The Order Passed By The Ld. Cit(A), Kolkata-20, Dated 06.05.2025For The Assessment Year2012-2013. 2. The Appeal Of The Revenue Is Barred By 69 Days. Considering The Submissions Of The Ld. Cit-Dr & Looking To The Facts Of The Case, We Condone The Delay Of 69 Days In Filing The Present Appeal By The Revenue & The Appeal Is Admitted For Hearing. 3. The Only Issue Raised In This Appeal Is Against The Order Of The Ld. Cit(A) In Deleting The Addition Of Rs.6,82,00,000/- Made U/S.68 Of The Act On Account Of Unexplained Cash Credits Received From Shell Entities In The Guise Of Share Capital.

For Appellant: ShriSoumitra Choudhury and Rainak Jain, AdvocatesFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 131Section 133(6)Section 143(2)Section 143(3)Section 148Section 68

recorded by the AO were based on incorrect facts and lack of independent application of mind. It is a well-settled legal principle that reassessment proceedings initiated on the basis of incorrect facts or borrowed satisfaction are invalid in the eyes of law. In the present case, the only allegation ... records, no such connection or transaction involving M/s Runicha Merchants Ltd. could be established. Therefore, the foundation of the reopening is flawed, rendering the reassessment proceedings unsustainable. The reliance can be placed on following judicial pronouncement: Belgundi Cements (P) Ltd vs. ITO [2024] 167 taxmann.com 219 (Karnataka) Nimesh Maheshbhai Shah

Rameshwar Finvest Private Limited, Kolkata vs. DCIT, Central Circle 3(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2107/KOL/2025[2008-2009]Status: DisposedITAT Kolkata23 Dec 2025AY 2008-2009

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dcit, Central Circle 3(3) Rameshwar Finvest Private Aaykar Bhawan Poorva, Limited Santil Palli, 110, Eastern 111, Park Street, Kolkata- Metropolitan Bypass, Opposite Vs. 700016, West Bengal Ruby, Kasba, Kolkata-700107, West Bengal (Appellant) (Respondent) Pan No. Aabcr1053N Assessee By : Shri S.K. Tulsiyan & Ms. Puja Somani, Ars Revenue By : Shri Sanat Kumar Raha, Dr Date Of Hearing: 17.11.2025 Date Of Pronouncement: 23.12.2025

For Appellant: Shri S.K. Tulsiyan &For Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 131(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 263Section 68

questionnaire were issued to the assessee and the assessee filed the copies of audited accounts, ITRs, bank statements, etc before the AO during the reassessment proceedings which were initiated by the ld. Rameshwar Finvest Private Limited; A.Y. 2008-09 AO u/s 147 of the Act by issuing notice

Tapan Kumar Pal, Sangrampur vs. DCIT, Circle 49(1), Kolkata

In the result, the both the appeals of the assessees’ are allowed

ITA 1487/KOL/2025[2013-2014]Status: DisposedITAT Kolkata23 Dec 2025AY 2013-2014

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Rabiul Islam Gain Ito, Ward 49(1), Gopalpur, Sangrampur, Basirhat, Uttarapan Complex, Ultadanga, North 24 Parganas, Maniktala Civic Centre, Kolkata- Vs. West Bengal-743286 700054, West Bengal (Respondent) (Appellant) Pan No. Anbpg1674J Tapan Kumar Pal Dcit, Circle 49(1) Vill-Parnaihati, P.O. Sangrampur, Uttarapan Complex, Ultadanga, North 24 Paraganas, West Maniktala Civic Centre, Kolkata- Vs. Bengal743422 700054, West Bengal (Appellant) (Respondent) Pan No. Baspp1538D Assessee By : Shri S.M. Surana, Ar Revenue By : S/Shri Sanat Kumar Raha Sandip Sarkar, Drs Date Of Hearing: 08.12.2025 Date Of Pronouncement: 23.12.2025

For Appellant: Shri S.M. Surana, ARFor Respondent: S/Shri Sanat Kumar Raha
Section 131Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

confirming the addition of alleged undisclosed cash deposit of ₹6,93,59,900/- on protective basis when no protective addition is allowed in reassessment proceedings. 3. For that the ld. CIT (A) erred in confirming the addition of Alleged undisclosed cash deposit of ₹6,93,59,900/- which cash belonged

Rabiul Islam Gain, Basirhat vs. ITO, Ward 49(1), Kolkata

In the result, the both the appeals of the assessees' are allowed

ITA 1485/KOL/2025[2013-2014]Status: DisposedITAT Kolkata23 Dec 2025AY 2013-2014

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

Section 131Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

confirming the addition of alleged undisclosed cash deposit of ₹6,93,59,900/- on protective basis when no protective addition is allowed in reassessment proceedings. 3. For that the Id. CIT (A) erred in confirming the addition of Alleged undisclosed cash deposit of ₹6,93,59,900/- which cash belonged

Gamnaram Okhaji Prajapati, Mumbai vs. DCIT. Circle 1(2)(1), Mumbai

Appeal is allowed

ITA 6791/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Dec 2025AY 2016-17

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh ShahFor Respondent: Shri Swapnil Choudhary
Section 115BSection 144Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 153CSection 234A

Faceless Assessing Officer under the scheme framed by the CBDT and not by Jurisdictional Assessing officer. 2.1 The re-assessment proceeding initiated and consequential reassessment proceeding initiated and consequential reassessment order passed u/s. 147 rws 1448 & 144 is invalid and be cancelled. 2.2 The above view is confirmed ... deleted.” 3. When the appeal was taken up for hearing the Learned Authorized Representative for the Assessee, at the outset, challenged the validity of reassessment proceedings contending that the approval/sanction obtained under Section 151 of the Act was not valid. In this regard, primary contention advanced on behalf

Gamnaram Okhaji Prajapati, Mumbai vs. Dy. CIT Circle 1(2)(1), Mumbai

Appeal is allowed

ITA 6790/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Dec 2025AY 2015-16
For Appellant: Shri Dinesh ShahFor Respondent: Shri Swapnil Choudhary
Section 115BSection 144Section 144BSection 147Section 148Section 148ASection 153CSection 234Section 234BSection 69A

after 01.04.2021 for the A.Y. 2015-16 is time barred further the benefit of relaxation under TOLA Act, 2020 is not available. Therefore the reassessment proceeding are barred by limitation and the assessment is liable to be declared null and void. 3.1 The reassessment notices ... Faceless Assessing Officer under the scheme framed by the CBDT and not by Jurisdictional Assessing officers. 3.2 The re-assessment proceeding initiated and consequential reassessment proceeding initiated and consequential reassessment order passed u/s.147 rws 144B & 144 is invalid and be cancelled. 4. The above view is confirmed by the Jurisdictional

Ghatkopar Laxminagar Sauli Co Op Hsg Society Ltd, Mumbai vs. Income Tax Officer Ward 27(1)(5), Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 6708/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Dec 2025AY 2019-20

Bench: Us Is That The Learned Commissioner Of Income Tax (Appeals) Has Disposed Of The Appeal Ex Parte, Without Considering The Written Submissions & Paper Book Duly Filed By The Assessee On The E-Filing Portal. Apart From Challenging The Validity Of Reopening Under Section 147, The Assessee Had Also Raised Grounds On Merits Against Various Additions, All Of Which Have Remained Unadjudicated.

Section 147

been preferred by the assessee against the order dated 28.08.2025 passed by the National Faceless Appeal Centre (NFAC), Delhi, arising out of the reassessment proceedings completed under section 147 of the Income-tax Act, 1961 for the assessment year 2019–20. 2 Ghatkopar Laxminagar Sauli Co-op Hsg. Society