“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

DCIT, Circle-1, Siliguri vs. Sushil Mitruka, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 1613/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Dec 2025AY 2017-18

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

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR

Section 139(1)Section 144BSection 147Section 148Section 148(2)

against him. The Appellant - assessee, as a Respondent before the ITAT was entitled to agitate the jurisdictional issue relating to the validity of the reassessment proceedings. We are, therefore, of the considered opinion that the impugned order passed by the ITAT suffers ITA Nos. 2178,1630,1630 & 1631/KOL/2025 Sushil Mitruka ... additional grounds, under Rule 27 of the ITAT Rules, pertaining to issues relating to the assumption of jurisdiction and the validity of the reassessment proceedings under section 153C of the Act.” 8.4. Therefore, we are inclined to admit the ground raised by the assessee under Rule

Cpt Elecy System Employees Coop T&C Society, Kancheepuram vs. ITO, Ward-1, Kancheepuram

In the result, appeal filed by the assessee is allowed in terms above

ITA 3058/CHNY/2025[2020-21]Status: DisposedITAT Chennai18 Dec 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No. 3058/Chny/2025 "नधा"रण वष"/Assessment Year: 2020-21 V. Cpt Elecy System Employees Ito, Coop T & C Society Che-W-(141) (91) No 30 S M Dass Avenue, Chennai, Iyappa Nagar, Tamil Nadu Kancheepuram-631501 [Pan: Aacac8508J] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 144BSection 147Section 148

subsequently, in appeal, the Supreme Court vide SLP (C) Diary No. 13266/2025, order dated 04.04.2025, categorically directed that the Revenue may proceed with the reassessment proceedings, but any adverse order against the petitioner therein shall not be given effect to until further orders. This direction of the Supreme Court ... Supreme Court, has not been stayed. 10. This Court has maintained a consistent position, that both JAO and FAO possess concurrent jurisdiction to initiate reassessment proceedings under Section 148 of the Act. In fact, in PC Jeweller Ltd. (Supra), a coordinate bench of this Court had dismissed a writ petition

Swamedas Panithasan, Chennai vs. ITO, Non-Corporate Ward 17(2), Chennai

In the result, appeal filed by the assessee is allowed in terms above

ITA 3056/CHNY/2025[2015-16]Status: DisposedITAT Chennai18 Dec 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.3056/Chny/2025 "नधा"रण वष"/Assessment Year: 2015-16 V. Swamedas Panithasan Ito, No 14/82 New No 20 Anna Salai, Non-Corporate Ward-17(2), Periyar Nagar A, T. Nagar Chennai. Chennai Alwarthiru Nagar, Alwarthirunagar, Chennai-600087 Tamil Nadu [Pan: Axjpp4321R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 144BSection 147Section 148

subsequently, in appeal, the Supreme Court vide SLP (C) Diary No. 13266/2025, order dated 04.04.2025, categorically directed that the Revenue may proceed with the reassessment proceedings, but any adverse order Swamedas Panithasan Vs ITO Non-Corp Ward 17(2), Chennai :: 10 :: against the petitioner therein shall not be given effect ... Supreme Court, has not been stayed. 10. This Court has maintained a consistent position, that both JAO and FAO possess concurrent jurisdiction to initiate reassessment proceedings under Section 148 of the Act. In fact, in PC Jeweller Ltd. (Supra), a coordinate bench of this Court had dismissed a writ petition

Assistant Commissioner of Income Tax, Circle-1(1)(1), Bengaluru vs. Hirehal Jairaj Balram, Bengaluru

ITA 1961/BANG/2025[2020-21]Status: FixedITAT Bangalore18 Dec 2025AY 2020-21

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. T. Srinivasa, CAFor Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore

Section 139(5)Section 143(1)Section 144Section 147Section 148Section 2(47)Section 250Section 50C

IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY

Chirag Chandrakant Mehta, Mumbai vs. Principal CIT-27, Mumbai

In the result, appeal of the assessee is dismissed

ITA 4397/MUM/2025[2015-16]Status: DisposedITAT Mumbai18 Dec 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2015-16 Chirag Chandrakant Mehta Vs Principal Commissioner Of C/O Ca Himanshu Gandhi Income Tax-27, Mumbai 16Th Floor, D Wing, Trade World Building, Kamala Mills Compound, Lower Parel, Mumbai- 400013 Pan: (Aabpm5091L) Appellant Respondent Present For: Appellant By : Shri Himanshu Gandhi, Ca Respondent By : Shri R.A. Dhyani, Cit Dr

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri R.A. Dhyani, CIT DR

Section 133(6)Section 143(2)Section 143(3)Section 144BSection 147Section 263Section 68

case was reopened for verification of opening capital of Rs. 2,37,53,300/- vide notice u/s 147 of Income Tax Act, 1961. During reassessment proceeding I had provided the copy of my 7 years capital account, Financials of companies & firm, details of gift received from family members in earlier ... also Managing Director of Jell Pharmaceuticals Pvt. Ltd. (PAN NO: AABCJ2207L) and partner in M/s Alka Chemical Industries. During reassessment proceeding Id. AO verified the details and even issued notice u/s 133(6) to 4 parties and after considering their reply passed reassessment order on 30.03.2022 and accepted the return

Assistant Commissioner of Income Tax, Central Circle, Jamshedpur vs. Benko Traders Private Limited, Kolkata

In the result, the appeal filed by the Revenue is dismissed

ITA 436/RAN/2024[2015]Status: DisposedITAT Ranchi17 Dec 2025

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.436/Ran/2024 Assessment Year: 2015-16 Acit, Cc, Jamshedpur…………….…….…............................……….……Appellant Vs. Benko Traders Pvt. Ltd....………...….…..….........……........……...…..…..Respondent 119, 4Th Floor, Block D, White House, Park Stree, Wb – 700016. [Pan: Aabcb1888R] Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 07, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-3, Patna For The Assessment Year 2015–16 Dated 25.09.2024 Passed U/S 250 Of The Income Tax Act (The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Under Section 139 Of The Act Declaring A Total Income As Nil. The Return Was Processed Under Section 143(1). Subsequently, The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Was Completed On 28.11.2017 Determining The Total Income At ₹9,88,28,406. Based On Information Received From The Investigation Wing, Mumbai, Relating To Alleged Use Of Stock Exchange Platform (Bse/Nse) For Generating Fictitious Long-Term/Short-Term Capital Gains Through Certain Scripts & Alleged Accommodation Entries, The Assessing Officer Recorded Reasons Under Section 147 Of The Act. A Notice Under Section 148 Was Issued The Assessee Filed Its Return Declaring The Same Income

Section 139Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69C

documentary evidence like copies of contract notes bank account etc to prove all the genuineness of the transactions during the course of reassessment proceeding Further the Ld. AO has not made any queries from the appellant in regard to the identity and genuineness of the reversal trading ... over and above the STT charges paid by the assessee to the brokers. However, during the course of reassessment proceedings the Ld. AO has not carried out any independent inquiry/verification to validate the allegation that undisclosed commission were paid to the broker over and above the STT charges & other charges

Indira Bai Jindal, Khargone vs. Income Tax Officer, NFAC

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

ITA 134/IND/2025[2013-14]Status: DisposedITAT Indore17 Dec 2025AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: None (Written request)For Respondent: Shri Ashish Porwal, Sr. DR

Section 142(1)Section 144BSection 147Section 148Section 271(1)(c)Section 271F

year. Subsequently, based on information received from the Investigation Wing showing that the assessee was a beneficiary of accommodation entries, the Assessing Officer initiated reassessment proceedings by issuing notice under section 148 of the Income-tax Act, 1961 (“the Act”). The Assessing Officer was in possession of tangible material ... assessee filed a return of income. However, the same was not e-verified and was, therefore, treated as non-est. During the course of reassessment proceedings, the Assessing Officer issued several notices under section 142(1) of the Act and also a show cause notice, granting multiple opportunities

Jaya Juneja, Indore vs. Income Tax Officer Ward 1(4), Indore

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

ITA 813/IND/2024[2015-16]Status: DisposedITAT Indore17 Dec 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Anil Kamal Garg, CA & Shri Aayush Garg, CAFor Respondent: Shri Ashish Porwal, Sr. DR

Section 147Section 148A

assessee filed a return of income on 26.04.2022 declaring the same income and capital loss as declared in the original return. During the reassessment proceedings the Assessing Officer was not satisfied with the explanations furnished by the assessee. The Assessing Officer invoked the provisions of section

Ashokbhai Anbabhai Kachadiya, Bhavnagar vs. The ITO, Ward-1(9), Bhavnagar

In the result, the appeal of the assessee is allowed

ITA 1373/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad17 Dec 2025AY 2013-14

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Ravindra, Sr. DR

Section 145(3)Section 147Section 148Section 234ASection 271(1)(c)Section 44A

raised the following grounds of appeal: "1. Learned CIT(A) has erred in law and on facts of the case in upholding the reassessment proceedings initiated under Section 148, which was barred by limitation and invalid as per amended provisions, instruction no. 1/2022 and judicial pronouncement. 2. Learned ... record. 9. We have carefully considered the rival submissions and perused the material available on record. It is an undisputed position that the reassessment proceedings in the present case were initiated beyond a period of three years from the end of the relevant assessment year and therefore the jurisdiction

Ashok Hirachand Shah, Panvel vs. Assessing Officer Ward 2, Panvel

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

ITA 812/PUN/2025[2011-12]Status: DisposedITAT Pune17 Dec 2025AY 2011-12

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.812/Pun/2025 धििाारण वर्ा / Assessment Year : 2011-12 Ashok Hirachand Shah, Assessing Officer, Plot No. 4, Mangal Bunglow, Ward – 2, Panvel Road No. 5, Sector No. 19, Vs. New Panvel, Tal.-Panvel-410206 Pan : Acdps4800M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Ajinkya Shah Department By : Shri Rajesh Gawali Date Of Hearing : 09-12-2025 Date Of 17-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 20.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Denial Of Natural Justice & Proper Opportunity The Learned Commissioner Of Income Tax (Appeals) Erred In Dismissing The Appeal Without Considering That The Appellant Was Denied Proper Opportunity & Natural Justice During The Assessment Proceedings. The Assessing Officer Called For Information At The Far End Of The Assessment Proceedings On 19/11/2018 & Despite The Appellant'S Authorized Representative Submitting The Details On 19/12/2018, The Ao Failed To Discuss Or Consider The Same. The Matter Ought To Have Been Remanded Back For Fresh Adjudication To Allow Proper Analysis Of The Transactions. 2. Addition Without Specifying The Section The Cit(A) Erred In Upholding The Addition Of Rs. 1,49,05,289/- Made By The Ao Without Specifying The Section Under Which The Addition Was Made. The Non-Mention Of The Specific Section Renders The Assessment Order Bad In Law, As It Violates The Principles Of Natural Justice & Transparency In Taxation. 3. Failure To Discharge Onus Under Section 69A

For Appellant: Shri Ajinkya ShahFor Respondent: Shri Rajesh Gawali

Section 147Section 69A

issues raised by the Ld. AO. The Ld. AO, however, did not find the explanation of the assessee satisfactory and proceeded to complete the reassessment proceedings by computing the total income at Rs.1,51,30,444/- thereby making addition(s) of :- (i)Rs.1,49,05,289/- on account of unexplained

Mr Shaikh Shakil Shaikh Ibrahim Bagwan, Jalgaon vs. ITO, Wrd-1(4), Jalgaon

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

ITA 2160/PUN/2025[2017-18]Status: DisposedITAT Pune17 Dec 2025AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2160/Pun/2025 धििाारण वर्ा / Assessment Year: 2017-18 Mr. Shaikh Shakil Shaikh Vs Ito, Ward-1(4), Ibrahim Bagwan, Jalgaon Prop. Of Javed Vegetable Company (Jvc), Barbhai Galli, Bodwad-425310, Dist-Jalgaon Maharashtra Pan-Attpb3077C Appellant Respondent

For Appellant: NoneFor Respondent: Shri Harshit Bari, Addl. CIT

Section 133(6)Section 139Section 147Section 148Section 250

response assessee furnished the return of income on 04.10.2024 declaring income of Rs. 2,44,180/- During the course of reassessment proceedings assessee did not responded to the communication dated 04.10.2024. Ld. AO called information from the Axis Bank u/s 133(6) of the Act. Ld. AO further observed that ... finding of the Ld. CIT(A) afirming the action of Ld. AO. The assessee has also made written submissions challenging the validity of reassessment proceedings as per the provisions of section 151A and scheme framed u/s 151A of the Act. 4 8. We however on going through the grounds

Kilaru Venkata Satish, Krishna Dist vs. DCIT, Central Circle-1(3), Hyderabad

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

ITA 933/HYD/2025[2018-19]Status: DisposedITAT Hyderabad17 Dec 2025AY 2018-19

Bench: Us), Which Reads As Under:

Section 147Section 148Section 148ASection 151Section 68

without obtaining the approval of the specified authority u/s. 151(ii) of the Act, we find substance in the same. Admittedly, the reassessment proceedings u/s. 147 of the Act had been revamped vide the Finance Act, 2021 w.e.f. 01.04.2021. The substituted Sections 147 to 159 and Section ... Income Tax Act (IT Act) by the Finance Act, 2021, radical and reformative changes are made governing the procedure for reassessment proceedings. Amended sections 147 to 149 and section 151 of the IT Act prescribe the procedure governing initiation of reassessment proceedings. However, for several reasons, the same gave rise

Krishnaveni Kokkula, Hyderabad vs. ITO., Ward-9(1), Hyderabad

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

ITA 558/HYD/2025[2016-17]Status: DisposedITAT Hyderabad17 Dec 2025AY 2016-17

Bench: Us:

Section 147Section 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

Laxmi Venkata Krishna Rice Corporation, Nalgonda vs. ITO, Ward-1, Suryapet

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

ITA 1700/HYD/2025[2017-18]Status: DisposedITAT Hyderabad17 Dec 2025AY 2017-18

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

Section 142(1)Section 144Section 147Section 148Section 148ASection 234ASection 69A

specified authority u/s. 9 Laxmi Venkata Krishna Rice Corporation vs. ITO 151(ii) of the Act, we find substance in the same. Admittedly, the reassessment proceedings u/s. 147 of the Act had been revamped vide the Finance Act, 2021 w.e.f. 01.04.2021. The substituted Sections 147 to 149 and Section ... Income Tax Act (IT Act) by the Finance Act, 2021, radical and reformative changes are made governing the procedure for reassessment proceedings. Amended sections 147 to 149 and section 151 of the IT Act prescribe the procedure governing initiation of reassessment proceedings. However, for several reasons, the same gave rise

Meenakshisundaram Saravanan, Chennai vs. Assistant Commissioner of Income Tax, Circle 1, Tirunelveli

ITA 3034/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Dec 2025AY 2016-17

For Respondent: Mr. ARV Sreenivasan, CIT

Section 144BSection 147Section 148

Indiran Selvi, Vellore vs. ITO, Ward-3, Vellore

ITA 3024/CHNY/2025[2015-16]Status: DisposedITAT Chennai17 Dec 2025AY 2015-16

For Appellant: Mr. Venkataraman, CAFor Respondent: Mr. ARV Sreenivasan, CIT

Section 144BSection 147Section 148

Raju Chandrasekar, Oduvanpatti, Tiruppattur (Tk) vs. Income Tax Officer, Ward-1, Karaikudi, Sekkalai Road

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

ITA 3000/CHNY/2025[2015-2016]Status: DisposedITAT Chennai17 Dec 2025AY 2015-2016

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 3000/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Ms. R. Anitha, Addl.CIT

Section 144BSection 147Section 148Section 148ASection 250

Court of Madras in the case of TVS Credit Services Ltd. v. DCIT in W.P. No. 22402 of 2024, the Ld.AR argued that the reassessment proceedings initiated by the Jurisdictional Assessing Officer are void ab initio. :- 3 -: 4. The Ld. DR relied on the order passed by the AO & First

D.B. Associate, Chennai vs. ITO, Ncw-10(1), Chennai

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

ITA 2995/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Dec 2025AY 2018-19

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2995/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19

For Appellant: Shri Hitesh, AdvocateFor Respondent: Ms. R. Anitha, Addl.CIT

Section 144BSection 147Section 148Section 148ASection 250

Court of Madras in the case of TVS Credit Services Ltd. v. DCIT in W.P. No. 22402 of 2024, the Ld.AR argued that the reassessment proceedings initiated by the Jurisdictional Assessing Officer are void ab initio. 3. The Ld. DR relied on the order passed by the AO & First Appellate

Palanisamy Jayakumar, Tiruppur vs. ITO, Ward 2(4), Tiruppur

In the result, the appeals filed by the assessee are allowed

ITA 2969/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Dec 2025AY 2019-20

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2967, 2968 & 2969/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20

For Appellant: Shri G. Tarun, AdvocateFor Respondent: Ms. R. Anitha, Addl.CIT

Section 144BSection 147Section 148Section 148ASection 250

Court of Madras in the case of TVS Credit Services Ltd. v. DCIT in W.P. No. 22402 of 2024, the Ld.AR argued that the reassessment proceedings initiated by the Jurisdictional Assessing Officer are void ab initio. 3. The Ld. DR relied on the order passed by the AO & First Appellate

Palanisamy Jayakumar, Tiruppur vs. ITO, Ward 2(4), Tiruppur

In the result, the appeals filed by the assessee are allowed

ITA 2968/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Dec 2025AY 2019-20

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2967, 2968 & 2969/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20

For Appellant: Shri G. Tarun, AdvocateFor Respondent: Ms. R. Anitha, Addl.CIT

Section 144BSection 147Section 148Section 148ASection 250

Court of Madras in the case of TVS Credit Services Ltd. v. DCIT in W.P. No. 22402 of 2024, the Ld.AR argued that the reassessment proceedings initiated by the Jurisdictional Assessing Officer are void ab initio. 3. The Ld. DR relied on the order passed by the AO & First Appellate