“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

Palanisamy Jayakumar, Triuppur vs. Iot Ward 2(4), Chennai

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

ITA 2967/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

C-2016 Itchiputhur Paccs, Vellore vs. ITO, Ward-1, Vellore

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

ITA 2191/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Dec 2025AY 2019-20

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. No.2191/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 C-2016 Itchiputhur Primary Agricultural Vs. The Income Tax Officer, Coop. Credit Society, 12Th Road, Ward 1, Itchiputhur Village, Arakkonam Tk, Vellore. Vellore 631 003. [Pan: Aabac1870C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri J. Saravanan, Advocate ""थ" की ओर से/Respondent By : Ms. Babitha, Jcit सुनवाई की तारीख/ Date Of Hearing : 11.12.2025 घोषणा की तारीख /Date Of Pronouncement : 17.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2019-20. 2. We Find That This Appeal Is Filed With A Delay Of 5 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, In 2

For Appellant: Shri J. Saravanan, AdvocateFor Respondent: Ms. Babitha, JCIT

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 80P(2)(a)

passing of order u/s. 148A(d) of the Act, all by the Jurisdictional Assessing Officer (JAO) after 29.03.2022, are invalid, and consequently the whole reassessment proceedings are liable to be quashed. 7. The Assessing Officer noted that the assessee has made cash deposits of ₹.22.4 lakhs in its bank account

Vama International, Mumbai vs. ACIT 22(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5456/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Dec 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Dharan Gandhi, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)

Section 143(1)Section 147Section 148

Page | 2 ITA No. 5456/Mum/2025 Α.Υ. 2012-13 Vama International 2. The grounds of appeal are as under: As regards validity of reassessment proceedings: 1. The Learned Commissioner (Appeals) erred in upholding the action of the learned Assessing Officer ('AO') in reopening the assessment u/s 147 of the Income ... learned Commissioner (Appeals) erred in confirming the action of learned AO in initiating reassessment proceedings without appreciating the fact that no income of the appellant chargeable to tax had escaped assessment. There was no reason to believe that income chargeable to tax had escaped assessment. 3. The learned AO erred

Income Tax Officer, Ward-44(1), Delhi vs. Savita Aggarwal, Delhi

ITA 800/DEL/2025[2015]Status: DisposedITAT Delhi17 Dec 2025

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaincome Tax Officer Vs. Savita Aggarwal Ward-44(1) A-147, Shankar Garden, Room No. 1804, 18Th Vikaspuri Floor, E-2 Block, Delhi – 110018 Spm Civic Centre Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacpa3523A Appellant .. Respondent

For Appellant: Sh. Suresh K.Gupta, CAFor Respondent: Sh. Om Prakash, Sr. DR

Section 147Section 148Section 149(1)Section 68

jurisdictional Delhi High Court in the case of IBIBO Group Private Limited Vs. Asst. CIT WP(C) 17639/2022 dated 13.12.2024 (Del) has quashed the reassessment proceedings for AY: 2015-16 on identical facts relying on the decision of UOI Vs. Rajeev Bansal (supra). 4. In the light of the aforesaid

Adesh Kumar Gupta, Delhi vs. Income Tax Officer, Ward 62(1), Delhi

In the result, ground no. 2 & 3 of the appeal is partly

ITA 6930/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Dec 2025AY 2019-20

Bench: Shri Pawan Singh(Physical Hearing) Adesh Kumar Gupta Ito, Ward-62(1), Delhi House No. 6, Sector -11, Pocket-C- Vs Civic Centre, Delhi – 110002. 5, Rohini, Delhi – 110085. [Pan: Aaipg9669H] Appellant / Assessee Respondent / Revenue

Section 145Section 147Section 254(1)Section 69C

against the order of ld. CIT(A) / NFAC dated 10.09.2025 for A.Y. 2019-20. The assessee has raised following grounds of appeal: “1. The reassessment proceedings and consequent reassessment both are invalid and without jurisdiction as the said assessment has been initiated and completed without complying with legal requirements

Sat Narain Sharma, Rohtak vs. Ward 2, Rohtak

In the result, appeal of the assessee is allowed

ITA 6167/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Pawan Singh(Physical Hearing) Sat Narayan Sharma Ward-2, Rohtak Village & Post Office Bohar, Dist. Vs Aayakarbhawan, Rohtak, Rohtak, Haryana – 124021. Haryana – 124001. [Pan: Afjps5702B] Appellant / Assessee Respondent / Revenue

Section 147Section 148Section 148ASection 234ASection 254(1)

which is illegal and void. Sat Narayan Sharma 5. The Id. Commissioner of Income Tax (Appeals) NFAC has erred in confirming the initiation of reassessment proceedings and the approval wrongly granted without application of mind and without verifying the facts from the records for issue of notice

Bansal Industries, Hansi vs. ITO Ward 1 Hissar, Hissar

In the result, the appeal filed by the assessee for A

ITA 5404/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad

Section 143(2)Section 147Section 148Section 151

amended 1961 Act, the issue concerning limitation is inextricably intertwined with two aspects: (a) First, the rank of the authority granting approval/sanction for triggering reassessment proceedings. (b) Second, the quantum of income which has escaped assessment." [Emphasis is ours) 12. Clearly, the revenue advanced the argument of interlinkage between limitation ... Section 151 of the amended Act (which has been extracted hereinabove) clearly specify the authority whose approval can trigger the reassessment proceedings. Thus, if three (3) years or less have elapsed from the end of the relevant AY, the specified authority who would grant approval for initiation of reassessment proceedings

Bansal Industries, Hansi vs. ITO Ward 1 Hissar, Hissar

In the result, the appeal filed by the assessee for A

ITA 5395/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri C.N. Prasad

Section 143(2)Section 147Section 148Section 151

Dy. Commissioner of Income Tax, Central Circle 3, Delhi vs. Pankaj Goel, Delhi

ITA 4159/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Dy. Commissioner Of Vs. Sh. Pankaj Goel, Income Tax, 662/3A, Ghati Road, Central Circle-3, Anand Paravt, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) With C.O. No.236/Del/2025 [Arising Out Of Ita No.4159/Del/2025] Assessment Year: 2017-18 Sh. Pankaj Goel, Vs. Dy. Commissioner Of Income 662/3A, Ghati Road, Tax, Anand Paravt, Central Circle-3, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) Assessee By Ms. Mansi Jain, Adv. Sh. Siddharth Bajaj, Adv. Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 17.12.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.4159/Del/2025 Along With Assessee’S Cross Objection C.O. No. 236/Del/2025 For Assessment & C.O. No.236/Del/2025

Section 13ASection 147Section 148Section 148ASection 151Section 29A

Income Tax Officer Ward 25 3 Delhi & Ors.(supra), a Coordinate Bench of this court examined the validity of initiation of reassessment proceedings, in cases where the income alleged to have escaped assessment was ₹50,00,000/- or 6 | P a g e & C.O. No.236/Del/2025 less. In the aforesaid context ... amended 1961 Act, the issue concerning limitation is inextricably intertwined with two aspects: (a) First, the rank of the authority granting approval/sanction for triggering reassessment proceedings. (b) Second, the quantum of income which has escaped assessment." (Emphasis is ours) 12. Clearly, the Revenue advanced the argument of interlinkage between limitation

Shailesh Kumar, Meerut vs. ACIT, Central Circle, Meerut

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

ITA 2108/DEL/2025[2012-13]Status: DisposedITAT Delhi17 Dec 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalshailesh Kumar, Asst. Cit (Central) C/O Malik & Co. Meerut. (Advisors & Advocate- Vs. Since 1927), 305/7, Thapar Nagar, Meerut-250001, Uttar Pradesh. Pan-Argpk0548N (Appellant) (Respondent) Appellant By Shri Sankalp Malik, Adv., Shri Sanjay Malik, Adv.,Shri Murtaza Shuberi, Adv. & Shri Praveen Bansal, Ca Respondent By Ms. Pooja Swaroop, Cit-Dr Date Of Hearing 18.11.2025 Date Of Pronouncement 17.12.2025 Order Per Yogesh Kumar U.S., Jm: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals)-3, Noida [“Ld. Cit(A)”, For Short], Dated 21.08.2024 For Assessment Year 2012-13. Shailesh Kumar Vs. Acit 2. Brief Facts Of The Case Are That A Search & Seizure Operation Was Carried Out On 24.05.2017 In The Residential Premises Of The Assessee & It Was Covered In The Search In The Case Of H.S. Tewari Group Of Cases. An Assessment Order Came To Be Passed U/S 142(3)/153A Of The Income Tax Act, 1961 (‘The Act’ For Short) By Making Addition Of Rs.12,01,153/- As The Assessee Failed To Prove The Source Of The Investment In Construction.

Section 132Section 142(3)Section 153Section 153A

search no incriminating material is found, in case of completed/unabated assessment, the only remedy available to the Revenue would be to initiate the reassessment proceedings under Sections 147/48 of the Act, subject to fulfilment of the conditions mentioned in Sections 147/148, as in such a situation, the Revenue cannot

Gian Gupta, New Delhi vs. ACIT, Circle- 33(1), New Delhi

In the result, this appeal is allowed

ITA 1307/DEL/2024[2011-12]Status: DisposedITAT Delhi17 Dec 2025AY 2011-12

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.1307/Del/2024 िनधा"रणवष"/Assessment Year: 2011-12 बनाम Gian Gupta, Acit, Kh. No. 389/2/2-415, Vs. Circle 33(1), Civic Centre, Ford Service Centre, Nh-8, Rangpuri, Minto Road, New Delhi. New Delhi. Pan No.Aaapg7797G अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 148Section 250Section 68

illegal, bad in law and without jurisdiction.” 2. Before us, the Ld. AR argued, with the help of a paper book, that firstly, the reassessment proceedings were barred by limitation since as per the proviso to section 147 of the Act, wherein it is specifically mentioned that no action will ... summarized his arguments and stated that: i. The assessee had fully and truly disclosed the facts during the first round and hence the reassessment proceedings were hit by the first proviso to section 147 of the Act, as the notice u/s 148 of the Act was issued well beyond

Gayathri Global Resources Private Limited, Jamshedpur vs. ITO Ward (1), Jamshedpur

In the result, both the appeals are allowed for statistical purposes

ITA 96/RAN/2025[2014-15]Status: DisposedITAT Ranchi16 Dec 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.456/Ran/2024 Assessment Year: 2013-14 Gayatri Global Pvt. Ltd …………….…….…............................……….……Appellant 153, Kamani Centre, Bistupur, Jharkhand-831001. [Pan: Aadcg3732B] Vs. Nfac, New Delhi…….....………...….…..….........……........……...…..…..Respondent I.T.A. No.96/Ran/2025 Assessment Year: 2014-15 Gayatri Global Pvt. Ltd …………….…….…............................……….……Appellant 153, Kamani Centre, Bistupur, Jharkhand-831001. [Pan: Aadcg3732B] Vs. Nfac, New Delhi…….....………...….…..….........……........……...…..…..Respondent Appearances By: Shri Manish Agarwal, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : December 16, 2025 Order Per Sonjoy Sarma: These Two Appeals Are Filed By The Assessee For The Assessment Years 2013–14 & 2014–15. Since The Issues Involved, The Assessment Proceedings & The Additions Made Are Common & On Identical Issues, Both The Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order. For The Sake Of Convenience, We First Take Up

Section 115BSection 144Section 147Section 148Section 68

96/Ranchi/2025 for assessment year 2014–15. 2. Brief facts of the case are that, for assessment year 2013–14, the assessee was subjected to reassessment proceedings and notice under I.T.A. No.456/Ran/2024 Gayatri Global Pvt. Ltd section 148 of the Income-tax Act, 1961 was issued on the basis of information ... received from the Investigation Wing alleging that the assessee had received share application money amounting to ₹37,44,600. During the reassessment proceedings, the Assessing Officer issued notices calling upon the assessee to furnish details such as the identity, address, and genuineness of the persons from whom the share application

Gayatri Global Private Limited, Jamshedpur vs. National Faceless Assessment Centre, New Delhi

In the result, both the appeals are allowed for statistical purposes

ITA 456/RAN/2024[2013-14]Status: DisposedITAT Ranchi16 Dec 2025AY 2013-14

Section 115BSection 144Section 147Section 148Section 68

Sunil Kumar Moolchandani, Bhopal vs. ITO, 1(2), Bhopal

Appeal is allowed for statistical purpose

ITA 577/IND/2025[2014-15]Status: DisposedITAT Indore16 Dec 2025AY 2014-15

Bench: Ms. Suchitra R. Kamble

Section 147Section 250

said order in a timely manner and was only able to review the contents of the same on 7th May, 2025. 3) That, the reassessment proceedings were initiated based on information received from the Office of the DDIT (Investigation), Unit- IL, Indore, alleging that the Appellant received an accommodation entry

Harkrishen Singh Tuli, Chandigarh vs. Income Tax Officer, Ward 1(3), Chandigarh

In the result, appeals of the assessee are partly allowed

ITA 786/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh16 Dec 2025AY 2020-21

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 784, 785 & 786/Chd/2024 िनधा"रण वष" / A.Y. : 2012-13, 2017-18 & 2020-21 Shri Harkrishen Singh Tuli, Vs The Ito, #359, Sector 9-D, Ward 1(3), Chandigarh. Chandigarh. "ायी लेखा सं./Pan No: Afrpt6944G अपीलाथ"/Appellant ""थ"/Respondent Assessee By : Shri Harkrishen Singh Tuli, Assessee Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr Date Of Hearing : 16.12.2025 Date Of Pronouncement : 16.12.2025

For Appellant: Shri Harkrishen Singh Tuli, AssesseeFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR

Section 143(3)Section 147Section 148Section 2(13)Section 37Section 44ASection 56(1)

786/CHD/2024 3 name. The Assessee admitted that this was done to earn a higher rate of interest available to senior citizens. 6. During the reassessment proceedings u/s 147, the AO treated the interest earned on these FDRs amounting to Rs. 51,41,996/- as "Income from Other Sources" and added

Harkrishen Singh Tuli, Chandigarh vs. Income Tax Officer, Ward 1(3), Chandigarh

In the result, appeals of the assessee are partly allowed

ITA 785/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh16 Dec 2025AY 2017-18

For Appellant: Shri Harkrishen Singh Tuli, AssesseeFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR

Section 143(3)Section 147Section 148Section 2(13)Section 37Section 44ASection 56(1)

Harkrishen Singh Tuli, Chandigarh vs. Income Tax Officer, Ward 1(3), Chandigarh

In the result, appeals of the assessee are partly allowed

ITA 784/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh16 Dec 2025AY 2012-13

For Appellant: Shri Harkrishen Singh Tuli, AssesseeFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR

Section 143(3)Section 147Section 148Section 2(13)Section 37Section 44ASection 56(1)

Deputy Commissioner of Income Tax Circle 2 1 1 Ahmedabad, Ahmedabad vs. Sunali Biren Shah, Ahmedabad

In the result, the appeal filed by the Department is dismissed the Cross

ITA 1726/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Kamal Deep Singh, Sr. DRFor Respondent: Shri Kamal Deep Singh, Sr. DR

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 271(1)(c)

alleging misuse of the National Multi Commodity Exchange (NMCE) platform and systematic tax evasion by certain clients/members through booking of fictitious profits and losses, reassessment proceedings under ITA No. 1726/Ahd/2025 & C.O. No. 84/Ahd/2025 DCIT vs. Sunali Biren Shah & Sunali Biren Shah vs. DCIT Asst. Year–2011-12 - 3– section ... dated 30.03.2018 in response to which the assessee filed return of income on 30.04.2018 declaring total income of ₹3,52,080/-. 4.1 During the reassessment proceedings, the Assessing Officer relied upon information received from the Investigation Wing and also obtained details from NMCE by issuing a notice under section

Vijaykumar Ukabhai Patel, Mehsana vs. Income Tax Office, Ward 1, Mehsana

The appeal of the assessee is allowed for statistical purposes

ITA 1712/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Abhijit, Sr. DR

Section 144Section 147Section 148Section 69A

agricultural land. Subsequently, based on information received from the Investigation Wing pursuant to a search action conducted in the case of VEE GEE Group, reassessment proceedings were initiated. The Assessing Officer initiated reassessment proceedings and during the reassessment proceedings, the Assessing Officer relied upon certain seized digital evidence

Thakorbhai Maganbhai Patel, Vadodara vs. The ITO, Ward- 3(1)(1), Vadodara

ITA 532/AHD/2023[2008-09]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2008-09

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Sakar Sharma, ARFor Respondent: Shri Kamal Deep Singh, Sr. DR

Section 131Section 142(1)Section 143(3)Section 147Section 148Section 2(14)(iii)Section 271(1)(c)

land, the Assessing Officer reopened the assessment by issuing notice under section 148 dated 27.03.2015 after obtaining approval from the competent authority. During reassessment proceedings, the Assessing Officer issued several notices under section 142(1) of the Act calling for details regarding the nature of land, distance from municipal limits ... appeal by granting relief only on the limited issues relating to nature of capital gain and determination of cost of acquisition, while confirming the reassessment proceedings and major additions made by the Assessing Officer. 6. The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing