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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

Pagadala Velugonda Reddy, Durg vs. ACIT-1(1), Bhilai

In the result, the appeal is dismissed

ITA 726/RPR/2025[2013-14]Status: HeardITAT Raipur05 Dec 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.726/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Pagadala Velugonda Reddy Lig 284, Hudco, Bhilai-490 009 (C.G.) Pan: Abmpv7318K

For Appellant: Shri Yash Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 147Section 271(1)(b)Section 271FSection 69

assessee is a senior citizen deriving income primarily from agricultural activities and was not required to file a return of income for A.Y.2013-14. Reassessment proceedings were initiated and completed ex-parte u/s. 147 r.w.s. 144 of the Income Tax 3 Pagadala Velugonda Reddy Vs. ACIT-1(1), Bhilai

Maria Rojalu Pothakamuri, Narsaraopeta vs. Income-Tax Officer, Ward-1, Narsaraopeta

In the result, appeal of the assessee is allowed

ITA 587/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2015-16

Bench: Ld. CIT(A). Before Ld. CIT(A), assessee has raised various grounds challenging the assessment order. After considering the submissions of the assessee, Ld.CIT(A) dismissed the appeal of the assessee. 4. Being aggrieved by the order of the Ld. CIT(A), assessee filed an appeal before the Tribunal by raising following grounds of

Section 139Section 147Section 148Section 148ASection 149(1)(b)Section 69ASection 748

with the prior approval of PCCII AP & Telangana, is invalid as the same has not given 7 clear days for compliance, consequently the entire reassessment proceedings are invalid and void ab initio. 4. The notice under section 148 dated 07.04.2022 issued by the lncome-tax Officer, Ward-1, Narasaraopeta ... invalid and barred by limitation. In view of the above findings and in light of binding judicial precedents, we hold that the reassessment proceedings initiated for AY 2015-16 are without jurisdiction, and hence the notice issued under section 148 and subsequent proceedings are quashed. Accordingly, the assessment completed under

Dasari Sai Annapurna L/R of Late Dasari Gopi Krishna Reddy, Vijayawada vs. The Assistant Commissioner of Income Tax, Central Circle-2(1), Vijayawada

In the result, the appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 583/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.583/Viz/2025 (िनधा"रण वष"/Assessment Year:2015-16) Dasari Sai Annapurna Vs. Assistant Commissioner L/R Of Late Dasari Gopi Of Income Tax, Krishna Reddy, Central Circle-2(1), Vijayawada. Vijayawada. Pan: Aeipd0990C (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Mv Prasad, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 27/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 28/03/2022, For The Assessment Year 2015-16. The 2 Dasai Sai Annapurna L/R Of Late Dasari Gopi Krishna Reddy Vs. Acit

For Appellant: Shri MV Prasad, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(2)Section 147Section 148Section 45Section 54F

dated 31/03/2021, was issued, therefore no infirmity arises from the validity of the jurisdiction that was framed by the AO for initiating the reassessment proceedings at the relevant point of time, i.e., during the lifetime of the assessee. 11. We have heard the Learned Authorised Representatives of both parties, perused

Seelamsetty Balaji, Vijayawada vs. Income Tax Officer, Ward-2(1), Vijayawada

In the result, appeal of the assessee is allowed

ITA 508/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2020-21

Bench: Shri Ravish Sood, Hon’Ble

Section 142(1)Section 147Section 148Section 44A

sae sei afte, feemaneua te, fexmarmeursy IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM “SMC” BENCH, VISAKHAPATNAM (HYBRID HEARING) Sf edie

Satyanarayana Koduru, Krishna Dist vs. Income Tax Officer, Ward-1, Gudiwada

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

ITA 491/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.491/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Satyanarayana Koduru, Vs. Income Tax Officer, Krishna District. Ward-1, Pan:Altpk1048C Gudiwada. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 148ASection 250Section 69Section 69A

contrary to the facts of the case and the provisions of law. 2) The Ld. CIT(A) ought to have held that the reassessment proceedings initiated pursuant to the notices issued u/ss 148A(b), 148A(d), and 148 dt. 06.03.2023, 24.03.2023, and 28.03.2023 respectively, are contrary to the scheme ... 151A of the Act. The jurisdictional Assessing Officer (ITO Ward 1, Gudiwada) lacked authority and competence in issuing the said notices. Consequently, the entire reassessment proceedings and the order passed thereunder are vold ab initio and liable to be quashed. 3) The Ld. CIT(A) erred in confirming the addition

Venkata Ramana Goda, Visakhapatnam vs. Assisstant Commissioner of Income Tax, Circle-3(1), Visakhapatnam

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

ITA 489/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2020-21

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.489/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Venkata Ramana Goda, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Circle-3(1), Pan: Abzpg3216A Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 17/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 08/03/2025. The 2 Venkata Ramana Goda Vs. Acit

For Appellant: Mrs. K. Hemalatha, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133(6)Section 147Section 148Section 151ASection 2(14)(iii)Section 234ASection 234BSection 250

Centre (NFAC), but as in the present case the same was issued by the Jurisdictional Assessing Officer (JAO), thus, the it had rendered the reassessment proceedings as void-ab-initio due to non-compliance with the statutory procedure. Ostensibly, the assessee to support his aforesaid contention had relied upon ... Assessment of Income Escaping Assessment Scheme, 2022” was invalid in law and, thus, on the said basis had sought for annulling of the reassessment proceedings and the consequential assessment order passed by the Assessment Unit, Income-tax Department, i.e., the Faceless Assessing Officer (FAO) under section 147 r.w.s 144B

Shakir Mohmmad, Visakhapatnam vs. The Income Tax Officer, Ward-2(5), Visakhapatnam

ITA 280/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.280/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Shakir Mohmmad, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Cffpm2965E Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 69A

issued u/s 148 of the Act and ought to have quashed the notice issued u/s 148 of the Act as invalid and the consequent reassessment proceedings as void ab initio. 3. The learned Commissioner of Income Tax (Appeals) is not justified in sustaining the addition of Rs.1 ... time to the appellant, which is less than the stipulated period of 7 clear days and consequently the notice u/s 148 and the entire reassessment proceedings are liable to be quashed as void-ab-initio." 3. As the assessee by raising the additional ground of appeal is seeking our indulgence

A & B Associates, Thiruvananthapuram vs. The Income Tax Officer, Thiruvananthapuram

In the result, the appeal of the assesse is allowed for statistical purpose

ITA 643/COCH/2025[2018-19]Status: DisposedITAT Cochin05 Dec 2025AY 2018-19

Bench: the Ld. CIT(A). The Ld.CIT(A) partly allowed the appeal filed by the assessee by directing the AO to -

For Appellant: Shri Lokanathan, C.AFor Respondent: Shri Sanjit Kumar Das, Sr. D/R
Section 115BSection 142(1)Section 144Section 147Section 148Section 148ASection 250

issuing directions to the Ld. AO, did not adjudicate several substantive legal grounds raised by the assessee regarding the validity of initiation of reassessment proceedings, jurisdictional infirmities, service of notice, and procedural irregularities. Nevertheless, since the assessee was not granted reasonable opportunity either during the reassessment proceedings

Bhavna Shetalkumar Patel, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal of the assessee stands allowed

ITA 1103/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Parin S Shah, ARFor Respondent: Shri Santosh Kumar, Sr. DR
Section 10(38)Section 142(1)Section 143(1)Section 144Section 144BSection 147Section 148Section 68

does not give rise to any triable issue. The additional ground is accordingly not admitted. 13. The AR assailed the validity of the reassessment proceedings initiated for the Assessment Year 2016-17 on several grounds. It was submitted that the notice under section 148 was issued ... Officer. The AR placed on record the copy of the assessment order in the husband's case (Paper Book pages 123-124), where the reassessment proceedings were completed by accepting the returned income without making any addition. It was submitted that the notice issued under section 143(2) read with

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

ITA 1636/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2012-13

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

For Appellant: Revenue by Shri R.P. Rastogi, CIT-DR
Section 143(3)Section 147Section 148Section 68Section 69A

upheld the validity of reopening under section 147 for all assessment years. He recorded that the Assessing Officer had initiated reassessment proceedings solely on the basis of seized unaccounted cash book and supporting vouchers found during the search in the Venus Group at the premises known as Terrace of Crystal

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

ITA 1635/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2011-12

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

For Appellant: Revenue by Shri R.P. Rastogi, CIT-DR
Section 143(3)Section 147Section 148Section 68Section 69A

upheld the validity of reopening under section 147 for all assessment years. He recorded that the Assessing Officer had initiated reassessment proceedings solely on the basis of seized unaccounted cash book and supporting vouchers found during the search in the Venus Group at the premises known as Terrace of Crystal

Nandkishore Telefilms & Media Private Limited, Mumbai vs. Circle 7(2)(2), Mumbai

In the result appeal of the revenue is dismissed

ITA 2563/MUM/2025[2013-14]Status: DisposedITAT Mumbai05 Dec 2025AY 2013-14

Bench: Ms. Padmavathy S & Shri. Raj Kumar Chauhan

Section 132(4)Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 68

issue of notice u/s.148 of the income Tax Act, 1961 by the learned Assessing Officer as valid and thereby upholding the validity of reassessment proceedings without considering the fact that the learned Assessing Officer has not applied his mind and having no independent satisfaction with regard to reopening

Shri Radha Krishan Mandir Trust, Delhi vs. Income Tax Officer, Ward Exemp 2(2), Delhi

In the result, Appeal of the Assessee is partly allowed

ITA 1481/DEL/2025[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Shri Radha Krishan Mandir Vs. Income Tax Officer, Trust, Opposite E Block, Greater Ward Exemption 2(2) Kailsah, Part-1, Delhi Civic Centre, Delhi Pan: Aakts7362K Appellant Respondent Assessee By Sh. Suresh Kumar Gupta, Ca Revenue By Sh. Shankar Lal Verma, Sr. Dr Date Of Hearing 09/09/2025 Date Of Pronouncement 05/12/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld.

Section 143(2)Section 144Section 148Section 292BSection 69A

ACIT W.P.(C) No.10298/2022 and Primary Real Estate Investments vs. Dy. CIT W.P.(C) No.9705/2023 both dated 27.08.2024 while quashing the reassessment proceedings for not issuing notice u/s 143(2) of IT Act. 8. Considering the above facts and circumstances, as the assessment has been completed without issue of notice

Diamond Realcon Private Limited, Delhi vs. ACIT, Central Circle-2, Faridabad

In the result, Appeal in ITA

ITA 1260/DEL/2025[2012-13]Status: DisposedITAT Delhi05 Dec 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1260/Del/2025 (A.Y. 2012-13) M/S Diamond Realcon Private Vs Assistant Commissioner Of Limited, Income Tax, Central Circle-Ii, Shop No. 68, Building No. 38, Faridabad, Surya House, Near Pnb, Devli, Haryana-121001 Khanpur, New Delhi-110062 Pan: Aadcd6696H Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 05/12/2025

Section 143(2)Section 147Section 148Section 151Section 153CSection 68

order of the Ld. AO without considering the fact, that the reasons to believe recorded by the Ld. AO for the initiation of reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. Diamond Realcon Pvt. Ltd. Vs. ACIT 6.2 That ... order of the Ld. AO without considering the fact, that the reasons to believe recorded by the Ld. AO for the initiation of reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances

Diamond Realcon Private Limited, New Delhi vs. ACIT, Central Circle-2, Faridabad

In the result, Appeal in ITA

ITA 1259/DEL/2025[2011-12]Status: DisposedITAT Delhi05 Dec 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1260/Del/2025 (A.Y. 2012-13) M/S Diamond Realcon Private Vs Assistant Commissioner Of Limited, Income Tax, Central Circle-Ii, Shop No. 68, Building No. 38, Faridabad, Surya House, Near Pnb, Devli, Haryana-121001 Khanpur, New Delhi-110062 Pan: Aadcd6696H Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 05/12/2025

Section 143(2)Section 147Section 148Section 151Section 153CSection 68

order of the Ld. AO without considering the fact, that the reasons to believe recorded by the Ld. AO for the initiation of reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. Diamond Realcon Pvt. Ltd. Vs. ACIT 6.2 That ... order of the Ld. AO without considering the fact, that the reasons to believe recorded by the Ld. AO for the initiation of reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances

Deputy Commissioner of Income Tax, Ghaziabad vs. Mahalaxmi Light House, Hapur

ITA 3514/DEL/2024[2018-19]Status: DisposedITAT Delhi05 Dec 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Deputy Commissioner Of Vs. Mahalakshmi Light House, Income Tax 285, Avas Vikas Vihar, Room No. 201, First Floor, Hapur, Uttar Pradesh Cgo Complex, Hapurchungi, Pan: Aatfm3627N Ghaziabad, Uttar Pradesh Appellant Respondent

Section 148Section 148ASection 69

figures. C.O No. 109/Del/2024 (in ITA No. 3514/Del/2024) “1. That the assessment u/s 147 is bad in law and required to be quashed as reassessment proceedings u/s 148 which led to assessment u/s 147 were initiated/completed without 4 ITA Nos. 3514, & C.O No. 109/Del/2024 DCIT Vs. Mahalaxmi Light House following

Deputy Commissioner of Income Tax, Ghaziabad vs. Mahalakshmi Light House, Hapur

In the result, Cross Objection filed by the Assessee is allowed

ITA 3513/DEL/2024[2015-16]Status: DisposedITAT Delhi05 Dec 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Deputy Commissioner Of Vs. Mahalakshmi Light House, Income Tax 285, Avas Vikas Vihar, Room No. 201, First Floor, Hapur, Uttar Pradesh Cgo Complex, Hapur Chungi, Pan: Aatfm3627N Ghaziabad, Uttar Pradesh Appellant Respondent

Section 147Section 69C

119/Del/2024 (in ITA No. 3513/Del/2024) “1. That the Ld. AO, NFAC has grossly erred on facts and in law in completing the reassessment proceedings u/s 147/144/144B of the Act, 1961 without issuing mandatory notice u/s 143(2) of the Act, 1961, and hence order of the reassessment passed u/s 147/144/144B ... section 148 of the Act. 13. In DIT v. Society for Worldwide Interbank Financial Telecommunications [2010] 323 ITR 249 (Delhi), this court invalidated a reassessment proceeding after noting that the notice under section 143(2) of the Act was not issued to the assessee pursuant to the filing

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 303/AGR/2025[2023-24]Status: DisposedITAT Agra04 Dec 2025AY 2023-24

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

reason to believe of the AO that the assessee had taken bogus purchase thro accommodation entries from one Sh. Md. Irfan. During reassessment proceedings, the AO issued summons to Md. Irfan and his statement was recorded on oath before the AO wherein, he admitted that he is engaged in trading ... Assessing Officer also issued a specific query relating to transactions made with Md. Irfan and a reply was also submitted during the course of reassessment proceedings on this issue and thereafter, the speaking order was passed by the Assessing Officer with the approval of the Addll. Commissioner of Income

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

ITA 302/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23
Section 131Section 143(3)Section 147Section 148Section 263Section 40ASection 68

reason to believe of the AO that the assessee had taken bogus purchase thro accommodation entries from one Sh. Md. Irfan. During reassessment proceedings, the AO issued summons to Md. Irfan and his statement was recorded on oath before the AO wherein, he admitted that he is engaged in trading ... Assessing Officer also issued a specific query relating to transactions made with Md. Irfan and a reply was also submitted during the course of reassessment proceedings on this issue and thereafter, the speaking order was passed by the Assessing Officer with the approval of the Addll. Commissioner of Income

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 301/AGR/2025[2021-22]Status: DisposedITAT Agra04 Dec 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

reason to believe of the AO that the assessee had taken bogus purchase thro accommodation entries from one Sh. Md. Irfan. During reassessment proceedings, the AO issued summons to Md. Irfan and his statement was recorded on oath before the AO wherein, he admitted that he is engaged in trading ... Assessing Officer also issued a specific query relating to transactions made with Md. Irfan and a reply was also submitted during the course of reassessment proceedings on this issue and thereafter, the speaking order was passed by the Assessing Officer with the approval of the Addll. Commissioner of Income