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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

Gmedapadu Pacs, East Godavari vs. ITO, Ward-1, Kakinada

ITA 573/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.573/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Gmedapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Kss Sarma, Ca रधजस् व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 16/10/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 18/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 10/02/2021 For Ay 2018-19. The Assessee Society Has Assailed The Impugned Order Passed By The Ao On The Following Grounds Of Appeal:

For Appellant: Sri KSS Sarma, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 80P

have carefully considered this ground and the applicability of the cited Supreme Court decision. The ruling in GKN Driveshafts (India) Ltd. pertains specifically to reassessment proceedings initiated under section 147 of the Act, where the AO issues a notice under section 148 and is mandated to provide reasons for reopening

Santosh Shankar Gujar, Laxmi Nagar, Thergaon vs. Income Tax Officer, Ward 8(3), Pune, Akurdi

In the result, the appeal filed by the assessee in ITA

ITA 2038/PUN/2024[2013 - 2014]Status: DisposedITAT Pune19 Nov 2025

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1654 & 2038/Pun/2024 िनधा"रण वष" / Assessment Years : 2014-15 & 2013-14 Santosh Shankar Gujar, Vs. Ito, Ward-8(3), Pune. H/No.246, Shiv Parvati Bunglow, Laxmi Nagar, Thergaon- 411033. Pan : Alnpg9944K Appellant Respondent Assessee By : Mrs. Vibha D. Gulabani Revenue By : Shri Umesh Phade Date Of Hearing : 02.09.2025 Date Of Pronouncement : 19.11.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2024 & 29.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2014-15 & 2013-14 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals, We Proceed To Dispose Of The Same By This Common Order. 3. First We Shall Take Up The Appeal Of The Assessee In Ita No.1654/Pun/2024 For A.Y. 2014-15 For Adjudication.

For Appellant: Mrs. Vibha D. GulabaniFor Respondent: Shri Umesh Phade
Section 139Section 142(1)Section 143(2)Section 144Section 147Section 148Section 2(47)Section 250Section 45Section 54F

rent of Rs.2,18,500/- on which TDS was deducted, however no return was furnished by the assessee. Accordingly, the Jurisdictional Assessing Officer initiated reassessment proceedings u/s 147 of the Act and notice u/s 148 of the Act was issued on 31.03.2021. However, due to technical glitches, the assessee could

Santosh Shankar Gujar, Near Vitthal Rukmini Mandir vs. Income Tax Officer, Ward 8(3), Pune, Akurdi

In the result, the appeal filed by the assessee in ITA

ITA 1654/PUN/2024[2014 - 2015]Status: DisposedITAT Pune19 Nov 2025

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1654 & 2038/Pun/2024 िनधा"रण वष" / Assessment Years : 2014-15 & 2013-14 Santosh Shankar Gujar, Vs. Ito, Ward-8(3), Pune. H/No.246, Shiv Parvati Bunglow, Laxmi Nagar, Thergaon- 411033. Pan : Alnpg9944K Appellant Respondent Assessee By : Mrs. Vibha D. Gulabani Revenue By : Shri Umesh Phade Date Of Hearing : 02.09.2025 Date Of Pronouncement : 19.11.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2024 & 29.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2014-15 & 2013-14 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals, We Proceed To Dispose Of The Same By This Common Order. 3. First We Shall Take Up The Appeal Of The Assessee In Ita No.1654/Pun/2024 For A.Y. 2014-15 For Adjudication.

For Appellant: Mrs. Vibha D. GulabaniFor Respondent: Shri Umesh Phade
Section 139Section 142(1)Section 143(2)Section 144Section 147Section 148Section 2(47)Section 250Section 45Section 54F

rent of Rs.2,18,500/- on which TDS was deducted, however no return was furnished by the assessee. Accordingly, the Jurisdictional Assessing Officer initiated reassessment proceedings u/s 147 of the Act and notice u/s 148 of the Act was issued on 31.03.2021. However, due to technical glitches, the assessee could

Kineta Global Limited, Hyderabad vs. DCIT., Circle-2(1), Hyderabad

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

ITA 800/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, 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, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

For Appellant: Sri S. VenkateswarluFor Respondent: Dr. Narendra Kumar Naik
Section 147Section 148Section 148ASection 151Section 151ASection 250(6)

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

Gurram Naveen, Rajanna Sircilla vs. ITO., Ward-2, Karimnagar

In the result, the appeal of the assessee is allowed

ITA 686/HYD/2025[2019-20]Status: DisposedITAT Hyderabad19 Nov 2025AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.686/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Shri Gurram Naveen Vs. Income Tax Officer Rajanna Sircilla Ward-2 Pan:Bihpg3983L Karimnagar (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Pavan Kumar Gorti राज" व "ारा/Revenue By:: Shri R Kumaran, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Gurram Naveen (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 20.02.2025 For The A.Y 2019-20. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: CA Pavan Kumar GortiFor Respondent: : Shri R Kumaran, Sr. DR
Section 139Section 144BSection 147Section 148Section 44ASection 69ASection 69C

Rs.2,17,310/-, including income of Rs.1,87,714/- declared under section 44AD of the Act. After considering the submissions of the assessee during reassessment proceedings, the Ld. AO found that there was a total deposit of Rs.12,21,810/-, including cash deposit of Rs.10 lakhs, in the SBI account