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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

Pedaveeti Swathi, Hyderabad vs. ITO, Ward 9(1), Hyderabad

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

ITA 1785/HYD/2025[2016-17]Status: DisposedITAT Hyderabad04 Mar 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1785/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Pedaveeti Swathi, Vs. Income Tax Officer, Hyderabad. Ward-9(1), Pan: Fugps2126J Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri T. Chaitanya Kumar, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 26/02/2026 घोषणा की तारीख/Date Of 04/03/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: 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 03/06/2025, 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, “The Act”), Dated 27/02/2024 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri T. Chaitanya KumarFor Respondent: Dr. Sachin Kumar, Sr.AR
Section 115BSection 142(1)Section 144BSection 147Section 148Section 148ASection 149Section 151ASection 69A

said notice is invalid and contrary to the provisions of Section 149 of the Act as amended by the Finance Act, 2021. Therefore, the reassessment proceedings initiated on the basis of such an invalid notice are void and without jurisdiction. Consequently, all proceedings and orders arising therefrom stand vitiated

Late Abdullah Abdulmajeed, Rep. by L/H, Pudukkottai vs. ITO, Ward-1, Pudukkottai

ITA 3294/CHNY/2025[2015-16]Status: DisposedITAT Chennai04 Mar 2026AY 2015-16
For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 69A

सुनवाईकीतारीख/Date of Hearing : 21.01.2026 घोषणाकीतारीख / Date of Pronouncement : 04.03.2026 आदेश / ORDER PER MANU KUMAR GIRI, JM: The present appeal arises out of reassessment proceedings initiated u/s. 147 of the Act for Assessment Year 2015-16, challenging the order dated 14.10.2025 passed by the Id.CIT(A), whereby the assessment framed ... said notice was issued with the prior approval of the Principal Chief Commissioner of Income Tax, Tamil Nadu & Puducherry, proposing initiation of reassessment proceedings u/s. 147 on the ground that income chargeable to tax had allegedly escaped assessment for AY 2015-16. 3. Subsequently, the JAO passed an order

Thangavel, Chennai vs. ITO, Non Corp Ward 10(3) Che, Chennai

The appeal of the assessee is allowed

ITA 3207/CHNY/2025[AY 2015-16]Status: DisposedITAT Chennai04 Mar 2026

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3207/Chny/2025 िनधा$रण वष$ /Assessment Year: 2015-16

For Appellant: Mr. N. Arjun Raj, Advocate for Mr. R. Sivaraman, AdvocateFor Respondent: Mr. M.D.Vijay Kumar, JCIT
Section 148Section 148ASection 149(1)Section 149(1)(b)Section 250Section 69A

hold that notice for A.Y. 2015-16 issued on 05.04.2022 u/s 148 of the new regime is barred by limitation. The resulting impugned reassessment proceedings as well as the impugned reassessment order are therefore bad in law and liable to be quashed. Thangavel :- 7 -: 11. Since we have allowed

Sivasundar Selvakumari, Chennai vs. ITO, Ncw-1(6), Chennai

In the result, the appeal of the assessee is allowed

ITA 3154/CHNY/2025[2016-17]Status: DisposedITAT Chennai04 Mar 2026AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. N. Balakrishnan, CIT
Section 139(4)Section 144BSection 147Section 194ISection 45

assessee has still not received the same. It was further submitted that reasons recorded for reopening were not furnished despite request, which vitiates the reassessment proceedings in view of the judgment of the Hon’ble Supreme Court in Comunidado of Chicalim Vs. ITO (247 ITR 271). 13. On merits ... contrary to law laid down by the Hon’ble Supreme Court in Comunidado of Chicalim vs. ITO (247 ITR 271), thereby vitiating the reassessment proceedings. 24. In view of the foregoing discussion, we hold that the reassessment proceedings are not sustainable in law and the addition of Rs.19

Gurusamy Suseela, Nungambakkam vs. Income Tax Officer, Nungambakkam

In the result, appeal of the assessee is allowed

ITA 2912/CHNY/2025[2010-11]Status: DisposedITAT Chennai04 Mar 2026AY 2010-11

Bench: Shri Aby T. Varkey & Ms. Padmavathy S

For Appellant: Mr. B. Ravi CAFor Respondent: Ms.R. Anitha, Addl.CIT
Section 147Section 148Section 149

well settled in law that, non-issuance of a valid notice u/s 148 of the Act is a jurisdictional defect which renders the entire reassessment proceedings to be bad in law and ab initio void. We are aware of the distinction between ‘issue of notice’ and ‘service of notice

Amit Shantaram Bagade Mited, Mumbai vs. Income Tax Officer Int Taxation Ward 1(2), Mumbai

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

ITA 832/MUM/2025[2019-20]Status: DisposedITAT Mumbai04 Mar 2026AY 2019-20

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rohan Despande &For Respondent: Shri Krishna Kumar, Sr.DR
Section 132Section 142(1)Section 147Section 148Section 148ASection 151ASection 69

following grounds of appeal: “1. The ld.AO/DRP erred in upholding notice under section 148 of the Income Tax Act, 1961 ("Act") and the reassessment proceedings for AY 2019-20. The notice under section 148A(b), proceedings under section 148A and notice under section 148 are wholly without jurisdiction ... suggesting escapement of income. 2. The ld.AO/DRP erred in upholding notice under section 148 of the Income Tax Act, 1961 ("Act") and the reassessment proceedings for AY 2019-20 without appreciating that the same were initiated by the Jurisdictional Assessing Officer and not by the Faceless Assessing Officer

Amit Shantaram Bagade, Thane vs. ITO (Int Tax) Ward-1(2)(1), Mumbai

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

ITA 6286/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Mar 2026AY 2020-21

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rohan Despande &For Respondent: Shri Krishna Kumar, Sr.DR
Section 132Section 142(1)Section 147Section 148Section 148ASection 151ASection 69

following grounds of appeal: “1. The ld.AO/DRP erred in upholding notice under section 148 of the Income Tax Act, 1961 ("Act") and the reassessment proceedings for AY 2019-20. The notice under section 148A(b), proceedings under section 148A and notice under section 148 are wholly without jurisdiction ... suggesting escapement of income. 2. The ld.AO/DRP erred in upholding notice under section 148 of the Income Tax Act, 1961 ("Act") and the reassessment proceedings for AY 2019-20 without appreciating that the same were initiated by the Jurisdictional Assessing Officer and not by the Faceless Assessing Officer

Jorss Bullion Pvt Ltd, Mumbai vs. Dy Commissioner of Income Tax -Central Circle 7(1), Mumbai

ITA 4758/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Mar 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain& Shri Omkareswar Chidara

Section 69C

assessment was reopened on the basis of DDIT Investigation information in relation to unexplained expenditure of Rs. 39,36,03,084. During the reassessment proceedings, the addition of unexplained expenditure of Rs. 39,36,03,084 [Amarnath International of Rs. 13,21,39,764 + Neeyorkan Corporation of Rs.4 ... made under Section 69C read with Section 115BBE on the ground that these three suppliers are not genuine parties. 03. During the course of reassessment proceedings, the detailed information in relation to this three parties along with supporting documents to demonstrate that the assessee company has actually sold goods

DCIT, Central Circle 7(1), Mumbai vs. Jorss Bullion Private Limited, Mumbai

ITA 4004/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Mar 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain& Shri Omkareswar Chidara

Section 69C

assessment was reopened on the basis of DDIT Investigation information in relation to unexplained expenditure of Rs. 39,36,03,084. During the reassessment proceedings, the addition of unexplained expenditure of Rs. 39,36,03,084 [Amarnath International of Rs. 13,21,39,764 + Neeyorkan Corporation of Rs.4 ... made under Section 69C read with Section 115BBE on the ground that these three suppliers are not genuine parties. 03. During the course of reassessment proceedings, the detailed information in relation to this three parties along with supporting documents to demonstrate that the assessee company has actually sold goods

Mahaveer Singh, Ahmedabad vs. The PCIT, Ahmedabad-1, Ahmedabad

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 840/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 139(1)Section 142(1)Section 143(3)Section 148Section 234FSection 263(1)Section 270ASection 270A(2)(b)Section 272A(1)(d)Section 44A

therefore the penalty provisions u/s. 270A(2)(b) is directly attracted. Whereas the assessing officer has failed to initiate the penalty proceedings in the reassessment proceedings which is erroneous and prejudicial to the interest of Revenue. Therefore Ld. PCIT issued a show cause notice dated

Bimal Kumar Ghosh, Raiganj vs. ITO, Ward 2(4), Raiganj

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

ITA 1600/KOL/2025[2013-2014]Status: DisposedITAT Kolkata03 Mar 2026AY 2013-2014

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI LAXMI PRASAD SAHU (Accountant Member)

For Appellant: Shri Siddarth Agarwal, AdvocateFor Respondent: Shri Soumitra Ghosh, Addl. CIT, Sr. DR
Section 139Section 144Section 147Section 148Section 250Section 44ASection 69A

return of income was filed u/s 139 of the Act, accordingly notice u/s 148 of the Act was issued to the assessee for completing reassessment proceeding u/s 147 of the Act, an opportunity was granted to the assessee for filing return of income. The assessee has filed return of income ... 44AD of the Act. But as per the assessment order there was no return of income filed by the assessee. During the course of reassessment proceedings, the AO granted various opportunities to the assessee but there was no explanation/response 3 Bimal Kumar Ghosh were provided. Accordingly, he completed the assessment

A-One Leathers, Chennai vs. Assistant Commissioner of Income Tax, Non Corporate Circle 4(1), Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 4148/CHNY/2025[2015-16]Status: DisposedITAT Chennai03 Mar 2026AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 4148/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 M/S. A-One Leathers, The Assistant Commissioner No.15/8, Vepery High Road, Vs. Of Income Tax, Periamet, Non-Corporate Circle 4(1), Chennai – 600 003. Chennai. Pan: Aaafa 4576H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Anandh, Advocate ""यथ" क" ओर से/Respondent By : Shri Aroon Praasad, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 03.03.2026 आदेश/ O R D E R Per George George K: This Appeal Filed By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 14.10.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2015-16. 2. The Grounds Raised Read As Follows:- :- 2 -:

For Appellant: Shri S. Anandh, AdvocateFor Respondent: Shri Aroon Praasad, Addl.CIT
Section 143(3)Section 147Section 148Section 250

respond to the notices issued u/s.142(1) of the Act. The reason stated for ex-parte order before the AO during the course of reassessment proceedings is that assessee’s business had suffered losses. It is stated that all the staff including the accountant had left the assessee’s employment ... statement of facts filed before the FAA in the earlier proceedings detailing why the assessee could not appear during the course of reassessment proceedings are reproduced below:- “The appellant is a partnership firm assessed under PAN AAAFA4576H and is engaged in the business of manufacturing or tanning leather and have

Income Tax Officer, Krishnagiri vs. Manoharan Ramesh, Krishnagiri

In the result, the appeal of the Revenue is dismissed

ITA 2798/CHNY/2025[2020]Status: DisposedITAT Chennai03 Mar 2026

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.2798/Chny/2025 िनधा#रण वष# /Assessment Year: 2020-21

For Appellant: Mr. Bhupendran, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 115BSection 144BSection 147Section 148Section 148ASection 250Section 69A

bank account. The relevant findings of the CIT(A) in this regard are extracted below: “9. The Assessing Officer in this case initiated reassessment proceedings on the basis of information regarding cash deposits and substantial cash withdrawals in the assessee’s bank account, along with contract receipts. After issuing notice

Menakuru Sukumar Reddy, Hyderabad vs. DCIT(A), Chennai

ITA 993/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 251(2)Section 69A

assessee, judicial precedents relied upon and the written submissions of the parties. The assessee has raised common legal grounds challenging the validity of the reassessment proceedings on the following counts: (i) Lack of jurisdiction in issuance of notice u/s 148 of the Act; (ii) Improper service of notice

Menakuru Sukumar Reddy, Hyderabad vs. DCIT(A), Chennai

In the result the appeal of the revenue is dismissed

ITA 992/CHNY/2025[2016-17]Status: DisposedITAT Chennai02 Mar 2026AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 147Section 148Section 251(2)Section 69A

assessee, judicial precedents relied upon and the written submissions of the parties. The assessee has raised common legal grounds challenging the validity of the reassessment proceedings on the following counts: (i) Lack of jurisdiction in issuance of notice u/s 148 of the Act; (ii) Improper service of notice

Menakuru Sukumar Reddy, Hyderabad vs. DCIT(A), Chennai

In the result the appeal of the revenue is dismissed

ITA 991/CHNY/2025[2015-16]Status: DisposedITAT Chennai02 Mar 2026AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 147Section 148Section 251(2)Section 69A

assessee, judicial precedents relied upon and the written submissions of the parties. The assessee has raised common legal grounds challenging the validity of the reassessment proceedings on the following counts: (i) Lack of jurisdiction in issuance of notice u/s 148 of the Act; (ii) Improper service of notice

ACIT, Chennai vs. Menakuru Sukumar Reddy, Chennai

ITA 1644/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Mar 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 991, 992 & 993/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16, 2016-17 & 2017-18 Menakuru Sukumar Reddy, 8-2-696-697, Road No.2, Banjara Hills, Hyderabad - 500 034. [Pan: Aabhm-8414-M] (अपीलार्थी/Appellant) Dcit, Vs. Central Circle -3(4), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.: 1639 & 1644/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16 & 2017-18 Acit, Central Circle -3(4), Chennai. (अपीलार्थी/Appellant) Menakuru Sukumar Reddy, Vs. 8-2-696-697, Road No.2, Banjara Hills, Hyderabad - 500 034. [Pan: Aabhm-8414-M] (प्रत्यर्थी/Respondent) Assessee By : Shri. P. Murali Mohana Rao, Ca Department By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 04.12.2025 घोषणा की तारीख/Date Of Pronouncement : 02.03.2026 आदेश /Order Per S. R. Raghunatha, Am : :-2-:

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143Section 143(3)Section 147Section 148Section 251(2)Section 69A

assessee, judicial precedents relied upon and the written submissions of the parties. The assessee has raised common legal grounds challenging the validity of the reassessment proceedings on the following counts: (i) Lack of jurisdiction in issuance of notice u/s 148 of the Act; (ii) Improper service of notice

ACIT, Chennai vs. Menakuru Sukumar Reddy, Chennai

ITA 1639/CHNY/2025[2015-16]Status: DisposedITAT Chennai02 Mar 2026AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 991, 992 & 993/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16, 2016-17 & 2017-18 Menakuru Sukumar Reddy, 8-2-696-697, Road No.2, Banjara Hills, Hyderabad - 500 034. [Pan: Aabhm-8414-M] (अपीलार्थी/Appellant) Dcit, Vs. Central Circle -3(4), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.: 1639 & 1644/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16 & 2017-18 Acit, Central Circle -3(4), Chennai. (अपीलार्थी/Appellant) Menakuru Sukumar Reddy, Vs. 8-2-696-697, Road No.2, Banjara Hills, Hyderabad - 500 034. [Pan: Aabhm-8414-M] (प्रत्यर्थी/Respondent) Assessee By : Shri. P. Murali Mohana Rao, Ca Department By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 04.12.2025 घोषणा की तारीख/Date Of Pronouncement : 02.03.2026 आदेश /Order Per S. R. Raghunatha, Am : :-2-:

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 147Section 148Section 251(2)Section 69A

आयकर अपीलीय अधिकरण, 'ए' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, CHENNAI श्री एस एस विश्वनेत्र रवि

Ravindrakumar Amratlal Jain, Mumbai vs. Income Tax Officer Ward-19(3)(1), Mumbai

In the result Assessee’s Appeal, is partly allowed

ITA 3453/MUM/2025[2011-12]Status: DisposedITAT Mumbai02 Mar 2026AY 2011-12

Bench: Shri Narender Kumar Choudhryshri Jagadish

For Appellant: Mr. Dhaval Shah, Ld. ARFor Respondent: Shri Annavaram Kosuri (Sr
Section 143(2)Section 147Section 148Section 250

that the Assessee in that case failed to prove the purchases including source of expenditure, by not offering any explanation in the course of reassessment proceedings and therefore in the absence of any explanation qua source of expenditure, the AO had applied the provisions of section

Assistant Commissioner of Income Tax, Central Circle, Panaji, Goa vs. Bagkiya Constructions Pvt. Ltd, Goa

The appeal of the Revenue is partly allowed in aforestated terms

ITA 148/PAN/2023[2017-18]Status: DisposedITAT Panaji27 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2017-2018 Asstt. Commissioner Of Income Tax, Central Circle, Panaji, Goa. . . . . . . . Appellant V/S M/S Bagkiya Construction Pvt. Ltd. Sf-3, Building No.-3. Techno Cidade, Chogam Rd., Alto Porvorim, Goa-403521. Pan: Aaccb9382M . . . . . . . Respondent Represented Assessee By: None For The Respondent Revenue By: Mr Senthil Kumar [‘Ld. Dr’] Date Of Conclusive Hearing : 29/01/2026 Date Of Pronouncement : 27/02/2026 Order Per G. D. Padmahshali; This Revenue’S Appeal Filed U/S 253(2) Of The Income- Tax Act, 1961 [‘The Act’] Challenges The Order Dt. 29/05/2023 Passed U/S 250 Of The Act By Commissioner Of Income Tax(Appeals-2), Panaji [‘Ld. Cit(A)’] Which In Turn Wheeled From The Order Dt. 25/08/2021 Passed U/S 147 Of The Act By Acit, Central Circle, Panaji, Goa [‘Ld. Ao’] Anent To Assessment Year 2017-18.[‘Ay’]

For Appellant: None for theFor Respondent: Mr Senthil Kumar [‘Ld. DR’]
Section 127(2)Section 131Section 133ASection 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 253(2)

order dt. 26/02/2021 issued u/s 127(2) of the Act was centralised and vide notice dt. 28/03/2021 issued u/s 148 of the Act the reassessment proceedings were initiated calling upon the assessee to file return in response thereto within 30 days therefrom. The assessee filed a return in response thereto ... alleged suppliers. Likewise, in another case ‘Nickunj Eximp Enterprises (P) Ltd. Vs ACIT’ [372 ITR 619 (Bom)] their hon’ble lordship upheld addition in reassessment proceedings by observing that, where in course of survey u/s 133A of the act it was found that assessee made certain bogus bills/expenses, since occasion