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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

ITO-15(3)(1), Mumbai vs. Sanjaykumar Shankarlal Export Private Limited, Navi Mumba

ITA 4157/MUM/2024[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 133ASection 147Section 148Section 148ASection 69C

return was filed on 28 September 2015 declaring ₹2,30,67,080/–. 4. The reassessment proceedings were triggered pursuant to information received from the Investigation Wing, which was based on a survey action under section 133A conducted on 30 November 2018 at the premises of one Shri Ashok Gupta, proprietor ... Riddhi Siddhi Impex, also controlled by the same group, and hence, notice under section 148 was issued on the same date. 5. During the reassessment proceedings, the assessee not only challenged the reopening under section 148 but also filed a detailed reply on merits supported by the following documentary evidence

ACIT 27 1 Mumbai, Mumbai vs. Bhavesh Ranchhodas Madiyar, Mumbai

ITA 4028/MUM/2024[2014]Status: DisposedITAT Mumbai31 Oct 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 133ASection 147Section 148Section 148ASection 69C

return was filed on 28 September 2015 declaring ₹2,30,67,080/–. 4. The reassessment proceedings were triggered pursuant to information received from the Investigation Wing, which was based on a survey action under section 133A conducted on 30 November 2018 at the premises of one Shri Ashok Gupta, proprietor ... Riddhi Siddhi Impex, also controlled by the same group, and hence, notice under section 148 was issued on the same date. 5. During the reassessment proceedings, the assessee not only challenged the reopening under section 148 but also filed a detailed reply on merits supported by the following documentary evidence

ACIT 27 1 Mumbai, Mumbai vs. Bhavesh Ranchhodas Madiyar, Mumbai

ITA 4026/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Oct 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 133ASection 147Section 148Section 148ASection 69C

return was filed on 28 September 2015 declaring ₹2,30,67,080/–. 4. The reassessment proceedings were triggered pursuant to information received from the Investigation Wing, which was based on a survey action under section 133A conducted on 30 November 2018 at the premises of one Shri Ashok Gupta, proprietor ... Riddhi Siddhi Impex, also controlled by the same group, and hence, notice under section 148 was issued on the same date. 5. During the reassessment proceedings, the assessee not only challenged the reopening under section 148 but also filed a detailed reply on merits supported by the following documentary evidence

Cpi India I Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Circle Int Tax 1(2)(1), Delhi

In the result, appeal of the assessee is partly allowed

ITA 1826/DEL/2025[2018-2019]Status: DisposedITAT Delhi31 Oct 2025AY 2018-2019

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.1826/िद"ी/2025(िन.व. 2018-19) Cpi India I Ltd. C/O Vasa Chauhan & Associates, Off. No. 41, 3Rd Floor, Hi Life Premises, P M Road, Santacruz West, Mumbai, Maharashtra 400054 ...... अपीलाथ"/Appellant Pan: Aadcc-1505-G बनाम Vs. Assistant Commissioner Of Income-Tax, International Taxation 1(2)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: Shri Dhanesh Bafna, (Through Vc) & Ms. Kashish Gupta, Chartered Accountants "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 05/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 31/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against Assessment Order Dated 31.01.2025 Passed U/S. 147 R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2018-19. 2. Shri Dhanesh Bafna, Appearing On Behalf Of The Assessee Submits That The Assessee Is A Tax Resident Of Mauritius. The Assesee Is An Investment Holding Company. The Assessee Has Obtained Global Business License From The Financial

For Appellant: Shri Dhanesh Bafna, (Through VC) &For Respondent: Shri M.S Nethrapal, CIT-DR
Section 112(1)(c)Section 147Section 48

India-Mauritius DTAA. 4. The ld. AR made statement at Bar that he is not pressing ground no. 2 of appeal challenging validity of reassessment proceedings. The ld. AR further submits that if ground no. 5 of appeal is allowed, the other grounds of appeal would become academic

Laxman Singh Solanki (Firm), Pali vs. ITO, Pali

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

ITA 795/JODH/2024[2014-15]Status: DisposedITAT Jodhpur30 Oct 2025AY 2014-15

Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Amit Kothari, C.AFor Respondent: Shri Arvind Kumar Gehlot, Addl. CIT DR
Section 143(3)Section 147Section 194ASection 194C

hearing the Ld. DR supported the order of the Ld. CIT(A). He submitted that the assessee had been non-compliant throughout the reassessment proceedings despite multiple statutory notices issued under sections 148, 142(1) and 144B. 7.1 The medical certificate relied upon was issued nearly a month after

Smt. Satyawati Marwaha Through Legal Heir Sh, Chander Sheikhar Marwaha, Jalandhar vs. Assistant Commissioner of Income Tax, Jalandhar

In the result, the appeal for Asstt

ITA 347/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

must be nexus between the material and escapement of income. The AO must record reasons showing due application of mind before taking recourse to reassessment proceedings. Still further the AO can assume jurisdiction for reassessment proceedings provided he has reasons to believe but the same cannot be taken recourse

Smt. Satyawati Marwaha Through Legal Heir Sh. Chander Sheikhar Marwaha, Jalandhar vs. Assistant Commissioner of Income Tax, Jalandhar

In the result, the appeal for Asstt

ITA 346/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

must be nexus between the material and escapement of income. The AO must record reasons showing due application of mind before taking recourse to reassessment proceedings. Still further the AO can assume jurisdiction for reassessment proceedings provided he has reasons to believe but the same cannot be taken recourse

Yogendrakumar Ramavtar Agarwal, Surat vs. ITO, Ward-1(2)(1), Surat

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

ITA 882/SRT/2025[2009-10]Status: DisposedITAT Surat30 Oct 2025AY 2009-10

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Yogendrakumar Ramavtar Ito, Ward-1(2)(5), Agarwal, Surat Current Jurisdiction: 2053-Mahaveer Textile Market, Vs. Ito, Ward 1(2)(1), Ring Road, Textile Area, Aayakar Bhavan, Near Majura Surat-395002. Gate, Opp. New Civil Hospital, Surat-395001 Pan No. Aarpa 7623 C Appellant Respondent

For Respondent: Mr. Rasesh Shah, CA
Section 147Section 148Section 69Section 69C

part of the assessee during reassessment made on the part of the assessee during reassessment made on the part of the assessee during reassessment proceedings but for finalization of this issue in dispute, it is proceedings but for finalization of this issue in dispute, it is proceedings but for finalization

Sofia Twist and Text Pvt Ltd, Surat vs. DCIT Circle 2(1)(1), Surat

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

ITA 739/SRT/2025[2017-18]Status: DisposedITAT Surat30 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2017-2018 Sofia Twist & Text Pvt Ltd, Dcit, Circle – 2(1)(1) 3003, Rathi Palace, Kamela Room No. 612, 6Th Floor, Darwaja, Ring Road, Vs. Aayakar Bhawan, Majurgate, Surat - 395002 Surat - 395002 Pan No. Aadcs4384F Appellant Respondent

For Appellant: Shri Ajay Uke, Sr. DRFor Respondent: Mr. Suresh K Kabra, CA
Section 148Section 151Section 68

ground assailing the very jurisdictional foundation an additional ground assailing the very jurisdictional foundation an additional ground assailing the very jurisdictional foundation of the reassessment proceedings, contending that the notice of the reassessment proceedings, contending that the notice of the reassessment proceedings, contending that the notice issued under Section ... limit, rendering to the assessee, fell clearly beyond the statutory limit, rendering to the assessee, fell clearly beyond the statutory limit, rendering the entire reassessment proceeding void the entire reassessment proceeding void ab initio and without jurisdiction. 3.3 Per contra, the he Ld. Departmental Representative (DR) Ld. Departmental Representative

Jitendrakumar Ambelal Patel, Na vs. Arivs.ITO, Ward-3, Navsari

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

ITA 660/SRT/2025[2009-10]Status: DisposedITAT Surat30 Oct 2025AY 2009-10

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Jitendrakumarambelal Patel Ito, Ward-3, 52, Kanbiwad. At & Po-Pananj, Room No. 108, Swapnalok Soc., Tal-Chikhli, Navsari-396521 Vs. Near Kaliawadi Bridge, Navsari - 396521 Pan No. Bncpp 7509 R Appellant Respondent

For Appellant: Shri J. K. Chandnani, Sr. DRFor Respondent: Shri P M Jagasheth, CA
Section 147Section 148Section 271(1)(c)

required under Section 147 of the Income equired under Section 147 of the Income-tax Act for the tax Act for the initiation of reassessment proceedings. initiation of reassessment proceedings. 6.2 It is now well-settled by a long line of judicial authorities, settled by a long line of judicial

Sanjay Sivabhagwan Keyal, Surat vs. ITO, Ward-2(3)(4), Surat

In the result, the appeal of the assessee is dismissed

ITA 636/SRT/2025[2009-10]Status: DisposedITAT Surat30 Oct 2025AY 2009-10

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Sanjay Sivabhagwan Keyal Ito, Ward – 2(3)(4), Flat No.304, 3Rd Floor, Room No.613, Vatika Township, Near Model, Vs. Aaaykar Bhavan, Township, Parvat Patia Majura Gate, Surat - 395010. Surat - 395002. Pan No. Adspk 6097N Appellant Respondent

For Appellant: Shri J.K. Chandnani, Sr. DRFor Respondent: Mr. Rasesh, CA
Section 144Section 148Section 69A

notice under section 148 of the Act. ITA No. 636/SRT/2025 3 Sanjay Sivabhagwan Keyal Sanjay Sivabhagwan Keyal 2.2 During the reassessment proceedings, the Assessing Officer, During the reassessment proceedings, the Assessing Officer, During the reassessment proceedings, the Assessing Officer, invoking his statutory powers under section ... compilation of judicial precedents relied upon. judicial precedents relied upon. 5. The Ground Nos s.1 and 3 of the appeal pertain to reassessment to reassessment proceeding challenged by the assessee. proceeding challenged by the assessee. The learned counsel for the The learned counsel for the ITA No. 636/SRT/2025 5 Sanjay

Dhaval Indravadan Gandhi, Surat vs. ITO, Ward 2, Bardoli

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

ITA 601/SRT/2025[2012-13]Status: DisposedITAT Surat30 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-2013 Shri Dhaval Indravadan Gandhi, Ito Ward-2, At & Post Areth, Tal Mandvi, Aayakar Bhavan, Janta Nagar Surat-394160. Vs. Society, Bardoli-394601. Pan No. Ajjpg 4246 J Appellant Respondent

For Appellant: Ms. Namita Patel, Sr. DRFor Respondent: Mr. Shaunak K. Zaveri, CA
Section 143(3)

originally filed may be treated as a return in response to the notice under section 148. the notice under section 148. 2.2 During the reassessment proceedings, the assessee was During the reassessment proceedings, the assessee was During the reassessment proceedings, the assessee was called upon to produce his called upon ... assessee, wherein the deponent has sworn by the assessee, wherein the deponent has averred that: 3. That during th That during the course of reassessment proceedings, I e course of reassessment proceedings, I submitted documentary evidence including a copy of my DP submitted documentary evidence including a copy

Sumitlal, Surat vs. ITO, Surat

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

ITA 545/SRT/2025[201011]Status: DisposedITAT Surat30 Oct 2025

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2010-2011 Sumitlal, Ito 101-B/2, Sanskrut Flats Umra, Aayakar Bhavan, Bharthana, Vs. Surat-395007. Surat-395007 Pan No. Acxpl 1238 Q Appellant Respondent

For Respondent: Mr. Nitin Paharia, CA&
Section 144Section 251(1)(a)Section 69

show response. Repeated statutory notices and a final show response. Repeated statutory notices and a final show-cause notice were also issued during the reassessment proceedings, but ued during the reassessment proceedings, but ued during the reassessment proceedings, but the the assessee assessee remained remained non non-compliant. compliant. Consequently

Income Tax Officer, Anavil Business Centre, Adajan vs. Abhishek Navnit Doshi, Mahidharpura

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

ITA 502/SRT/2025[2014-15]Status: DisposedITAT Surat30 Oct 2025AY 2014-15

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2014-2015 Ito, Abhishek Navnit Doshi, 405, Income Tax Office, Anavil 204/205, 2Nd Floor, 6/1911-12, Business Centre, Hazira Road, Vs. Jin Shanti Bldg. Mahidharpura, Adajan, Surat-395003. Surat-395009. Pan No. Afhpd 0064 M Appellant Respondent

For Respondent: Mr. Sapnesh Sheth, Advocate

issuance of notice under section 148 on 29.07.2022, followed by the issuance of notice under section 148 on the same date. 2.2 During the reassessment proceedings, the assessee furnished During the reassessment proceedings, the assessee furnished During the reassessment proceedings, the assessee furnished audit reports, bank statements, export invoices, purchase

Tirupati Shyam Enterprise, Surat vs. DCIT, Circle 1(1)(1), Surat

In the result, the appeal of the assessee is allowed

ITA 318/SRT/2025[2015-16]Status: DisposedITAT Surat30 Oct 2025AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-2016 Tirupati Shyam Enterprise Nfac, Delhi Current F.P. No. 139 Orleaans, Near Jurisdiction: Dy. Cit Circle- Sosyo Circle Udhna Magadalla Vs. 1(1)(1), Road, Surat-395007. Aayakar Bhavan, Near Majura Gate, Opp. New Civil Hospital, Surat-395001. Pan No. Aagft 3570 Q Appellant Respondent

For Appellant: Mr. J.K. Chandnani, Sr. DRFor Respondent: Mr. Rasesh Shah, CA
Section 147Section 148Section 5Section 68

additional ground challenging the validity of the reassessment additional ground challenging the validity of the reassessment additional ground challenging the validity of the reassessment proceedings, which being purely legal in nature and going to root of , which being purely legal in nature and going to root of , which being purely ... initiate that sufficient time was still available to the Department to initiate that sufficient time was still available to the Department to initiate reassessment proceedings under reassessment proceedings under the unamended regime and, the unamended regime and, therefore, the relaxation provisions contained in the Taxation and therefore, the relaxation provisions

Alkeshkumar Maganbhai Patel, Bharuch vs. Income Tax Officer (ITO), Ward 1(1) Bharuch, Bharuch

In the result, the Appeal of the Assessee is dismissed

ITA 292/SRT/2025[2017-18]Status: DisposedITAT Surat30 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2017-2018 Alkeshkumar Maganbhai Patel, Ito Ward 1(1), 30 Atmiya Nagar, Near Kgm Income Tax Office, Bharuch, Vidyalay Zadeshw Zadeshwar, Vs. Income-Tax Office, Hari Kunj, Bharuch-392011. Station Road, Bharuch-356069. Pan No. Bklpp 8435 L Appellant Respondent

For Appellant: None for the assesseeFor Respondent: Ms. Namita Patel, Sr. DR
Section 144Section 147Section 148Section 250Section 69ASection 80T

Assessing Officer issued further noti Subsequently, the Assessing Officer issued further noti Subsequently, the Assessing Officer issued further notices during the course of the Reassessment Proceedings but the same also the course of the Reassessment Proceedings but the same also the course of the Reassessment Proceedings but the same also

Jigneshbhai Arvindbhai Patel, Surat vs. ITO, Ward 2(3)(2), Surat

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

ITA 272/SRT/2025[2013-14]Status: DisposedITAT Surat30 Oct 2025AY 2013-14

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2013-2014 Jigneshbhai Arvindbhai Patel, Ito Ward-2(3)(2), 84, Angreji Faliyu, Opp. Post Income Tax Office, Majura Gate, Office, Amroli, Surat-394107. Vs. Surat-395001. Pan No. Bczpp 8713 R Appellant Respondent

For Respondent: Mr. Sapnesh Sheth, Advocate
Section 148Section 50C

counsel for the assessee sought to raise an the assessee sought to raise an additional ground additional ground impugning the very validity of the reassessment proceedings. It was contended very validity of the reassessment proceedings. It was contended very validity of the reassessment proceedings. It was contended that

Vapi Marchant Saving and Credit Co-Op Society Limited, Vapi vs. Income Tax Officer, Ward-9, Vapi

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

ITA 838/SRT/2023[2010-11]Status: DisposedITAT Surat30 Oct 2025AY 2010-11

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2010-2011 Vapi Merchant Saving & Credit Ito Ward-9, Co-Op Society Ltd., Income Tax Office, Nr. Vaishali Office No. 130, First Floor, Varun Vs. Char Rasta, Nh-8, Gidc, Complex, Opp. Reliance Super Vapi-396191. Market Gidc, Vapi-396195. Pan No. Aaaav 3925 E Appellant Respondent

For Appellant: Mr. J.K. Chandnani, Sr. DRFor Respondent: Mr. Hem Chhajed, AR
Section 139Section 139(1)Section 148Section 80A(5)Section 80P(2)(a)Section 8O

accounts accounts 3. Interest received from members Interest received from members Rs.25,25,308/ Rs.25,25,308/- 2.2 During During During reassessment reassessment reassessment proceeding, the Assessing proceeding, the Assessing proceeding, the Assessing Officer Officer Officer brought to the knowledge of the assessee that in view of provision of brought ... assessee cannot be Vapi Merchant Saving and Credit Co-op Vapi Merchant Saving and Credit Co 5 Society Ltd permitted to convert the reassessment proceedings as his appeal or permitted to convert the reassessment proceedings as his appeal or permitted to convert the reassessment proceedings as his appeal or revision

Dy.Commissioner of Income Tax, Thrissur vs. The Csb Bank Ltd, Thrissur

In the result, the appeal of revenue is dismissed

ITA 542/COCH/2025[2014-15]Status: DisposedITAT Cochin30 Oct 2025AY 2014-15

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Satish Modi, CAFor Respondent: Shri. Sanjit Kumar Das, CIT DR
Section 115Section 115JSection 144BSection 147Section 250

passed on 20/12/2016 assessing total income of the Assessee at (-)INR.85,54,79,970/- after making addition of INR.12,09,000/-. Thereafter, reassessment proceedings were initiated in the case of the Assessee which culminated into passing of the Assessment Order, dated 28/07/2023, passed under Section 143(3) read with Section

Dy. Commissioner of Income Tax, Jaipur vs. Hem Chand Jain, Jaipur

In the result, appeal of the Revenue is dismissed and Cross Objection of the assessee is allowed

ITA 670/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT &
Section 147Section 148Section 148ASection 151Section 250

NFAC has erred on facts and in law in not deciding the ground of the assessee challenging initiation of reassessment proceedings u/s 148 of the Act as approval was not taken from appropriate authority u/s 151 of the Act and thus the entire proceedings is illegal ... after expiry of three years from end of relevant AY without taking approval of PCCIT as contemplated by section 151(ii), same would invalidate reassessment proceedings. Fives India Engineering & Projects (P.) Ltd. Vs. ITO (2024) 298 Taxman 762 (Mad.) (HC) Where revenue issued notice u/s 148 to assessee after lapse