“tangible material”

ReassessmentSection 147Section 1472,812 judgments

The decision most relied on for tangible material is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on tangible material

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.

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.

CIT v. Kelvinator of India Ltd.

256 ITR 1 · 2002 · High Court

439

citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

CIT v. Orient Craft Ltd.

354 ITR 536 · 2013 · High Court

366

citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.

384 ITR 147 · 2016 · High Court

274

citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

PCIT v. RMG Polyvinyl (I) Ltd.

396 ITR 5 · 2017 · High Court

272

citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

CIT v. Foramer France

264 ITR 566 · 2003 · Supreme Court

253

citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

Haryana Acrylic Manufacturing Company v. CIT

308 ITR 38 · 2009 · High Court

248

citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Judgments citing tangible material

Gehna Jewellers Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle-4(2)(1), Mumbai

ITA 1004/MUM/2024[2012-13]Status: DisposedITAT Mumbai04 Nov 2024AY 2012-13

Bench: the Tribunal. Vide order dated 22/11/2017 passed by the Tribunal in ITA No. 3530/MUM/2017 the order passed under Section 263 of the Act was set aside and

For Appellant: Shri V.C. ShahFor Respondent: Mrs. Beena Santosh/Mr. Pushkraj

Section 143(3)Section 144Section 147Section 148Section 263

from the said party. In our view, in the facts of the present case, the aforesaid information received from the investigation wing formed sufficient tangible material for initiation of re-assessment proceedings under Section 147 of the Act. As per the reasons recorded, the Assessing Officer had formed a belief

Smt. Sudha Agarwal, Jaipur vs. ITO, Ward-6(4), Jaipur

In the result, the appeal filed by the assessee stands partly allowed with no orders to cost

ITA 532/JPR/2024[2013-14]Status: HeardITAT Jaipur30 Oct 2024AY 2013-14

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR

Section 10(38)Section 147Section 148Section 69A

Trib.) For assumption of jurisdiction u/s 147 the AO has to form a prima facie opinion on the basis of tangible material that there is an escapement of income. Reasons recorded and/or the documents available on record must show a nexus and relevancy to the opinion formed ... reasons so recorded. Mere fact that the assessee sold certain shares with certain value on the stock exchange cannot by itself be held as tangible material. Further the AO has not just recorded a reason to believe rather recorded a conclusive finding that assessee is involved in manage trading

Mohd Sajid Mohd Mazahir Shaikh, Mumbai vs. NFAC, Delhi, Mumbai

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

ITA 2231/MUM/2024[2014-15]Status: HeardITAT Mumbai30 Oct 2024AY 2014-15

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Mohd Sajid Mohd Mazahir Shaikh Nfac, Delhi 65 Lala Nigam Road, Colaba Vs. Mumbai-400 005

For Appellant: NoneFor Respondent: Shri R. R. Makwana

Section 147Section 148Section 151Section 250Section 69A

material facts is without jurisdiction being barred by limitation. 3. For that the reasons mentioned in the assessment order, the same lack and tangible material and suffers from borrowed satisfaction, therefore the entire proceedings are bad in law and ab initio void. Moreover it appears that before initiation of reassessment

DCIT 15(1)(1), Mumbai vs. Antony Motors P.Ltd, Navi Mumbai

In the result the appeals filed by the assessee & revenue stands partly allowed

ITA 724/MUM/2016[2007-08]Status: DisposedITAT Mumbai30 Oct 2024AY 2007-08

Bench: Smt Beena Pillai & Smt Renu Jauhri[Assessment Year: 2009-10] [Assessment Year: 2008-09] [Assessment Year: 2007-08] Dy. Commissioner Of M/S. Antony Motors Pvt. Income-Tax- 15(1)(1) Ltd. Room No.517, A-390/391, 5Th Floor, Midc, Ttc, Vs. Aayakar Bhavan, Industrial Zone, Maharshi Karve Road, Navi Mumbai- 400701. Mumbai- 400020. Pan: Aaaca4719K (Appellant) (Respondent)

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Paresh Deshpande – Sr. A.R

Section 133(6)Section 143(3)Section 145(3)Section 148

must have reason to believe that income chargeable to tax escaped assessment. It is submitted that for arriving at such conclusion, there must be ―tangible material‖ available with the Ld.AO on record. The Ld.AR submitted that, in the present facts of the case, there is nothing on record to substantiate ... based on the fulfilment of the precondition stipulated under the section and that, it is mere ‗change of opinion‘ without there being any tangible material to come to such conclusion. 5.4. On the contrary the Ld.DR vehemently opposed the arguments of the Ld.AR. He submitted that the objections are decided

DCIT 15(1)(1), Mumbai vs. Antony Motors P.Ltd, Navi Mumbai

In the result the appeals filed by the assessee & revenue stands partly allowed

ITA 723/MUM/2016[2008-09]Status: DisposedITAT Mumbai30 Oct 2024AY 2008-09

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Paresh Deshpande – Sr. A.R

Section 133(6)Section 143(3)Section 145(3)Section 148

DCIT 15(1)(1), Mumbai vs. Antony Motors P.Ltd, Navi Mumbai

In the result the appeals filed by the assessee & revenue stands partly allowed

ITA 722/MUM/2016[2009-10]Status: DisposedITAT Mumbai30 Oct 2024AY 2009-10

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Paresh Deshpande – Sr. A.R

Section 133(6)Section 143(3)Section 145(3)Section 148

Subhash Kumar Kedia, Hyderabad vs. Asst. Commissioner of Income Tax Central Circle-3(1), Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 707/HYD/2020[2015-16]Status: DisposedITAT Hyderabad29 Oct 2024AY 2015-16

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.707/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Subhash Kumar Kedia Vs. Asstt. C. I. T. Hyderabad Central Circle 3(1) Pan:Afvpk8915Q Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No. 405/Hyd/2020 (िनधा"रण वष"/Assessment Year: 2015-16) Vs. Shri Bikash Kumar Asstt. C. I. T. Kedia Hyderabad Central Circle 3(1) Pan:Afapk8794E Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Vamshi Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 09/10/2024 घोषणा की तारीख/Pronouncement: 29/10/2024 आदेश/Order Per Manjunatha, G. A.M These Two Appeals Filed By Different Assessees Are Directed Against The Separate, But Identical Orders Dated 31/01/2020 Of The Learned Cit (A)-11, Hyderabad Relating To Page 1 Of 33

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Vamshi Krishna, DR

Section 143(3)Section 153ASection 68

assessment of Long-Term Capital Gain derived from purchase and sale of shares. From the above, it is undisputedly clear that there is fresh tangible material in the form of material, found during the course of survey which is subsequent to completion of assessment for the impugned A.Ys and therefore ... argument of the learned Counsel for the assessee that the reopening of the assessment was not based on any fresh tangible material but merely on change of opinion is devoid of any merit and unsustainable. Further, the Hon'ble Apex Court in the case of Raymond Woollen Mills

Bikash Kumar Kedia, Hyderabad vs. Asst. Commissioner of Income Tax, Central Circle-3(1), Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 405/HYD/2020[2015-16]Status: DisposedITAT Hyderabad29 Oct 2024AY 2015-16

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Vamshi Krishna, DR

Section 143(3)Section 153ASection 68

Assistant Commissioner of Income Tax Corporate Circle 1 1, Chennai vs. Capital First Limited(Merged With Idfc First Bank Limited), Chennai

In the result, both the appeal filed by the Revenue and the Cross

ITA 1692/CHNY/2024[2017-18]Status: DisposedITAT Chennai29 Oct 2024AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1692/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 & C.O. No. 63/Chny/2024 [In I.T.A. No. 1692/Chny/2024] The Assistant Commissioner Of Vs. Capital First Limited (Merged With Income Tax, Idfc Bank Limited), Kpm Tower, 7Th Floor, No. 1, Harrington Road, Corporate Circle 11, Chennai. Chetpet, Chennai 600 031. [Pan:Aacck6863C] (अपीलाथ"/Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri M. Rajan, Cit Assessee By : Shri Ketan K. Ved, C.A. सुनवाई की तारीख/ Date Of Hearing : 23.10.2024 घोषणा की तारीख /Date Of Pronouncement : 29.10.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 14.03.2024 Passed By The Ld. Commissioner Of Income Tax, National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. Since, The Issues Raised In The Revenue’S Appeal & The Cross Objections Of The Assessee Are Similar & Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To Hear The Appeal

For Appellant: Shri Ketan K. Ved, C.AFor Respondent: Shri M. Rajan, CIT

Section 115JSection 143(3)Section 147Section 148

check abuse of power by the Assessing Officer. Hence, after 1st April, 1989, the Assessing Officer has power to reopen, provided there is "tangible material" to come 6 I.T.A. No.1692/Chny/24 & C.O. No. 63/Chny/24 to the conclusion that there is escapement of income from assessment. Reasons must have a live link

Assistant Commissioner of Income Tax, Mumbai vs. Hdfc Life Insurance Company Limited, Mumbai

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

ITA 2716/MUM/2023[2019-20]Status: DisposedITAT Mumbai29 Oct 2024AY 2019-20

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailacit – 1(1)(1) 597, Aayakar Bhavan, Mk Road, Mumbai Maharashtra–400020……………. Appellant

For Appellant: Shri Ms. Aarti VissanjiFor Respondent: Shri Manoj Kumar Sinha, Sr. AR

Section 10Section 144Section 250Section 28Section 44

reopening the assessment would have to be regarded as a mere change of opinion which has also not been based on any tangible material. Consequently, we hold that the reopening of the assessment is contrary to law. The Petition would have, therefore, to be allowed". Respectfully following the above

Jagtar Singh Bassi, Jalandhar vs. ACIT (Int. Taxation), Chandigarh

In the result, Assessee’s appeal is allowed

ITA 309/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh28 Oct 2024AY 2011-12

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 309/Chd/2024 "नधा"रण वष" / Assessment Year : 2011-12 Jagtar Singh Bassi, Vs. The Acit C/O Y.K.& Co., बनाम (Int Taxation), Chartered Accountants, Circle, 4Th Floor, Ambika Tower, Chandigarh Police Lines, Jalandhar "थायी लेखा सं./Pan No: Gfxpb5393R अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Y.K. Sud, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 12.09.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 28.10.2024

For Appellant: Shri Y.K. Sud, CAFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 151Section 309Section 69

proceedings u/s 147/148, CIT (A) failed to appreciate that neither the notice u/s 148 was served upon the assessee, nor the AO has any tangible material in his possession for formation of belief of escapement of income and further no sanction has been taken

Asstt. Commissioner of Income-Tax Circle-5, Pune vs. Renu Electronics Private Limited, Pune

In the result, appeal of the Revenue is dismissed

ITA 353/PUN/2024[2011-12]Status: DisposedITAT Pune25 Oct 2024AY 2011-12

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.353/Pun/2024 िनधा"रण वष" / Assessment Year: 2011-12 The Assistant V Renu Electronics Private Commissioner Of S Limited, S.No.2/6, Near Baner Income Tax, Circle-5, Telephone Exchange, Baner, Pune. Pune – 411045. Pan: Aaacr8741G Appellant / Revenue Respondent / Assessee Cross Objection No.18/Pun/2024 िनधा"रण वष" / Assessment Year: 2011-12 The Assistant V Renu Electronics Private Commissioner Of S Limited, S.No.2/6, Near Baner Income Tax, Circle-5, Telephone Exchange, Baner, Pune. Pune – 411045. Pan: Aaacr8741G Appellant / Revenue Respondent / Assessee Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 03/10/2024 Date Of Pronouncement 28/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Are Two Appeals Ita No.353/Pun/2024 Filed By The Revenue & Cross Objection C.O. No.18/Pun/2024 Filed By The

Section 10ASection 142(3)Section 143(3)Section 147Section 250Section 32(1)(iia)

material facts, the reopening u/s 148 be declared null and void. 3) The assessee submits that in this case there was no fresh tangible material with the A.O. for reopening the case and hence, the reopening u/s 148 is invalid in law and accordingly, the reasst. order be declared null

Ambaji Avenues Private Limited, Mumbai vs. Income Tax Officer, Ward-9(1)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3922/MUM/2024[2012-13]Status: DisposedITAT Mumbai25 Oct 2024AY 2012-13

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailassessment Year: 2012-13 Ambaji Avenues Private Limited Income Tax Officer- 9(1)(2), Mumbai A-109, Akshay Mittal Indl. Premises, M.V. Road, Sanjay Vs. Building No. 5, Andheri (W), Mumbai-400059. Pan: Aajca 8264 G (Appellant) (Respondent) Present For: Assessee By : Shri Ramesh Kumar Malpani Revenue By : Shri Manoj Kumar Sinha, Sr. Dr Date Of Hearing : 09.09.2024 Date Of Pronouncement : 25.10.2024 O R D E R Per Amarjit Singh: This Appeal Of The Assessee For The Assessment Year 2012-13 Is Directed Against The Order Dated 19.06.2024 Passed By The Ld. Commissioner Of Income-Tax (Appeal), Nfac, Delhi. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Ramesh Kumar MalpaniFor Respondent: Shri Manoj Kumar Sinha, Sr. DR

Section 143(3)Section 147Section 148Section 68

DCIT (2021) 439 ITR 168 (Bombay) wherein it is held that after a period of 4 years even if the assessing officer has some tangible material given to the conclusion that there is an escapement of income from 7 Ambaji Avenues Private Limited A.Y. 2012-13 assessment, he cannot exercise

Assistant Commissioner of Income Tax 4(1)(1), Mumbai vs. Ankur Agrawal, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 2308/MUM/2024[2011-12]Status: DisposedITAT Mumbai25 Oct 2024AY 2011-12

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailassessment Year: 2011-12 Acit 4(1)(1), Mumbai Ankur Agrawal 2401, 2402, Anmol Pride, Opp. Vs. Patel Auto Petrol Pump, Off Sv Road Goregaon West, Mumbai- 400062. Pan: Akopa 7201 P (Appellant) (Respondent)

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri Ajay Chandra, CIT, DR

Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

presumption can be drawn to hold otherwise. In the said case the Hon'ble High Court has held that in absence of any tangible material to show that huge cash was transferred from one side to another, addition cannot be sustained. 16.7 The decision of the Hon'ble Delhi High ... evidence sufficient to raise an inference. A deeming provision, thus, enable he revenue to raise an inference against an assessee on the basis of tangible material and not on mere suspicion, conjectures or perceptions." 17 Judgements of Hon'ble Supreme Courts:- 17.1 The Honourable Supreme Court in the case

Aptiv Connection Systems India Private Limited, Kochi, Kerala vs. Deputy Commissioner of Income-Tax, Corporate Circle 1(1), Ernakulam, Kerala

ITA 749/COCH/2023[2010-11]Status: DisposedITAT Cochin23 Oct 2024AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Smt. V. Swarnalatha, Sr. D.R

Section 10ASection 143(3)Section 147Section 148

Assessing Officer invoked section 148/147 mechanism without even indicating in the above extracted reasons as to whether any fresh tangible material existed herein or not. We find in this factual backdrop that Indu Lata Rangwala vs. DCIT [2016] 384 ITR 337 (Del) holds in para 35.6 that such fresh tangible ... material ought to form the basis for initiating sec.148/147 proceedings. We make it clear that there is no fresh tangible material before us in the case records. This assessee’s appeal ITA.No.735/Coch./2023 succeeds in very terms thereby all issues on merits stand render academic. Ordered accordingly. ITA.No.749/Coch

Aptiv Connection Systems India Private Limited, Kochi, Kerala vs. Assistant Commissioner of Income Tax, Corporate Circle 1(1), Kochi, Kerala

ITA 736/COCH/2023[2014-15]Status: DisposedITAT Cochin23 Oct 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Smt. V. Swarnalatha, Sr. D.R

Section 10ASection 143(3)Section 147Section 148

Aptiv Connection Systems India Private Limited, Kochi, Kerala vs. Assistant Commissioner of Income-Tax, Corporate Circle 1(1), Kochi, Ernakulam, Kerala

ITA 735/COCH/2023[2009-10]Status: DisposedITAT Cochin23 Oct 2024AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Smt. V. Swarnalatha, Sr. D.R

Section 10ASection 143(3)Section 147Section 148

Nvidia Graphics Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Central Circle 2(4), Bangalore

In the result, appeal filed by the assessee s party allowed

ITA 1111/BANG/2024[2014-15]Status: DisposedITAT Bangalore23 Oct 2024AY 2014-15

Bench: Shri George George K & Ms. Padmavathi. Sr Assessment Year : 2014-15 M/S. Nvidia Graphics Pvt. Ltd., Vs. Acit, Mahadevpura Village, Central Circle – 2(4), K. R. Puram Hobli, Marathalli Bangalore. Bagmane Goldstone Building, North Tower, Mahadevpura S.O, Bangalore – 560 048. Pan : Aabcn 9200 H Appellant Respondent Assessee By : Shri. Nageshwar Rao, Advocate Revenue By : Ms. Neha Sahay, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 17.10.2024 Date Of Pronouncement : 23.10.2024

For Appellant: Shri. Nageshwar Rao, AdvocateFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bengaluru

Section 143(3)Section 147Section 148Section 234BSection 234CSection 250Section 271(1)(c)Section 28

India has disclosed all the primary material facts during the course of the assessment proceedings.” 9. Further, it was submitted that there is no tangible material warranting issuance of notice under section 148 of the Act and contended that the reassessment proceedings have been initiated on a change of opinion ... passing original assessment order under section 143(3), consideration of same could not to be considered as change of opinion and, thus, there was tangible material to believe that there was an escapement of income [2023] 147 taxmann.com 73 (Madras) Karur Kongu Charitable Trust v. Income-tax Officer: In this

Abans Realty and Infrastructure Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, the appeal by the assessee for the assessment year

ITA 3648/MUM/2024[2018-19]Status: DisposedITAT Mumbai22 Oct 2024AY 2018-19

Bench: Shri Prashant Maharishishri Sandeep Singh Karhail

For Appellant: Shri Suyog BhaveFor Respondent: Shri PushkrajBhange Patil, Sr.DR

Section 143(3)Section 148Section 250Section 69C

details. were available on record and no addition in relation to alleged business loss or alleged commission was made. There is no new tangible material. b. SEBI interim order dated 20.08.2015 referred in the Assessment order was in regards to illiquid stock options only. However our case relates to currency

Abans Realty and Infrastructure Private Ltd, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 4(3), Mumbai

In the result, the appeal by the assessee for the assessment year

ITA 3647/MUM/2024[2015-16]Status: DisposedITAT Mumbai22 Oct 2024AY 2015-16

Bench: Shri Prashant Maharishishri Sandeep Singh Karhail

For Appellant: Shri Suyog BhaveFor Respondent: Shri PushkrajBhange Patil, Sr.DR

Section 143(3)Section 148Section 250Section 69C