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“income escaping assessment”

ReassessmentSection 147Section 1471,518 judgments

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

Leading authorities on income escaping assessment

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.

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.

CIT v. Sun Engineering Works (P) Ltd.
198 ITR 297 · 1992 · Supreme Court
814
citing judgments

A court's pronouncement derives its scope and color from the specific questions involved in the case, thus, due regard must always be given to the questions framed before the court when interpreting its judgment.

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.

CIT v. Jet Airways (I) Ltd.
331 ITR 236 · 2011 · High Court
694
citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

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.

Judgments citing income escaping assessment

The New India Assurance Co Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(2)(2), Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2622/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

circumstances, it would be necessary to turn to section 147 of the Act, which reads as under: "147. Income escaping assessment.—If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may subject to the provisions of sections

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle-3(2)(2), Mumbai

Year Objection No

ITA 2620/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 Nov 2025AY 2016-17
For Appellant: Shri Faroog IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

circumstances, it would be necessary to turn to section 147 of the Act, which reads as under: "147. Income escaping assessment.—If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may subject to the provisions of sections

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle-3(2)(2), Mumbai

Year Objection No

ITA 2619/MUM/2024[2015-16]Status: DisposedITAT Mumbai21 Nov 2025AY 2015-16
For Appellant: Shri Faroog IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

circumstances, it would be necessary to turn to section 147 of the Act, which reads as under: "147. Income escaping assessment.—If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may subject to the provisions of sections

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle -3(2)(2), Mumbai

ITA 2618/MUM/2024[2013-14]Status: DisposedITAT Mumbai21 Nov 2025AY 2013-14
Section 115JSection 143(3)Section 147Section 148

four years from the end of the relevant assessment year, First Proviso to Section 147 of the Act, reproduced hereunder, was applicable. "147. Income escaping assessment.—If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject ... circumstances, it would be necessary to turn to section 147 of the Act, which reads as under: "147. Income escaping assessment.—If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may subject to the provisions of sections

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle -3(2)(2), Mumbai

ITA 2617/MUM/2024[2010-11]Status: DisposedITAT Mumbai21 Nov 2025AY 2010-11
Section 115JSection 143(3)Section 147Section 148

four years from the end of the relevant assessment year, First Proviso to Section 147 of the Act, reproduced hereunder, was applicable. “147. Income escaping assessment.—If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject ... four years from the end of the relevant assessment year, First Proviso to Section 147 of the Act, reproduced hereunder, was applicable. “147. Income escaping assessment.—If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(2)(2), Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2616/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Nov 2025AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

circumstances, it would be necessary to turn to section 147 of the Act, which reads as under: "147. Income escaping assessment.—If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may subject to the provisions of sections

DCIT, Circle- 19(1), Delhi vs. Rakshit Buildcon Pvt. Ltd., Delhi

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

ITA 4727/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmadcit, Circle 19 (1), Vs. Rakshit Buildcon Pvt. Ltd., C – 1/207, 2Nd Floor, Delhi. Sector 11, Rohini, New Delhi – 110 085. (Pan : Aaecr2414E) (Appellant) (Respondent) Assessee By : Shri Salil Aggarwal, Sr. Advocate Shri Shailesh Gupta, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 21.11.2025 O R D E R Per S.Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Delhi-23 [“Ld. Cit(A)”, For Short] Dated 14.08.2024 For Ay 2017-18. “(I) "Whether On Facts & Circumstances Of The Case & In Law, The Ld. Cit(A), Has Erred In Not Appreciating That Detailed Investigation Was Already Carried Out By The Investigation Wing On The Issue Of Bogus Short Term Capital Loss From Alankit Group & The Assessee Was Not Able To Substantiate Its Claim With Evidences."

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 147Section 148Section 151

Gujarat HC) has decided the same issue as under :- “Section 149, read with sections 148 and 148A, of the Income-tax Act, 1961 - Income escaping assessment - Time limit for issuance of notice (TOLA) - Assessment year 2016-2017 - Assessing Officer issued impugned notice under section ... ITAT Mumbai) (supra) has decided the issue as under :- “Section 149, read with sections 148 and 148A, of the Income-tax Act, 1961 - Income escaping assessment - Time limit for issuance of notice - Assessment year 2017-18 - Assessee filed its return of income for assessment year 2017-18 - Assessing Officer issued

Shambhu Dayal Soni, Ramganj Bazar vs. Income Tax Officer Ward 2(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 921/JPR/2025[2017-18]Status: DisposedITAT Jaipur20 Nov 2025AY 2017-18
For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 115BSection 147Section 148Section 148ASection 149(1)(b)Section 151(2)Section 69A

fifty lakh rupees or more: One of the conditions for issuing notice u/s 148 with reference to Sec. 149(1)(b) is that income escaping assessment is likely to amount Rs.50 lacs or more. In the case of the assessee, notice u/s 148 was issued without working out that

M/S Bajrang Lal Jindal, Kanpur vs. Astt. Commissioner of Income Tax-I, Kanpur

In the result, the appeal of the assessee is allowed

ITA 373/LKW/2017[2008-09]Status: DisposedITAT Lucknow20 Nov 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2008-09 M/S Bajrang Lal Jindal, 140, Vs. Asstt. Commissioner Of Income Anandpuri, Kanpur, U.P. Tax-I, Kanpur Pan: Aanpj5660J (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 27.08.2025 Date Of Pronouncement: 20.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A)- Kanpur, Confirming The Addition Of Rs. 1,46,11,400/- Made To The Returned Income Of The Assessee As Unexplained Cash Credits By The Assessing Officer In His Order Dated 31.03.2016 For The Assessment Year 2008-09. The Grounds Of Appeal Are As Under: - “1. That The Ld. Cit (A) I, Kanpur Has Erred In Confirming Addition Of Rs. 14611400.00 To The Returned Income Of The Assessee As Unexplained Cash Credits. 2. That The Reasons Recorded For Initiation Of Proceedings U/S 147 By Issue Of Notice U/S 148 Were Based On Improper Premise & Accordingly No Legal & Factual Lengs To Stand & Acordingly All Subsequent Proceedings Are Bad In Law. 3. That The Observation Of The Ld. Cit (A) I, Kanpur Confirming View Of Ld. A O That M/S. Maa Devasar Commodity Is Inexistant Is Factually Incorrect. 4. That Ld. Cit (A) I, Kanpur Has Erred In Not Appreciating The Fact That When The Beneficiary Of The Funds Are Not The Assessee, There Could Be No Addition In His Hands.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. Amit Kumar, DR
Section 147Section 148Section 68

borrowed satisfaction of the Investigation Wing and the AO had not done any independent enquiries before coming to a conclusion of income escaping assessment. He drew our attention to the fact that two of the bank accounts i.e. bank A/c No.628805005488 and A/c No.628805005674 stood in the name of different ... required to apply his mind to any report received from other Agencies / Investigation Wing to determine whether a case is made out for income escaping assessment. We find from the narration of the report that is given in the assessment order, that other than to state that the said accounts

ITO(It)-3(2)(1), Mumbai vs. Shapoorji Pallonji Mistry, Mumbai

ITA 3674/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Nov 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Satya Pal Kumar - CIT DR
Section 147Section 148Section 148ASection 149Section 151Section 3Section 3(1)

directly co- related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping assessment was less than Rupees one lakh: (a) a reassessment notice could be issued under Section 148 within four years after obtaining the approval ... appropriate authorities specified under Section 151 of the new regime. The effect of Section 151 of the new regime is thus: (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal

Income Tax Officer (It)-3(2)(1), Kautilya Bhawan vs. Shapoorji Pallonji Mistry, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 3523/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Nov 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. Advocate and Shri Divesh Chawla, AdvocateFor Respondent: Shri Satya Pal Kumar - CIT DR
Section 147Section 148Section 148ASection 149Section 151Section 3Section 3(1)

directly co- related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping assessment was less than Rupees one lakh: (a) a reassessment notice could be issued under Section 148 within four years after obtaining the approval ... appropriate authorities specified under Section 151 of the new regime. The effect of Section 151 of the new regime is thus: (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal

Income Tax Officer (International Taxation) 3(2)(1), Kautilya Bhawan Mumbai vs. Shapoorji Pallonji Mistry, Mumbai

ITA 3440/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Nov 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Satya Pal Kumar - CIT DR
Section 147Section 148Section 148ASection 149Section 151Section 3Section 3(1)

directly co- related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping assessment was less than Rupees one lakh: (a) a reassessment notice could be issued under Section 148 within four years after obtaining the approval ... appropriate authorities specified under Section 151 of the new regime. The effect of Section 151 of the new regime is thus: (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal

Anil Kumar Agarwal, Agra vs. DCIT 2(1)(1), Agra

In the result, the appeal of the assessee is allowed

ITA 101/AGR/2025[2011-12]Status: DisposedITAT Agra19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Anil Kumar Agarwal, Vs. Dy. Cit, 44, R. S. Residency, Circle-2(1)(1), Dayal Bagh, Agra, Up Agra (Appellant) (Respondent) Pan: Aampa3335J Assessee By : Shri Rajni Kant Verma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Shri Rajni Kant Verma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 133(6)Section 143(3)Section 148Section 68

Agra, notice under Section 148 of the Act stood issued to the assessee on 27-03-2018 on the ground, cash deposit represent income escaping assessment of the assessee.The Learned AO on receipt of the AIR information issued notice under Section

Ashok Rudraraju, Visakhapatnam vs. Income-Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 439/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 439/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2016-17) Ashok Rudraraju, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Visakhapatnam. Pan: Aqvpr4058L

For Appellant: Shri I. Kama Sastry, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 151(1)Section 151ASection 251(1)(a)Section 69A

three years from the end of the relevant assessment year and the as per the AO himself the information in his possession reveals income escaping assessment of Rs.29,39,061 only. 3. The order passed under section 148A(d) dated 27.07.2022 and the notice under section 148 issued ... w.e.f. 01.04.2021. The substituted Sections 147 to 159 and Section 151 of the Act, applicable w.e.f. 01.04.2021 are culled out as under: “Income escaping assessment- 147. If any income chargeable to tax, in the case of an assessee, has escaped assessment for any assessment year, the Assessing Officer may, subject

Sonu Agarwal, Jaipur vs. Income Tax Officer Ward 1(3), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1263/JPR/2025[2016-2017]Status: DisposedITAT Jaipur19 Nov 2025AY 2016-2017

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Gaurav Awasthi, JCIT
Section 10(38)Section 139Section 147Section 148Section 148ASection 250

related to the time when the notice is issued. This plays out as follows under the old regime: Sonu Agarwal, Jaipur. (i) If income escaping assessment was less than Rupees one lakh: (a) a reassessment notice could be issued under Section 148 within four years after obtaining the approval ... appropriate authorities specified under Section 151 of the new regime. The effect of Section 151 of the new regime is thus : (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal

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)

w.e.f. 01.04.2021. The substituted Sections 147 to 159 and Section 151 of the Act, applicable w.e.f. 01.04.2021 are culled out as under: “Income escaping assessment- 147. If any income chargeable to tax, in the case of an assessee, has escaped assessment for any assessment year, the Assessing Officer may, subject

Arulmigu Vaikunda Perumal and Embarswamy Devasthanam, Kanchipuram vs. ITO, Exemptions Ward-2, Chennai

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

ITA 2525/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Nov 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2525/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Arulmiguvaikunda The Income Tax Officer, Perumal & Embarswamy Vs. Exemptions Ward 2, Devasthanam, Chennai. No.01, Sunguvachatram, Sungavachatram S.O, Sriperumbudur, Kanchipuram – 602 105. Pan: Aafta 4259C (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S.P. Chidambaram, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 19.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 19.11.2025

For Appellant: Shri S.P. Chidambaram, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144BSection 147Section 148Section 148ASection 250

Chennai is lacking jurisdiction in view of Notification issued by the CBDT dated 29.03.2022 which formulated a Scheme called “the e- assessment of Income Escaping Assessment Scheme, 2022”. By relying upon the decision of the Hon’ble High Court of Madras in the case of TVS Credit Services

Sri Muthu Agencies, Puducherry vs. ITO, Ward-3, Puducherry

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

ITA 2507/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Nov 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2507/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Sri Muthu Agencies, The Income Tax Officer, No.9, 3Rd Cross, Vs. Ward 3, Sri Ramnagar, Puducherry Achariyapuram, Villianur, Puducherry – 605 110. Pan: Achfs 9277N (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri H. Yeshwanth Kumar, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 19.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 19.11.2025

For Appellant: Shri H. Yeshwanth Kumar, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144BSection 147Section 148Section 250

Puducherry is lacking jurisdiction in view of Notification issued by the CBDT dated 29.03.2022 which formulated a Scheme called “the e- assessment of Income Escaping Assessment Scheme, 2022”. By relying upon the decision of the Hon’ble High Court of Madras in the case of TVS Credit Services

Sujatha Hariharan, Chennai vs. ITO, Ncw-3(3), Chennai

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

ITA 2491/CHNY/2025[2015-16]Status: DisposedITAT Chennai19 Nov 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 2490 & 2491/Chny/2025 निर्धारण वर्ष/Assessment Year: 2015-16 Smt. Sujatha Hariharan, Old No.20, New No.8, Poes Road, 2Nd Street, Teynampet, Chennai - 600 018. The Income Tax Officer, Vs. Non-Corporate Ward 3(3), Chennai. Pan: Bgcps 5734A (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri Y. Sridhar, Fca प्रत्यर्थी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 18.11.2025 घोषणा की तारीख/Date Of Pronouncement : 19.11.2025 आदेश/Order Per George George K: These Appeals Filed By The Assessee Are Directed Against Two Different Orders Of Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi Both Dated 24.07.2025, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act'). The Relevant Assessment Year Is 2015-16.

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144BSection 147Section 148Section 148ASection 250

Chennai is lacking jurisdiction in view of Notification issued by the CBDT dated 29.03.2022 which formulated a Scheme called "the e-assessment of Income Escaping Assessment Scheme, 2022”. By relying upon the decision of the Hon'ble High Court of Madras in the case of TVS Credit Services

Sujatha Hariharan, Chennai vs. ITO, Ncw-3(3), Chennai

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

ITA 2490/CHNY/2025[2015-16]Status: DisposedITAT Chennai19 Nov 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 2490 & 2491/Chny/2025 निर्धारण वर्ष/Assessment Year: 2015-16 Smt. Sujatha Hariharan, Old No.20, New No.8, Poes Road, 2Nd Street, Teynampet, Chennai - 600 018. Pan: Bgcps 5734A (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By The Income Tax Officer, Vs. Non-Corporate Ward 3(3), Chennai. (प्रत्यर्थी/Respondent) : Shri Y. Sridhar, Fca : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 18.11.2025 घोषणा की तारीख/Date Of Pronouncement : 19.11.2025 आदेश/Order Per George George K: These Appeals Filed By The Assessee Are Directed Against Two Different Orders Of Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi Both Dated 24.07.2025, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act'). The Relevant Assessment Year Is 2015-16.

Section 144BSection 147Section 148Section 148ASection 250

Chennai is lacking jurisdiction in view of Notification issued by the CBDT dated 29.03.2022 which formulated a Scheme called "the e-assessment of Income Escaping Assessment Scheme, 2022". By relying upon the decision of the Hon'ble High Court of Madras in the case of TVS Credit Services