“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

Trd 309 Pallinatham Mpcs, Trichy vs. Assessing Officer, Ward 2(1) Trichy, Trichy

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

ITA 2482/CHNY/2025[2019-2020]Status: DisposedITAT Chennai19 Nov 2025AY 2019-2020

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2482/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 M/S. Trd 309 Pallinatham The Income Tax Officer, Mpcs, Vs. Ward 2(1), Pallinatham Valavanthi Post, Trichy Musiri Tk, Tiruchirappalli – 621 211. Pan: Aafat 2275G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri V. Alagappan, Ca (Through Virtual Mode) ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 18.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 19.11.2025

For Appellant: Shri V. Alagappan, CAFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 144BSection 147Section 148Section 148ASection 250

Trichy 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

Kisan International Trading Fze, New Delhi vs. ACIT, Int. Tax 2(1)(2), Delhi

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

ITA 6152/DEL/2024[2012-13]Status: DisposedITAT Delhi19 Nov 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Kisan International Trading Fze, Vs. Acit, Circle C/O Shri Tarandeep Singh, Advocate Int. Tax 2(1)(2), C – 179, Mansarover Garden, Delhi. New Delhi – 110 015. (Pan :Aaeck0424D) (Appellant) (Respondent) Assessee By : Shri Tarandeep Singh, Advocate Shri Sandeep Yadav, Advocate Revenue By : Shri Vikram Singh Sharma, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 19.11.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Delhi – 43 [“Ld. Cit(A)”, For Short] Dated 06.12.2024 For The Assessment Year 2012-13 Raising Following Grounds Of Appeal :- “1. That On Facts & In Law The Order Dated 06Th December 2024 Passed By The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As The "Cit(A)'} & Order Dated 23Rd December 2019 Passed By The Assessing Officer (Hereinafter Referred To As The "Ao") Are Bad In Law & Void Ab Initio.

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Vikram Singh Sharma, Sr. DR

Section 115A(5)Section 147Section 148Section 195Section 251

filed return of income in India for the year under consideration. he held that the entire amount of Rs.8,49,50,002/- was income escaping assessment which was chargeable to tax in India. Ld. AR further submitted that it will be relevant to note here that the amount of Rs.8 ... before the lower authorities, it was repeatedly submitted by the assessee that the AO has erroneously picked up a wrong figure of alleged income escaping assessment. In this regard, he submitted that copy of Form 26-AS has been filed on record at pages 19 to 22 of the paper

Prabu Karuppaiah, Pudukkottai vs. ITO, Ward-1, Pudukkottai

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

ITA 2494/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Nov 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 2492, 2493 & 2494/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Shri Prabu Karuppaiah, The Income Tax Officer, 8/115, Avudaiyarkoil Poovalur Vs. Ward 1, Bo, Pudukkottai Avadaiyar Kovil, Pudukkottai – 614 618. Pan: Clepp 3346R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Y. Sridhar, Fca ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 18.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 18.11.2025

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 144BSection 147Section 148Section 148ASection 250

Pudukkottai 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

Prabu Karuppaiah, Pudukkottai vs. ITO, Ward-1, Pudukkottai

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

ITA 2493/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Nov 2025AY 2018-19

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 144BSection 147Section 148Section 148ASection 250

Prabhu Karuppaiah, Pudukkottai vs. ITO, Ward-1, Pudukkottai

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

ITA 2492/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Nov 2025AY 2018-19

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 144BSection 147Section 148Section 148ASection 250

Rajendrasinh Ranjitsinh Jadeja, Khakhadabela, Paddhari vs. ITO WD 2(1)(4), RKT, Rajkot

In the result, appeal filed by the assessee, is allowed, to the extent indicated above

ITA 459/RJT/2025[2012-2013]Status: DisposedITAT Rajkot17 Nov 2025AY 2012-2013

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.459/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) Rajendrasinh Ranjitsinh Jadeja Vs. Ito Ward 2 (1) (4), Khakhadabela, Paddhari, Aayakar Bhawan, Race Course Rajkot - 360110 Ring Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agvpj2529E (Appellant) (Respondent) Appellant By : Shri Gaurang Khakhar, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 01/09/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am ; Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2012-13, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 26/07/2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Dated 25/11/2009 U/S 144 R.W.S 147 Of The Income Tax Act, 1961. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1. That The Reasons Recorded U/S 147 Of The I.T. Act, 1961 By The Ld. A.O. Were Merely Based On The Suspicion & Without Any Tangible Material So As To Suggest Any Escapement Of Income. Hence The Reassessment Proceedings Are Liable To Be Quashed Rajendrasinh Ranjitsinh Jadeja

For Appellant: Shri Gaurang Khakhar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 144Section 147Section 148Section 250

bank account number before issuing notice u/s 148 of the Act. (iv)Mere deposit in the bank account does not constitute that income escaped assessment, the money in the bank account may be deposited out of the past savings / by sale of investment etc, which was not verified by assessing ... verified the bank account number before issuing notice u/s 148 of the Act. Mere deposit in the bank account does not constitute that income escaped assessment, the money in the bank account may be deposited out of the past savings / by sale of investment etc, which was not verified

Vijit Singh, Jaipur vs. ITO Ward 3(2) Jaipur, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1246/JPR/2025[2009-10]Status: DisposedITAT Jaipur17 Nov 2025AY 2009-10

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

Section 147Section 234ASection 250

therefore, dismissed. Also refer PAC AIR SYSTEMS P. LTD. vs. ITO (2020) 58 CCH 0001 DelTrib it has been held that Reassessment—Income escaping assessment— Assessee filed present appeal challenging order of CIT(A) wherein, AO's action was accepted—Assessee contended that AO had erred in assumption of jurisdiction ... quashed-Assessee's appeal partly allowed. In the case of Gorika Investment And Export (P) LTD. vs. ITO (2018) 53 CCH 0168 DelTribReopening—Income escaping assessment—Validity thereof-Assessee filed return of income declaring income which was processed u/s.143(1)—AO issued notice u/s.148 after recording reasons that income

Ratan N Motwani (HUF), Mumbai vs. ITO Ward 23(3)(1), Mumbai

In the result, assessee’s appeal is allowed

ITA 5532/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Nov 2025AY 2017-18

Bench: Smt. Beena Pillai & Smt.Renu Jauhri7 (A.Y.2017-18)

For Appellant: Shri. Bhadresh Doshi, CAFor Respondent: Shri Uma Shankar Prasad- CIT

Section 132Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 68

having the jurisdiction for the same in view of Section 151A and the notification issued thereunder notifying e-Assessment of Income Escaping Assessment Scheme, 2022 and, thereby, rendering the said order and the notice as well as the entire assessment proceeding as null and void. 4. On the facts

Income Tax Officer, Income Tax Department, Visakhapatnam vs. Quality Steel Shoppe Private Limited, Visakhapatnam

In the result, the Cross Objection No

ITA 454/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam14 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.454/Viz/2024 ("नधा"रण वष"/Assessment Year: 2018-19) Income Tax Officer, Vs. Quality Steel Shoppe Ward-2(1), Private Limited, Visakhapatnam. Visakhapatnam. Pan: Aaacq1115D (Appellant) (Respondent) C.O. No. 18/Viz/2024 (In आ.अपी.सं /454/Viz/2024) ("नधा"रण वष"/Assessment Year: 2018-19)

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Sri Badicala Yadagiri

Section 144Section 144BSection 147Section 148Section 148ASection 151A

assessee ie. the order uls. 148A(d) passed by the Jurisdictional AO is in violation of 'e-Assessment of Income Escaping Assessment Scheme, 2022' and therefore, the assessment order passed u/s. 147 is void ab initio. The judgement of Hon'ble Telangana High Court in the case of Kankanala Ravindra ... quashing the order passed u/s 148A(d) by the JAO contrary the stipulations of S.151A of the Act and E-Assessment of Income Escaping Assessment scheme, 2022. 2. The learned Commissioner of Income-Tax (Appeals) is justified quashing the notice u/s 148 on the ground that the assessing officer

Income Tax Officer, Ward-1, Nellore vs. Venkata Ramanamma Sakamuri, Nellore

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

ITA 482/HYD/2025[2018-19]Status: DisposedITAT Hyderabad14 Nov 2025AY 2018-19

Bench: Us:

Section 147Section 148Section 148ASection 151

transactions amounted to 4,75,04,970/-. The assessee did not file a return of income for the relevant year, prompting concerns about income escaping assessment. Numerous notices were issued under Sections 5 ITO vs. Venkata Ramanamma Sakamuri 148 and 142(1), including show cause notices, all of which went ... Principal Commissioner of Income Tax, Tirupati Charge, Tirupati while the notice for the relevant assessment year has been issued on 07.04.2022 and the income escaping assessment is more than 50,00,000/-. The order of under clause (d) of section 148A of the Income-tax Act, 1961 by Principal Commissioner

Sarvesh Kumar, Farrukhabad vs. Income Tax Officer Ward 4(2)(2) Farrukhabad, Farrukhabad

In the result, the appeal of the assessee is allowed

ITA 452/AGR/2024[2017-18]Status: DisposedITAT Agra13 Nov 2025AY 2017-18

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sarvesh Kumar, Vs. Ito, Okharu Khanpur, Ward-4(2)(2), Farrukhabad, Fatehgarh, Farrukhabad Ho 209601 (Appellant) (Respondent) Pan: Dsqpk3348G Assessee By : Shri Swaran Singh, Ca Shri Shailesh Gupta, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 18/11/2025

For Appellant: Shri Swaran Singh, CAFor Respondent: Shri Anil Kumar, Sr. DR

Section 115BSection 139Section 139(1)Section 139(4)Section 142(1)Section 143(3)Section 144Section 147Section 148Section 44A

Income-tax Act by ignoring the returns. 2. The main contention of the assessees is that it was a case of income escaping assessment and, therefore, the initiation of assessment proceedings without the issue of notice under section 148 in each case was invalid. Reference to Explanation ... where no return of income has been furnished by the assessee" as appearing in the Explanation, for treating it as a case of "Income escaping assessment, has to be seen on the expiry of the period within which the assessee can file the return. Otherwise, even on the first

Guiness Finance & Leasing Pvt. Ltd., Kolkata vs. ITO, Ward 6(2), Kolkata

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 1633/KOL/2025[2015-2016]Status: DisposedITAT Kolkata13 Nov 2025AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Guiness Finance & Leasing Pvt. Ltd..….……………….……….……….……Appellant 3Rd Floor, Baid Property, 10, Canning Street, Burra Bazar, Kol-1.. [Pan: Aabck1388B] Vs. Ito, Ward-6(2), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri Miraj D Shah, Ar, Appeared On Behalf Of The Appellant. Shri Sandeep Lakra, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Brief Facts Of The Case Of The Assessee Are That The Assessee 2. Company Filed Its Return Of Income For The A.Y 2015-16 On 30.09.2015 Declaring Total Income Of Rs.Nil. The Said Return Was Selected For Scrutiny On The Reason That The Assessee Is The Beneficiary Of Credit Of Rs.1,28,38,232/- From Penny Stock Company M/S Steel Exchange Ltd. Notices U/S 143(2) & 142(1) Of The Act Were Issued & Thereafter, The Case Of The Assessee Reopened By Issuing Notice U/S 148 Of The Act On 14.07.2022. The Assessing Officer Passed An Ex Parte Order U/S 147 Guiness Finance & Leasing Pvt. Ltd R.W.S. 144B Of The Act On 29.05.2023 Adding Rs.1,28,38,391/- To The Total Income Of The Assessee.

Section 143(2)Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 250

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

Pallavi Das, Chennai vs. ITO, Non Corp. Ward 7(1) Che, Chennai

ITA 1026/CHNY/2025[2015-16]Status: DisposedITAT Chennai13 Nov 2025AY 2015-16

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1026/Chny/2025

Section 147Section 148Section 148ASection 151Section 151A

assessing officer and not the faceless assessing officer. We have noted the following provisions of Section 151A of the Act:- ".....[Faceless assessment of income escaping assessment. 22 151A. (1) The Central Government may make a scheme, by notification in the Official Gazette, for the purposes of assessment, reassessment ... Central Government hereby makes the following Scheme, namely:- 1. Short title and commencement.—(1) This Scheme may be called the e-Assessment of Income Escaping Assessment Scheme, 2022. (2) It shall come into force with effect from the date of its publication in the Official Gazette. 2. Definitions

Somnath Ramdas Jadhav, Ahmednagar vs. ITO Ward 2, Ahmednagar

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

ITA 441/PUN/2025[2016-17]Status: DisposedITAT Pune12 Nov 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

Type of transactions Amount 1. Deposited Cash in Account with Shri Renukamata Multi State Urban Co-operative Credit Society Limited 5051750 Total income escaping assessment 5051750 Thus, on perusal of the details available on record, it is noticed that during the previous year relevant to the assessment year under consideration

Somnath Ramdas Jadhav, Ahmednagar vs. ITO, Ward 2, Ahmednagar

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 440/PUN/2025[2015-16]Status: DisposedITAT Pune12 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

Type of transactions Amount 1. Deposited Cash in Account with 5051750 Shri Renukamata Multi State Urban Co-operative Credit Society Limited Total income escaping assessment 5051750 Thus, on perusal of the details available on record, it is noticed that during the previous year relevant to the assessment year under consideration

Somnath Ramdas Jadhav, Ahmednagar vs. ITO, Ward 2, Ahmednagar

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 439/PUN/2025[2013-14]Status: DisposedITAT Pune12 Nov 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

Somnath Ramdas Jadhav, Ahmednagar vs. ITO Ward 2, Ahmednagar

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

ITA 1093/PUN/2025[2015-16]Status: DisposedITAT Pune12 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamore

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

Somnath Ramdas Jadhav, Ahmednagar vs. ITO Ward2, Ahmednagar

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 1092/PUN/2025[2013-14]Status: DisposedITAT Pune12 Nov 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

Somnath Ramdas Jadhav, Ahmednagar vs. ITO Ward 2, Ahmednagar

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 1089/PUN/2025[2016-17]Status: DisposedITAT Pune12 Nov 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

Lal Chand Meena, Jaipur vs. ITO WD 5(2), Jaipur

ITA 1074/JPR/2025[2013-14]Status: DisposedITAT Jaipur11 Nov 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Anoop Bhatia, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT

Section 143(1)Section 147Section 148Section 2Section 50CSection 54F

sought to be re-opened after lapse of four years, it has to be only for the reason that the income escaping assessment is due to the reason of failure on the part of the assessee to disclose fully and truly all material facts necessary for his 9 Lal Chand