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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

Dharampal Satyapal Ltd., New Delhi vs. ACIT Central Circle 29, New Delhi

ITA 5519/DEL/2024[2015-16]Status: DisposedITAT Delhi15 Oct 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2015-16 Dharampal Satyapal Ltd., Vs. Acit, 98, Okhla Industrial Estate Central Circle-29, Phase Iii, New Delhi. Tehkhand, New Delhi – 110 020. Pan: Aaacd0132H (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi; Shri Satya Jeet Goel; & Shri Rajat Garg, Cas Revenue By : Shri Amit Jain, Cit-Dr Date Of Hearing : 11.09.2025 Date Of Pronouncement : 15.10.2025 Order

For Appellant: Shri R.S. SinghviFor Respondent: Shri Amit Jain, CIT-DR
Section 115JSection 144CSection 147Section 148Section 148ASection 149Section 69ASection 80ISection 92C

dated 30/07/2022 under the amended regime. 2.1 The jurisdiction u/s 147 of the Act has been assumed on the alleged ground of income escaping assessment to the tune of Rs. 25,21,29,980/- purportedly arising from alleged evasion of VAT by consignee agents of the appellant. It was alleged ... notice u/s 148 dated 30/07/2022 2.1 That on the facts and circumstances of the case, in absence of there being any case of income escaping assessment represented in the form of an ‘Asset', the notice u/s 148 after lapse of period of three-years is barred by limitation

Hiteshi Leasing and Housing Pvt Ltd, New Delho vs. DCIT, Circle-1, Faridabad

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

ITA 4620/DEL/2024[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarhiteshi Leasing & Housing Pvt. Ltd., Vs. Dcit, Circle 1, Yogi Associates, Faridabad. E – 335, East Of Kailash, New Delhi – 110 005. (Pan : Aaach8298J) (Appellant) (Respondent) Assessee By : Shri Pushpdeep Singh, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 28.08.2025 Date Of Order : 15.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals), Gurgaon-3 [For Short ‘Ld. Cit (A)] Dated 04.081.2024 For Assessment Year 2011-12 Raising Following Grounds Of Appeal :- “(A) That On The Facts & Circumstances Of The Case The Learned Assessing Officer & Cit(A), While Passing The Order Erred In: A. Passing The Assessment Order Dated 26.03.2015 U/S 153A Despite The Fact The Assessee Was Not Searched & The Assessee Was Issued Notice Under Section 153C On 29.1 1.2013. This Is A Jurisdictional Error

For Appellant: Shri Pushpdeep Singh, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 131Section 153ASection 153CSection 68

further submitted that the list of documents mentioned in para 3 hereinabove, cannot be regarded as incriminating as they don't suggest any income escaping assessment as the effect of those documents have been duly incorporated in the books and balance sheet of the Assessee Company. He further submitted that

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

In the result, the appeals of the revenue in ITA No

ITA 712/JPR/2025[2017-18]Status: DisposedITAT Jaipur14 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, "B" JAIPUR डा० एस. सीतालक्ष्मी, न्यायिक

Thanaraj Sumathi, Mayiladuthurai vs. ITO, Ward-1, Kumbakonam

In the result, appeal filed by the assessee is allowed

ITA 2031/CHNY/2025[2019-20]Status: DisposedITAT Chennai14 Oct 2025AY 2019-20

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2031/Chny/2025 यनिाारणवर्ा / Assessment Year:2019-20 Thanaraj Sumathi, Income Tax Officer, No.3/25, North Street, Vs. Ward-1 Moovalur, Kumbakonam. Mayiladuthurai – 609806. Tamil Nadu. [Pan:Knyps-1061-J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Cit. सुनवाईकीतारीख/Date Of Hearing : 13.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anitha, CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

issued a notification dated 29.03.2022 [after laying the same before each House of Parliament] and formulated a Scheme called "the e-Assessment of Income Escaping Assessment Scheme, 2022" (herein after ‘the Scheme’). And that the Scheme provides that (a) the assessment, reassessment or re-computation u/s.147

Anthonymuthu Udayar Xavier, Sivaganga vs. ITO, Ward-1, Karaikudi

In the result, the appeal of the assessee is allowed

ITA 1943/CHNY/2024[2014-15]Status: DisposedITAT Chennai14 Oct 2025AY 2014-15

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:1943/Chny/2024 धििाारणवर्ा / Assessment Year:2014-15 Anthonymuthu Udayar Xavier, Income Tax Officer, 78 Mgr Salai, Vs. Ward-1 Soodamanipuram, Karaikudi. Karaikudi, Sivaganga – 630 002. Tamil Nadu. [Pan:Aaapx-3145-R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Addl. Cit. सुिवाईकीतारीख/Date Of Hearing : 14.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025 आदेश /O R D E R

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 143(1)Section 143(3)Section 147Section 148Section 148ASection 69Section 69A

been noticed that notices cannot be issued in a case for AY 2013-14, AY 2014-15 and AY 2015-16. if the income escaping assessment, in that case for that year, amounts to or is likely to amount to less than fifty lakh rupees. Hence, in order to reduce ... information and material may not be provided in a case for AY 2013-14. AY 2014-15 and AY 2015-16, if the income escaping assessment, in that case for that year, amounts to or is likely to amount to less than fifty lakh rupees. Separate instruction shall be issued

Marisetti Dhana Tataji, Tadepalligudem vs. Income Tax Officer, Ward-1, Tadepalligudem

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

ITA 448/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2018-19

Bench: Shri Ravish Sood, Hon’Ble

Section 142(1)Section 147Section 148Section 69A

w.e.f. 01.04.2021. The substituted Sections 147 to 149 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

Marisetti Dhana Tataji, Tadepalligudem vs. Income Tax Officer, Ward-1, Tadepalligudem

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

ITA 447/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2018-19

Bench: Shri Ravish Sood, Hon’Ble

Section 142(1)Section 147Section 148Section 69A

w.e.f. 01.04.2021. The substituted Sections 147 to 149 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

Marisetti Dhana Tataji, Tadepalligudem vs. Income Tax Officer, Ward-1, Tadepalligudem

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

ITA 446/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2018-19

Bench: Shri Ravish Sood, Hon'Ble**

Section 147Section 148

w.e.f. 01.04.2021. The substituted Sections 147 to 149 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

Ananda Aqua Exports, Ganapavaram vs. Income Tax Officer, Ward-1, Bhimavarm

ITA 15/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2017-18
Section 143(3)Section 148Section 148ASection 149(1)(b)Section 250Section 250(6)Section 69Section 69A

have invoked the provisions of section 69 of the IT Act. 6. It is crucial and relevant to take note that the income escaping assessment is less than the threshold limit of Rs.50 lacs, therefore, it impacts the determination of income escaping assessment and theapplicability of statutory provisions such

Saroj Devi Haldiya, Jaipur vs. ITO Ward-6(1), Jaipur

ITA 917/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Oct 2025AY 2015-16
For Appellant: Shri S.B. Natani, CAFor Respondent: Mrs.Anita Rinesh, JCIT-DR
Section 147Section 271(1)(c)Section 56(2)(ix)Section 57

framing reasons to believe. The provisions of section 147 as on the date of issue of notice under section 148 are as under - [Income escaping assessment. s.147. If the [Assessing] Officer [has reason to believe] that any income chargeable to has escaped assessment for any assessment year, he may, subject ... framing reasons to believe. The provisions of section 147 as on the date of issue of notice under section 148 are as under - [Income escaping assessment. s.147. If the [Assessing] Officer [has reason to believe] that any income chargeable to has escaped assessment for any assessment year, he may, subject

Arpita Mathew Arukakkal, Nagpur vs. ITO Ward 5(3), Nagpur

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

ITA 501/NAG/2025[2016-17]Status: DisposedITAT Nagpur10 Oct 2025AY 2016-17

Bench: Shri Pavan Kumar Gadalearpita Mathew Arukakkal, Residency Road, Sadar Nagpur- 440001, ……………. Appellant Maharashtra. Pan – Arkpm3965D V/S Income Tax Officer ……………. Respondent Ward–5(3), Nagpur, Maharashtra. Assessee By:Shri.Sapan Usrethe.A.R. Revenue By :Shri.Surjit Kumar Saha.Sr.Dr

For Appellant: Shri.Sapan Usrethe.A.RFor Respondent: Shri.Surjit Kumar Saha.Sr.DR
Section 144Section 144BSection 148Section 151(1)

Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022 as well as the E- Assessment of Income Escaping Assessment Scheme, 2022 promulgated by the CBDT and hence notice and subsequent proceeding is void. 4. On the facts and circumstances of the case the learned National Faceless Appeal Centre

No 368 Kolakaluru Primary Agricultural Co Operative Credit Society Limited, Guntur vs. Income Tax Officer, Ward-1, Tenali

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

ITA 455/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Oct 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.455/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) No. 368 Kolakaluru Vs. The Income Tax Officer, Primary Agricultural Co- Ward-1, Operative Credit Society Tenali. Limited, Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/10/2025 घोषणा की तारीख/Date Of 10/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee-Society Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 25/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The 2 No. 368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited Vs. Ito

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 151Section 151ASection 80PSection 80P(2)(a)

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

Pramila Agarwal, Jaipur vs. The Income Tax Officer Ward-2(5), Jaipur

In the result, the appeal of the assessee is allowed

ITA 531/JPR/2025[2011-12]Status: DisposedITAT Jaipur10 Oct 2025AY 2011-12
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 10(38)Section 147Section 148Section 68

decided the issue as under:- Section 148A, read with sections 147, 148, 153A and 153C, of the Income-tax Act, 1961 Income escaping assessment Conducting inquiry, providing opportunity before issue of notice under section 148 (Scope of provision) - Assessment years 2016-17 and 2017-18 - Assessing Officer issued on assessee ... reported in 329 ITR 110 wherein it has been held as under:- Reassessment Notice Condition precedent Formation of belief that income escaped assessment Assessing Officer treating share application money as bogus accommodation entries – Payments through banking channel and companies investing money genuine – No independent application of mind by Assessing Officer

Bhawani Developers, Lucknow vs. Income Tax Officer-4(1), Lucknow-New

Appeal is disposed of in accordance with the aforesaid

ITA 253/LKW/2025[2018-19]Status: DisposedITAT Lucknow09 Oct 2025AY 2018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 115BSection 133(6)Section 142(1)Section 144BSection 147Section 68

Authorities Scheme, 2022. 6 Copy of CBDT's Notification No. 18/2022 issued vide F. No. 370142/16/2022-TPL(Part1), dated 29.03.2022, notifying e- Assessment of Income Escaping Assessment Scheme, 2022. COMPILATION OF CASE LAWS 7 Copy of judgement and order dated 14.09.2023 passed by Hon'ble High Court of Telangana

Deputy Commissioner of Income Tax, Salem vs. Govinda Rajulu Srinivasan, Salem

In the result, appeal of the Revenue is dismissed

ITA 1250/CHNY/2025[2017-18]Status: DisposedITAT Chennai09 Oct 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1250/Chny/2025 Assessment Years: 2017-18 Deputy Commissioner Of Income Govinda Rajulu Srinivasan, Tax No.21, Chinna Ezhuthukkara Street, Circle-1, Shevapet, Salem, Salem Tamil Nadu-636 002. [Pan: Avmps5356G] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.Bhupendran, Advocate, प्रत्यर्थी की ओर से /Revenue By : Ms.C.Yamuna, Cit. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 09.10.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.Bhupendran, AdvocateFor Respondent: Ms.C.Yamuna, CIT
Section 147Section 148Section 151Section 68

authority is directly corelated 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

Deputy Commissioner of Income Tax, Circle 3(1), Visakhapatnam vs. Vizag Re-Bars Private Limited, Visakhapatnam

In the result, the cross objection filed by the assessee is allowed

ITA 428/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.428/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2017-18) Dy. Cit – Circle – 3(1) Vs. M/S. Vizag Re-Bars Private Limited 35, 50-92-35, Sankara Matam Road Plot No. 1 Ida, Edulapaka Bonangi, Opposite Reliance Fresh Parawada Mandal – 531021 Beside Reliance Fresh, Near By Main Road Andhra Pradesh Madhuranagar, Dwaraka Nagar Visakhapatnam – 530016 [Pan:Aabcv2581M] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 10(38)Section 115JSection 143(3)Section 147Section 148Section 148A

Appeals) is justified in quashing the notice issued u/s 148 by the jurisdictional Assessing officer contrary to the provisions of 'E-Assessment of Income Escaping Assessment Scheme' which stipulates that a notice u/s 148 can be issued after 29.03.2022 only by the Faceless Assessing officer. 2. The learned Commissioner ... 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

R. Jayanna HUF, Bengaluru vs. DCIT, Central Circle-2(2), Bangalore

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

ITA 986/BANG/2025[2013-14]Status: DisposedITAT Bangalore08 Oct 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2013-14

For Appellant: Shri Raghavendra Chakravarthy, CAFor Respondent: Shri Balusamy N, JCIT (DR)
Section 139Section 147Section 148Section 2(47)Section 54F

honourable Supreme Court of India has held that reassessment under Section 148 is strictly limited to income escaping assessment, not permitting taxpayers to introduce new deductions or claims unrelated to the original assessment. or claims unrelated to the original assessments. (a) The appellant failed to claim Section 54F in their

Income Tax Officer, Piramal Chambers vs. Soni Ajay Jain, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3841/MUM/2025[2016-17]Status: DisposedITAT Mumbai08 Oct 2025AY 2016-17

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankar

For Appellant: Shri G. V. GindeFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 10(38)Section 147Section 148Section 148ASection 149Section 151Section 250

regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. 8.2 Under new regime, if income escaping assessment is more than Rupees 50 lakhs, a reassessment notice could be issued after the expiry of three years from the end of the relevant assessment

Harendra Pratapray Doshi (HUF), Mumbai vs. ITO Ward 41(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3788/MUM/2025[2012-13]Status: DisposedITAT Mumbai08 Oct 2025AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Bhadresh Doshi, CAFor Respondent: Shri Hemanshu Joshi, (Sr. DR)
Section 143(2)Section 143(3)Section 147Section 292B

errors in filling of the client code. At any rate, what can be taxed in the hands of the present Assessee is the income escaping assessment. Even if the Revenue's theory of the Assessee having enabled the clients to claim contrived losses, the Revenue had to bring on record

Tigerhill Tradelink Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the Appellant is Dismissed

ITA 956/KOL/2025[2014-2015]Status: DisposedITAT Kolkata03 Oct 2025AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 250Section 271BSection 68

invalid and contrary to the statutory scheme of faceless reassessment as mandated under Section 151A of the Act and the e- Assessment of Income Escaping Assessment Scheme, 2022. The said scheme, read with Section 144B, unequivocally requires that such notices be issued only by an authority selected through an automated