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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

Vividhodhesha Prathamika Gramina Krushi Sahakara Sangha Ni Gejjalagere, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result appeal of the assessee is partly allowed

ITA 2071/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmedassessment Year: 2018-19

For Appellant: Shri Tarun Kothari, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 147Section 148Section 151Section 254Section 80P

respectively. Accordingly, a notice under section 148 of the Act was issued for income escaping assessment as on 1st April 2022. The assessee in response to the notice issued under section 148 of the Act filed return of income as on 29th April 2022 wherein declared income at NIL after ... other hand, the learned DR before me submitted that the assessee has participated in the proceedings initiated on account of income escaping assessment and therefore no defect can be pointed out before the Tribunal in the notice issued for initiating the proceedings under section 147 of the Act. The learned

M/S. Dholera Realcon LLP, Ahmedabad vs. The ITO, Ward-3(2)(1), Ahmedabad

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 1545/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad17 Apr 2025AY 2017-18

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

Section 115BSection 133(6)Section 147Section 148Section 271ASection 68Section 69

justice. 10. The Ld. Assessing Authority has grievously erred in law while issuing notice for reopening of the assessment as there is no income escaping assessment therefore, notice issued u/s. 148 of the Income Tax Act is unwarranted and unjustifiable. 11. The appellant craves leave to add, alter or amend

ACIT, Circlle-34, Kolkata vs. Subhas Kumar Kedia, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1677/KOL/2024[2016-17]Status: DisposedITAT Kolkata17 Apr 2025AY 2016-17

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1677/Kol/2024 (नििाारण वर्ा / Assessment Year : 2016-2017) Acit, Circle-34, Kolkata Vs Subhas Kumar Kedia, 41, N.S.Road, Kolkata Pan No. :Afnpk 9669 M (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Ms. Shreya Loyalka, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 21/01/2025 घोषणा की तारीख/Date Of Pronouncement : 17/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 05.06.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2016-2017, On The Following Grounds Of Appeal :- I) That On The Facts & In The Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order U/S.148A(D) & All Subsequent Proceedings. Ii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Failed To Acknowledge The Fact That The Assesse Had Not Expressed Any Grievance Against The Validity Of Order U/S 148A(D) By Moving Any Writ Petition Which Should Have Been Done In Case Of Any Grievance After Getting The Sald Order U/S.148A(D). Iii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order When The Ld. Cit(A) Has No Jurisdiction To Deal With The Question Whether The 148A(D) Order Was Passed Validly Or Properly As An Order U/S.148A(D) Is Not An Appealable Order Before Ld. Cit(A) As Per Section 246A.

For Appellant: Ms. Shreya Loyalka, ARFor Respondent: Shri P.N.Barnwal, CIT-DR
Section 148Section 148ASection 149Section 151Section 246ASection 3Section 69A

issued u/s 148 are invalid. In the given case it is evident from the order under sec 148A(d) that the amount of income escaping assessment as alleged by the AD was more than Rs. 50 lakh. Thus, the approval for sanction of the notice under sec 148 and order

E Ashwath Narayan, Bangalore vs. Income Tax Officer, Ward-3(3)(1), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 1920/BANG/2024[2015-16]Status: DisposedITAT Bangalore17 Apr 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Sri S. Satish, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 142(1)Section 144Section 147Section 148Section 148ASection 149(1)Section 250Section 69A

order u/s 148A(d) of the Act was completely blank and devoid of any contents, & thus violating the basic ingredients of income escaping assessment & thus rendering the entire proceedings void-ab-initio and illegal. Lastly the AR of the assessee submitted that the CIT(A) gross erred in overlooking ... completely blank and devoid of any contents, & thus violating the basic ingredients of E. Ashwath Narayan, Bangalore Page 8 of 19 income escaping assessment & thus rendering the entire proceedings void-ab-initio and illegal. We will take up both the legal grounds ad seriatim. 9.4 Before us, the ld.AR

Income Tax Officer -42(1)(3), Mumbai, Kautilya Bhavan, Bkc, Bandra vs. Krishna Deep Builders, Mumbai

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

ITA 6240/MUM/2024[2017-18]Status: DisposedITAT Mumbai17 Apr 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am Krishna Deep Builders Ito Ward – 42(1)(3) B/203, 2Nd Floor, Goyal Shopping Arcade, Room No. 715, Kautilya Bhavan, C- Opp. Railway Station, S. V. Road, Vs. 41 To C-43, G Block, Bandra Kurla Borivali, West, Mumbai – 400092. Complex, Bandra (East), Mumbai – 400051. Pan/Gir No. Aaafk375Q (Assessee) : (Respondent) Ito Ward – 42(1)(3) Krishna Deep Builders Room No. 715, Kautilya Bhavan, C-41 To B/203, 2Nd Floor, Goyal Shopping C-43, G Block, Bandra Kurla Complex, Vs. Arcade, Opp. Railway Station, S. V. Bandra (East), Mumbai – 400051. Road, Borivali, West, Mumbai – 400092. Pan/Gir No. Aaafk375Q (Assessee) : (Respondent) : Shri. Ajay Singh Assessee By Respondent By : Shri. Hemanshu Joshi (Sr. Dr) Date Of Hearing : 20.01.2025 Date Of Pronouncement : 17.04.2025 O R D E R Per Kavitha Rajagopal, J M: These Are Cross Appeals Filed By The Revenue & The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The

For Respondent: Shri. Hemanshu Joshi (Sr. DR)
Section 144Section 147Section 148Section 148ASection 250Section 56(2)Section 56(2)(vi)Section 56(2)(vii)Section 69Section 69A

There is no iota of doubt that the criteria for issuance of notice u/s. 148 ought to have been income escaping assessment amounting to Rs. 50 lacs or more in cases, where 3 years but not 10 years have elapsed from the end of the impugned year. 10. We would

Krishna Deep Builders, Mumbai vs. Income Tax Officer Ward-42(1)(3), Mumbai

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

ITA 5768/MUM/2024[2017-18]Status: DisposedITAT Mumbai17 Apr 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am Krishna Deep Builders Ito Ward – 42(1)(3) B/203, 2Nd Floor, Goyal Shopping Arcade, Room No. 715, Kautilya Bhavan, C- Opp. Railway Station, S. V. Road, Vs. 41 To C-43, G Block, Bandra Kurla Borivali, West, Mumbai – 400092. Complex, Bandra (East), Mumbai – 400051. Pan/Gir No. Aaafk375Q (Assessee) : (Respondent) Ito Ward – 42(1)(3) Krishna Deep Builders Room No. 715, Kautilya Bhavan, C-41 To B/203, 2Nd Floor, Goyal Shopping C-43, G Block, Bandra Kurla Complex, Vs. Arcade, Opp. Railway Station, S. V. Bandra (East), Mumbai – 400051. Road, Borivali, West, Mumbai – 400092. Pan/Gir No. Aaafk375Q (Assessee) : (Respondent) : Shri. Ajay Singh Assessee By Respondent By : Shri. Hemanshu Joshi (Sr. Dr) Date Of Hearing : 20.01.2025 Date Of Pronouncement : 17.04.2025 O R D E R Per Kavitha Rajagopal, J M: These Are Cross Appeals Filed By The Revenue & The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The

For Respondent: Shri. Hemanshu Joshi (Sr. DR)
Section 144Section 147Section 148Section 148ASection 250Section 56(2)Section 56(2)(vi)Section 56(2)(vii)Section 69Section 69A

There is no iota of doubt that the criteria for issuance of notice u/s. 148 ought to have been income escaping assessment amounting to Rs. 50 lacs or more in cases, where 3 years but not 10 years have elapsed from the end of the impugned year. 10. We would

Bses Yamuna Power Ltd, Delhi vs. ACIT, Circle-5(1), New Del;Hi

The appeal of the assessee is allowed on legal issues

ITA 4853/DEL/2017[2008-09]Status: DisposedITAT Delhi16 Apr 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

Before adjudicating the issues under disputes, it is pertinent to have a look at the statutory provision of income escaping assessment as envisaged under section 147 of IT Act, which stipulate "If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment

Bses Yamuna Power Ltd., New Delhi vs. DCIT, Circle- 5(1), New Delhi

The appeal of the assessee is allowed on legal issues

ITA 4852/DEL/2017[2007-08]Status: DisposedITAT Delhi16 Apr 2025AY 2007-08

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

Before adjudicating the issues under disputes, it is pertinent to have a look at the statutory provision of income escaping assessment as envisaged under section 147 of IT Act, which stipulate "If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment

Kishan Beej, Jamnagar vs. ITO Ward 2(1), Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 384/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Apr 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.384/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Kishan Beej Ito, Wared-2(1) बनाम Kashivishvanath Road Jamnagar – 361 001 Nr. P & T Office Vs. Jamnagar – 361 001 Pan : Aacfk 2114 P (अपीलाथ"/Appellant) (""यथ"/Respondent) :

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 115BSection 142(1)Section 147Section 148Section 234ASection 250Section 271ASection 69Section 69A

Kishan Beej Vs. ITO 4 7.The ld. Counsel also stated that in all the notices issued by the assessing officer, the income escaped assessment is shown to the tune of Rs.21 lakhs, which is not applicable after 1st April 2021. The criteria to issue the notice, after 1st April ... that if the income escaped assessment exceeds Rs.50 lakhs, then only notices can be issued to the assessee in new law regime, after after 1st April 2021. The ld.Counsel for the assessee submitted that the notices were issued to the assessee by following new provisions of the Act, which

Ajay Bakliwal, Kota vs. ACIT, Central Circle, Kota

In the result, the appeal of the assessee is allowed

ITA 1275/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Apr 2025AY 2012-13
For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 129Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 147Section 148Section 153ASection 2(22)(e)

relevant part of the decision along with head notes is reproduced as under- "II. Section 147 of the Income-tax Act, 1961-Income escaping assessment -Non disclosure of primary facts Assessment year 2003-04 - Where during original assessment proceedings, assessee did not disclose that it was holding more than ... cannot be treated to be an order of assessment -Held, yes Section 147, read with section 143, of the Income-tax Act, 1961 Income escaping assessment Non-disclosure of primary facts Assessee filed loss return which was processed under section 143(1)- Subsequently, on basis of audit objection relating

Mark Foods, Mumbai vs. Income Tax Officer-28(2)(1), Mumbai

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

ITA 4102/MUM/2024[2015-16]Status: DisposedITAT Mumbai09 Apr 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Girish Agrawal

For Appellant: Shri Shashank Mehta, CAFor Respondent: Shri R. R. Makwana, Addl. CIT
Section 143Section 147Section 148Section 151ASection 153CSection 68

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 ... 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 Commissioner

Inderpal Singh Chhabra, Rourkela vs. ACIT, Rourkela

In the result, appeal of the assessee is allowed

ITA 450/CTK/2024[AY 2018-19]Status: DisposedITAT Cuttack08 Apr 2025

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.450/Ctk/2024 (नििाारण वर्ा / Assessment Year : 2018-2019) Inderpal Singh Chhabra Vs Acit, Circle Rourkela Prop: Essar Enterprises Daily Market, C/O Crazy Cool, Main Rd, Po/Ps : Rourkela, Dist : Sundargarh Pan No. :Ajlpc 6337 J (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri P.K.Mishra & Shri Baidyanath Behera, Advocates राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 08/04/2025 घोषणा की तारीख/Date Of Pronouncement : 08/04/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Nfac, Delhi Dated 04.09.2024 In Din & Order No.Itba/Nfac/S/250/2024-25/1068345718(1)), For The Assessment Year 2018-19. 2. Shri P.K.Mishra, Advocate Appeared On Behalf Of The Assessee. Shri Sanjay Kumar, Ld Cit Dr Represented On Behalf Of The Revenue. 3. The Assessee Is Engaged In The Transportation Of Coal & Trading In Coals. It Was Submitted By Ld Ar That The Original Return Filed By The Assessee Came To Be Processed U/S.143(3) Of The Act By The Nfac & The Assessment Came To Be Completed On 10.02.2021 Accepting The Returned Income. Ld Ar Drew Our Attention To Page 3 Of The Paper Book

For Appellant: Shri P.K.Mishra & Shri BaidyanathFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 142(1)Section 143(3)Section 206CSection 43B

this juncture." The purpose of section 148A and the issuance of notice u/s.148 is for a reopening of an assessment where there is income escaping assessment and not for the purpose of investigation of suspicion of income escaping assessment. When all data was available before the Assessing Officer, nothing stopped

Income Tax Officer 23 3 6, Piramal Chambers vs. Rahul Hariprasad Tibrewal, Mumbai

ITA 430/MUM/2025[2017-18]Status: DisposedITAT Mumbai08 Apr 2025AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

For Appellant: Shri Dharmesh ShahFor Respondent: Shri R. R. Makwana
Section 144BSection 147Section 148Section 148ASection 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

Swati Energy & Projects (P) Ltd., Mumbai vs. DCIT 14(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 310/MUM/2025[2010-11]Status: DisposedITAT Mumbai08 Apr 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Shri Pradip N. Kapasi, A/RFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 143(3)Section 148Section 151Section 234D

from the end of the relevant assessment year, the first proviso to Section 147 of the Act squarely applies, which read as under:- “Income escaping assessment. 147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year

Dharamvir Singh, Village Thamber vs. ITO Ward 1, Ambala

In the result, the impugned order and the proceedings are unsustainable in law

ITA 66/CHANDI/2024[2015-2016]Status: DisposedITAT Chandigarh07 Apr 2025AY 2015-2016

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ajay Jain, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 147Section 148Section 148ASection 149Section 151

given sanction under section 151 of income Tax act in mechanical manner without going in to material and without verifying the facts relating income escaping assessment & therefore entire proceeding is bad in law deserves to quashed. 5. That the CIT(A) has wrongly upheld addition of Rs. 1079994 on account ... given sanction under section 151 of income Tax act in mechanical manner without going in to material and without verifying the facts relating income escaping assessment & therefore entire proceeding is bad in law deserves to quashed. 4. The learned DR opposed the admission of additional grounds, arguing that they were

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 17/PUN/2024[2018-19]Status: DisposedITAT Pune07 Apr 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

taxmann.com 211 (Bombay), it is observed and decision delivered by Hon'ble Judges- Section 147 of the Income-tax Act, 1961-Income escaping assessment - Non-disclosure of primary facts - Change of M/s. Accord Mediplus Pvt. Ltd. opinion - Assessment year 2006-07-Whether, even in absence of assessee's, failure

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 15/PUN/2024[2016-17]Status: DisposedITAT Pune07 Apr 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

taxmann.com 211 (Bombay), it is observed and decision delivered by Hon'ble Judges- Section 147 of the Income-tax Act, 1961-Income escaping assessment - Non-disclosure of primary facts - Change of M/s. Accord Mediplus Pvt. Ltd. opinion - Assessment year 2006-07-Whether, even in absence of assessee's, failure

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 14/PUN/2024[2015-16]Status: DisposedITAT Pune07 Apr 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

taxmann.com 211 (Bombay), it is observed and decision delivered by Hon'ble Judges- Section 147 of the Income-tax Act, 1961-Income escaping assessment - Non-disclosure of primary facts - Change of M/s. Accord Mediplus Pvt. Ltd. opinion - Assessment year 2006-07-Whether, even in absence of assessee's, failure

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 13/PUN/2024[2014-15]Status: DisposedITAT Pune07 Apr 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

taxmann.com 211 (Bombay), it is observed and decision delivered by Hon'ble Judges- Section 147 of the Income-tax Act, 1961-Income escaping assessment - Non-disclosure of primary facts - Change of M/s. Accord Mediplus Pvt. Ltd. opinion - Assessment year 2006-07-Whether, even in absence of assessee's, failure

Dalpat Baraiya, Ahmedabad vs. The Income Tax Officer, Ward-3(3)(1), Ahmedabad

In the result, the appeal filed by the Assessee is hereby allowed

ITA 1692/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad03 Apr 2025AY 2016-17

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 147Section 148Section 148ASection 151Section 54B

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 PART E the prior approval