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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

Asst.Commissioner of Income Tax, Bandra Kurla Complex Mumbai vs. Devang Ajit Javeri, Mumbai

In the result, appeal of the Revenue is dismissed on aforesaid terms

ITA 4498/MUM/2024[2016-17]Status: DisposedITAT Mumbai29 Jan 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 147Section 153CSection 269Section 269SSection 271DSection 271ESection 275Section 275(1)Section 275(1)(c)

regime is applicable and the prior approval must be obtained from the appropriate authority specified u/s.151 of the new regime if the alleged income escaping assessment is more than Rs.50,00,000/-. 16. In para 75, the Hon'ble Apex Court has specifically held that in terms of Ashish Aggarwal ... after 01/04/2021, the prior approval must be obtained from the appropriate authorities specified u/s 151 of the new regime and where the alleged income escaping assessment is more than Rs 50 lakhs for an assessment year after lapse of 3 years then a reassessment notice could only be issued after

Asst. Commissioner of Income Tax, Bandra Kurla Complex vs. Devang Ajit Jhaveri, Mumbai

In the result, appeal of the Revenue is dismissed on

ITA 4497/MUM/2024[2013-14]Status: DisposedITAT Mumbai29 Jan 2025AY 2013-14
Section 143(3)Section 147Section 153CSection 269SSection 271DSection 271ESection 275Section 275(1)Section 275(1)(c)

regime is applicable and the prior approval must be obtained from the appropriate authority specified u/s.151 of the new regime if the alleged income escaping assessment is more than Rs.50,00,000/-. 16. In para 75, the Hon'ble Apex Court has specifically held that in terms of Ashish Aggarwal ... after 01/04/2021, the prior approval must be obtained from the appropriate authorities specified u/s 151 of the new regime and where the alleged income escaping assessment is more than Rs 50 lakhs for an assessment year after lapse of 3 years then a reassessment notice could only be issued after

Devang Ajit Jhaveri, Mumbai vs. JCIT, Range 17(1), Mumbai

In the result, appeal of the Revenue is dismissed on aforesaid terms

ITA 3510/MUM/2024[2011-12]Status: DisposedITAT Mumbai29 Jan 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 147Section 153CSection 269Section 269SSection 271DSection 271ESection 275Section 275(1)Section 275(1)(c)

regime is applicable and the prior approval must be obtained from the appropriate authority specified u/s.151 of the new regime if the alleged income escaping assessment is more than Rs.50,00,000/-. 16. In para 75, the Hon'ble Apex Court has specifically held that in terms of Ashish Aggarwal ... after 01/04/2021, the prior approval must be obtained from the appropriate authorities specified u/s 151 of the new regime and where the alleged income escaping assessment is more than Rs 50 lakhs for an assessment year after lapse of 3 years then a reassessment notice could only be issued after

Devang Ajit Jhaveri, Mumbai vs. JCIT, Range 17(1), Mumbai

In the result, appeal of the Revenue is dismissed on

ITA 3509/MUM/2024[2011-12]Status: DisposedITAT Mumbai29 Jan 2025AY 2011-12
Section 143(3)Section 147Section 153CSection 269Section 269SSection 271DSection 271ESection 275Section 275(1)Section 275(1)(c)

regime is applicable and the prior approval must be obtained from the appropriate authority specified u/s.151 of the new regime if the alleged income escaping assessment is more than Rs.50,00,000/-. 16. In para 75, the Hon'ble Apex Court has specifically held that in terms of Ashish Aggarwal ... after 01/04/2021, the prior approval must be obtained from the appropriate authorities specified u/s 151 of the new regime and where the alleged income escaping assessment is more than Rs 50 lakhs for an assessment year after lapse of 3 years then a reassessment notice could only be issued after

Shiv Vegpro Private Limited, Kota vs. PCIT-Udaipur, Udaipur

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

ITA 1014/JPR/2024[2017-18]Status: DisposedITAT Jaipur28 Jan 2025AY 2017-18
For Appellant: Shri Mahendra Gargieya, (Adv.) &For Respondent: Mrs. Alka Gautam, (CIT-DR)
Section 147Section 263Section 36(1)(iii)Section 36(1)(va)Section 43B

assessment and not from date on which order of reassessment has been passed - Held, yes Section 147 of the Income-tax Act, 1961 - Income escaping assessment - General - Whether where assessment is sought to be reopened only on one or more specific grounds and reassessment is confined to one or more ... deal with orders of assessment passed by the primary authority. While Section 147 confers power on the Assessing Authority itself to proceed against income escaping assessment, Section 154 of the Act empowers such authority to correct a mistake apparent on the face of the record. The power of appeal

H Venkatesh Reddy, Bengaluru vs. Income Tax Officer, Ward-4(3)(2), Bengaluru

In the result, the appeal of the assessee is hereby allowed

ITA 1669/BANG/2024[2015-16]Status: DisposedITAT Bangalore28 Jan 2025AY 2015-16

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

For Appellant: Shri Abhilash, AdvocateFor Respondent: Shri V Parithivel, JCIT (DR)
Section 139Section 142(1)Section 147Section 148Section 271(1)Section 271(1)(c)Section 274

failed to do so. The return of income was filed only after the issuance of a notice for income escaping assessment under section 148 of the Act. The return filed in response to Section 148 was accepted without any variation, addition, or disallowance. However, the lower authority levied a penalty

Asia Society India Centre, Mumbai vs. Income Tax Officer, (Exemption)-1(1), Mumbai

ITA 3921/MUM/2024[2012-13]Status: DisposedITAT Mumbai22 Jan 2025AY 2012-13

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ram Krishn Kedia
Section 11(1)Section 11(2)Section 11(3)Section 12ASection 143(3)Section 25Section 250

income of the past year of the petitioner as income of the assessment year 2001-02, there can be no question of any income escaping assessment in the past assessment years i.e. the assessment years 1998-99 to 2000-01. It follows that the assessing officer cannot entertain any reason

Tej Singh Sinsinwar, Jaipur vs. ITO Ward 1(2), Alwar

In the result, appeal of the assessee is allowed

ITA 1100/JPR/2024[2011-12]Status: DisposedITAT Jaipur21 Jan 2025AY 2011-12
For Appellant: Shri Vinod Kumar Gupta, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250

doubt on the correctness of this proposition but then, as we have elaborately explained earlier in this order, the material must indicate income escaping assessment rather than desirability of further probe in the matter which may or may not lead to income escaping the assessment. On the basis of reasons ... recorded in this case, such an inference about income escaping assessment, in our humble understanding, cannot be drawn" The Hon'ble Allahabad High Court in the case of Ganga Prasad Maheshwari 139 ITR 1043 dissected the phrase and made some noteworthy observations. It noted that Reason - means cause or justification

Mack Star Marketing Private Limited, Mumbai vs. Deputy Commissioner of Income Tax 2(2)(1), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 4994/MUM/2024[2013-14]Status: DisposedITAT Mumbai21 Jan 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mr. Yash VarmaniFor Respondent: Mr. R.R. Makwana, Sr. DR
Section 144BSection 147

counsel for the assessee in the written submission filed before us. 2.1 Subsequently, the Assessing Officer recorded reasons to believe that income escaped assessment and accordingly issued notice u/s 148 of the Act on 27.03.2018. In the reasons recorded, the Assessing Officer noted that on the building maintenance charges ... reference to the proviso to Section 147 applicable during the relevant period. For ready reference, the said proviso is reproduced as under: "147. Income escaping assessment.— If the Assessing Officer, for reasons to be recorded by him in writing, is of the opinion that any income chargeable

Vinod Kumar Singhal, Bangalore vs. Principal Commissioner of Income Tax-3, Bengaluru

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

ITA 1004/BANG/2024[2014-15]Status: DisposedITAT Bangalore20 Jan 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahuandshri. Soundararajan Kassessment Year : 2014-15

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Shri. D. K. Mishra, PR.CIT(DR)(ITAT), Bangalore
Section 131Section 132(4)Section 143(2)Section 147Section 263

valid return as per section 139 of the Act. 12. The section 142 is enquiry before assessment, 143 deals the assessment, 147 is income escaping assessment and 148 is issue of notice where income has escaped assessment as per the Act. In case of income escaping assessment the notice under

Railroad Logistics India Pvt. Ltd., Mumbai vs. Pr Commissioner of Income Tax-3, Mumbai

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

ITA 2564/MUM/2023[2012-2013]Status: DisposedITAT Mumbai13 Jan 2025AY 2012-2013

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Girish Agarwal, Am Railroad Logistics India Pvt. Ltd. The Principal Commissioner Of C/O Metal Trim, Gala No.1, Tankiwala Income Tax Pcit, Mumbai-3 Room No. 612, 6Th Floor, Aayakar Indl. Estate, Steel Made Compound, Marol Vs. Maroshi Road, Marol, Andheri (E) , Bhavan, Maharishi Karve Road, Mumbai – 400 059. Mumbai-400020 Pan/Gir No. Aaccr3484J (Assessee) : (Respondent) Assessee By : Shri. Satish R. Mody Respondent By : Shri. Tushar Mohite Sr. Ar Date Of Hearing : 18.10.2024 Date Of Pronouncement : 13.01.2025 O R D E R Per Kavitha Rajagopal, J M:

For Appellant: Shri. Satish R. ModyFor Respondent: Shri. Tushar Mohite Sr. AR
Section 143(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JM AND SHRI. GIRISH AGARWAL, AM Railroad

Sadbhav Engineering Ltd., Ahmedabad vs. DCIT, Central Circle 1(3), Ahmedabad

ITA 235/AHD/2021[2018-19]Status: DisposedITAT Ahmedabad10 Jan 2025AY 2018-19

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarsr. No. Appellant Respondent 1-7 It(Ss)A.No./ Asstt.Year 170 To 175 & 235/Ahd/2021 Asst. Year 2012- 13 To 2018-19 Sadbhav Engineering Ltd. Nr. Havmour Restaurant Navrangpura Ahmedbad. Dcit, Cent.Cir.1(3) Ahmedabad. 8-14 183 To 189/Ahd/2021 Asst. Year 2012- 14 To 2018-19 Pan : Aadcs 0852 Q Dcit, Cent.Cir.1(3) Ahmedabad. Sadbhav Engineering Ltd. Nr. Havmour Restaurant Navrangpura Ahmedabad. (Applicant) (Responent) Assessee By Shri Dhinal Shah, Ar Revenue By: Shri H. Phani Raju, Cit-Dr सुनवाई की तारीख /Date Of Hearing : 18/10/2024 घोषणा की तारीख / Date Of Pronouncement: 10/01/2025 आदेश/Order Per Bench: The Above Cross-Appeals Of The Assessee & The Revenue Are Against The Consolidated Order Of The Ld. Commissioner Of Income Tax(Appeals) 11, Ahmedabad All Dated 04.08.2021 Passed Under Section 250(6) Of The Income Tax Act, 1961 (“The Act" For Short) For The

For Respondent: Shri H. Phani Raju, CIT-DR
Section 115BSection 132Section 139(1)Section 143(3)Section 153ASection 250(6)Section 69ASection 80I

आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ 'A' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT

Garware Technical Fibres Limited, Pune vs. DCIT, CC-1(3), Pune

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 1703/PUN/2024[2020-21]Status: DisposedITAT Pune09 Jan 2025AY 2020-21

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: CA Ritu Kamal KishoreFor Respondent: Shri Amol Khairnar, CIT-DR And Shri Ramnath P Murkunde
Section 131Section 132Section 139Section 143(2)Section 153A

cash receipts. Since the cash expenses incurred are Rs.3225.74 lakhs as against the cash receipts of Rs.3165.75lakhs there is no question of any income escaping assessment. 3. The notings in the excel sheets and the statement recorded by Mr. Dalvi, he has stated that the expenses are towards BD "Business

Garware Technical Fibres Limited, Pune vs. DCIT, CC-1(3), Pune

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 1700/PUN/2024[2017-18]Status: DisposedITAT Pune09 Jan 2025AY 2017-18

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: CA Ritu Kamal KishoreFor Respondent: Shri Amol Khairnar, CIT-DR And Shri Ramnath P Murkunde
Section 131Section 132Section 139Section 143(2)Section 153A

cash receipts. Since the cash expenses incurred are Rs.3225.74 lakhs as against the cash receipts of Rs.3165.75lakhs there is no question of any income escaping assessment. 3. The notings in the excel sheets and the statement recorded by Mr. Dalvi, he has stated that the expenses are towards BD "Business

Garware Technical Fibres Limited, Pune vs. DCIT, CC-1(3), Pune

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 1699/PUN/2024[2016-17]Status: DisposedITAT Pune09 Jan 2025AY 2016-17

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: CA Ritu Kamal KishoreFor Respondent: Shri Amol Khairnar, CIT-DR And Shri Ramnath P Murkunde
Section 131Section 132Section 139Section 143(2)Section 153A

cash receipts. Since the cash expenses incurred are Rs.3225.74 lakhs as against the cash receipts of Rs.3165.75lakhs there is no question of any income escaping assessment. 3. The notings in the excel sheets and the statement recorded by Mr. Dalvi, he has stated that the expenses are towards BD "Business

Garware Technical Fibres Limited, Pune vs. DCIT, CC-1(3), Pune

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 1698/PUN/2024[2015-16]Status: DisposedITAT Pune09 Jan 2025AY 2015-16

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: CA Ritu Kamal KishoreFor Respondent: Shri Amol Khairnar, CIT-DR And Shri Ramnath P Murkunde
Section 131Section 132Section 139Section 143(2)Section 153A

cash receipts. Since the cash expenses incurred are Rs.3225.74 lakhs as against the cash receipts of Rs.3165.75lakhs there is no question of any income escaping assessment. 3. The notings in the excel sheets and the statement recorded by Mr. Dalvi, he has stated that the expenses are towards BD "Business

Garware Technical Fibres Limited, Pune vs. DCIT, CC-1(3), Pune

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 1697/PUN/2024[2014-15]Status: DisposedITAT Pune09 Jan 2025AY 2014-15

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: CA Ritu Kamal KishoreFor Respondent: Shri Amol Khairnar, CIT-DR And Shri Ramnath P Murkunde
Section 131Section 132Section 139Section 143(2)Section 153A

cash receipts. Since the cash expenses incurred are Rs.3225.74 lakhs as against the cash receipts of Rs.3165.75lakhs there is no question of any income escaping assessment. 3. The notings in the excel sheets and the statement recorded by Mr. Dalvi, he has stated that the expenses are towards BD "Business

Royal Sundaram General Insurance Company Ltd, Chennai vs. DCIT, Ltu, Chennai

In the result, the appeals of the assesse and Revenue are dealt

ITA 93/CHNY/2018[2014-15]Status: DisposedITAT Chennai08 Jan 2025AY 2014-15

Bench: Shri Aby T Varkey & Shri Amitabh Shuklastaal 3H Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 Frefzor Af /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15

For Appellant: Shri Vikaram Vijayaraghavan, AdvocateFor Respondent: Shri A.Sanjay for Ms V.Pushpa
Section 143(3)Section 148

there cannot be any case for reopening u/s 148. 2.6 At this stage we deem it necessary to examine the statutory provisions of Income escaping assessment postulated u/s 147 of the act reproduced herein below. “4.4147, Income escaping assessment.—if the 2[Assessing Officer]3[has reason to believe] that

Royal Sundaram General Insurance Company Ltd, Chennai vs. DCIT, Ltu, Chennai

In the result, the appeals of the assesse and Revenue are dealt as under:-

ITA 92/CHNY/2018[2013-14]Status: DisposedITAT Chennai08 Jan 2025AY 2013-14

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

For Respondent: Shri A.Sanjay for Ms V.Pushpa
Section 143(3)Section 148

there cannot be any case for reopening u/s 148. 2.6 At this stage we deem it necessary to examine the statutory provisions of Income escaping assessment postulated u/s 147 of the act reproduced herein below. “…..147. Income escaping assessment.—If the 2[Assessing Officer]3[has reason to believe] that

Royal Sundaram General Insurance Company Ltd, Chennai vs. DCIT, Ltu, Chennai

ITA 90/CHNY/2018[2011-12]Status: DisposedITAT Chennai08 Jan 2025AY 2011-12

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ष /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Insurance Company Limited, Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] Dy. Commissioner Of Income Tax, Large Tax Payer Unit, Chennai. आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ष /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, Large Tax Payer Unit, Chennai. M/S.Royal Sundaram General Insurance Company Limited, (अपीलार्थी/Appellant) Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से / Assessee By Shri Vikaram Vijayaraghavan, Advocate प्रत्यर्थी की ओर से /Revenue By Shri A.Sanjay For Ms V.Pushpa, सुनवाई की तारीख/Date Of Hearing Sr.Standing Counsel For It Dept. घोषणा की तारीख /Date Of Pronouncement 15.10.2024 08.01.2025 Per Bench: आदेश / Order The Following Appeals Have Been Raised By The Appellant Assessee & Appellant Revenue Contesting Assessment / Appellate Orders For Ays 2008-09 To Ay 2014-15. As The Grounds Of Appeal In Respective Appeals Of Assessee & Revenue Are Largely Common, All The Appeals Are Adjudicated Through This Common Orders. S. No. Appeal Nos. Ays Appellate Cit(A) Order Details Revenue A B C D E F 1

Section 143(3)Section 148

there cannot be any case for reopening u/s 148. 2.6 At this stage we deem it necessary to examine the statutory provisions of Income escaping assessment postulated u/s 147 of the act reproduced herein below. “.....147. Income escaping assessment.—If the 2[Assessing Officer]3[has reason to believe] that