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“material facts necessary for assessment”

ReassessmentSection 147Section 147564 judgments

DEPUTY COMMISSIONER OF INCOME TAX, GANDHINAGAR vs. GUJARAT STATE PETROLEUM CORPORATION LIMITED, GANDHINAGAR

ITA 1254/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

Nos.1254 & 1249/Ahd/2025 Gujarat State Petroleum Corporation Limited – A.Ys. 2014-15 & 2015-16 of the assessee in disclosing fully and truly all material facts necessary for assessment. 5.1. Jurisdictional High Court in the case of Gujarat Enviro Protection & Infrastructure Ltd. (cited supra) held as follows: “Section 80-IA, read with sections ... Fabrics (cited supra) held that when there is no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, then reopening of assessment is invalid in law by observing as follows: “… 7. Examining the facts of the present case in the light

DEPUTY COMMISSIONER OF INCOME TAX, GANDHINAGAR vs. GUJARAT STATE PETROLEUM CORPORATION LIMITED, GANDHINAGAR

ITA 1249/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

Nos.1254 & 1249/Ahd/2025 Gujarat State Petroleum Corporation Limited – A.Ys. 2014-15 & 2015-16 of the assessee in disclosing fully and truly all material facts necessary for assessment. 5.1. Jurisdictional High Court in the case of Gujarat Enviro Protection & Infrastructure Ltd. (cited supra) held as follows: “Section 80-IA, read with sections ... Fabrics (cited supra) held that when there is no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, then reopening of assessment is invalid in law by observing as follows: “… 7. Examining the facts of the present case in the light

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

ITA 1166/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

Nos.1254 & 1249/Ahd/2025 Gujarat State Petroleum Corporation Limited – A.Ys. 2014-15 & 2015-16 of the assessee in disclosing fully and truly all material facts necessary for assessment. 5.1. Jurisdictional High Court in the case of Gujarat Enviro Protection & Infrastructure Ltd. (cited supra) held as follows: “Section 80-IA, read with sections ... Fabrics (cited supra) held that when there is no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, then reopening of assessment is invalid in law by observing as follows: “… 7. Examining the facts of the present case in the light

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

ITA 1165/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

Nos.1254 & 1249/Ahd/2025 Gujarat State Petroleum Corporation Limited – A.Ys. 2014-15 & 2015-16 of the assessee in disclosing fully and truly all material facts necessary for assessment. 5.1. Jurisdictional High Court in the case of Gujarat Enviro Protection & Infrastructure Ltd. (cited supra) held as follows: “Section 80-IA, read with sections ... Fabrics (cited supra) held that when there is no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, then reopening of assessment is invalid in law by observing as follows: “… 7. Examining the facts of the present case in the light

GRANULES INDIA LIMITED,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is dismissed

ITA 1289/HYD/2025[2010-11]Status: DisposedITAT Hyderabad13 Mar 2026AY 2010-11

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआयकर अपील सं / Ita No.1289/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2010-11) Granules India Limited Vs. Dcit- Circle -2(1) 15Th Floor, Granules Tower Signature Tower, Botanical Garden Road Sy. No. 6(P) Of Kondaput Kondapur, Hyderabad – 500084 Sy. No. 37 Of Kothaguda Telangana Opp. Botanical Gardens Serilingampalluy, R.R. District Pan: Aaacg7369K Hyderabad-500084, Telangana (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

Section 10BSection 143(3)Section 148Section 154Section 271(1)(c)

relevant assessment year without any allegation as to failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. The assessee had also challenged the additions made by the A.O. towards disallowance of deduction claimed under section 10B of the Act in respect ... also devoid of merit going by the facts available on record, because the assessee has failed to disclose fully and truly all material facts necessary for assessment which is evident from the 10 Granules India Limited relevant financial statements filed by the assessee and also the assessment order passed

PIYUSH ASHOK MEHTA,MUMBAI vs. DCIT, CENTRAL CIRCLE 6(4), MUMBAI, MUMBAI

Accordingly, Ground No. 2 raised by the Assessee in the present appeal in allowed

ITA 9092/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Mar 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Ms. Deepika Arora
Section 133ASection 143(1)Section 143(3)Section 147

section 147 of the I.T.Act, there is a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment.” 3. As per the reason recorded for re-opening the assessment, a survey under Section 133A of the Act was conducted at the business ... Cartier Gems. According to the Assessing Officer there was failure on the part of Assessee to disclose fully and truly all material facts necessary for assessment. Therefore, reassessment proceedings were initiated for the Assessment Year 2009-2010 and 2010-2011. The Assessee filed objections to the reopening of the assessment

PIYUSH ASHOK MEHTA,MUMBAI vs. DCIT, CENTRAL CIRCLE 6(4), MUMBAI, MUMBAI

Accordingly, Ground No. 2 raised by the Assessee in the present appeal in allowed

ITA 9091/MUM/2025[2009-10]Status: DisposedITAT Mumbai11 Mar 2026AY 2009-10

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Ms. Deepika Arora
Section 133ASection 143(1)Section 143(3)Section 147

section 147 of the I.T.Act, there is a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment.” 3. As per the reason recorded for re-opening the assessment, a survey under Section 133A of the Act was conducted at the business ... Cartier Gems. According to the Assessing Officer there was failure on the part of Assessee to disclose fully and truly all material facts necessary for assessment. Therefore, reassessment proceedings were initiated for the Assessment Year 2009-2010 and 2010-2011. The Assessee filed objections to the reopening of the assessment

MEENA JEWELS AND PEARLS,HYDERABAD vs. ACIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1225/HYD/2024[2010-11]Status: DisposedITAT Hyderabad25 Feb 2026AY 2010-11
For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(3)Section 147Section 148

valid when there is no failure on the part of the assessee to disclose fully and truly all the relevant material facts necessary for assessment. It is pertinent to note that the claim of the assessee as purchases made from KIPL is based on the documentary evidence including the payment

ROHITKUMAR CHINUBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

ITA 1961/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

furnished as mandated by law and there was no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. It was further contended that the reopening was initiated beyond four years from the end of the relevant assessment year and, therefore

SAURABHBHAI ROHITBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

ITA 1960/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

furnished as mandated by law and there was no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. It was further contended that the reopening was initiated beyond four years from the end of the relevant assessment year and, therefore

RAVISUM CREATIVE PROMOTIONS PVT. LTD (FORMERLY KNOWN AS AGRO INVESTMENT PVT. LTD,MUMBAI vs. ACIT CEN CIR 8 (11(1), MUMBAI

In the result, appeal is allowed

ITA 1616/MUM/2022[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarravisun Creative Promotions Pvt. Ltd., Acit, Formerly Known As Ravisun Agro 6Th Floor, Aaykar Bhavan, Investments Pvt. Ltd. New Marine Lines, Vs. 305, Surat Sadan, Surat Street, Churchgate, Masjit Bunder, Mumbai - 400020 Mumbai – 400049 (Appellant) : (Respondent) Pan No. Aabcr 9224M Appellant By : Ms. Radha Halbe Respondent By : Shri Annavaran Kosuri, Sr.- Dr (Appellant) (Respondent) Date Of Hearing : 17.02.2026 Date Of Pronouncement : 20.02.2026

For Appellant: Ms. Radha HalbeFor Respondent: Shri Annavaran Kosuri, Sr.- DR
Section 143(3)Section 147Section 148Section 14ASection 43B

escaped assessment for AY.2010- 11 by reason of the failure on part of the assessee to disclose fully and truly all material facts necessary for assessment within the meaning of Ravisum Creative Promotions Pvt. Ltd. proviso to the Sec 147 of the Act. Hence, the case is required

RAMESH PURSHOTTAM MODI ,MUMBAI vs. INCOME TAX OFFICER CIRCLE 22(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 6577/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Purshottam Ito Circle 22(1) Modi Income Tax 303, Modi House, Linking Vs. Department, Road, Khar West, Piramal Chamber, Mumbai-400 052 Dr. Ss Rao Marg, Parel, Mumbai 0 400 012 Pan/Gir No. Aahpm2793F (Applicant) (Respondent) Assessee By Shri Ashwani Kumar A/W Ms. Deepali Aggarwal, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 12.02.2026 Date Of Pronouncement 19.02.2026

Section 143(3)Section 144BSection 147Section 148Section 250Section 94(7)Section 94(8)

relevant assessment year and that there was no failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. On this basis, it was contended that the assumption of jurisdiction under section 147 was bad in law. 14. The learned AR further pointed

SPICE OF LIFE HOTELS AND ESTATES PRIVATE LIMITED,MUMBAI vs. DCIT-2(3)(1), MUMBAI

ITA 7704/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

notice could have been issued only if there is a failure on part of the assessee to disclose fully and truly all material facts necessary for assessment. We say this because in the present case an assessment order was already passed on June 30, 2017 under section

SPICE OF LIFE HOTELS AND ESTATES PRIVATE LIMITED,MUMBAI vs. DCIT- 2(3)(1), MUMBAI

ITA 7703/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

notice could have been issued only if there is a failure on part of the assessee to disclose fully and truly all material facts necessary for assessment. We say this because in the present case an assessment order was already passed on June 30, 2017 under section

JADAV JEWELLERS PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-2(3), CHENNAI

The appeal of the assessee is allowed

ITA 2911/CHNY/2025[2013-14]Status: DisposedITAT Chennai16 Feb 2026AY 2013-14

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2911/Chny/2025 िनधा"रण वष" /Assessment Year: 2013-14

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 143(3)Section 144BSection 147Section 148Section 154Section 250Section 68

there was no failure on the part of the Appellant to disclose fully and truly all material facts necessary for assessment, and therefore the reopening beyond four years was bad in law and void ab initio. 4. The order of the Learned CIT(A) is contrary to law in upholding

S S I MEDIA INDIA PVT. LTD.,CHENNAI vs. ACIT, NCC-20(1), CHENNAI

The appeal of the assessee is allowed

ITA 2346/CHNY/2025[2011-12]Status: DisposedITAT Chennai13 Feb 2026AY 2011-12

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2346/Chny/2025 िनधा#रण वष# /Assessment Year: 2011-12

For Appellant: Mr. V.Balaji, C.A ()For Respondent: Mr. Saujanya Ranjan, JCIT
Section 143(3)Section 148Section 151Section 250Section 32

relevant assessment year without there being any failure on the part of the appellant to disclose fully and truly all material facts necessary for assessment. 2.3 The learned CIT(A) failed to appreciate that the issue of depreciation was already examined during the original assessment u/s 143(3), and reopening ... there cannot be a reopening without there being a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. The ld. AR drew our attention to the notice u/s. 148 of the Act (page 60 of paper book) and the reasons recorded

DCIT-2(1)(1), MUMBAI, MUMBAI vs. BANK OF BARODA , BANK OF BARODA

In the result, both the appeals filed by the Revenue and both the cross objections

ITA 4913/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri C. Naresh, ARFor Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 115JSection 143(3)Section 147Section 14ASection 244ASection 250Section 36(1)(viia)

written off has escaped assessment for A.Y.2015-16 due to reasons attributable to the assessee for failure to disclose fully and truly all material facts necessary for assessment for that year. 5. On the basis of material available on record and on perusal and careful consideration of the same, I have

DCIT-2(1)(1), MUMBAI vs. BANK OF BARODA, MUMBAI

In the result, both the appeals filed by the Revenue and both the cross objections

ITA 4869/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri C. Naresh, ARFor Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 115JSection 143(3)Section 147Section 14ASection 244ASection 250Section 36(1)(viia)

written off has escaped assessment for A.Y.2015-16 due to reasons attributable to the assessee for failure to disclose fully and truly all material facts necessary for assessment for that year. 5. On the basis of material available on record and on perusal and careful consideration of the same, I have

KULDIP SINGH,RANCHI vs. DCIT/ACIT, CIRCLE-1, RANCHI

In the result, the appeal of the assessee is allowed

ITA 180/RAN/2025[14-15]Status: DisposedITAT Ranchi10 Feb 2026

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.180/Ran/2025 Assessment Year: 2014-15 Kuldip Singh…………………….……….……...................……….……Appellant The Avenue Vishnupuri Marg, Upper Burdwan Compound, Lalpur, Ranchi- 834001. [Pan: Agjps6921P] Vs. Dcit/Acit, Circle-1, Ranchi…...…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kailash Gautam, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2026 Date Of Pronouncing The Order : February 10, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 06.03.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

that:- Whether since admittedly there was no failure on part of petitioner to make return or to disclose fully and truly all material facts necessary for assessment, proviso to new section, which bars issue of notice under section 148 after expiry of four years from end of relevant assessment year ... relevant assessment year unless there was a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. In the instant case, the relevant assessment year was 1997-98 and the Assessing Officer had issued notice for reopening under section

AMIBEN RAJESHKUMAR PUNATAR,RAJKOT vs. ITO, WARD-1(2)(1), RAJKOT, RAJKOT

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

ITA 24/RJT/2026[2015-16]Status: DisposedITAT Rajkot06 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.24/Rjt/2026 िनधा"रण वष"/Assessment Year : 2015-16 Amiben Rajeshkumar Punatar, बनाम/ Ito, Ashish, 41-New Jagnath Plot, Vs Ward – 1(2)(1), Rajkot – 360001(Gujarat) Rajkot "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahrpp4181F (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR
Section 10(38)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 250

petitioner, there is no whisper, what to speak of any allegation, that the petitioner had failed to disclose fully and truly all material facts necessary for assessment and that because of this failure there has been an escapement of income chargeable to tax. The assessee, had already disclosed

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