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“section 144 assessment”

Assessment ProceduresSection 144Section 14411 judgments

The decision most relied on for section 144 assessment is CIT v. B.N. Bhattacharya & Another (118 ITR 461), cited in 1,656 judgments on BharatTax.

Leading authorities on section 144 assessment

CIT v. B.N. Bhattacharya & Another
118 ITR 461 · 1997 · Supreme Court
1,656
citing judgments

Appealing a tax assessment requires more than just filing the appeal; it involves actively pursuing it. The assessee must effectively engage with the appellate process.

Tin Box Company v. CIT
249 ITR 216 · 2001 · Supreme Court
624
citing judgments

When an issue is remitted to the Assessing Officer for fresh adjudication, the AO must conduct a de novo examination and provide the assessee a full opportunity of being heard. The assessee is bound to comply with the notices issued by the AO.

ACIT v. Hotel Blue Moon
321 ITR 362 · 2010 · Supreme Court
623
citing judgments

The issuance of a notice under Section 143(2) within the statutory time limit is mandatory for completing an assessment under Section 143(3), and the failure to do so renders the assessment invalid. This defect is not curable under Section 292BB of the Income Tax Act, 1961.

CIT v. Calcutta Knitwears
362 ITR 673 · 2014 · Supreme Court
528
citing judgments

The recording of a satisfaction note by the Assessing Officer is a jurisdictional prerequisite for assessments under Section 153C, and the six-year limitation period for such assessments is reckoned from the date this satisfaction is recorded.

Roshan Di Hatti v. CIT
107 ITR 938 · 1977 · Supreme Court
477
citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. S. Goyanka Lime & Chemical Ltd.
64 Taxmann.com 313 · 2015 · Supreme Court
340
citing judgments

A mechanical approval by the prescribed authority under Section 151, made without independent application of mind, vitiates and renders the entire reassessment proceedings invalid. Such approvals, often indicated by brief, unreasoned endorsements, lead to the quashing of the reopening of assessment.

Kachwala Gems v. JCIT
288 ITR 10 · 2007 · Supreme Court
332
citing judgments

In a best judgment assessment, some guesswork is inherent, but the estimate must be fair and not arbitrary. Books of account can be rejected under Section 145(3) if the assessee fails to substantiate entries or prove the genuineness of transactions, leading to estimation of income.

United Electrical Co. (P.) Ltd. v. CIT
258 ITR 317 · 2002 · High Court
309
citing judgments

Reassessment proceedings under Section 147 cannot be initiated based on general or vague information lacking a specific link to the assessee's transaction, and requires the Assessing Officer to apply an independent mind and form a 'reason to believe' based on reasonable grounds, not mere suspicion.

Judgments citing section 144 assessment

Income Tax Officer, Ward-44(1), Delhi vs. Vishap Bajaj, Delhi

In the result, the Revenue’s appeal is allowed for statistical purposes

ITA 6338/DEL/2025[2017]Status: DisposedITAT Delhi21 Jan 2026

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Bleasstt. Year : 2017-18 Income Tax Officer, Vs. Vishap Bajaj, Room No. 1804, 18Th Floor, Al-113, Shalimar Bagh, Civic Centre, Delhi – 110 088 New Delhi (Pan: Aetps4340E) (Appellant) (Respondent) Appellant By : Sh. A.K. Arora, Sr. Dr. Respondent By : None

For Appellant: Sh. A.K. Arora, Sr. DRFor Respondent: None
Section 144Section 69A

assessee responded to the show cause notice and submitted ledger, cash book and invoices, which contradicts the assumption of non-compliance underlying the section 144 assessment and AO has drawn adverse conclusions without proper verification; ignoring material evidence submitted by the assessee and relied on conjectures and unsubstantiated assumptions thus

Deputy Commissioner of Income Tax Central Circle Dehradun, Dehradun vs. Sunil Panwar, Dehradun

Appeal is dismissed

ITA 159/DDN/2025[2023-24]Status: DisposedITAT Dehradun13 Jan 2026AY 2023-24

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 159/Ddn/2025 : Asstt. Year: 2023-24 Dcit, Vs Sunil Panwar, Central Circle, B-103, Plot No. 95/96, Dopon Dehradun-248001 Palm City, Dehrakhas, Dehradun-248001 (Appellant) (Respondent) Pan No. Bbvpp7657R Assessee By : Sh. Saurabh Gupta, Adv. Revenue By : Ms. Poonam Sharma, Cit-Dr Date Of Hearing: 13.01.2026 Date Of Pronouncement: 13.01.2026 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2023-24, Arises Against The Cit(A)-3, Noida’S Din & Order No. Itba/Apl/M/250/2025-26/1076671109(1) Dated 03.06.2025, In Proceedings U/S 144 Of The Income Tax Act, 1961. 2. Heard Both The Parties At Length. Case File Perused.

For Appellant: Sh. Saurabh Gupta, AdvFor Respondent: Ms. Poonam Sharma, CIT-DR
Section 144

vide the Finance Act 2024 w.e.f. 01.10.2024. 2 Sunil Panwar And that the learned Assessing Officer had undisputedly framed his section 144 assessment on 01.02.2025 against the assessee. 4. Faced with this clinching factual position, we are of the considered view that the learned CIT(A)’s impugned remand direction

Income Tax Officer, Faridabad vs. Harbans Lal, Faridabad

Appeal is partly allowed

ITA 6402/DEL/2025[2018]Status: DisposedITAT Delhi25 Nov 2025

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Income Tax Officer, Vs. Sh. Harbans Lal, Faridabad H. No. 411/1, Parvatiya Colony, Phase-1, Faridabad, Haryana Pan: Acupl8554E (Appellant) (Respondent) Assessee By None Department By Sh. Manoj Kumar, Sr. Dr

Section 144Section 147

action adding the assessee’s bogus purchases sourced from various accommodation entry providers herein from Kolkata; totalling to Rs.45.21 lakhs in his section 144 assessment dated 14th March, 2023, without properly appreciating the relevant factual matrix. 3. I have given my thoughtful consideration to the Revenue’s and the assessee

Geet Singh, Rampur vs. ITO, Rampur

Appeal is partly allowed

ITA 3873/DEL/2025[2017-18]Status: DisposedITAT Delhi21 Aug 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Geet Singh, Saijna, Po Begmabad, Rampur Bilaspur, Rampur Pan: Femps1562A (Appellant) (Respondent) Assessee By None Department By Sh. Manoj Kumar, Sr. Dr

Section 115BSection 144Section 69A

further seeks to buttress the point that the assessee all along has nowhere filed the relevant details explaining source thereof either in section 144 assessment framed on 04.12.2019 nor in the lower appellate proceedings. 3. I have given my thoughtful consideration to the assessee’s pleadings all along and Revenue

Satish, Jind vs. Assessing Officer, Jind

Appeal is partly allowed

ITA 5619/DEL/2024[2011-12]Status: DisposedITAT Delhi22 Apr 2025AY 2011-12

Bench: Sh. Satbeer Singh Godaraita No. 5619/Del/2024 : Asstt. Year : 2011-12 Satish, Vs Income Tax Officer, House No. 680, Nirjan, Ward-1, Jind Haryana-126102 Haryana (Appellant) (Respondent) Pan No. Dfups0022C Assessee By: None Revenue By : Sh. Sanjay Kumar, Sr. Dr Date Of Hearing: 22.04.2025 Date Of Pronouncement: 22.04.2025 Order

For Appellant: NoneFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 143(3)Section 144Section 54B

emerges during the course of hearing with the valuable assistance coming from the department side that the learned Assessing Officer had framed his section 144 assessment in the assessee’s case on 05.12.2018 adding the assessee’s entire cash deposits of Rs.48,00,000/- as unexplained. And that the learned

Mahesh Kumar Verma, Delhi vs. Pr, CIT Central Knp, Meerut

Appeal is dismissed in above terms

ITA 2530/DEL/2024[2017-18]Status: DisposedITAT Delhi02 Dec 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2017-18 Sh. Mahesh Kumar Verma, Vs. Pr. Cit, 1245, 4Th Floor, Kucha Central Kanpur, Mahajani Chandni Chowk, Meerut Delhi Pan :Acapv8456B (Appellant) (Respondent) Assessee By None Department By Ms. Jaya Choudhary, Cit(Dr)

Section 144Section 148Section 153CSection 263

Central), Kanpur at Meerut herein has rightly assumed his section 263 revision jurisdiction terming the Assessing Officer’s corresponding section 153C read with section 144 assessment dated 30th December, 2021 assessing the assessee’s gross profit @ 2% of the total unaccounted purchases made in cash as an erroneous one causing

Pradeep Kumar Gandhi, Uttar Pradesh vs. Ward 1(2)(1) Meerut, Meerut

Appeal is partly allowed in above terms

ITA 2757/DEL/2024[2017-18]Status: DisposedITAT Delhi28 Nov 2024AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18

Section 144Section 69A

respective findings indicates that an addition u/s 69A as unexplained money of Rs. 12,41,500/- has been made in his hands in section 144 assessment framed on 27.12.2019 and upheld in the lower appellate discussion. The assessee’s case admittedly does not dispute the clinching fact that

Shobha.K.N, Ramanagara vs. Income Tax Officer, Ward-1, Ramanagaram

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1397/BANG/2024[2017-18]Status: DisposedITAT Bangalore02 Sept 2024AY 2017-18

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL BENGALURU “B” BENCH, BENGALURU BEFORE SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI LAXMI PRASAD SAHU (Accountant Member)

For Appellant: Sri. Raghavendra R. Chakravarthy, CAFor Respondent: Sri. Ganesh R. Ghale, Standing Counsel
Section 142(1)Section 144Section 154

rectification application under section 154 of the Income Tax Act dated 15.10.2019 asking the Assessing Officer to delete the additions made under section 144 assessment. The said rectification application of the assessee stand rejected by the Assessing Officer vide order dated 18.10.2019. Thereafter, the assessee filed an appeal before

Ashok Vishnu Wagh, Nashik vs. ITO, Ward1(4), Nashik

Appeal is allowed for statistical purposes in above terms

ITA 840/PUN/2024[2011-12]Status: DisposedITAT Pune31 Jul 2024AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Rao

For Appellant: Mr. Naimish DixitFor Respondent: Shri Ramnath P. Murkunde
Section 144Section 250Section 69A

appeal seeks to reverse both the lower authorities action making section 69A unexplained money addition of Rs.59,92,500/- in the course of section 144 assessment dated 07.12.2018; as upheld in the lower appellate discussion. 3. It transpires during the course of hearing that although the Assessing Officer had framed

Dipak Budharam Sharma, Mumbai vs. Income Tax Officer Ward 31(1)(4), Mumbai

Appeal is allowed for statistical purposes

ITA 1905/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Jul 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Omkareshwar Chidaraassessment Year: 2017-18

For Appellant: NoneFor Respondent: Ms. Dhivya Ruth J., Sr. D.R
Section 144Section 250Section 68Section 69A

similar deposits in the relevant previous year which have been assessed as business turnover @ 8%; resulting in addition of Rs.8,41,230/- in section 144 assessment dated 19.10.2019 as upheld in the lower appellate discussion. Faced with this situation, we invited the Revenue’s apt attention to the learned

Ravi Balwantrai Mehta, Mumbai vs. Assistant Commissioner of Income Tax, Circle 23(3), Mumbai

Appeal is allowed for statistical purposes in above terms

ITA 2840/MUM/2023[2017-18]Status: DisposedITAT Mumbai10 Jul 2024AY 2017-18

Bench: Shri Satbeer Singh Godara (Jm) & Shri Girish Agrawal (Am)

Section 143(3)Section 144Section 271ASection 68

respect of additions made thereon.” 3. It emerges during the course of hearing that the Assessing Officer had framed his section 144 assessment dated 29.12.2019 in assessee’s case making section 68 unexplained cash credits addition of Rs. 3,44,65,000/- representing the cash deposited during demonetizing period