true and full disclosure — 198 judgments | BharatTax

E2E SUPPLY CHAIN SOLUTIONS LIMITED,CHENNAI vs. ACIT, CORPORATE CIRCLE 1(1), CHENNAI

In the result, the appeal for AY 2008-09 is treated as allowed for statistical purposes in terms of above order

ITA 3101/CHNY/2025[2013-14]Status: DisposedITAT Chennai09 Mar 2026AY 2013-14

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos. 3100 & 3101/Chny/2025 "नधा"रण वष"/Assessment Years: 2008-09 & 2013-14 M/S. E2E Supply Chain V. Assistant Commissioner Solutions Limited, Of Income Tax, 4Th Floor, East Coast Centre, Corporate Circle -1(1), 534, Anna Salai, Teynampet, Chennai. Chennai – 600 018. [Pan: Aabce 7932 P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. S. Dwarakesh, C.A. ""यथ" क" ओर से /Revenue By : Ms. R. Anitha, Addl. Cit सुनवाईक"तार"ख/Date Of Hearing : 02.03.2026 घोषणाक"तार"ख /Date Of : 09.03.2026 Pronouncement आदेश / O R D E R Per Manu Kumar Giri, Jm:

For Appellant: Mr. S. Dwarakesh, C.AFor Respondent: Ms. R. Anitha, Addl. CIT

Learned CIT(A) ought to have quashed the underlying reassessment proceedings, as the Appellant had made a true and full disclosure of all material facts during the course of the first reassessment proceedings, rendering the subsequent reassessment bad in law. ITA Nos.3100 & 3101/Chny/2025 (AYs: 2008-09 & 2013-14) E2E Supply

E2E SUPPLY CHAIN SOLUTIONS LIMITED,CHENNAI vs. ACIT, CORPORATE CIRCLE 1(1), CHENNAI

In the result, the appeal for AY 2008-09 is treated as allowed for statistical purposes in terms of above order

ITA 3100/CHNY/2025[2008-09]Status: DisposedITAT Chennai09 Mar 2026AY 2008-09

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos. 3100 & 3101/Chny/2025 "नधा"रण वष"/Assessment Years: 2008-09 & 2013-14 M/S. E2E Supply Chain V. Assistant Commissioner Solutions Limited, Of Income Tax, 4Th Floor, East Coast Centre, Corporate Circle -1(1), 534, Anna Salai, Teynampet, Chennai. Chennai – 600 018. [Pan: Aabce 7932 P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. S. Dwarakesh, C.A. ""यथ" क" ओर से /Revenue By : Ms. R. Anitha, Addl. Cit सुनवाईक"तार"ख/Date Of Hearing : 02.03.2026 घोषणाक"तार"ख /Date Of : 09.03.2026 Pronouncement आदेश / O R D E R Per Manu Kumar Giri, Jm:

For Appellant: Mr. S. Dwarakesh, C.AFor Respondent: Ms. R. Anitha, Addl. CIT

Learned CIT(A) ought to have quashed the underlying reassessment proceedings, as the Appellant had made a true and full disclosure of all material facts during the course of the first reassessment proceedings, rendering the subsequent reassessment bad in law. ITA Nos.3100 & 3101/Chny/2025 (AYs: 2008-09 & 2013-14) E2E Supply

REKHABEN SHARADKUMAR MEHTA,MUMBAI vs. WARD 42(1)(4), MUMBAI

In the result, Grounds No

ITA 8318/MUM/2025[2012-13]Status: DisposedITAT Mumbai05 Mar 2026AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Bijayananda Prusethrekhaben Sharadkumar Vs Ito Ward 42(1)(4) Mehta Room No.733, Kautilya Bhawan, 211 Tiwari Bhawan, S Modi Bkc, Mumbai 400051 Road, Kandivali West, Mumbai-400067 Pan:Ahppm8680G Appellant Respondent

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Bhagirath Ramawat (SR DR)

Section 143(3)Section 147Section 151Section 250Section 69BSection 92A

Raymond Woollen Mills Ltd. (supra), we find that where income has escaped assessment due to the failure of the assessee to make a true and full disclosure of material facts, the Assessing Officer is justified in assuming jurisdiction under section 147. In the present case, considering that no return

N.A.M. EXPRESSWAY LIMITED,DELHI vs. DCIT, CIRCLE-5(1), HYDERABAD

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

ITA 2044/HYD/2025[2018-19]Status: DisposedITAT Hyderabad04 Mar 2026AY 2018-19

Bench: the due date provided for filing return of income u/s 139(1) of the Act, which attracts the provisions section 43B, however, the said amount 3

Section 139(1)Section 143(3)Section 270ASection 270A(9)Section 274Section 43B

auditor quantified the disallowance in Form No.3CD. It was the explanation of the assessee before the AO that the assessee has made true and full disclosure of facts with regard to labour cess, however, while filing the return of income, the assessee erroneously did not disallow Rs.46

GULMOHAR TOWERS PRIVATE LIMITED,KOLKATA vs. INCOME TAX OFFICER, WARD 10(2), KOLKATA

In the result, the appeal of the assessee is allowed

ITA 976/KOL/2025[2011-12]Status: DisposedITAT Kolkata10 Feb 2026AY 2011-12

Section 143(1)Section 147Section 148Section 148(2)

well settled position in law that the material/fact which could be\ndiscovered by due diligence cannot be held to be true and full disclosure under the Income Tax\nAct.\nAs such, it is held that the assessee-company's income chargeable to tax to the tune of\nRs.43 ... without any profit or\nloss on such sale of investments. In third para the Id. AO noted that\nthe assessee has not made true and full disclosure of the material\nnecessary for determination of its income chargeable to tax and\nfinally held that the income to the tune

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

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

ITA 2954/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

case for the issue of such notice. The duty which is cast upon the assessee is to make a true and full disclosure of the primary facts at the time of the original assessment. Production before the Income-tax Officer of the account books or other evidence from which material ... will not necessarily amount to disclosure contemplated by law. The duty of the assessee in any case does not extend beyond making a true and full disclosure of primary facts. Once he has done that his duty ends. It is for the Income-tax Officer to draw the correct inference

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

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

ITA 2953/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

case for the issue of such notice. The duty which is cast upon the assessee is to make a true and full disclosure of the primary facts at the time of the original assessment. Production before the Income-tax Officer of the account books or other evidence from which material ... will not necessarily amount to disclosure contemplated by law. The duty of the assessee in any case does not extend beyond making a true and full disclosure of primary facts. Once he has done that his duty ends. It is for the Income-tax Officer to draw the correct inference

SHREE KRISHNA GYANODAYA FLOUR MILLS PVT. LTD.,,KOLKATA vs. ACIT, CENTRAL CIRCLE 4(3),, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2179/KOL/2025[2011-2012]Status: DisposedITAT Kolkata31 Dec 2025AY 2011-2012

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Shree Krishna Gyanodaya Acit, Central Circle 4(3) Flour Mills Pvt. Ltd. Aaykar Bhawan Poorva 15Th Floor, 46C, Chowringhee 110, Kolkata-700107, Vs. Road, Everest House, Kolkata- West Bengal 700071, West Bengal (Appellant) (Respondent) Pan No. Aahcs8774P Assessee By : Shri S.K. Tulsiyan, Ar Revenue By : Shri Sanat Kumar Raha, Dr Date Of Hearing: 01.12.2025 Date Of Pronouncement: 31.12.2025

For Appellant: Shri S.K. Tulsiyan, ARFor Respondent: Shri Sanat Kumar Raha, DR

Section 139(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 151(1)Section 153ASection 68

details of escapement of income-the AO will draw nexus between the findings and reason to believe. g. Findings of the AO on true and full disclosure of the material facts necessary for assessment under proviso to section 147 of the Act:- The Ld. AO is required to give details

RATORI MAA TRADING P.LTD,DELHI vs. ITO, WARD-21(1), NEW DELHI

In the result, the appeal is dismissed

ITA 4485/DEL/2019[2010-11]Status: DisposedITAT Delhi29 Dec 2025AY 2010-11

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandraratori Maa Trading P. Ltd. Vs Ito M-98, 2Nd Floor, Jagat Ward -21(1) Rampark, Laxmi Nagar, New C. R. Building, New Delhi Delhipan: Aaecr0612A Appellant Respondent Assessee By None Revenue By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 18/12/2025 Date Of Pronouncement 29/12/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-7, New Delhi Dated

Section 143(3)Section 147Section 148Section 151

provided to it and represents the undeclared income. The Assessing Officer has referred to the subsequent information and adverted to the concept of true and full disclosure of facts It is alre neticeable that there was specific information received from the office of the DIT (INV-V) as regards

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

authority what inferences, whether of fact or law, should be drawn. Case of AO and rebuttal thereto The findings of the AO on true and full disclosure of material facts are set out in para 8 of reasons, which is reproduced hereunder. 8. Findings of the AD on true

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

authority what inferences, whether of fact or law, should be drawn. Case of AO and rebuttal thereto The findings of the AO on true and full disclosure of material facts are set out in para 8 of reasons, which is reproduced hereunder. 8. Findings of the AD on true

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

authority what inferences, whether of fact or law, should be drawn. Case of AO and rebuttal thereto The findings of the AO on true and full disclosure of material facts are set out in para 8 of reasons, which is reproduced hereunder. 8. Findings of the AD on true

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

authority what inferences, whether of fact or law, should be drawn. Case of AO and rebuttal thereto The findings of the AO on true and full disclosure of material facts are set out in para 8 of reasons, which is reproduced hereunder. 8. Findings of the AD on true

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

authority what inferences, whether of fact or law, should be drawn. Case of AO and rebuttal thereto The findings of the AO on true and full disclosure of material facts are set out in para 8 of reasons, which is reproduced hereunder. 8. Findings of the AD on true