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“regular assessment”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(40) / Section 143(3) / Section 1442,899 judgments

The decision most relied on for regular assessment is CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd. (374 ITR 645), cited in 1,823 judgments on BharatTax.

Leading authorities on regular assessment

CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd.
374 ITR 645 · 2015 · High Court
1,823
citing judgments

In Section 153A proceedings, the scope of assessment extends to abated proceedings, enabling an assessee to raise fresh legal claims that could have been made in regular assessment proceedings.

Lalchand Bhagat Ambica Ram v. CIT
37 ITR 288 · 1959 · Supreme Court
570
citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

Canara Housing Development Co. v. DCIT
49 Taxmann.com 98 · 2014 · High Court
283
citing judgments

Proceedings under Section 153A of the Income Tax Act are not confined solely to incriminating material found during a search, and the Assessing Officer can assess total income for the relevant years.

DCIT v. Sunil Kumar Sharma
159 Taxmann.com 179 · 2024 · High Court
269
citing judgments

Loose sheets of paper containing jottings, not shown to be part of regularly maintained books of accounts, do not constitute incriminating material for initiating assessment under section 153C. The satisfaction note required for 153C proceedings must specify the assessment year to which the alleged incriminating material belongs.

CIT v. British Paints India Ltd.
188 ITR 44 · 1991 · Supreme Court
204
citing judgments

The Assessing Officer has a duty to examine whether an assessee's books of account truly disclose the correct income and is not bound to accept the accounting system regularly employed by the assessee or methods followed in earlier years. Each assessment year is a distinct and self-contained unit for tax purposes.

CIT v. Lavanya Land (P) Ltd.
83 Taxmann.com 161 · 2017 · High Court
172
citing judgments

In a search assessment under Section 153A or 153C, additions cannot be sustained if the material or transactions relied upon do not relate or pertain to the assessee. Regular books of accounts not unearthed during search do not constitute incriminating material to justify additions.

All Cargo Global Logistics Ltd. v. Deputy Commissioner of Income-tax
23 Taxmann.com 103 · 2012 · High Court
162
citing judgments

Additions cannot be made under Section 153A for assessment years where original assessments have become final, unless incriminating material relevant to those years is unearthed during the search operation under Section 132.

CIT v. Gurubachhan Singh J. Juneja
302 ITR 63 · 2008 · High Court
147
citing judgments

When unaccounted receipts or suppressed sales are detected and books of account are rejected under Section 145(3), additions to income must be restricted to the profit element embedded in such transactions, not the entire transaction value. This profit element is to be estimated by considering the assessee's regular profit ratio as per books of account.

Judgments citing regular assessment

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle 2(4), Hyderabad

ITA 1300/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

ITA 973/HYD/2024[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

ITA 972/HYD/2024[2019-20]Status: DisposedITAT Hyderabad18 Feb 2026AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO

Dinesh Chand Jain, Kanpur vs. Dy. Commissioner of Income Tax, Central Circle-1, Kanpur

In the result, the appeal of the assessee is allowed

ITA 692/LKW/2025[2012-13]Status: DisposedITAT Lucknow17 Feb 2026AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2012-13 Dinesh Chand Jain, Vs. Dy. Cit, 7/189, Swaroop Nagar, Kanpur- Central Circle-1, Kanpur 280002, U.P. Pan: Adbpj2732Q (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.R.N. Shukla, Add Cit Dr Date Of Hearing: 04.12.2025 Date Of Pronouncement: 17.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Ao Under Section 143(3) R.W.S. 154 Of The Income Tax Act, 1961 On 28.04.2016. The Grounds Of Appeal Are As Under:- “1.1 Because The Id. "Cit(A)" Has Erred In Law & On Facts In Upholding The Action Of The Assessing Officer In Withdrawing The Refund Of Interest Amounting To Rs. 8,20,163/-, Paid To The Assessee U/S 244A Of The Income-Tax Act, 1961 On Excess Amount Of Self-Assessment Tax Paid U/S 140A Of The Act. 1.2 Because The View Taken By Id. "Cit(A)" While Upholding The Action Of The Assessing Officer Is Based On Misinterpretation Of The Provisions Of Clause (B) Of Sub-Section (1) Of Section 244A Of The Act, As Applicable At The Relevant Point Of Time. 2. Because, In Any Case & Without Prejudice To The Grounds Hereinfore, While Upholding The Action Of The Assessing Officer In Withdrawing The Interest Paid To The Assessee U/S 244A Of The Act, The Ld. "Cit(A)" Failed To Appreciate That The Issue Of Payment Of Interest On Excess Amount Paid U/S 140A Was Debatable In Nature & It Could Not Have Been Decided By Invoking The Provisions Of Section 154 Of The Act As The Same Did Not Constitute A Mistake Apparent From The Record.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.R.N. Shukla, Add CIT DR
Section 140ASection 143(3)Section 154Section 240Section 244Section 244ASection 244A(1)(a)Section 244A(1)(b)

simple interest. It held that such cases would fall under the residuary clause (b) of section 244A. It therefore, held that tax paid on regular assessment was also eligible for interest under section 244A. Furthermore, it had relied upon the decision of Union of India vs. Tata Chemicals ... clarify that interest was not allowable on tax paid under section 140A, unless it results in an excess after regular assessment. Thus, the excess interest allowed earlier under section 244A on self-assessment tax paid under section 140A was contrary to the law and its withdrawal through rectification under section

Labh Combines Pvt. Ltd., Kolkata vs. DCIT, Circle 7(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2382/KOL/2025[2017-2018]Status: DisposedITAT Kolkata17 Feb 2026AY 2017-2018

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 132Section 132(4)Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)Section 250Section 68

point of time. The material facts regarding accommodation entry involve in the information was not disclosed by the Assessee company during the course of regular assessment. 6. In view of the above, provisions of clause (b) of explanation 2 to section 147 are applicable to facts of this case

Small Industries Development Bank of India, Mumbai vs. Circle 3(3)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 2763/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Feb 2026AY 2020-21

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Arun Kanti Datta, CIT DR
Section 143(3)Section 263

09/03/22. the L.d. AO passed assessment order u/s 143(3). Therefore, the L.d. AO had applied his mind during the course of the regular assessment and as a result the assessment order passed by the Ld. AO is not erroneous and prejudicial to the interest of the revenue. We further ... head "Recoveries out of Bad Debts" and thus the proposal to initiate revisionary proceeding u/s 263 be dropped. Thus, the assesse during the regular assessment submitted all the documents and letters explaining all the 3 points which have been duly considered by the assessing office and therefore the order

Shri Hanuman Credit Souharda Sahakari Sangh Ltd, Belagavi vs. Income Tax Officer, Ward - 1, Nippani

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 235/PAN/2025[2017-18]Status: DisposedITAT Panaji16 Feb 2026AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80P(2)(a)

more precise, the solitary substantial issue between the parties is regarding correctness of learned PCIT’s revision directions terming the Assessing Officer’s corresponding regular assessments framed hereinabove as erroneous ones causing prejudice to interest of the Revenue for having treated this taxpayer as a “cooperative society” registered u/sec.2 ... accept the assessee’s contentions challenging correctness of the learned PCIT’s revision directions in all these assessment years. The Assessing Officer’s corresponding regular assessments stand restored as a necessary corollary. Ordered accordingly. 4. These assessees’ seven appeals are allowed in above terms. A copy of this common order

Hemant Dahyalal Bhatt, Mumbai vs. DCIT, Central Circle 6(2), Mumbai

In the result, appeals of the assessee for assessment years 2012–13 to 2016–17 are allowed, and appeals for assessment years 2017–18 and 2018–19 are allowed for statistical purposes

ITA 7913/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Feb 2026AY 2018-19

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

Section 10(14)Section 10(14)(ii)Section 144Section 153ASection 24

have been made solely on the basis of examination of return of income, financial statements, and other documents which were already part of the regular assessment record, and which had attained finality long prior to the search action. 7. The legal position governing the scope of additions in unabated assessments

Hemant Dahyalal Bhatt, Mumbai vs. DCIT, Central Circle 6(2), Mumbai

In the result, appeals of the assessee for assessment years 2012–13 to 2016–17 are allowed, and appeals for assessment years 2017–18 and 2018–19 are allowed for statistical purposes

ITA 7912/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Feb 2026AY 2017-18

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

Section 10(14)Section 10(14)(ii)Section 144Section 153ASection 24

have been made solely on the basis of examination of return of income, financial statements, and other documents which were already part of the regular assessment record, and which had attained finality long prior to the search action. 7. The legal position governing the scope of additions in unabated assessments

Hemant Dahyalal Bhatt, Mumbai vs. DCIT, Central Circle 6(2), Mumbai

In the result, appeals of the assessee for assessment years 2012–13 to 2016–17 are allowed, and appeals for assessment years 2017–18 and 2018–19 are allowed for statistical purposes

ITA 7911/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

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

Section 10(14)Section 10(14)(ii)Section 144Section 153ASection 24

have been made solely on the basis of examination of return of income, financial statements, and other documents which were already part of the regular assessment record, and which had attained finality long prior to the search action. 7. The legal position governing the scope of additions in unabated assessments

Hemant Dahyalal Bhatt, Mumbai vs. DCIT, Central Circle 6(2), Mumbai

In the result, appeals of the assessee for assessment years 2012–13 to 2016–17 are allowed, and appeals for assessment years 2017–18 and 2018–19 are allowed for statistical purposes

ITA 7910/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Feb 2026AY 2015-16

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

Section 10(14)Section 10(14)(ii)Section 144Section 153ASection 24

have been made solely on the basis of examination of return of income, financial statements, and other documents which were already part of the regular assessment record, and which had attained finality long prior to the search action. 7. The legal position governing the scope of additions in unabated assessments

Hemant Dahyalal Bhatt, Mumbai vs. DCIT, Central Circle 6(2), Mumbai

In the result, appeals of the assessee for assessment years 2012–13 to 2016–17 are allowed, and appeals for assessment years 2017–18 and 2018–19 are allowed for statistical purposes

ITA 7909/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Feb 2026AY 2014-15

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

Section 10(14)Section 10(14)(ii)Section 144Section 153ASection 24

have been made solely on the basis of examination of return of income, financial statements, and other documents which were already part of the regular assessment record, and which had attained finality long prior to the search action. 7. The legal position governing the scope of additions in unabated assessments

Hemant Dahyalal Bhatt, Mumbai vs. DCIT, Central Circle 6(2), Mumbai

In the result, appeals of the assessee for assessment years 2012–13 to 2016–17 are allowed, and appeals for assessment years 2017–18 and 2018–19 are allowed for statistical purposes

ITA 7908/MUM/2025[2013-14]Status: DisposedITAT Mumbai12 Feb 2026AY 2013-14

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

Section 10(14)Section 10(14)(ii)Section 144Section 153ASection 24

have been made solely on the basis of examination of return of income, financial statements, and other documents which were already part of the regular assessment record, and which had attained finality long prior to the search action. 7. The legal position governing the scope of additions in unabated assessments

Hemant Dahyalal Bhatt, Mumbai vs. DCIT, Central Circle 6(2), Mumbai

In the result, appeals of the assessee for assessment years 2012–13 to 2016–17 are allowed, and appeals for assessment years 2017–18 and 2018–19 are allowed for statistical purposes

ITA 7907/MUM/2025[2012-13]Status: DisposedITAT Mumbai12 Feb 2026AY 2012-13

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

Section 10(14)Section 10(14)(ii)Section 144Section 153ASection 24

have been made solely on the basis of examination of return of income, financial statements, and other documents which were already part of the regular assessment record, and which had attained finality long prior to the search action. 7. The legal position governing the scope of additions in unabated assessments

Shri Suchha Singh Through L/R Ranjit Singh, Kaputhalla vs. Principal Commissioner of Income Tax -1, Jalandhar

ITA 36/ASR/2021[2011-12]Status: HeardITAT Amritsar11 Feb 2026AY 2011-12

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm

For Appellant: Sh. Sandeep Vijh (CA) – Ld. ARFor Respondent: Sh. Farhat Khan (Ld. CIT) - DR
Section 133(6)Section 142(1)Section 143(3)Section 148Section 263

supporting the assessment order and made out a case of one of the possible views as taken by Ld. AO during the course of regular assessment proceedings. The Ld. AR contended that sufficient explanations and documents were already furnished by the assessee during the course of regular assessment proceedings

Kesireddy Ravinder Reddy, Hyderabad vs. ITO Ward-11(1), Hyderabad

ITA 1617/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.1617 & 1722/Hyd/2025

For Appellant: Sri Mohd Afzal, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(1)Section 269SSection 271DSection 274Section 275

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO

Mall Hotel Limited, Delhi vs. DCIT Circle 16(1), Delhi

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

ITA 5060/DEL/2025[2009-10]Status: DisposedITAT Delhi11 Feb 2026AY 2009-10

Bench: Shri C.N. Prasadassessment Year 2009-10 Mall Hotel Limited Vs. Dcit D-893, New Friends Colony, Circle -16 (1) Sujan Mohindra Road, Delhi Delhi Pan No.Aadcm3128R Appellant Respondent Appellant Sh. Anand Kumar Pandey, Advocate Sh. Archit Pandey, Advocate Respondent Sh. Manoj Kumar, Sr. Dr

Section 143(3)

assessment proceedings for the A.Y.2018-19 in the draft assessment order dated 12.04.2021 and the contention of the assessee was accepted while passing the regular assessment order u/s. 143(3) of the Act dated 17.04.2021 which are placed at pages 25 to 35 of the paper book. 4. The Ld. Counsel

Faizan Ahmad, Dehradun vs. Pr.CIT, Dehradun

Appeal is allowed

ITA 821/DEL/2021[2015-16]Status: DisposedITAT Delhi11 Feb 2026AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandraita No. 821/Del/2021 : Asstt. Year: 2015-16 Faizan Ahmad, Vs Pcit, Verendra Kalra & Co., Cas, Dehradun-248001 75/7, Rajpur Road, Dehradun-248001 (Appellant) (Respondent) Pan No. Acbpa6844R Assessee By : Ms. Ruchika Rana, Adv. Revenue By : Ms. Monika Singh, Cit-Dr Date Of Hearing: 11.02.2026 Date Of Pronouncement: 11.02.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2015-16 Arises Against The Pcit, Dehradun’S Din & Order No. Itba/Rev/F/Rev5/2020-21/1031618340(1) Dated 19.03.2021, In Proceedings U/S 263 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Ms. Ruchika Rana, AdvFor Respondent: Ms. Monika Singh, CIT-DR
Section 263

during the course of hearing that the assessee/appellant is aggrieved against the learned PCIT’s section 263 revision directions holding the Assessing Officer’s regular assessment framed on 15.11.2017; as an erroneous 2 Faizan Ahmad one, since having not carried out the necessary detailed enquiries regarding land advance(s) received ... considered view in this factual backdrop that once the Assessing Officer could not have travelled beyond the scope of limited scrutiny, his regular assessment framed on 15.11.2017 could neither be termed as an an erroneous one nor that causing prejudice to the interest of the Revenue going by PCIT

Hasmukh Ugarchand Gadhecha, HUF, Ahmedabad vs. The ITO, Ward-5(2)(2), Ahmedabad

The appeal of the assessee stands allowed

ITA 591/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.591/Ahd/2025 िनधा"रण वष" /Assessment Year : 2013-14 Hasmukh Ugarchand The Ito बनाम/ Gadhecha, Huf Ward-5(2)(2) V/S. 3Rd Floor, Anjalee House Ahmedabad – 380 015 Cg Road Navrangpura Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aaahg 7194 K (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Hargovind Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/11/2025 घोषणा की तारीख /Date Of Pronouncement: 09/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 26/12/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2013-2014. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Hasmukh Ugarchand Gadhecha, Huf Vs. Ito Asstt.Year : 2013-14 2 “1. That The Ld.Cit(A) Erred In Law & In The Facts Of The Case In Confirming The Order Of The Ao In Reopening Assessment U/S.147 Of The Act.

For Appellant: Shri Deepak R. Shah, ARFor Respondent: Shri Hargovind Singh, Sr.DR
Section 10(38)Section 143(3)Section 147Section 148Section 153CSection 250Section 68Section 69C

evident from the above discussion that in this case the issues under consideration were never examined by the AQ during the course of regular assessment, In this case, return of Income has been filed for the year under consideration, however, no assessment was made Hasmukh Ugarchand Gadhecha ... income of ₹3,37,840 and claiming exempt Long Term Capital Gain (LTCG) on Sawaca Business Machines Ltd. This return was scrutinized, and a regular assessment order was passed under section 143(3) on 30.07.2015 assessing the income of the assessee at Rs. 348147/-. 8.2. Under the first proviso

Amiben Rajeshkumar Punatar, Rajkot vs. ITO, Ward-1(2)(1), 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

whisper in the reasons recorded, of any tangible material which came to the possession of the assessing officer subsequent to the completion of regular assessment under section 143(3) of the Act. The assessee has disclosed the long- term capital gain (LTCG) on the impugned shares in its return ... after four years. Besides, there is no failure on the part of the assessee to disclose fully and truly all material facts during the regular assessment under section 143(3) of the Act. It reflects an arbitrary exercise of the power conferred under section 147 of the Act, therefore, reassessment