“reasons recorded”

ReassessmentSection 148Section 14813,127 judgments

The decision most relied on for reasons recorded is Hindustan Lever Ltd. v. R.B. Wadkar (268 ITR 332), cited in 695 judgments on BharatTax.

Leading authorities on reasons recorded

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.

T.S. Balaram ITO v. Volkart Bros.

82 ITR 50 · 1971 · Supreme Court

382

citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.

354 ITR 536 · 2013 · High Court

366

citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.

384 ITR 147 · 2016 · High Court

274

citing judgments

Reassessment proceedings are invalid if initiated based on documents already available on record without fresh tangible material, and if the sanction under section 151 is accorded mechanically, indicating non-application of mind.

M/s Sahara India (Farms) v. CIT & Anr.

300 ITR 403 · 2008 · Supreme Court

268

citing judgments

The requirement of statutory prior approval by a high-ranking authority, even if administrative, serves as an in-built protection against arbitrary exercise of power by the Assessing Officer. While such approval need not record elaborate reasoning, the approving authority has a heavy duty to ensure it is not an empty ritual, fulfilling its purpose of supervisory control.

Haryana Acrylic Manufacturing Company v. CIT

308 ITR 38 · 2009 · High Court

248

citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Pepsi Foods (P.) Ltd. v. Asstt. CIT

367 ITR 112 · 2014 · High Court

225

citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Sarthak Securities Co. Pvt. Ltd. v. ITO

329 ITR 110 · 2010 · High Court

217

citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

Judgments citing reasons recorded

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad.

ITA 1873/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos. 1870 To 1875/Hyd/2025

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

asset nor any expenditure nor any entry or entries in the books of account. The Assessing Officer has not recorded his satisfaction in the reasons recorded for reopening of the assessment regarding fulfilling of the conditions specified u/s 149(1)(b) of the Act. The Assessing Officer has not even ... lakhs or more for each of the A.Ys taken up for initiation of proceedings u/s 147/148 of the Act. He has referred to the reasons recorded for reopening of the assessment and submitted that the Assessing Officer in the reasons recorded has not pointed out which asset is constituting

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1872/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1870/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1571/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 132(4)Section 143(3)Section 148

entire assessment proceedings becomes void ab initio. 8. The learned Counsel for the assessee further referring to the reasons recorded by the A.O submitted that, the A.O invoked explanation (2) clause (i) of section 148 of the Act on the presumption that once a search is initiated under section ... suggest income escaped the assessment for the relevant Asst. Years has simply issued notice under section 148 of the Act on the basis of reasons recorded for reopening of the assessment without there being an iota of discussion in the reasons that the documents found during search suggest escapement

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1566/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ. अपी.सं / Ita Nos.1566 & 1571/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2020-21 & 2021-22) M/S. Exel Rubber Private Ltd Vs. Hyderabad Dy.Cit Central Circle 1 (2) Hyderabad Pan:Aaace4495J (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V. Prasad, Ca राजस्व द्वारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 20/01/2026 घोषणा की तारीख / Pronouncement: 18/02/2026 Per Manjunatha, G. A.M. आदेश/Order These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 14/07/2025 For The A.Ys 2020-21, 2021-22 & 2022-23 Respectively. Since Common Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 132(4)Section 143(3)Section 148

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2542/KOL/2025[2015-16]Status: DisposedITAT Kolkata18 Feb 2026AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2541 & 2542/Kol/2025 Assessment Years: 2013-14 & 2015-16 Dcit, Cc-1(2), Kolkata…………..…....…………….……….……….……Appellant Vs. M/S Amluckie Investment Company Ltd.……………….....……...…..…..Respondent 2Nd Floor, 10 Princep Street, Kolkata-700072. [Pan: Aacca6749H] Appearances By: Shri Manoj Kr. Pati, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 12, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Filed By The Revenue Are Directed Against Separate Orders Both Dated 21.07.2025 Of The Cit(A)-20, Kolkata Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Years 2013–14 2015-16 Respectively. Since Both The Appeals Relate To The Same Assessee & Arisen From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Both The Appeal Filed By The Revenue With A Delay Of 35 Days & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

Section 131Section 143(2)Section 147Section 148Section 250

wherein the appeal of the assessee has been allowed on legal ground as well as on merits as the ld. CIT(A) found that reasons recorded suffers from non-application of mind of the Assessing Officer. The ld. CIT(A) while allowing the appeal of the assessee gave his findings ... borrowed satisfaction and wrong facts is void. After examination of appellant submission and facts of the case, I find the following; 1. the reasons recorded and approval obtained under s.151 speak of derivative turnover and therefore suffer from non-application of mind, rendering the entires.147 assumption ultra vires

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2541/KOL/2025[2013-14]Status: DisposedITAT Kolkata18 Feb 2026AY 2013-14

Section 131Section 143(2)Section 147Section 148Section 250

Usha Yadav, Etawah vs. ITO 2(2)(5)- Etawah, Etawah

In the result, grounds raised by the assessee are allowed for statistical purpose

ITA 431/AGR/2025[2019-20]Status: DisposedITAT Agra17 Feb 2026AY 2019-20

Bench: : Shri S. Rifaur Rahmanassessment Year: 2019-20 Usha Yadav Vs. Ito, D/O Shri Ummad Singh Mitra Ward 2(2)(5), Etawah Puram Colony, Bharthana Road, Etawah Pan : Agzpy7652F (Appellant) (Respondent) Assessee By Shri Gaurav Goyal, Ca Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 17.02.2026 Date Of Pronouncement 17.02.2026 Order

Section 148

appellant without properly appreciating the facts of the case. 3. That the assumption of facts made in the notice u/s 148/147 read with reasons recorded was erroneous and proceedings initiated are ab-initio void. 4. That imposition of interest under various provisions of Income Tax Act is illegal

Vijay Pratap Singh Chauhan, Chanderi Distt Ashok Nagar vs. Income Tax Officer, Ashok Nagar

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

ITA 127/AGR/2025[2017-18]Status: DisposedITAT Agra17 Feb 2026AY 2017-18

Bench: : Shri S. Rifaur Rahmanassessment Year: 2017-18 Vijay Pratap Singh Chauhan Vs. Ito, Nanakpur Chanderi Ashoknagar Ashok Nagar, Madhya Pradesh Pan : Fpnps4033A (Appellant) (Respondent) Assessee By Shri Amit Sogani, Adv. Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 17.02.2026 Date Of Pronouncement 17.02.2026 Order

Section 148Section 2Section 50(2)(x)Section 50CSection 56(2)(X)Section 69

learned CIT(A) also wrongly confirmed the same. 2. That the learned AO grossly mistaken in providing the unsigned copy of reasons recorded in writing and also failed to supply the copy of sanction by PCIT and the learned CIT(A) also do not accepted the mistake of learned

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

after recording the reasons to believe u/s 148(2) of the Labh Combines Pvt. Ltd. Act. The copy of the reason recorded is available at page no. 96 of the paper book which is extracted below: “The Assessee company filed its return of income on 13 10.2017 declaring total income ... view that assessment has been made without any application of mind by the AO and mistake is committed repeatedly by the AO in the reasons recorded, in the notice u/s 142(1) of the Act as well as assessment order dated 17.03.2022 passed u/s 147 r.w.s. 144B

Surana Bros Pvt. Ltd., Kolkata vs. ITO, Ward 12(1), Kolkata

Appeal of the assessee is allowed

ITA 2143/KOL/2025[2009-2010]Status: DisposedITAT Kolkata17 Feb 2026AY 2009-2010

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

Section 143(2)Section 144Section 147Section 148Section 250

adjudication. 6. After hearing the rival submission and perusing the material available on record, we find from the perusal of reasons recorded by the AO that the AO relied on the information received from Singapore. A copy of which is available at page No. 4 of the paper book ... Investigation, Forensic Division Competent Authority Singapore, without any verification on its own as apparent from the facts mentioned by the AO in the reasons recorded. We noted that during the year assessee has sold Rs. 6,11,500 equity shares for Rs. 3,22,65,000/-. We note that

Jiya Exim Private Limited, Kolkata vs. ITO, Ward 5(1), Kolkata

ITA 2142/KOL/2025[2012-2013]Status: DisposedITAT Kolkata17 Feb 2026AY 2012-2013

Section 143(1)Section 144Section 147Section 148Section 150(1)Section 150(2)Section 151Section 151(1)Section 250

CERTIFIED TO BE TRUE COPY For JIYA EXIM (P) LTD. Vinut foul. Director Whether the Addl. Commissioner is satisfied on the 12. reasons recorded by the ITO/DCIT/ACIT that it is a fit case for the issue of Notice u/s.148 Yes Dated: March, 2019 Name: SK. Z.H. TANWEER Designation: Addl. C.I.T ... 16/01/25 CERTIFIED TO BE TRUE COPY For JIYA EXIM (P) LTD. Vinent you. Director 13 Whether the Commissioner / Board is satisfied on the reasons recorded by the ITO/DCIT/ACIT that it is a fit case for the issue of Notice u/s.148 લભપડાJલાડ Dated: March, 2019 Name: JAYANT DIDDI Designation: Pr.C.I.T

Poonam Gupta, Bengaluru vs. DCIT, Circle-5(1)(1), Bangalore

In the result appeal filed by the assessee is allowed

ITA 793/BANG/2025[2017-18]Status: DisposedITAT Bangalore17 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2017-18

For Appellant: Shri Manish Tiwari, CAFor Respondent: Shri Subramanian, Jt.CIT (DR)(ITAT), Bengaluru

Section 10Section 147Section 68

term capital gain, there is no reason to believe for the assessing officer that assessee has obtained any benefit. He further referred to the reasons recorded to show that the above scrip was alleged to be used for booking of the bogus long-term capital gain. However the assessee ... offered the above sum as a short-term capital gain and paid tax thereon. Therefore the reasons recorded by the ld.AO does not withstand the test of reason to believe. He specifically referred to paragraph No. 7 of the notice of reopening wherein it is stated that the assessee

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)

believe recorded by ld. AO which were provided to the assessee along with notice dated 21.06.2021. On a perusal of the Annexure-A i.e. reasons recorded Spice Life Hotels and Estates Pvt. Ltd. for reopening of assessment under section 147 of the Act, at paragraph ... assessee to disclose all material facts, however nothing has brought on record in support of such statement. Under such facts and circumstances the reasons recorded by the ld. AO found to be in violation of 1st proviso to section 147, against the settled propositions as laid down

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)

Quetzal Buildtech Private Limited, Haryana vs. Income Tax Officer, Haryana

ITA 6409/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Feb 2026AY 2016-17

Bench: Shri C.N. Prasad

Section 115BSection 139(1)Section 143(2)Section 147Section 234BSection 68Section 69C

referring to ground No.1 and 2 of grounds of appeal challenging the reopening of assessment as illegal and bad in law, submitted that the reasons recorded for reopening of assessment which were placed at page 28 of the paper book at para -7, is that clause-(a) of Explanation

Ashok Kumar, Merrut vs. ITO, Meeut

In the result, the appeal of the assessee is partly allowed as indicated above

ITA 5090/DEL/2025[2011-12]Status: DisposedITAT Delhi17 Feb 2026AY 2011-12

Bench: Shri C.N. Prasadassessment Year 2011-12 Asok Kumar S/O Sher Singh Vs. Ito 24, Nagli, Azamabad Ward -1 (1) Meerut -250001 Meerut Pan No.Blapk3060J Appellant Respondent Appellant Sh. Manish Kumar, Advocate Respondent Sh. Manoj Kumar, Sr. Dr

Section 142Section 148

result thereof, the reason to believe is totally based on AIR information only without making any Inquiry or application of mind and consequently the reason recorded is in fact a reason to suspect and not reason to believe. Grounds Concerning Opportunity: 11. The authority below in the facts and circumstances ... further find that the sanction obtained in terms of section 151 of the Act was not provided to the assessee along with the reasons recorded despite assessee asking the the same in writing before the Id. AO. This, in our considered opinion, is against the settled principles of natural justice

Ravendra Singh, Agra vs. ACIT, Circle 1(2)(1), Agra

In the result, appeal filed by the assessee is allowed for statistical purposes and direct the ld

ITA 499/AGR/2025[2012-2013]Status: DisposedITAT Agra16 Feb 2026AY 2012-2013

Bench: : Shri S. Rifaur Rahmanassessment Year: 2012-13 Ravendra Singh Vs. Acit, 28, Tota Ka Taal Circle 1(2)(1), Loha Mandi, Uttar Pradesh Agra Pan : Abyps5329K (Appellant) (Respondent) Assessee By Shri Shashank Agarwal, Adv. Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 16.02.2026 Order

Section 143(2)Section 143(3)Section 148Section 151Section 250(6)Section 68

valid approval under section 151 was obtained. 5. The learned CIT(A) failed to consider that the Assessing Officer did not furnish the reasons recorded for reopening despite request, thereby vitiating the reassessment. 6. The learned CIT(A) erred in upholding the addition of Rs. 8,74,800 made under

Sagar Dwellings P Ltd, Near Sun Temple Gwalior vs. ACIT, Faceless

In the result, assessee’s appeal is dismissed

ITA 373/AGR/2025[2014-15]Status: DisposedITAT Agra16 Feb 2026AY 2014-15

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

respondent revenue. 6. On the basis of aforesaid grounds raised in this appeal, the main points for determination are as to (i) whether the reasons recorded by the Assessing Officer were not sufficient to trigger the reopening u/s. 147 of the Act and the sanction u/s. 151 was given ... transportation of goods were found to be fictitious. Admittedly, assessee also failed to produce confirmation on said purchases from Jai Baba Gurudev Traders. The reasons recorded by the Assessing Officer are supported with cogent factual matrix and were sufficient to trigger the reopening u/s. 147 of the Act. The action

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

assessee filed return of income requested for reasons for reopening the assessment vide letter dated 24.09.2019. In the reasons recorded, the A.O has stated that information has been received from DCIT, Central Circle, in pursuant to a search under email dated 15.06.2016 asserting that the assessee has entered into bogus ... already been considering during the original proceedings and is settled by the assessee through VSVS. The Ld. AR argued that the A.O in the reasons recorded (page 49 of paper book) has stated the receipt from the same parties as income escaping assessment which is factually incorrect