“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

Adarsh Developers, Mumbai vs. ITO, Ward 22(3)(1), Mumbai

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

ITA 7945/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 147Section 148Section 148ASection 151Section 151ASection 50CSection 50C(2)

learned CIT(A) erred in upholding the reassessment order u/s 147 when: (a) there was no failure to disclose material facts, (b) the reasons recorded were incorrect and based on mere "information", and (c) the reopening was based on change of opinion and without any tangible material. 8. Stamp Duty

Din Dayal Jalan Textiles Pvt Ltd, Mumbai vs. Asst. CIT 4(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7678/MUM/2025[2022-23]Status: DisposedITAT Mumbai16 Feb 2026AY 2022-23

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardin Dayal Jalan Textile Acit-4(1)(1), Pvt. Ltd. Room No. 642, 6Th 904-5, Royal Square, 9Th Vs. Floor, Aayakr Floor, 173, Dr. Vigas Bhavan, Queen Street, Mumbai-400 002 Road, Mumbai – 400 001 Pan/Gir No. Aabcd2310E (Applicant) (Respondent) Assessee By Shri D. C. Jain, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 09.02.2026 Date Of Pronouncement 16.02.2026

Section 132Section 143(3)Section 144BSection 2Section 69A

filed its return of income declaring total income of Rs. 5,50,90,910/-.The case was selected for scrutiny under CASS on the reasons recorded as “Large squared up loans during the year, Reduction in profit because of application of Income Computation and Disclosure Standards and Information in verification

M/S. Armstrong Energy Pvt Ltd, Mumbai vs. The DCIT 6(1)(1), Mumbai

ITA 3395/MUM/2025[2008-09]Status: DisposedITAT Mumbai16 Feb 2026AY 2008-09

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarm/S Armstrong Energy Pvt. Vs. Dcit 6(1) (1), Mumbai Ltd. Room No. 504, 5Th 5Th Floor, Militia Apartment, Floor, Aayakar Bhavan, Mathur Pakhadi Road, M.K. Road, Mazgaon, Mumbai 400020 Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Acit 6(1) (1), Mumbai Vs. M/S Armstrong Energy Pvt. Room No. 504, 5Th Floor, Ltd. Aayakar Bhavan, M.K. 5Th Floor, Militia Road, Apartment, Mathur Mumbai 400020 Pakhadi Road, Mazgaon, Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Assessee By Shri Nishit Gandhi Revenue By Shri Rajesh Kumar Yadav (Cit-Dr) Date Of Hearing 10.12.2025 Date Of Pronouncement 16.02.2026 आदेश / Order Per Sandeep Gosain, Jm: M/S. Armstrong Energy Pvt. Ltd.

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 151(2)Section 251(1)(a)Section 68

facts and circumstances of the case and in law, the Ld. AO has not provided copy of reasons recorded and satisfaction note at the time of notice issued u/s 148 of the Income Tax Act, 1961 6. On the facts and circumstances of the case ... view of the aforesaid undisputed factual position, we hold that the very foundation for initiation of reassessment proceedings is vitiated, as the reasons recorded for reopening do not demonstrate that any income chargeable to tax had escaped assessment. Therefore, we are of the view that when no income

Siddharth Bhaskar Shah, Mumbai vs. Pr. Commissioner of Income Tax-27, New Mumbai

ITA 3327/MUM/2025[2022-23]Status: DisposedITAT Mumbai16 Feb 2026AY 2022-23

Bench: Shri Sandeep Gosain & Shri Om Prakash Kantι.Τ.Α. Νο. 3327/Mum/2025 Α.Υ: 2022-23 Siddharth Bhaskar Shah Vs Pcit -27 803, Neelkanth Indraprastha, Valley, Rajawadi, Ghatkopar (E) Mumbai - 400077 Pan – Bigps6015Q Room No. 401, 4Th Floor, Tower No. 6, Vashi Rly Stn, Commercial Complex Vashi, Navi Mumbai. (Appellant) (Respondent) Assessee By | Shri Satyaprakash Singh Revenue By | Shri Vivek Permapurna, Cit (Dr) Date Of Hearing 19.11.2026 Date Of Pronouncement 16.02.2026 Order Per: Shri. Sandeep Gosain, J.M.: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dt. 24.04.2025 Passed Under Section 263 Of The Income Tax Act, 1961 (‘The Act'), By The Pr.Cit(A) For The Assessment Year 2022-23. The Assessee Has Raised The Following Grounds Of Appeal: 1. The Learned Principal Commissioner Of Income-Tax Has Erred In Law & On Facts In Not Appreciating That Where The A.O. After Detailed Verification Of Record & Making Enquires Had Framed The Assessment, The Revision Powers Conferred On The Principal Cit Under Section 263 Of Act, Cannot Invoked Only Based On A Change Of Opinion. 2

Section 263Section 54F

purchase consideration of Rs. 20,00,64,750/- and against the same the assessee had also claimed deduction u/s 54F of the Act. Therefore reasons recorded by Ld. PCIT for revision of the order of assessment dated 20.03.2024 was that since the assessee had purchased six residential flats in Bangalore

ACIT-6(1)(1), Mumbai vs. Armstrong Energy Pvt. Ltd., Mumbai

ITA 2940/MUM/2025[2008-09]Status: DisposedITAT Mumbai16 Feb 2026AY 2008-09

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 151(2)Section 251(1)(a)Section 68

Nilesh Ashanand Thacker, Bhuj vs. ITO Ward 4, Gandhidham (Bhuj)

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

ITA 377/RJT/2025[2012-13]Status: DisposedITAT Rajkot13 Feb 2026AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.377/Rjt/2025 (िनधा"रण वष" /Assessment Year: (2012-13) (Physical Hearing) Nilesh Ashanand Thacker, बनाम Income-Tax Officer, Ward-4, / Near-Laxmi Vekari Mahakali Gandhidham (Bhuj-2)-370 201 Vs. Shopping Mall, Jublee Circle, Bhuj, Kutch-300 001(Gujarat) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Adhpt 8610R (अपीलाथ"/ Appellant) (""थ"/Respondent)

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR

Section 143(3)Section 234ASection 250Section 271(1)(c)Section 69A

other material brought on record. We note that in assessee’s case the satisfaction is recorded by the Ld.PCIT on the reasons recorded stating “Yes I am satisfied”, the same is reproduced below for ready reference: Nilesh A Thacker Nilesh A Thacker 15. We have gone through the above satisfaction ... satisfied” is not correct, as the learned PCIT did not mention, as to how and why he was satisfied with the reasons recorded by the assessing officer. Therefore, we have gone through the above satisfaction / approval given by the ld PCIT, and noted that it is a mechanical approval

Nirman, Ahmedabad vs. DCIT, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1509/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalnirman, Vs. 35, Vasantkunj Society, New Dcit, Sharda Mandir Road, Paldi, Circle-2(1)(1), Ahmedabad-380007 Ahmedabad [Pan :Aabfn 7155 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Parin Shah, Ar Respondent Represented By: Shri C. Dharani Nath, Sr Dr Date Of Hearing 03.02.2026 Date Of Pronouncement 13.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

Section 132Section 148Section 250Section 69A

money u/s 69A of the Act and added the same to the income of the assessee. 4. For the sake of ready reference, the reasons recorded for reopening the case are reproduced here asunder:- “BASIS OF FORMING REASON TO BELIEVE AND DETAILS OF ESCAPEMENT OF INCOME: As per the information ... your re-opening of assessment proceedings and issuance of notice u/s 148 dated 30-03-2021 on following grounds:- 1) You have provided only reasons recorded the Assessing Officer who was in charge of the case at that time. You have not provided copy of permission/satisfaction obtained from your higher

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

ground that the depreciation claimed by the assessee at 25% on display structure is excessive and therefore income has escaped assessment. In the reasons recorded for reopening, the A.O has stated that these structures should be treated as buildings and to be depreciated at 10% and since the assessee ... 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 (page 61 of paper book) to submit that the very basis for reopening is the income declared by the assessee where depreciation is claimed

DCIT Central Circle- 7(1), Mumbai vs. Bhavik Prafulchandra Vora, Gujrat

In the result, the appeal filed by the revenue is dismissed and cross-objection filed by assessee is partly allowed

ITA 7602/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai ()

Section 143(3)Section 148Section 151Section 151ASection 68

148A issued notice u/s 148 of the Act on 30/07/2022, which was approved by the Principal Commissioner of Income-tax–3, Ahmedabad, wherein the reasons recorded states that income chargeable to tax amounting to ₹10,25,756/- had escaped assessment for the year under consideration. The Ld.AR submitted that

DCIT Central Circle- 7(1), Mumbai vs. Pranavkumar Prafulchandra Vora, Gujrat

In the result, the appeal filed by the revenue is dismissed and cross-objection filed by assessee is partly allowed

ITA 7596/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 147Section 148Section 151ASection 68

148A issued notice u/s 148 of the Act on 28/07/2022, which was approved by the Principal Commissioner of Income-tax–3, Ahmedabad, wherein the reasons recorded states that income chargeable to tax amounting to ₹37,76,422/- had escaped assessment for the year under consideration. The Ld.AR submitted that

Dattatray Vithoba Sawant, Kalyan vs. Income Tax Officer, WD-42(2)(2), Mumbai

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

ITA 6081/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 10(14)Section 133ASection 142(1)Section 148Section 148ASection 151Section 151ASection 3Section 80CSection 80G

148A issued notice u/s 148 of the Act on 06/07/2022, which was approved by the Principal Commissioner of Income Tax–17, Mumbai, wherein the reasons recorded states that income chargeable to tax amounting to Rs.2,58,383/- had escaped assessment for the year under consideration. The Ld.AR submitted that

Park View Automotives Private Limited, Delhi vs. ITO, Ward 19(3), Delhi

In the result, the appeal of the assessee is dismissed

ITA 5711/DEL/2025[2012-13]Status: DisposedITAT Delhi13 Feb 2026AY 2012-13

Bench: Ms Madhumita Roy & Shri Naveen Chandraassessment Year : 2012-13 Park View Automotives P. Ltd., Vs. Ito, S-606, School Block, Ward 19(3), Laxmi Nagar, Delhi. Delhi – 110 092. Pan: Aaecp3499H (Appellant) (Respondent) Assessee By : Shri Mukesh Jain, Ca & Shri Samyak Jain, Advocate Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 05.02.2026 Date Of Pronouncement : 13.02.2026 Order Per Madhumita Roy, Jm:

For Appellant: Shri Mukesh Jain, CA &For Respondent: Shri Manish Gupta, Sr. DR

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

which remained un-complied with as on date. In such circumstances, as per information received in this office as mentioned in the reasons recorded u/s 147 of Act 1961 your company is one of the beneficiary of accommodation entries of Rs 13,60,000/- through paper/shell companies of Rajesh

M/S Stance Consumer Electronics Private Limited, Delhi vs. Deputy Commissioner of Income Tax, CC-32, Delhi

In the result appeal of the assessee for AY 2017-18 in ITA No

ITA 2792/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.2791 & 2792/Del/2025 (Assessment Yearss 2016-17 & 2017-18)

Section 143(3)Section 147Section 148Section 250Section 68

that the consideration received from three companies from the sale of shares as accommodation entry. The claim of the assessee was that in the reasons recorded before reopening the assessment u/s 147, satisfaction was recorded of escapement of income to the extent of Rs.39,27,750/- being rotation of money ... reassessment order passed and the consideration received from the sale of shares was added as unexplained credits u/s 68 of the Act. The reasons recorded Stance Consumer Electronics Pvt. Ltd. vs. DCIT before issue of notice u/s 148 as available at pages 35 to 38 of the PB are reproduced

M/S Stance Consumer Electronics Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, CC-32, Delhi

In the result appeal of the assessee for AY 2017-18 in ITA No

ITA 2791/DEL/2025[2016-17]Status: DisposedITAT Delhi13 Feb 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.2791 & 2792/Del/2025 (Assessment Yearss 2016-17 & 2017-18)

Section 143(3)Section 147Section 148Section 250Section 68

Talshibhai Kanjibhai Narola, Damnagar vs. The ITO WD 3(1)(4), RKT, Amreli-Rajkot

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

ITA 980/RJT/2025[2018-19]Status: DisposedITAT Rajkot12 Feb 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Ms. Devina Patel, Ld. A.R

Section 115BSection 147Section 148Section 250(6)Section 69A

Appeals), National Faceless Appeal Centre (NFAC) erred confirming action of assessing officer in issuing notice u/s 148 of the Act in the light of reasons recorded and thus failed to appreciate that assessment framed u/s 147 r.w.s. 144B is bad in law. 4.The learned Commissioner (Appeals), National Faceless Appeal Center

Shree Keshav Co Op Credit Society Ltd, Junagadh vs. The DCIT/ACIT, Cir 1(1), Rajkot

In the result, both appeals filed by the assessee, are allowed

ITA 794/RJT/2025[2020-21]Status: DisposedITAT Rajkot12 Feb 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR

Section 143(3)Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Revenue, informed the Bench that Hon`ble High Court has only removed the word “co-operative” from the reproduction of reasons recorded by the assessing officer. Hence it does not impact on the ratio laid down by the Hon`ble Court. Learned Counsel for the assessee, has also argued before

Shree Keshav Co Op Credit Society Ltd, Junagadh vs. The DCIT/ACIT, Cir - 1(1), Rajkot

In the result, both appeals filed by the assessee, are allowed

ITA 793/RJT/2025[2018-19]Status: DisposedITAT Rajkot12 Feb 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR

Section 143(3)Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Prabhulal Kalji Doshi, Mumbai vs. ITO Ward 19(2)(4), Mumbai

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

ITA 7421/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 143(3)Section 148Section 148ASection 151Section 68

assessment was completed u/s 143(3) of the Act vide order dt. 18.12.2019 wherein the issue of cash deposited during demonetisation was considered, therefore reasons recorded for reopening is factually incorrect and reopened on incorrect facts, therefore reopening is bad in law. 2. The Id CIT (A) failed to appreciate ... 148A issued notice u/s 148 of the Act on 27/05/2022, which was approved by the Principal Commissioner of Income Tax–19, Mumbai, wherein the reasons recorded states that income chargeable to tax amounting to Rs.28,86,000/- had escaped assessment for the year under consideration. The Ld.AR submitted that

DCIT-2(1)(1), Mumbai vs. 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)

that there was no new tangible material available with the Ld. AO for reopening the assessee’s case which is also evident from the reasons recorded for reopening. The Ld. AR further argued that there was no failure on the part of the assessee to disclose fully and truly

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)