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“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

Sh. Gurdeep Singh Mahal, Sirsa vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 233/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issued u/s 148 dtd 31.03.2021 is placed at Page 17 of the paper book of Ashok Kumar Thukral and the approval along with the reasons recorded for reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening ... respectfully submitted that the assessee filed his original return of income on 28.08.2015. Thereafter, a notice u/s 148 of the Act along with the reasons recorded was issued on 30.03.2021. A copy of the notice is placed at Page 22 of the paper book of Rakesh Kumar and the reasons

Sh. Devender Kumar, Yamuna Nagar vs. ITO, Ward -1, Yamuna Nagar

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 192/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issued u/s 148 dtd 31.03.2021 is placed at Page 17 of the paper book of Ashok Kumar Thukral and the approval along with the reasons recorded for reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening ... respectfully submitted that the assessee filed his original return of income on 28.08.2015. Thereafter, a notice u/s 148 of the Act along with the reasons recorded was issued on 30.03.2021. A copy of the notice is placed at Page 22 of the paper book of Rakesh Kumar and the reasons

Sh. Baljinder Singh, Chandigarh vs. Pr.CIT, Chandigarh -1, Chandigarh

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 167/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

issued u/s 148 dtd 31.03.2021 is placed at Page 17 of the paper book of Ashok Kumar Thukral and the approval along with the reasons recorded for reopening are placed at Pages 19 to 22 of the paper book of Ashok Kumar Thukral.  Pursuant to the reopening ... respectfully submitted that the assessee filed his original return of income on 28.08.2015. Thereafter, a notice u/s 148 of the Act along with the reasons recorded was issued on 30.03.2021. A copy of the notice is placed at Page 22 of the paper book of Rakesh Kumar and the reasons

Income Tax Officer- 22(1)(6), Mumbai vs. Arvind Premchand Jain, Mumbai

In the result the appeal filed by the revenue is dismissed

ITA 2878/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Feb 2026AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 10(38)Section 147Section 148Section 250Section 68

adverse evidence in his possession and held to be against the assessee Ground No. 2, as the issue has not covered in 3. reasons recorded for reopening. The assessment of the assessee was reopened based on the information that the assessee is one of the beneficiaries of transactions ... course of re-opened assessment proceedings, notwithstanding the fact that the reasons for such issue have not been included in the reasons recorded under sub section (2) of section 148 of the Act. 12. As such, in terms of Explanation 3 to section 147 of the Act, prima facie

Surendranagar District Co Op Producers Union Limited, Surendranagar vs. Assistant Commissioner of Income Tax, Surendranagar Circle

In the result, appeal filed by the assessee is allowed

ITA 429/RJT/2025[2014-15]Status: DisposedITAT Rajkot10 Feb 2026AY 2014-15

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 429/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Surendranagar District Co. Op. Acit, Circle, Producers Union Ltd. Vs. Surendranagar-363035 Plot No.249, Phase 2 Gidc Market Yard Circle, Sursagar Dairy, Wadhwan Road, Surendranagar-363035 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas8375B (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : Heard On 09/10/2025, Refixed For Clarification On 03.11.2025 & Finally Heard On 02.02.2026 : 10/02/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, A.M.:

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 234ASection 250Section 271(1)(c)Section 80P(2)(b)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

Kuldip Singh, Ranchi vs. DCIT/ACIT, Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 180/RAN/2025[14-15]Status: DisposedITAT Ranchi10 Feb 2026

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.180/Ran/2025 Assessment Year: 2014-15 Kuldip Singh…………………….……….……...................……….……Appellant The Avenue Vishnupuri Marg, Upper Burdwan Compound, Lalpur, Ranchi- 834001. [Pan: Agjps6921P] Vs. Dcit/Acit, Circle-1, Ranchi…...…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kailash Gautam, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2026 Date Of Pronouncing The Order : February 10, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 06.03.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

after full verification. The notice under section 148 dated 22.11.2019 was issued beyond four years from the end of AY 2014–15 and the reasons recorded while issuing notice u/s 143(2) r.w.s 147 dated 21.09.2020 do not allege any failure on the part of the assessee to disclose fully ... Assessment was completed under section 143(3) wherein certain additions were made to assessee's income - Subsequently, assessment was reopened in case of assessee - Reason recorded by Assessing Officer was that in case of search conducted in case of one 'N', it was found that there was a syndicate operating

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6211/MUM/2025[1996-97]Status: DisposedITAT Mumbai10 Feb 2026AY 1996-97

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

returns filed u/s.139(1) of the Act be treated as returns filed in compliance with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC ... before the revenue authorities. The Ld. DR, therefore, strongly supported the order passed by the Ld. AO. He further drew our attention to the reasons recorded for reopening the assessment, as placed at APB page 7, which are reproduced herein below: CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6209/MUM/2025[1998-99]Status: DisposedITAT Mumbai10 Feb 2026AY 1998-99

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

returns filed u/s.139(1) of the Act be treated as returns filed in compliance with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC ... before the revenue authorities. The Ld. DR, therefore, strongly supported the order passed by the Ld. AO. He further drew our attention to the reasons recorded for reopening the assessment, as placed at APB page 7, which are reproduced herein below: CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6195/MUM/2025[1996-97]Status: DisposedITAT Mumbai10 Feb 2026AY 1996-97

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

returns filed u/s.139(1) of the Act be treated as returns filed in compliance with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC ... before the revenue authorities. The Ld. DR, therefore, strongly supported the order passed by the Ld. AO. He further drew our attention to the reasons recorded for reopening the assessment, as placed at APB page 7, which are reproduced herein below: CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6194/MUM/2025[2000-01]Status: DisposedITAT Mumbai10 Feb 2026AY 2000-01

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

returns filed u/s.139(1) of the Act be treated as returns filed in compliance with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC ... before the revenue authorities. The Ld. DR, therefore, strongly supported the order passed by the Ld. AO. He further drew our attention to the reasons recorded for reopening the assessment, as placed at APB page 7, which are reproduced herein below: CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6193/MUM/2025[1997-98]Status: DisposedITAT Mumbai10 Feb 2026AY 1997-98

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

returns filed u/s.139(1) of the Act be treated as returns filed in compliance with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC ... before the revenue authorities. The Ld. DR, therefore, strongly supported the order passed by the Ld. AO. He further drew our attention to the reasons recorded for reopening the assessment, as placed at APB page 7, which are reproduced herein below: CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

ITA 6192/MUM/2025[1999-00]Status: DisposedITAT Mumbai10 Feb 2026AY 1999-00

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

Section 143(3)Section 144Section 250Section 271(1)(c)

returns filed u/s.139(1) of the Act be treated as returns filed in compliance with the notice issued u/s.148 of the Act. The reasons recorded for reopening the assessment were provided to the appellant. During the course of reassessment proceedings, the appellant denied owning any such Bank account in HSBC ... before the revenue authorities. The Ld. DR, therefore, strongly supported the order passed by the Ld. AO. He further drew our attention to the reasons recorded for reopening the assessment, as placed at APB page 7, which are reproduced herein below

DCIT, Central Circle 7(1), Mumbai vs. Dr D Y Patil Educational Academy, Mumbai

In the result, the appeal filed by the revenue stands

ITA 3922/MUM/2025[2015]Status: DisposedITAT Mumbai10 Feb 2026

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

Section 132Section 147Section 153CSection 250Section 68

assessment on the same issue amounts to change of opinion, which is not permitted under section 147 of the Act. 2.3 Further, please refer reasons recorded for re-opening of assessment page nos 2 to 4 of the paper book. On perusal of the same, it can be seen that ... income has escaped assessment. There should be a live link between the tangible material and the formation of belief on the basis of the reasons recorded that income has escaped assessment. The Assessing Officer has miserably failed in establishing that link inasmuch as he only mentions that the appellants have

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

assessee has not disclosed true and correct income and that the income chargeable to tax had escaped assessment in the said year. The reasons recorded by the AO to form the belief of escapement of income/reopening of assessment are reproduced as below: Hasmukh Ugarchand Gadhecha, HUF vs. ITO Asstt.Year ... years unless there is a failure on the part of the assessee to disclose fully and truly all material facts. Upon perusal of the reasons recorded by the AO, we find that the AO relied on information from the Investigation Wing regarding a search on Shri Shirish Chandra Shah, alleging

Income Tax Officer Ward 7.2.1 Ahmedabad, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1268/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR
Section 143(1)(a)Section 148Section 250

reopening of the assessment. 5. At the outset, the Ld.Counsel for the assessee has invited our attention to the copy of the reasons recorded by the AO for re-opening of the assessment, the contents of which, for the sake of ready reference, are reproduced as under:- “1. The above ... 57/Ahd/2025 (By Assessee) ITO vs. Raghavbhai Gordhanbhai Narola Asst.Years : 2013-14, 2015-16 & 2016-17 5 6. The assessee filed objections against the said reasons recorded for re- opening of the assessment, copy of which has been placed at page Nos.3 to 5 of the paper-book. The relevant para

Income Tax Officer Ward 7.2.1 Ahmedabad, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1267/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR
Section 143(1)(a)Section 148Section 250

reopening of the assessment. 5. At the outset, the Ld.Counsel for the assessee has invited our attention to the copy of the reasons recorded by the AO for re-opening of the assessment, the contents of which, for the sake of ready reference, are reproduced as under:- “1. The above ... 57/Ahd/2025 (By Assessee) ITO vs. Raghavbhai Gordhanbhai Narola Asst.Years : 2013-14, 2015-16 & 2016-17 5 6. The assessee filed objections against the said reasons recorded for re- opening of the assessment, copy of which has been placed at page Nos.3 to 5 of the paper-book. The relevant para

Income Tax Officer, Ward 7.2.1, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1266/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR
Section 143(1)(a)Section 148Section 250

reopening of the assessment. 5. At the outset, the Ld.Counsel for the assessee has invited our attention to the copy of the reasons recorded by the AO for re-opening of the assessment, the contents of which, for the sake of ready reference, are reproduced as under:- “1. The above ... 57/Ahd/2025 (By Assessee) ITO vs. Raghavbhai Gordhanbhai Narola Asst.Years : 2013-14, 2015-16 & 2016-17 5 6. The assessee filed objections against the said reasons recorded for re- opening of the assessment, copy of which has been placed at page Nos.3 to 5 of the paper-book. The relevant para

Deputy Commissioner of Income Tax, Central Circle-3(3), Kolkata vs. Adhunik Infrastructures Private Limited, Kolkata

In the result, the appeal filed by the Revenue is dismissed

ITA 1069/KOL/2024[2015-16]Status: DisposedITAT Kolkata09 Feb 2026AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 131Section 131(1)Section 143(3)Section 148Section 250Section 68Section 69A

time to explain and furnish the document in respect of the transaction of ₹30 Lakh and though the same was not part of the reasons recorded for reopening the case, the assessee complied with the requirement and furnished the documents being ledger of M/s. Desire Merchandies Pvt. Ltd. since inception ... given facts and circumstances, were hold that there is no infirmity in the order of the Ld. CIT-A. " 7. For the reasons recorded above, no question of law muchless substantial questions arises in this appeal. It stands meritless and accordingly dismissed. " In the instant case also, besides submitting

Nova Elevators Private Limited, Mumbai vs. ITO-13(1)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 7248/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarnova Elevators Private Vs Ito -13(1)(1), Mumbai Limited Maharashtra-400020 402, Dimple Apts., 4E, Asha Nagar, Kandivali East, Mumbai-400101 Pan: Aadcn0305K Appellant Respondent Assessee By : Shri Sharad Patel, Ca Respondent By : Shri Leyaqat Ali Aafaqui, (Sr Ar) Date Of Hearing : 29/01/2026 Date Of Pronouncement : 09/02/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-51, Mumbai [For Brevity ‘The Ld. Cit(A)], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2014-15, Date Of Order 12.09.2025. The Impugned Order Emanated From The Order Of The Ld. Income-Tax Officer Ward-13(1)(1), Mumbai

For Appellant: Shri Sharad Patel, CAFor Respondent: Shri Leyaqat Ali Aafaqui, (SR AR)
Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

Reopening Bad in Law The CIT(A) and Assessing Officer erred in the reopening under section 147 of the Act. The reasons recorded were based merely on borrowed satisfaction from the Investigation Wing/ DCIT (Central Circle) without any independent application of mind or a live nexus to the assessee ... under section 148 merely on borrowed satisfaction, without any independent application of mind to the assessee's own transactions and factual records. b. The reasons recorded for reopening were not furnished at the time of issuance of notice under section 148 and were supplied only

Kishore Anand Shetty, Goregaon East Mumbai vs. Circle 32(2), Mumbai

In the result, both the appeals of the assessee are allowed in terms indicated above

ITA 4975/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

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

Section 143(3)Section 271(1)(c)Section 50CSection 54F

correct reading of the statutory proviso and on the admitted factual position. 30. In view of the foregoing discussion, and for the reasons recorded hereinabove, we hold that the assessee has satisfied the conditions of section 54F. The purchase/construction of the new residential house, in the facts of this case