“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

Rajkamal Agro Industries, Deesa vs. ITO, Ward 1, Palanpur

In the result, the appeal of the assessee stands allowed

ITA 1853/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Jan 2026AY 2015-16

Bench: Shri Sanjay Gargआयकर अपील सं /Ita No.1853/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Rajkamal Agro Industries The Ito बनाम/ Deesa Palanpur Highway Ward-I V/S. At Rasna, Deesa – 385 535 Palanpur 385 001 (Gujarat) "थायी लेखा सं./Pan: Aaifr 7263 C (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08/01/2026 घोषणा की तारीख /Date Of Pronouncement: 09/01/2026 आदेश/O R D E R 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 04/09/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2015-2016. 2. The Assessee, In This Appeal, Has Taken The Following Grounds Of Appeal:

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Smt. Mamta Singh, Sr.DR

Section 147Section 250

assessment. He, in this respect, has brought my attention to Page No.58 of the paper-book, which is a copy of the reasons recorded for reopening of the assessment u/s.147 of the Act. The reopening of the assessment has been made by the Assessing Officer (AO), in this case ... made by the audit party regarding undervaluation of the closing stock of the assessee which has been reproduced verbatim by the AO in the reasons recorded for reopening of the assessment. The Ld. AR submitted that reopening of the assessment, on this issue, has also been made

Doriswamy Gopi, Bengaluru vs. Income Tax Officer, Ward 3(1)(1), Bengaluru

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

ITA 2020/BANG/2025[A.Y. 2017-18]Status: DisposedITAT Bangalore09 Jan 2026

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Nagaraja K.H, CAFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department

Section 139Section 147Section 148Section 151Section 292B

November 2017 placed on pages 117 to 159 of the paper book. 3.1 However, the ld. AR submitted that the AO in the reasons recorded for reopening the assessment under section 147 of the Act has observed that the assessee has not filed the return of income for the year ... under consideration. To this effect, the learned AR drew attention on page 239 of the paper book where the reasons recorded for reopening of the assessment were placed. Accordingly, it was the contention of the ld. AR that the reopening of the assessment under section

Devi Manubhai Shah, Mumbai vs. ITO - Circle 32(1), Mumbai

ITA 7005/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Jan 2026AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Piyush ChhajedFor Respondent: Shri Annavaran Kosuri

Section 143(1)Section 143(3)Section 147Section 54F

erred in denying the exemption claimed under section 54F without appreciating that there was no whisper about the said exemption claimed in the reason recorded and there was no addition made on the basis of reasons and therefore the only addition in regard to denial of exemption under Section.54F which ... proceedings are validly initiated, the Assessing Officer can assess any income that comes to light even if the same is not mentioned in the reasons recorded for reopening the assessment. 5. We have considered the rival submission and have perused the material on record. 6. The Assessing Officer has recorded

DCIT(CC)-8(3), Mumbai vs. Santosh Vimlesh Mehta, Mumbai

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

ITA 3725/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Jan 2026AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2012-13 Dcit(Cc)-8(3) Santosh Vimlesh Mehta Room No. 661 6Th Floor, Aaykar 10, Mumbadevi Road, Vs. Bhavan, Maharshi Karve Road, Mumbadevi, Mumbai-400002 Mumbai-400020 Mumbai Pan No. Abhpm 0883 H Appellant Respondent

For Appellant: Mr. Devendra JainFor Respondent: Mr. Virabhadra Mahajan, SR-DR

Section 10(38)Section 69A

return filed on 21.12.2012. The Assessing Officer declared in the return filed on 21.12.2012. The Assessing Officer thereafter furnished a copy of the reasons recorded for reopening, thereafter furnished a copy of the reasons recorded for reopening, thereafter furnished a copy of the reasons recorded for reopening, to which

Jsp Projects (P) Ltd, Delhi vs. DCIT, Central Circle-13, Delhi/South Delhi

In the result, the appeal of the assessee is allowed

ITA 3594/DEL/2025[2014-2015]Status: DisposedITAT Delhi09 Jan 2026AY 2014-2015

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2014-15] M/S Jsp Projects Private Dcit, Central Circle-13, 2Nd Floor, Income Tax Building, Limited, C/O- Ca Vaibhav Goel, 75, Vs E-2 Ara Centre, Jhandewalan Navyug Market, First Floor, Extension, Delhi-110055 Ghaziabad(Up) Uttar Pradesh-201001 Pan-Aadcj0677L Appellant Respondent Assessee By Shri Ved Jain, Adv. Ms. Uma Upadhyay, Ca & Shri Aditya Garg, Adv. Revenue By Ms. Amisha S. Gupta, Cit-Dr Date Of Hearing 15.10.2025 Date Of Pronouncement 09.01.2026 Order Per Amitabh Shukla, Am

Section 127(2)Section 153CSection 63Section 65BSection 68

reliance has also been placed upon the sworn statement of Shri Gupta under section 132(4) dated 18.10.2019. There is nothing substantial in the reasons recorded or the order under section 153C which allude towards any incriminating material found qua the assessee. The judicial precedents on the subject pronounced

Rakesh Divedi, Delhi vs. Income Tax Officer, Ward 43(6), Delhi

In the result, appeal of the Assessee is allowed

ITA 3290/DEL/2025[2009-10]Status: DisposedITAT Delhi09 Jan 2026AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwalrakesh Divedi, Income Tax Officer, 87, Triveni Apartments, Ward-43(6), Delhi. Pitampura, New Delhi - Vs. 110034. Pan-Apcpd9179A (Appellant) (Respondent) Shri Pranshu Singhal, Ca Assessee By & Ms. Mansi Jain, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 30/10/2025 Date Of Pronouncement 09/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 07.03.2025 In Appeal No.40/10204/2018-19 Arising Out Of The Order Passed By The Income Tax Officer, Ward-40(3) U/S 143(3) Of The Act (‘The Act’ For Short) Dated 20.12.2016 For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Proprietor Of M/S Triambkay Gauri Impex. The Information Was Received By The Ao From Investigation Wing That There Were Cash Deposits In The Bank Account Of The Assesse With Icici Bank, However, Income Of The Assessee & Gross Receipt Has Not Rakesh Divedi Vs. Income Tax Officer Commensurate With The Cash So Deposited, Therefore, After Recording The Reason U/S 147, Notice U/S 148 Was Issued On 31.03.2016 After Obtaining Statutory Approval From The Pcit. Thereafter, Assessment Was Completed Vide Order Dated 20.12.2016 Wherein Total Addition Of Rs. 5,20,88,345/- Was Made U/S 68 Of The Act For Cash Deposited In The Bank Accounts By Holding The Same As Unexplained Cash Credits. 3. Against The Said Order, Assessee Has Filed An Appeal Before Ld. Cit(A) Who Vide Impugned Order Has Partly Allowed The Appeal Of The Assessee & Directed The Ao To Make Addition Of Peak Credit Of The Total Deposits In The Bank Accounts.

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68

case, the Ld. CIT(A) has erred in confirming the order of the AO despite the same having been made on the basis of reasons recorded without there being independent application of his mind. (ii) That the reassessment order passed by the AO is bad and liable to be quashed ... with respect to the validity of reopening of the assessment as the approval given by ld. PCIT is mechanical approval and reasons recorded are vague and based on borrowed satisfaction. 10. Heard both the parties and perused the materials available on record. In the instant case, ld. PCIT has granted

Assisstant Commissioner of Income Tax, Jhandewalan Extn vs. Om Prakash Arora, Connaught Place

In the result, appeal of the Revenue vide ITA No

ITA 5031/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue Cross Objection No.42/Del/2025 (Arising Out Of Ita No.5031/Del/2024) [Assessment Year: 2015-16] Om Prakash Arora, Assistant Commissioner Of Income M-3, Flat No.103, Avg Tax, Central Circle-01, Bhawan The Variety Books Vs E-2, Jhandewalan Extn. Depot. Connaught Place, New Delhi-110055 New Delhi-110001 Pan-Accpa9774F Assessee Revenue [Assessment Year: 2016-17] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue

Section 139(1)Section 143(3)Section 147Section 148Section 151

escaped assessment. In response to the said notice, the Appellant filed return of income on 20.02.2019. The Appellant also requested for supply of reasons recorded before issue of notice under section 148 of the Act for reopening the assessment. The certifiedof the reasons recorded was supplied to the Appellant ... Nos.5029 & 5031/Del/2024 & CO No.42/Del/2025 transferred to the learned Addl. CIT under section 127 of the Act. It was also contested that the reasons recorded were unsigned, undated and without any stamp or seal of the office and therefore, such unsigned and undated reasons could not be taken as valid reasons

Assisstant Commissioner of Income Tax, Jhandewalan Extn vs. Om Prakash Arora, Connaught Place

In the result, appeal of the Revenue vide ITA No

ITA 5029/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Section 139(1)Section 143(3)Section 147Section 148Section 151

Best Bull Stock Trading Pvt Ltd., New Delhi vs. ACIT, Central Circle-18, New Delhi

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

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

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

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

below the rank of Asstt. CIT or Dy. CIT unless the Jt. CIT is satisfied on the reasons recorded by such AO that it is a fit case for the issue of such notice. Provided that, after the expiry of four years from the end of the relevant assessment year ... such notice shall be issued unless the Chief CIT or CIT is satisfied, on the reasons recorded by the AO aforesaid, that it is a fit case for the issue of such notice. (2) In a case other than a case falling under sub-s. (1), no notice shall

Best Bull Stock Trading Pvt Ltd., New Delhi vs. ACIT Central Circle-18, Delhi

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

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

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

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

Assistant Commissioner of Income Tax, Central Circle-25 New Delhi, Delhi vs. Faridabad Presswell Pvt Ltd, Delhi

In the result, the appeal of the

ITA 2801/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2801/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Assistant Commissioner Of Faridabad Presswell Pvt. Ltd. Income Tax, Vs. 24, Ashoka Chamber, 5B, Central Circle-25, Room No.317, Rajindra Park, Pusa Road, 3Rd Floor, E-2, Ara Centre, New Delhi. Jhandewalan Extension, Pan No. Aaacfs815B Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 250

around was not so categorical. Even so, such ground could be inferred from the fact that the assessee had been repeatedly asking for the reasons recorded, which were not supplied to her. Even before the Tribunal, right from September 2004, the assessee 6 had been requesting for production ... adjudication. The Ld. DR argued that the case of Smt. Gurinder Kaur (supra) was distinguishable as in that case the reasons recorded were never shared with the assessee. The Ld. DR concluded her arguments by stating that the ground challenging the irregularity in exercise of powers u/s 153D

Afsha Shamim Ahmed Khan, Nashik vs. The ITO Ward-1(3), Nashik

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

ITA 2858/PUN/2025[2010-11]Status: DisposedITAT Pune08 Jan 2026AY 2010-11

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2858/Pun/2025 निर्धारण वषा / Assessment Year: 2010-11 Afsha Shamim Ahmed Khan, V The Income Tax Officer, 11, Paradise Plaza, Opposite S Ward-1(3), Nashik. Alone Point, Hotel Shingada Talao, Nashik – 422001. Pan: Azmpk3812B Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod Shingte Revenue By Shri Madhukar Anand – Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2010-11 Dated 20.03.2025 Emanating From The Assessment Order Passed Under Section 144 Of The Act, Dated 11.12.2017. The Assessee Has Raised The Following Grounds Of Appeal :

Section 142(1)Section 144Section 148Section 2(14)Section 250Section 271(1)(c)Section 54

No.2858/PUN/2025 [A] Income-tax[2023] 149 taxmann.com 248 (Bombay)Writ Petition No.3259 of 2022February 10,2023 has directed Assessing Officer to provide copy of reasons recorded along with copy of approval by the competent authority and copy of information based on which notice u/s.148 issued. Therefore, respectfully following

Pinnacle Consrto and Ecohomes Pvt.Ltd, Pune vs. DCIT Circle-4, Pune

In the result, appeal filed by the assessee is allowed

ITA 2818/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2818/Pun/2025 निर्धारण वषा / Assessment Year : 2017-18 Pinnacle Contro & V Dcit, Ecohomes Pvt. Ltd., S Circle-4, Pune. Madhav Heritage, Tilak Road, Sadashiv Peth, Pune – 411030. Pan: Aaecp0400E Appellant/ Assessee Respondent /Revenue Assessee By Shri Suhas P. Bora Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18Dated 01.10.2025 Emanating From The Assessment Order Passed Under Section 147 Of The Act, Dated 27.08.2021. The Assessee Has Raised The Following Grounds Of Appeal : “1. Reassessment Bad In Law.

Section 143(3)Section 147Section 148Section 151Section 250Section 250(6)

fresh tangible material and corroborative evidence warranting the reopening of the case u/s 148 of the Act was available with the Assessing Officer; the reasons recorded merely reflect a change of opinion and is bad in law and without jurisdiction 3. Failure to furnish relied-upon material. The learned ... furnish the documents and evidences allegedly relied upon while recording the reasons for reopening (such as the verbatim copy of the reasons recorded for re-opening of the assessment and the copy of sanction taken from Jt. Commissioner of Income Tax U/s. 151 of the Act to issue Notice

Income Tax Officer, Pune vs. Sagar Construction Company, Pune

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT

Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

No.43/PUN/2025 18. The Ld. Counsel for the assessee in his yet another plank of argument submitted that as per the reasons recorded by the Assessing Officer, he has stated that the assessee has taken loan of Rs.1,62,00,000/- in cash and interest amount has also been paid ... that the above contrary stand taken by the Assessing Officer shows that there is absolutely lack of mind by the Assessing Officer and the reasons recorded are merely on the basis of presumption. The Assessing Officer has not carried out any inquiry or verified the facts before drawing the conclusion

M. Shashikant and Co, Mumbai vs. Ward 23(2)(1), Mumbai

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

ITA 6599/MUM/2025[2010-11]Status: DisposedITAT Mumbai08 Jan 2026AY 2010-11

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 143(1)Section 143(3)Section 147

engaged in providing accommodation entries in the guise of purchase transactions. 4. On the basis of the said information, it was alleged in the reasons recorded that the assessee had obtained accommodation purchase entries of ₹67,05,344/- from M/s. Aadi Impex and ₹9,94,644/- from M/s. Kailash Enterprises ... actual purchases from M/s. Aadi Impex were only to the extent of ₹49,17,130/- and not ₹67,05,344/- as stated in the reasons recorded. 3 M Shashikant And Co 5. In response to the show cause issued by the Assessing Officer, the assessee furnished comprehensive documentary evidence

Saluja Steel and Power Pvt. Ltd., Giridih vs. ACIT, C, Dhanbad

In the result, appeal of the assessee is allowed

ITA 287/RAN/2025[13-14]Status: DisposedITAT Ranchi07 Jan 2026

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: Shri Devesh Poddar, AdvocateFor Respondent: Shri Rajib Jain, CIT-DR

Section 131Section 142(1)Section 143(3)Section 148Section 156

search operation, reasons were the paper book. The same reads as follows :- ITA No.287/Ran/25 6. It was the submission that in the reasons recorded the AO recorded the names of the companies in the first page as Riddhi Siddhi Investment Pvt. Ltd., M/s Shivam Financial Consultants ... Ganeev Associate is a partnership firm wherein some of the directors with the assessee company are also partners. Ld. AR submitted that in the reasons recorded the AO has alleged that the share applicants are bogus company and that Ganeev Associates does not appear in the list of shareholders reported

Colen Chemical Pvt. Ltd., Jamshedpur vs. ITO, Ward 1(1), Jamshedpur

In the result, both appeals of the assessee are allowed

ITA 167/RAN/2025[2014-15]Status: DisposedITAT Ranchi07 Jan 2026AY 2014-15

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita No.165 & 167/Ran/2025 (निि ारण वर्ा / Assessment Year :2013-2014 & 2014-2015) Colen Chemical Pvt. Ltd, Vs. Ito Ward-1(1), Jamshedpur 1St Floor, Room No.9, Tiwary Bechar Complex, Main Rd. Bistupur, Jamshedpur-831001 स्थायी लेखा सं./Pan No. : Aabcc 3978 K (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri Sunil Surana, Ar राजस्व की ओर से /Revenue By : Shri Ram Chandra Marndi, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख/Date Of Pronouncement : 07/01/2026 आदेश / O R D E R Per Bench : These Two Appeals Are Filed By The Assessee Against The Separate Orders Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Both Dated 31.03.2025 For The Assessment Year 2013-2014. 2. It Was Submitted By The Ld.Ar That For The Assessment Year 2013- 2014 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29/01/2016 & For The Assessment Year 2014-2015 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29.12.2016. Notice U/S.148 Of The Act For A.Y.2013-2014 Came To Be Issued On 28.03.2018 & For A.Y.2014-2015 The Notice Was Issued On 24.06.2019. The Ld. Ar Drew Our Attention To Reason Recorded To Reopening For The Assessment Year 2013-2014 At Pages 47 To 51 Of The Paper Book Which Reads As Follows:-

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ram Chandra Marndi, Sr.DR

Section 143(3)Section 147Section 148

A.Y.2013-2014 came to be issued on 28.03.2018 and for A.Y.2014-2015 the notice was issued on 24.06.2019. The Ld. AR drew our attention to reason recorded to reopening for the assessment year 2013-2014 at pages 47 to 51 of the paper book which reads as follows:- ITA No.165&167/Ran/25 ... No.165&167/Ran/25 3. The Ld. AR drew our attention to reason recorded to reopening for the assessment year 2014-2015 at pages 5 to 9 of the paper book which reads as follows:- ITA No.165&167/Ran/25 ITA No.165&167/Ran/25 4. It was submission that as the reopening has been done

Colen Chemical Pvt. Ltd., Jamshedpur vs. ITO, Ward 1(1), Jamshedpur

In the result, both appeals of the assessee are allowed

ITA 165/RAN/2025[2013-14]Status: DisposedITAT Ranchi07 Jan 2026AY 2013-14

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ram Chandra Marndi, Sr.DR

Section 143(3)Section 147Section 148

Late Joseph George Ashok George Varrakunnel Rep. by Legal Heir, Chennai vs. DCIT, Company Circle-II(2), Chennai

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

ITA 2067/CHNY/2025[2011-12]Status: DisposedITAT Chennai07 Jan 2026AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2067/Chny/2025 िनधा"रण वष"/Assessment Year: 2011-12 Late Joseph George Ashok George Vs. The Deputy Commissioner Of Vattakunnel Rep. By Legal Heir, Home Income Tax, Stead Apartment B3 B Block, It Company Circle Ii(2), Highway, Kandanchavadi, Chennai. Chennai 600 096. [Pan:Adppv0091E]

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT

Section 54Section 54FSection 68

three occasions and the same are placed at pages 3, 8 & 9 of the paper book and we find no reasons recorded by the ld. CIT(A) in respect of such submissions in the impugned order. Considering the facts and circumstances of the case, we remand the matter

Kaishar Interiors Private Limtied, Mumbai vs. Deputy Commissioner of Income Tax Circle 4(2)(2), Mumbai

Accordingly Ground No.16 raised by the Assessee is allowed

ITA 5665/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh Kukreja &For Respondent: Shri Hemanshu Joshi

Section 143(3)Section 147Section 148Section 14A

proceedings under Section 147 of the Act were initiated by issuance of notice, dated 18/03/2015, under Section 148 of the Act. Copy of the reasons recorded for reopening the assessment were provided to the Assessee against which the Assessee filed objections. In the objections the Assessee took a stand that ... parties stated in the reasons recorded for reopening assessment from whom the Assessee was alleged to have taken bogus accommodation entry, the Assessee had only transacted with 3 parties (namely, M/s. Parasnath Enterprises, M/s. Shiv Industries & Karni Granimarmo Pvt. Ltd.) during the relevant previous year. Further, the Assessing Officer