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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

Sms Group Gmbh, New Delhi vs. ACIT, Circle-3(1)(2) Int. Taxation, New Delhi

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

ITA 1592/DEL/2022[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

assessee raising preliminary objections and brought to our notice relevant submissions made along with reliance of the decision of ITAT, Vishakhapatnam objecting to the reasons recorded for reopening the assessment. Further, he referred to page 1 of supplementary paper book, which are the submissions made before ... Group Gmbh the AO has treated these receipts as FTS in reassessment order instead of treating them as business receipts as mentioned in the reasons recorded. However, ld. CIT (A) observed that it does not vitiate the reassessment proceedings because some receipts as mentioned in the reasons recorded has been

Sms Group Gmbh, New Delhi vs. ACIT, Circle-3(1)(2), Int. Taxation, New Delhi

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

ITA 1591/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

assessee raising preliminary objections and brought to our notice relevant submissions made along with reliance of the decision of ITAT, Vishakhapatnam objecting to the reasons recorded for reopening the assessment. Further, he referred to page 1 of supplementary paper book, which are the submissions made before ... Group Gmbh the AO has treated these receipts as FTS in reassessment order instead of treating them as business receipts as mentioned in the reasons recorded. However, ld. CIT (A) observed that it does not vitiate the reassessment proceedings because some receipts as mentioned in the reasons recorded has been

Hiteshbhai Rameshbhai Patel, Surat vs. ITO Ward, 2, Bardoli

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

ITA 484/SRT/2025[2012-13]Status: DisposedITAT Surat23 Dec 2025AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-13 Hiteshbhai Rameshbhai Patel Income Tax Officer, 466 Kanbivad, Goddha Mahuwa, Ward-2, Bardoli, Income Tax Taluka Valod, Dist. Surat 394630 Vs. Office, 2Nd Floor, Bsnl Gujarat, Building, Opp. Jalaram Temple, Station Road, Bardoli- 394601 Pan No. Avdpp 6788 Q Appellant Respondent Assessee By : Mr. Sakar Sharma, Ar Revenue By : Mr. J.K. Chandani, Sr-Dr

For Appellant: Mr. Sakar Sharma, ARFor Respondent: Mr. J.K. Chandani, Sr-DR
Section 143(3)Section 147Section 148Section 151(1)Section 68

constitute income and, therefore, could not form the basis for recording a valid belief of escapement of income. It was submitted that the reasons recorded by the Assessing Officer were founded on mere suspicion, were vague and far-fetched, and disclosed no tangible material to indicate tax evasion ... Coming to the merits of the additional ground, we observe that the assessee has not placed on record a copy of the reasons recorded for reopening. However, from the assessment order, it is evident that the Assessing Officer recorded reasons on the basis of information regarding substantial cash deposits aggregating

Shri Shanidev Charitable Trust, Ajmer vs. CIT Exemption, Jaipur

The appeals are hereby dismissed being barred by limitation

ITA 477/JPR/2025[2024-25]Status: HeardITAT Jaipur23 Dec 2025AY 2024-25

Bench: Learned Cit(E), Jaipur By Way Of Two Application I.E. One U/S 12A(1)(Ac)(Iii) Of The Income Tax Act ( In Short “The Act”) To Seek Its Registration. Shri Shanidev Charitable Trust, Ajmer. Another Application Were Also Presented By The Applicant Before Learned Cit(E) Seeking Approval U/S 80G Of The Act.

For Appellant: NoneFor Respondent: Shri Rajesh Ojha, CIT
Section 12A(1)(ac)Section 3Section 5Section 80G

Vide two separate orders of same date i.e. 29.11.2024, Learned CIT(E) rejected both the application for the reasons recorded therein. That is how, the impugned orders are challenged by the applicant trust. 3. Feeling aggrieved by the rejection of the above said two applications, the applicant Trust presented before ... jurisdiction of condoning the delay. There is no occasion for us to interfere with the discretion so exercised by the High Court for the reasons recorded. First, the claimants were negligent in pursuing the reference and then in filing the proposed appeal. Secondly, most of the claimants have accepted

Shri Shanidev Charitable Trust, Ajmer vs. CIT Exemption, Jaipur

The appeals are hereby dismissed being barred by limitation

ITA 476/JPR/2025[2024-25]Status: HeardITAT Jaipur23 Dec 2025AY 2024-25

Bench: Learned Cit(E), Jaipur By Way Of Two Application I.E. One U/S 12A(1)(Ac)(Iii) Of The Income Tax Act ( In Short “The Act”) To Seek Its Registration. Shri Shanidev Charitable Trust, Ajmer. Another Application Were Also Presented By The Applicant Before Learned Cit(E) Seeking Approval U/S 80G Of The Act.

For Appellant: NoneFor Respondent: Shri Rajesh Ojha, CIT
Section 12A(1)(ac)Section 3Section 5Section 80G

Vide two separate orders of same date i.e. 29.11.2024, Learned CIT(E) rejected both the application for the reasons recorded therein. That is how, the impugned orders are challenged by the applicant trust. 3. Feeling aggrieved by the rejection of the above said two applications, the applicant Trust presented before ... jurisdiction of condoning the delay. There is no occasion for us to interfere with the discretion so exercised by the High Court for the reasons recorded. First, the claimants were negligent in pursuing the reference and then in filing the proposed appeal. Secondly, most of the claimants have accepted

Khazana Stores Pvt. Ltd., Ahmedabad vs. The ITO, Ward-2(1)(1), Ahmedabad

ITA 1506/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Makarand Vasant Mahadeokarआयकर अपील सं/Ita No. 1506/Ahd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Khazana Stores Pvt. Ltd. The Ito Gf 2 Commerce House 2 बनाम/ Ward 2(1)(1) Judges Bunglow Road, V/S. Ahmedabad 380 015 Bodakdev, Ahmedabad 380 054 स्थायी लेखा सं./Pan: Aaack 7880 R (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) Assessee By: Shri S.N. Divatia & Shri Samir Vora, Ars Revenue By : Shri Kalpesh Rupavatia, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 30/09/2025 घोषणा की तारीख / Date Of Pronouncement: 23/12/2025 आदेश/Order 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 07/07/2025 For Assessment Year (Ay) 2017-18. 2. The Assessee, In This Appeal Has Taken The Following Grounds Of Appeal:

For Appellant: Shri S.N. Divatia &For Respondent: Shri Kalpesh Rupavatia, Sr. DR
Section 143(1)Section 147Section 148Section 250Section 69A

legal ground. 5. The Ld.AR at the outset, has drawn our attention to the opening para of the assessment, wherein, the AO has mentioned reasons recorded for re- opening of the assessment as under: "The assessee's case has selected/pushed through Insight Portal for reopening of assessment u/s.147 ... such, the assessment of the assessee is being reopened on the basis of the information available in the insight portal and the reason recorded accordingly. It is worthwhile to point out here that the proposal of the reopening of the assessment is not prepared on the format given

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 427/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

bogus loan taken from Dishman Group holding the same as the unaccounted income of the assessee, as against the observation made in the reasons recorded of bogus expenses of commission paid. 5 The Ld. CIT(A) confirmed the addition so made by AO. The assessee has, thus, come in appeal ... Representatives of the parties and gone through the record. At the outset, the Ld. Counsel for the assessee has invited our attention to the reasons recorded for reopening of the assessment, copy of which has been placed at paper book page No. 125 onwards, contents of which, for the sake

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby\nallowed

ITA 426/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2015-16
For Appellant: \nShri S.N. Soparkar, Sr.AdvocateFor Respondent: \nShri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

bogus loan taken from\nDishman Group holding the same as the unaccounted income of the assessee,\nas against the observation made in the reasons recorded of bogus expenses of\ncommission paid.\n5 The Ld. CIT(A) confirmed the addition so made by AO. The assessee\nhas, thus, come in appeal ... Representatives of the\nparties and gone through the record. At the outset, the Ld. Counsel for the\nassessee has invited our attention to the reasons recorded for reopening of the\nassessment, copy of which has been placed at paper book page No. 125\nonwards, contents of which, for the sake

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 425/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

bogus loan taken from Dishman Group holding the same as the unaccounted income of the assessee, as against the observation made in the reasons recorded of bogus expenses of commission paid. 5 The Ld. CIT(A) confirmed the addition so made by AO. The assessee has, thus, come in appeal ... Representatives of the parties and gone through the record. At the outset, the Ld. Counsel for the assessee has invited our attention to the reasons recorded for reopening of the assessment, copy of which has been placed at paper book page No. 125 onwards, contents of which, for the sake

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 424/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

bogus loan taken from Dishman Group holding the same as the unaccounted income of the assessee, as against the observation made in the reasons recorded of bogus expenses of commission paid. 5 The Ld. CIT(A) confirmed the addition so made by AO. The assessee has, thus, come in appeal ... Representatives of the parties and gone through the record. At the outset, the Ld. Counsel for the assessee has invited our attention to the reasons recorded for reopening of the assessment, copy of which has been placed at paper book page No. 125 onwards, contents of which, for the sake

Yash Sugars Limited, Georai vs. PCIT, Nashik-1, Nashik

In the result, the appeal filed by the assessee is dismissed as Infructuous

ITA 1108/PUN/2024[2014-15]Status: DisposedITAT Pune23 Dec 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1108/Pun/2024 Assessment Year : 2014-15 Yash Sugars Limited, Vs. Pcit, Nashik-1 Plot No.18, Saraswati Colony, Rangar Chowk, Taluk Georai, Georai – 431 127 Maharashtra Pan : Aaacy3092K Appellant Respondent

For Appellant: Shri Shubham RathiFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(2)Section 143(3)Section 263Section 68

Demerger during the year and the Assessing Officer has travelled beyond his jurisdiction and made the addition of unsecured loans other than the reasons recorded for reopening. On merits, the assessee company contended that certain amounts were inadvertently remaining to be mentioned while filing the income tax return

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. Siddheshwari Vyapaar Private Limited, Kolkata

In the result, appeal of the revenue is dismissed

ITA 2280/KOL/2025[2012-13]Status: DisposedITAT Kolkata23 Dec 2025AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.2280/Kol/2025 (निर्धारणवर्ा/Assessment Years :2012-2013) Dcit, Central Circle-1(2), Vs Siddheshwarivyapaar Pvt Ltd Kolkata 2Nd Floor, 159, Ravindra Sarani Kolkata-700007 Pan No. :Aancs 2337 J (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) रधजस्वकीओरसे /Revenue By : Shri Sanat Kumar Raha, Cit-Dr निर्धाररतीकीओरसे /Assessee By : Shrisoumitra Choudhury & Rainak Jain, Advocates सुनवाई की तारीख / Date Of Hearing : 09/12/2025 घोषणा की तारीख/Date Of Pronouncement : 23.12.2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Revenueagainst The Order Passed By The Ld. Cit(A), Kolkata-20, Dated 06.05.2025For The Assessment Year2012-2013. 2. The Appeal Of The Revenue Is Barred By 69 Days. Considering The Submissions Of The Ld. Cit-Dr & Looking To The Facts Of The Case, We Condone The Delay Of 69 Days In Filing The Present Appeal By The Revenue & The Appeal Is Admitted For Hearing. 3. The Only Issue Raised In This Appeal Is Against The Order Of The Ld. Cit(A) In Deleting The Addition Of Rs.6,82,00,000/- Made U/S.68 Of The Act On Account Of Unexplained Cash Credits Received From Shell Entities In The Guise Of Share Capital.

For Appellant: ShriSoumitra Choudhury and Rainak Jain, AdvocatesFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 131Section 133(6)Section 143(2)Section 143(3)Section 148Section 68

total income of the assessee. 5. In appellate proceedings, the ld. CIT(A)quashed the reopening of the assessment by observing that the reasons recorded by the Assessing Officer were based on incorrect facts and lack of independent application of mind, by observing and holding as under :- 5.1 I have ... proprietorship concern, which subsequently moved through M/s Runicha Merchants Ltd and finally reached M/s PanchratanCommotrade Pvt. Ltd. The appellant has strongly objected to the reasons recorded for the reopening, both 4 before the AO and before this office. It was specifically contended that the recorded reasons were factually incorrect

Mahak Doshi Legal Heir of Late Aditya Doshi, Kolkata vs. I.T.O., Ward - 2(1), Kolkata

Appeal of the assessee is allowed

ITA 2075/KOL/2025[2011-2012]Status: DisposedITAT Kolkata23 Dec 2025AY 2011-2012

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 147Section 148Section 250

pertinent to note that the assessee filed return of income declaring total income of Rs. 10,82,800/-. We note that the reasons recorded by the AO are very cryptic and were recorded without any application of mind. For the sake of reference, the reasons recorded are extracted below: “Information ... actually undisclosed income of assessee Shri Aditya Doshi during F.Y. 2010-11 relevant to AY 2011- 12.” 4. The perusal of above reasons recorded reveals that the AO has not recorded any satisfaction in the reasons to believe and relied on the information received from DGIT (Inv.) without doing

Aalekha Supply Pvt. Ltd., Kolkata vs. I.T.O., Ward - 4(3), Kolkata

Appeal of the assessee is allowed

ITA 1286/KOL/2025[2013-2014]Status: DisposedITAT Kolkata23 Dec 2025AY 2013-2014

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 139(1)Section 147Section 148Section 250

notice u/s 148 of the Act on 02.06.2020 declaring the same as was declared u/s 139(1) of the Act. We have perused the reasons recorded by the AO. We find that the same are very cryptic, non speaking and recorded without application of mind and that at best

Pinkal Dilip Bhansali, Mumbai vs. Income Tax Officer 19(2)(4), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 1701/MUM/2025[2011-12]Status: DisposedITAT Mumbai23 Dec 2025AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2011-12

For Appellant: Mr. Sapnesh D Sheth (Virtually
Section 148Section 69C

lacked the reopening was based on borrowed satisfaction, lacked the reopening was based on borrowed satisfaction, lacked independent application of mind, and that the reasons recorded independent application of mind, and that the reasons recorded independent application of mind, and that the reasons recorded were vague and did not establish ... have considered the submissions and examined the We have considered the submissions and examined the We have considered the submissions and examined the reasons recorded for reopening. It is evident that the Assessing reasons recorded for reopening. It is evident that the Assessing reasons recorded for reopening. It is evident

Estate of Vandravan P Shah, Mumbai vs. Assistant Commissioner of Income Tax, Circle 19(3), Mumbai

In the result all the three captioned appeals are dismissed

ITA 5403/MUM/2024[2017-18]Status: DisposedITAT Mumbai23 Dec 2025AY 2017-18
Section 132Section 147Section 148Section 153CSection 159Section 35A

nCIT(A) grossly erred in approving the validity of the re-opened\nassessment order overlooking the following fats and legal issues:\nThe reasons recorded clearly indicate that the AO did not\npossess the documentary evidence as also, the statement recorded\non the basis of which the genuineness of contribution made ... ncontrary to the law and in violation to the first proviso to section\n147 of the Act in as much as the reason recorded do not indicate\nany failure on the part of the assessee to disclose truly and fully\nall the material facts necessary for assessment.\n2. That

Estate of Vandravan P Shah, Mumbai vs. Assistant Commissioner of Income Tax, Circle 19(3), Mumbai

In the result all the three captioned appeals are dismissed

ITA 5402/MUM/2024[2012-13]Status: DisposedITAT Mumbai23 Dec 2025AY 2012-13
For Appellant: Ms. Shivani ShahFor Respondent: Mr. Hemanshu Joshi, Sr. DR
Section 132Section 147Section 148Section 153CSection 159Section 35A

nCIT(A) grossly erred in approving the validity of the re-opened\nassessment order overlooking the following fats and legal issues:\nThe reasons recorded clearly indicate that the AO did not\npossess the documentary evidence as also, the statement recorded\non the basis of which the genuineness of contribution made ... ncontrary to the law and in violation to the first proviso to section\n147 of the Act in as much as the reason recorded do not indicate\nany failure on the part of the assessee to disclose truly and fully\nall the material facts necessary for assessment.\n2. That

Estate of Vandravan P Shah, Mumbai vs. Assistant Comissioner of Income Tax, Circle 19(3), Mumbai

In the result all the three captioned appeals are dismissed

ITA 5401/MUM/2024[2011-12]Status: DisposedITAT Mumbai23 Dec 2025AY 2011-12

Bench: Sandeep Gosain () & Shri Om Prakash Kant ()

For Respondent: Ms. Shivani Shah
Section 147Section 148Section 35A

following fats and legal issues: assessment order overlooking the following fats and legal issues: assessment order overlooking the following fats and legal issues: - The reasons recorded clearly indicate that the AO did not The reasons recorded clearly indicate that the AO did not The reasons recorded clearly indicate that ... section contrary to the law and in violation to the first proviso to section 147 of the Act in as much as the reason recorded do not indicate 147 of the Act in as much as the reason recorded do not indicate 147 of the Act in as much

Gdr Finance and Leasing P. Ltd, Delhi vs. Income Tax Officer, Delhi

In the result, the appeal of the assessee is allowed

ITA 802/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2018-19 M/S Gdr Finance & Leasing Vs. Assessment Unit, Pvt. Ltd., Income Tax Officer, 323, Agrawal Plaza, Nfac. Dda Community Centre, Shalimar Bagh, New Delhi – 110 088. Pan: Aaacg2363D (Appellant) (Respondent) Assessee By : Shri C.S. Aggarwal, Sr. Advocate; Shri Rupinder Aggarwal, Shri R.P. Mall, Shri Uma Shankar, Ms Suman Verma & Ms Vidushi Aggarwal, Advocates Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 23.12.2025 Order Per Vimal Kumar, Jm:

For Appellant: Shri C.S. Aggarwal, Sr. AdvocateFor Respondent: Shri Om Parkash, Sr. DR
Section 133(6)Section 142Section 143(2)Section 147Section 148Section 148ASection 151ASection 250

either on facts or legality. Hence, the order of the Assessing Officer is treated as void ab inito, in the absence of any valid reasons recorded.” 7.3 In view of the above material facts, by respectfully following the judicial precedent, it is held that the ld. AO, in the satisfaction

Jaibro Industries, Delhi vs. ACIT, Delhi

In the result, the appeal of the assessee is dismissed

ITA 100/DEL/2025[2012-13]Status: DisposedITAT Delhi23 Dec 2025AY 2012-13

Bench: Shri M. Balaganesh & Shri Vimal Kumarassessment Year : 2012-13 Jaibro Industries, Vs. Acit, T-306, Vikas Chamber, Circle 36(1), D-Block, Central Market, New Delhi. Prashant Vihar, New Delhi – 110 034. Pan: Aagfj4977R

For Appellant: NoneFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 131Section 132Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

erred in law in upholding the validity of proceedings u/s 147 read with section 148 of the Act, ignoring the fact that the reasons recorded for issue of notice under section 148 of the Act are without making any allegation that the appellant has failed to disclose fully and truly