“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

Shri Parasram Commodities Pvt Ltd., Delhi vs. DCIT, Circle-23(1), Delhi

In the result the appeal of the assessee is allowed

ITA 4630/DEL/2025[2012-13]Status: DisposedITAT Delhi18 Mar 2026AY 2012-13

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2012-13

Section 143(3)Section 147Section 148Section 68

sham transaction. The assessee explained all material facts regarding genuineness of the transaction. He further submitted that the addition is not based on the reasons recorded for re-opening. The reasons for re-opening was only for that the assessee has provided amount of Rs. One Crore to Shri Ravinder

Chhabi Lata Sahu, Rourkela vs. Income Tax Officer, Ward-4, Rourkela

In the result, the appeal of the assessee is allowed

ITA 626/CTK/2025[2009-10]Status: DisposedITAT Cuttack16 Mar 2026AY 2009-10

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2009-10 Chhabi Lata Sahu Ito, Ward-4, Rourkela

For Appellant: Shri S. K. Sarangi & Bishwa Jyoti Pattnaik, ARsFor Respondent: Shri Shakeer Ahamed, Sr. DR

Section 143Section 148

Ahamed, Sr. DR represented on behalf of the revenue. 3. It was submitted by the ld. AR placed before us the copy of the reasons recorded and the same reads as under: 2 4. It was the submission that the original assessment in the case of the assessee was completed ... assessee has not fully and truly disclose all the material facts necessary for the assessment. It was the submission that on perusal of the reasons recorded it clearly shows that the reopening has been done only on the basis of reappraisal of the evidences as is already available in file

ACIT-17(1), Mumbai vs. Sunil Giridhar Raheja HUF, Mumbai

In the result, the appeal filed by the Revenue stands partly allowed for statistical purposes

ITA 7560/MUM/2025[2013-14]Status: DisposedITAT Mumbai16 Mar 2026AY 2013-14

Bench: Smt. Beena Pillai () & Shri Arun Khodpia ()

Section 133(6)Section 148Section 68

Wing report, extracted in the assessment order, specifically states that the assessee received Rs.25,00,000/- from M/s. Sampada Chemicals Ltd., and even the reasons recorded for reopening indicated that only Rs. 25,00,000/- had escaped assessment. 4.1. The Ld.AR submitted that, however, before concluding the assessment, the Ld.AO ... enquiry, the Ld. AO proceeded to 5 I.T.A. No. 7560/Mum/2025 make addition of Rs. 50,00,000/-, which was beyond the scope of the reasons recorded for reopening the assessment. 4.2. The Ld. AR further submitted that, the details furnished by the assessee were never properly verified

Granules India Limited, Hyderabad vs. DCIT, Circle-2(1), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 1289/HYD/2025[2010-11]Status: DisposedITAT Hyderabad13 Mar 2026AY 2010-11

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआयकर अपील सं / Ita No.1289/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2010-11) Granules India Limited Vs. Dcit- Circle -2(1) 15Th Floor, Granules Tower Signature Tower, Botanical Garden Road Sy. No. 6(P) Of Kondaput Kondapur, Hyderabad – 500084 Sy. No. 37 Of Kothaguda Telangana Opp. Botanical Gardens Serilingampalluy, R.R. District Pan: Aaacg7369K Hyderabad-500084, Telangana (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

Section 10BSection 143(3)Section 148Section 154Section 271(1)(c)

book profits at Rs.30,50,73,292/-. 8. The case has been, subsequently reopened under section 147 of the Act for the reasons recorded, as per which, income chargeable to tax had been escaped assessment on account of excess allowance of deductions towards profit derived from 100% export-oriented undertakings ... assessee vide letter dated 04.12.2017 once again made a request for reasons for reopening of the assessment. The A.O. vide letter dated 08.12.2017 furnished reasons recorded for reopening of the assessment as requested by the assessee. The assessee did not file any objections in response to reasons for reopening

Deputy Commissioner of Income Tax, Chennai vs. M/S Sundaram Asset Management Company Limited, Chennai

In the result, both the appeals filed by the Revenue are dismissed

ITA 2281/CHNY/2025[2015]Status: DisposedITAT Chennai13 Mar 2026

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.2280 & 2281/Chny/2025 िनधा"रण वष"/Assessment Years: 2013-14 & 2015-16 The Deputy Commissioner Of Vs. M/S. Sundaram Asset Management Income Tax, Company Limited, Circle 1 (Ltu), Chennai. No. 46, Sundaram Towers, Whites Road, Royapettah, Chennai 600 014. [Pan: Aaics4257J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Venkat Ramanan, Ca ""थ" की ओर से/Respondent By : Ms. C. Vatchala, Jcit सुनवाई की तारीख/ Date Of Hearing : 04.02.2026 घोषणा की तारीख /Date Of Pronouncement : 13.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against The Different Orders Dated 18.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) 16, Chennai, For The Assessment Years 2013-14 & 2015-16. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We

For Appellant: Shri Venkat Ramanan, CAFor Respondent: Ms. C. Vatchala, JCIT

Section 14ASection 194HSection 40Section 40a

Rule 8D. The ld. CIT(A) held the same would lead to double disallowance and deleted the same vide his reasons recorded at para 5.4.3 of the impugned order. On perusal of para 5.4.3 of the impugned order, we find no infirmity in the order

Deputy Commissioner of Income of Tax, Chennai vs. M/S. Sundaram Asset Management Company Limited, Chennai

In the result, both the appeals filed by the Revenue are dismissed

ITA 2280/CHNY/2025[2013]Status: DisposedITAT Chennai13 Mar 2026

For Appellant: Shri Venkat Ramanan, CAFor Respondent: Ms. C. Vatchala, JCIT

Section 14ASection 194HSection 40Section 40a

Bharat Thakarshi Mamania, Mumbai vs. ITO 22(1)(6), Mumbai

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

ITA 8510/MUM/2025[2012-2013]Status: DisposedITAT Mumbai13 Mar 2026AY 2012-2013

Bench: Smt. Beena Pillai ()

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 69C

treat the original return of income as the return filed in response to the said notice and also sought a copy of the reasons recorded for reopening of the assessment. It is submitted that thereafter no communication was received from the Ld. AO until around 19/01/2019, when the assessee ... that In the said assessment order, the Ld. AO recorded that a notice under section 143(2) was issued on 31/03/2018, and that the reasons recorded for reopening were communicated to the 3 I.T.A. No. 8510/Mum/2025 assessee vide letter dated 15/10/2018. However, the Ld.AR contends that the assessee neither received

DCIT, Central Circle-32, Delhi vs. Bses Yamuna Power Limited, New Delhi

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

ITA 5474/DEL/2025[2009-10]Status: DisposedITAT Delhi13 Mar 2026AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumardcit, Bses Yamuna Power Limited, Central Circle-32, Room No.359, E2, Ara Centre, Delhi. Vs. Jhandewalan Extension, New Delhi-110055. [ Pan-Aabcc8569N (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Ms. Deepashree Rao, Adv. & Shri Shivam Gupta, Ca Department By Ms. Monika Singh, Cit-Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Revenue Is Against Order Dated 23.05.2025 Of The Learned Commissioner Of Income Tax (Appeals)-30, New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 20.12.2016 Of Ld. Assessing Officer/Dcit, Circle-5(1), New Delhi (Hereinafter Referred To As ‘The Ld. Ao’ ) U/S 147/143(3) Of The Act For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Original Return Of Income Was Filed By Assessee On 29.09.2009 U/S 139(1) Of The Act After Adjusting Brought Forward Losses Of Dcit Vs. Bses Yamuna Power Ltd.

Section 139(1)Section 143(3)Section 147Section 148Section 250

Liver Ltd. Vs. R.B. Wadkar (2004) 268 ITR 332 (Bom.) that once there is no scope of any addition/deletion or substitution in the reopening reasons recorded by the learned prescribed authority as the same have to be read on standalone basis, the CIT(A) has rightly decided the instant legal

Pbg International Private Limited, New Delhi vs. Income Tax Officer, Delhi

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

ITA 2890/DEL/2024[2016-17]Status: DisposedITAT Delhi13 Mar 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarpbg International Private Income Tax Officer, Limited, Ward-19(1), C.R. Building, Cb-4B, Dda Flats, Vs. Delhi-110002. Munirka, Delhi-110067. Pan-Aabcp8752E (Appellant) (Respondent) Assessee By Shri Anil Goyal, Ca Ms. Harpreet Kaur Hansra Sr. Dr Department By 20.01.2026 Date Of Hearing Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: This Appeal Filed By The Assessee Is Against Order Dated 29.04.2024 Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As 'The Ld. Cit(A)'] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As 'The Act'] Arising Out Of Assessment Order Dated 25.03.2022 Of The Ld. Assessing Officer U/S 147 R.W.S 144B Of The Act For Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Filed His Original Return Of Income On 14.10.2016 Declaring Total Income Of Rs.4,42,670/- Along With Computation Of Income, Auditors' Report & Audited Accounts Of The Assessee. Ld. Ao On Basis Of Incriminating & Tangible Information & After Following Due Process, Re-Opened Pbg International Pvt. Ltd. Vs. Ito

Section 142(1)Section 147Section 148Section 151Section 250Section 68Section 690

return filed in response to notice under section 148 dated 31.03.2021. Through this letter, the assessee had also requested for providing copies of the reasons recorded for reopening of the case. Accordingly, the AO provided copy of reasons recorded for reopening of the case along with approval under section

Jaswinder Singh Grewal, Punjab vs. Income Tax Officer, Ward 6(1), Chandigarh

In the result, appeal of the Assessee is dismissed

ITA 968/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh12 Mar 2026AY 2013-14

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 968/Chd/2025 "नधा"रण वष" / Assessment Year : 2013-14 Jaswinder Singh Grewal, The Ito, H. No. 569, Phase Iiia, बनाम Ward 6(1), Mohali 160053 Chandigarh Vs. "थायी लेखा सं./ Pan No: Ajwpg9873E अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. Vivek Vardhan, Addl. CIT

Section 115BSection 144Section 147Section 148Section 251Section 69A

file of Ld. AO. 3. That on law, facts, and circumstances of the case, the impugned reassessment order deserves to be quashed since the reasons recorded before issuing notice u/s 148 were factually incorrect and the amount of unexplained credit in reasons recorded

Nisha Dudheria, Bangalore vs. Income Tax Officer, Ward-5(2)(3), Bengaluru

In the result the ground No

ITA 316/BANG/2025[2015-16]Status: DisposedITAT Bangalore12 Mar 2026AY 2015-16

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2015-16 Ms. Nisha Dudheria, 66, Navniketan, The Income Tax Officer, Kr Road, Basavanagudi, Ward-5(2)(3), Vs. Bangalore – 560 004. Bangalore. Pan: Bkrpd5938G Appellant Respondent Shri K.R. Pradeep, Advocate & Assessee By : Ms. Girija G.P., Advocate : Shri Subramanian – Jcit Dr Revenue By Date Of Hearing : 09-02-2026 Date Of Pronouncement : 12-03-2026

For Appellant: Ms. Girija G.P., Advocate

Section 142Section 143Section 148Section 68

Assessee on 31.03.2018. The Assessee on 20.04.2018 by way of a letter reiterated her return of income filed originally. The Assessee asked for the reasons recorded for reopening of the assessment on 07.05.2018 which were provided to the assessee on 08.05.2018. Subsequently, on 21.12.2018, the assessee objected to the reopening

DCIT, Central Circle 1, Rajkot vs. R K Dreamland, Rajkot

ITA 564/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 143(3)Section 147Section 148Section 250

assessee vide notice dated:\n23.01.2023 and further, in view of natural justice, the images of original seized\nmaterial pertaining to the assessee and reasons recorded for the re-opening of the\nassessment have also been supplied and discussed in the notices issued

assessee vide notice dated: 23.01.2023 and further, in view of natural justice, the images of original seized material pertaining to the assessee and reasons recorded for the re-opening of the assessment have also been supplied and discussed in the notices issued

R K Dreamland, Rajkot vs. DCIT, CC-1, Rajkot

ITA 558/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 143(3)Section 147Section 148Section 250

R K Dreamland, Rajkot vs. DCIT, CC-1, Rajkot

ITA 557/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 143(3)Section 147Section 148Section 250

Rk Dreamland, Rajkot vs. ACIT, CC-1, Rajkot

ITA 556/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18

Section 143(3)Section 147Section 148Section 250

R K Dreamland, Rajkot vs. ACIT, CC-1, Rajkot, Rajokt

ITA 555/RJT/2024[2016-17]Status: DisposedITAT Rajkot11 Mar 2026AY 2016-17

Section 143(3)Section 147Section 148Section 250

Vibhuti Krunal Patel, Sabarmati vs. ITO Ward 2(1)(2) Ahmedabad, Vejalpur

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

ITA 1369/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad11 Mar 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Tr Senthil Kumar

For Appellant: Shri Vivek Chavda, ARFor Respondent: Shri Abhijit, Sr. DR

Section 115BSection 147Section 148

issued the notice u/s 148 mechanically merely relying upon the information received from the investigation wing. The AO never furnished the copy of reasons recorded to the appellant. Therefore, till today, the appellant is not aware about the core reason of reopening. However, on plain reading of the order