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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

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle-3(2)(2), Mumbai

ITA 2620/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 Nov 2025AY 2016-17
Section 115JSection 143(3)Section 147Section 148

filed on 24/03/2011 be treated as return filed in response to the notice issued under Section 148 of the Act. A copy of the reasons recorded for reopening assessment was furnished to the Assessee. The Assessee filed objections against the reasons recorded for reopening assessment which was disposed ... with section 147 of the Income Tax Act (‘the Act’) as valid. 2. The CIT(A) failed to appreciate the fact that in the reasons recorded, the AO has not disclosed any specific non- disclosure of material facts by the appellant.” 8. We have heard the both the sides

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle-3(2)(2), Mumbai

ITA 2619/MUM/2024[2015-16]Status: DisposedITAT Mumbai21 Nov 2025AY 2015-16
Section 115JSection 143(3)Section 147Section 148

filed on 24/03/2011 be treated as return filed in response to the notice issued under Section 148 of the Act. A copy of the reasons recorded for reopening assessment was furnished to the Assessee. The Assessee filed objections against the reasons recorded for reopening assessment which was disposed ... with section 147 of the Income Tax Act (‘the Act’) as valid. 2. The CIT(A) failed to appreciate the fact that in the reasons recorded, the AO has not disclosed any specific non- disclosure of material facts by the appellant." 8. We have heard the both the sides

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle -3(2)(2), Mumbai

ITA 2618/MUM/2024[2013-14]Status: DisposedITAT Mumbai21 Nov 2025AY 2013-14
Section 115JSection 143(3)Section 147Section 148

filed on 24/03/2011 be treated as return filed in response to the notice issued under Section 148 of the Act. A copy of the reasons recorded for reopening assessment was furnished to the Assessee. The Assessee filed objections against the reasons recorded for reopening assessment which was disposed ... with section 147 of the Income Tax Act (‘the Act’) as valid. 2. The CIT(A) failed to appreciate the fact that in the reasons recorded, the AO has not disclosed any specific non- disclosure of material facts by the appellant.” 8. We have heard the both the sides

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle -3(2)(2), Mumbai

ITA 2617/MUM/2024[2010-11]Status: DisposedITAT Mumbai21 Nov 2025AY 2010-11
Section 115JSection 143(3)Section 147Section 148

treated as filed in response\nto the notice under Section 148 of the Act. The Assessee was\nprovided a copy of reasons recorded for reopening the\nassessment and the same read as under:\n\nITA No. 2616-2623 /Mum /2024, ITA No. 2845, 2841, 2836, 2834,\n2827 ... assessment year.\n\n13. It is the contention of the Assessee that the reassessment\nproceedings are bad in law as, inter-alia, the reasons recorded\nby the Assessing Officer for reopening assessment reasons\nrecorded fail to demonstrate link between the tangible material\nand formation of belief that income chargeable

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(2)(2), Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2616/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Nov 2025AY 2012-13

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

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

filed on 24/03/2011 be treated as return filed in response to the notice issued under Section 148 of the Act. A copy of the reasons recorded for reopening assessment was furnished to the Assessee. The Assessee filed objections against the reasons recorded for reopening assessment which was disposed ... with section 147 of the Income Tax Act (‘the Act’) as valid. 2. The CIT(A) failed to appreciate the fact that in the reasons recorded, the AO has not disclosed any specific non- disclosure of material facts by the appellant.” 8. We have heard the both the sides

Harish Kumar Singh, Greater Noida vs. ITO, Ward 3(2), Bulandshahr

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

ITA 1501/DEL/2022[2012-13]Status: DisposedITAT Delhi21 Nov 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarharish Kumar Singh, Vs. Ito, Ward 3 (2), A – 70, Sector P – 3, Bulandshahr. Greater Noida – 201 308 (Uttar Pradesh). (Pan :Awkps2738M) (Appellant) (Respondent) Assessee By :Shri Mayank Patwari, Advocate Shri Akash Ojha, Ca Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 28.08.2025 Date Of Order : 21.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 31.03.2022 For The Assessment Year 2012-13. 2. At The Time Of Hearing, Ld. Ar Of The Assessee Submitted That The Registry Has Pointed Out A Delay Of 28 Days In Filing The Appeal Before The Tribunal, However, The Appeal Filed Through Online On 30.05.2022 Against The Order

For Appellant: Shri Mayank Patwari, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 147Section 148

Income Tax (Appellate Tribunal) Rules and it is purely legal issue and the same is reproduced below :- “Ground 8 : That the reasons recorded for reopening the assessment were based on incorrect facts and the approval was granted in a mechanical manner without any application of mind. Ground 9 : That

Hry Warehousing Corporation vs. Joint Commissioner of It

ITA/526/2005HC Punjab & Haryana20 Nov 2025

Bench: MR. JUSTICE AMARINDER SINGH GREWAL,MR. JUSTICE JAGMOHAN BANSAL

Section 10(29)Section 139Section 143Section 143(3)Section 147Section 148Section 260A

respondent in the light of judgment of Rajasthan High Court in Rajasthan State Warehousing Corporation (supra) changed its opinion and reopened assessment. The reasons recorded for re-assessment by Assessing Authority read as: "In this case the assessee filed its return of income declaring NIL taxable income claiming that whole

Hiralal Agencies Pvt. Ltd., Ranchi vs. DCIT, Circle-1, Ranchi

Appeal of the assessee is allowed

ITA 288/RAN/2024[2011-12]Status: DisposedITAT Ranchi20 Nov 2025AY 2011-12

Bench: the Ld. CIT(A) where appeal of the assessee was dismissed sustaining the order of the AO.

Section 142(1)Section 143(3)Section 144Section 147Section 148Section 151(1)

notice under Section 148 was issued on 11.08.2017 for reopening the completed assessment. During the reassessment proceedings, a certified copy of the reasons recorded for reopening was furnished to the assessee. The assessee was also issued notice under Section 142(1) of the Act. On examination of the ledger accounts ... from the end of the relevant assessment year (A.Y. 2011–12), even though the original assessment had been completed under Section 143(3). The reasons recorded for reopening do not allege any failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment

Income Tax Officer, Kota vs. Kota Karamachari Sahakari Samiti Limited, Kota

Appeal is allowed

ITA 1432/JPR/2025[2018-19]Status: DisposedITAT Jaipur20 Nov 2025AY 2018-19
For Appellant: Shri P.C.Parwal, FCAFor Respondent: Sh. Rajesh Ojha, CIT
Section 143(1)Section 143(2)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

nArguments hard. File perused.\n3.\nIn the course of arguments, Ld. DR for the department-appellant has\nsimply submitted that he relies on the reasons recorded by the Assessing\nOfficer.\nOn the other hand, Ld. AR for the assessee has submitted that he\nstands by the reasons recorded by Learned ... department-appellant, we uphold the decision\nby Learned CIT(A) whereby he deleted the addition made by the Assessing\nOfficer for the reasons recorded therein.\nResult\n10.\nIn view of the above discussion and findings, this appeal is allowed.\nFile be consigned to the record room after the needful

M/S Bajrang Lal Jindal, Kanpur vs. Astt. Commissioner of Income Tax-I, Kanpur

In the result, the appeal of the assessee is allowed

ITA 373/LKW/2017[2008-09]Status: DisposedITAT Lucknow20 Nov 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2008-09 M/S Bajrang Lal Jindal, 140, Vs. Asstt. Commissioner Of Income Anandpuri, Kanpur, U.P. Tax-I, Kanpur Pan: Aanpj5660J (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 27.08.2025 Date Of Pronouncement: 20.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A)- Kanpur, Confirming The Addition Of Rs. 1,46,11,400/- Made To The Returned Income Of The Assessee As Unexplained Cash Credits By The Assessing Officer In His Order Dated 31.03.2016 For The Assessment Year 2008-09. The Grounds Of Appeal Are As Under: - “1. That The Ld. Cit (A) I, Kanpur Has Erred In Confirming Addition Of Rs. 14611400.00 To The Returned Income Of The Assessee As Unexplained Cash Credits. 2. That The Reasons Recorded For Initiation Of Proceedings U/S 147 By Issue Of Notice U/S 148 Were Based On Improper Premise & Accordingly No Legal & Factual Lengs To Stand & Acordingly All Subsequent Proceedings Are Bad In Law. 3. That The Observation Of The Ld. Cit (A) I, Kanpur Confirming View Of Ld. A O That M/S. Maa Devasar Commodity Is Inexistant Is Factually Incorrect. 4. That Ld. Cit (A) I, Kanpur Has Erred In Not Appreciating The Fact That When The Beneficiary Of The Funds Are Not The Assessee, There Could Be No Addition In His Hands.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. Amit Kumar, DR
Section 147Section 148Section 68

KANPUR HAS ERRED IN CONFIRMING ADDITION OF Rs. 14611400.00 TO THE RETURNED INCOME OF THE ASSESSEE AS UNEXPLAINED CASH CREDITS. 2. THAT THE REASONS RECORDED FOR INITIATION OF PROCEEDINGS u/s 147 BY ISSUE OF NOTICE u/s 148 WERE BASED ON IMPROPER PREMISE AND ACCORDINGLY NO LEGAL AND FACTUAL LENGS

Neha Jain, Hyderabad vs. Income Tax Officer, Ward-9(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1275/HYD/2025[2016-17]Status: DisposedITAT Hyderabad20 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1275/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Neha Jain Vs. Income Tax Officer Hyderabad Ward 9(1) Pan:Asnpj2794B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Siddharth Toshnival राज" व "ारा/Revenue By:: Shri Rajnaj Agarwala, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/11/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Neha Jain (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 27.06.2025 For The A.Y 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate Siddharth ToshnivalFor Respondent: : Shri Rajnaj Agarwala, Sr. DR
Section 144BSection 147Section 45Section 69A

further submitted that the assessee has never entered into any JDA. Further, the Ld. AR invited our attention to the reasons recorded by the Ld. AO placed at page no. 11 of the paper book and submitted that the Ld. AO wrongly assumed that the assessee had executed a development

R S Ispat Limited, Salt Lake vs. DCIT, Circle 12(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1921/KOL/2025[2012-2013]Status: DisposedITAT Kolkata20 Nov 2025AY 2012-2013

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(2)Section 143(3)Section 147Section 148Section 154Section 250Section 68

Subsequently, the case of the assessee was reopened by issue of notice u/s 148 of the Act dated 07.03.2018. The AO supplied the reasons recorded for reopening vide letter dated 17.08.2018, according to which, the AO was in receipt of information from the Joint Commissioner of Sales-tax, West Bengal ... record. The assessee has challenged the validity of the reopening of assessment u/s 147 of the Act. For the sake ready reference the reasons recorded for reopening the assessment are extracted below:- “In the aforesaid case, the assessee filled his return of income on 08/08/2013 of Rs. 29491010/-. The assessment

M/S. Muse Advertising and Media Pvt. Ltd., Kolkata vs. I.T.O., Ward - 10(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2202/KOL/2024[2011-2012]Status: DisposedITAT Kolkata20 Nov 2025AY 2011-2012

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(3)Section 147Section 148Section 250

opened u/s 147 of the Act by issue of notice u/s 148 of the Act dated 27.03.2018 and the relevant portion of the reasons recorded for reopening read as under: “On perusal of the information, it is seen that a search and seizure operation was conducted in the case ... assessment was completed u/s 143(3) of the Act. According to the Ld. AR therefore, all the primary facts and particulars relating the purported reasons recorded for reopening was fully and truly disclosed at the time of original assessment and therefore the notice issued u/s 148 of the Act dated

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Ramasamy Rajasehar, Perambalur

In the result, appeal filed by the Revenue is dismissed and the Cross-Objection filed by the assessee is partly allowed

ITA 3336/CHNY/2024[2014-15]Status: DisposedITAT Chennai20 Nov 2025AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Mr. Shiva Srinivas, C.I.T
Section 143(3)Section 69

income on 20.09.2019. Thereafter, notice u/s.143(2) of the Act was issued on 09.10.2019. Upon request, the AO also furnished to the assessee the reasons recorded for initiating proceedings u/s.153C of the Act. 7. The AO noted that certain loose sheets, marked as Annexure No.ANN/RR/NS/LS/S, were seized from

Aroma Chemicals, Moradabad vs. ACIT, Circle-1, Moradabad

In the result, appeal filed by the assessee is allowed

ITA 2465/DEL/2025[2015-16]Status: DisposedITAT Delhi20 Nov 2025AY 2015-16

Bench: Yogesh Kumar U.S. & Shri Brajesh Kumar Singh

Section 144Section 147Section 148Section 68

assessment proceedings and therefore, we first take up this ground for adjudication. 9. In this regard, the Ld. AR referred to the reasons recorded by the AO for initiating the proceedings u/s 148 of the Act, dated 30.03.2021 which were enclosed as Annexure to the AO’s letter dated ... also placed at page no. 71 to 75 of the paper book filed by the assessee. The Ld. AR submitted that in the reasons recorded, no intelligible basis for the escapement of income of Rs. 1,31,95,600/- has been brought on record by the AO. Further, there

Om Prakash, Hathras vs. Income Tax Officer, Ward 4(3)(4), Hathras

In the result, the appeal of the assessee is allowed

ITA 153/AGR/2025[2011-12]Status: DisposedITAT Agra19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Om Prakash, Vs. Income Tax Officer, Village Baramai, Ward-4(3)(4), Sadabad, Hathras Hathras (Appellant) (Respondent) Pan: Dkbpp7713K

For Appellant: Shri Rajesh Malhotra, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 144Section 147Section 148Section 151

escaped assessment and issued notice under Section 148 of the Act on 26-03-2018 after obtaining approval from the Ld PCIT, Aligarh. The reasons recorded for reopening the assessment are as under:- Om Prakash 5. The Learned AO forwarded these reasons along with the proforma to the Learned PCIT ... whole period of 1-1-2008-31-3-2012 and no cash deposits except Rs. 2,000/- was found thereon. Whereas in the reasons recorded, the Learned AO had stated that assessee had deposited Rs. 28,26,470/- in the bank account. In the assessment order, the Learned

Anil Kumar Agarwal, Agra vs. DCIT 2(1)(1), Agra

In the result, the appeal of the assessee is allowed

ITA 101/AGR/2025[2011-12]Status: DisposedITAT Agra19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Anil Kumar Agarwal, Vs. Dy. Cit, 44, R. S. Residency, Circle-2(1)(1), Dayal Bagh, Agra, Up Agra (Appellant) (Respondent) Pan: Aampa3335J Assessee By : Shri Rajni Kant Verma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Shri Rajni Kant Verma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 133(6)Section 143(3)Section 148Section 68

Learned AO formed a belief that income of the assessee had escaped assessment and accordingly proceeded to reopen the assessment of the assessee. The reasons recorded for reopening the assessment were duly supplied to the assessee and assessee filed objections to the same. The Learned AO disposed of the objections

Mayurbhai Jaysukhlal Shah, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

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

ITA 319/RJT/2024[2013-14]Status: DisposedITAT Rajkot19 Nov 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 319/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Mayurbhai Jaysukhlal Shah Vs. Principal Commissioner Of 601, Cross Way, P.N. Marg, Income Tax, Jamnagar Jamnagar, Gujarat-361001 Office Of The Principal Commissioner Of Income Tax.Pcit, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afgps1754J (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 10(38)Section 143Section 147Section 263Section 68

borrowed satisfaction and the reasons of reopening as furnished by the assessing officer, contain lot of mistakes. The reasons recorded were not spell out the belief of the assessing officer that the Income of the assessee escaped assessment. For that Ld. Counsel relied on the various judgements of High Courts

Joint Commissioner of Income Tax, Ajmer vs. Vijeta Lodha, Jaipur

ITA 390/JPR/2023[2015-16]Status: DisposedITAT Jaipur19 Nov 2025AY 2015-16
For Appellant: Shri Rajeev Sogani, C.A. (through V.C.)For Respondent: None
Section 10(38)Section 142(1)Section 143(2)Section 68Section 69C

CIAL.\nContentions\n19. Ld. DR for the department has contended that in view of specific\nobservations made by the Assessing Officer, for the reasons recorded in\nthe assessment order, Learned CIT(A) was not justified in deleting the said\naddition as the share transactions were found to be bogus based ... followed in Sumati Dayal vs. CIT (1995) 214 ITR 810,\nalready referred to above.\n47. In view of the material available and the reasons recorded by the\nAssessing Officer there is no merit in the contention on behalf of the\nassessee that the Assessing Officer place reliance only

Sudhir Babu Chalasani, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 1352/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Nov 2025AY 2017-18

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 10(38)Section 69A

declaring total income of Rs.3,60,560/-. The assessment has been subsequently reopened u/s 147 of the Income Tax Act, 1961, for the reasons recorded, as per which, information received from Investigation Wing shows that, the assessee had sold shares of penny stocks from Stampede Capital Ltd during