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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

Bora Agro Foods, Pune vs. DCIT, Cir-5, Pune

In the result, all the appeals filed by the Assessee are partly\nallowed

ITA 2362/PUN/2025[2016-17]Status: DisposedITAT Pune11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250Section 69A

course of search on Kele Group, evidence\nwas found that Mr. Kele had paid interest in cash to Bora Agro. The\ncopy of the reasons recorded for reopening the case are enclosed\nherewith as Annexure A. In the said reasons, the learned A.O. has\nstated that in the course ... allowed.\nGround Number 1:\n6. Assessee has challenged notice u/s 148. The Assessee has filed\ncopy of Reasons recorded for Reopening. The relevant part of the\nITA Nos.2360, 2361 & 2362/PUN/2025[A]\nReasons Recorded for Reopening is scanned and reproduced as\nunder :\n3.\nAnalysis of information collected/received:-\nInformation has been received

Bora Agro Foods, Pune vs. DCIT, Cir-5, Pune

In the result, all the appeals filed by the Assessee are partly\nallowed

ITA 2361/PUN/2025[2017-18]Status: DisposedITAT Pune11 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 250Section 69A

course of search on Kele Group, evidence\nwas found that Mr. Kele had paid interest in cash to Bora Agro. The\ncopy of the reasons recorded for reopening the case are enclosed\nherewith as Annexure A. In the said reasons, the learned A.O. has\nstated that in the course ... allowed.\nGround Number 1:\n6.\nAssessee has challenged notice u/s 148. The Assessee has filed\ncopy of Reasons recorded for Reopening. The relevant part of the\nReasons Recorded for Reopening is scanned and reproduced as\nunder :\n3. Analysis of information collected/received:-\nInformation has been received from DDIT/ADIT (Inv.), Unit

Bora Agro Foods, Pune vs. DCIT, Cir-5, Pune

In the result, all the appeals filed by the Assessee are partly\nallowed

ITA 2360/PUN/2025[2015-16]Status: DisposedITAT Pune11 Mar 2026AY 2015-16
Section 143(3)Section 147Section 148Section 250Section 69A

course of search on Kele Group, evidence\nwas found that Mr. Kele had paid interest in cash to Bora Agro. The\ncopy of the reasons recorded for reopening the case are enclosed\nherewith as Annexure A. In the said reasons, the learned A.O. has\nstated that in the course ... allowed.\nGround Number 1:\n6. Assessee has challenged notice u/s 148. The Assessee has filed\ncopy of Reasons recorded for Reopening. The relevant part of the\nReasons Recorded for Reopening is scanned and reproduced as\nunder :\n3.\nAnalysis of information collected/received:-\nInformation has been received from DDIT/ADIT (Inv.), Unit

Dayachary Ponnekanti, Hyderabad vs. DCIT, Circle 1(1), Hyderabad

ITA 1985/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Mar 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia(In आयकर अपीलसं./I.T.A. No.1985/Hyd/2025 (निर्धारणवर्ष/ Assessment Year:2016-17) Dayachary Ponnekanti, Hyderabad. Pan: Ahspp5496L Vs. Dcit, Circle-1(1), Hyderabad. (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By राजस्वकाप्रतिनिधित्व/ Department Represented By सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/ Date Of Pronouncement Shri H. Srinivasulu, Advocate Shri Mathivanan S A, Sr. Ar 02/03/2026 11/03/2026 Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Dayachary Ponnekanti, ("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 08/10/2025 For The A.Y.2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 143Section 144Section 147Section 148Section 148ASection 69Section 69A

immovable property for a sum of Rs.3.6Cr in F.Y 2014-15 and such transaction extended to A.Υ 2016-17. (B) Ld. A.O's reasons recorded have no nexus between the material on record and belief formed for reopening of the assessment. (C) Ld. A.O failed to record the correct

DCIT., Circle-2(1), Hydrabad vs. Kalptaru Investments Private Limited, Hyderabad

ITA 1077/HYD/2025[2013-14]Status: DisposedITAT Hyderabad11 Mar 2026AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.1077/Hyd/2025

For Appellant: Sri P Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 147Section 148

have declared the reopening to be void ab initio. (iv) For that on the facts and in the circumstances of the case, the reasons recorded for reopening the assessment was based on borrowed satisfaction and the AO did not objectively apply his own mind to the purported information received ... assessee has traded in currency futures which are liquid and recognized by Securities and Exchange Board of India [in short “SEBI”]. Therefore, the reasons recorded by the Assessing Officer are without application of mind and factually incorrect. The learned Authorised Representative of the Assessee has submitted that the reason recorded

Piyush Ashok Mehta, Mumbai vs. DCIT, Central Circle 6(4), Mumbai

Accordingly, Ground No. 2 raised by the Assessee in the present appeal in allowed

ITA 9092/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Mar 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Ms. Deepika Arora
Section 133ASection 143(1)Section 143(3)Section 147

failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment.” 3. As per the reason recorded for re-opening the assessment, a survey under Section 133A of the Act was conducted at the business premises of M/s Vinay Unique Developers, an associate ... Learned Authorised Assessment Year 2009-2010 & 2010-2011 Representative for the Assessee, at the outset, submitted that the Assessing Officer has in the reasons recorded for reopening assessment had referred to unsecured loans borrowed by M/s. Landmark Realty amounting to INR.8,69,00,000/- and by the Assessee amounting

Piyush Ashok Mehta, Mumbai vs. DCIT, Central Circle 6(4), Mumbai

Accordingly, Ground No. 2 raised by the Assessee in the present appeal in allowed

ITA 9091/MUM/2025[2009-10]Status: DisposedITAT Mumbai11 Mar 2026AY 2009-10

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Ms. Deepika Arora
Section 133ASection 143(1)Section 143(3)Section 147

failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment.” 3. As per the reason recorded for re-opening the assessment, a survey under Section 133A of the Act was conducted at the business premises of M/s Vinay Unique Developers, an associate ... Learned Authorised Assessment Year 2009-2010 & 2010-2011 Representative for the Assessee, at the outset, submitted that the Assessing Officer has in the reasons recorded for reopening assessment had referred to unsecured loans borrowed by M/s. Landmark Realty amounting to INR.8,69,00,000/- and by the Assessee amounting

Combine Diamonds Private Limited, Bandra Kurla Complex, Mumbai vs. Assistant Commissioner of Income Tax -5(1)(2), Mumbai

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

ITA 2480/MUM/2025[2009-10]Status: DisposedITAT Mumbai11 Mar 2026AY 2009-10

Bench: Shri Narender Kumar Choudhrya N D Shri Prabhash Shankara.Y: 2009-10 Combine Diamonds Vs. Acit-5(1)(2), Mumbai Private Limited Fw 6010B, 6Th Floor, Bharat Diamond Bourse, East Wing, Bandra Kurla Complex, Bandra East, Mumbai – 400051. Pan/Gir No. Aaacc9949H (Applicant) (Respondent) Assesseeby : Shri Rahul Sarda, Ca Revenue By : Shri Virabhadra Mahajan (Sr. Dr)

For Appellant: Shri Rahul Sarda, CAFor Respondent: Shri Virabhadra Mahajan (SR. DR)
Section 142(1)Section 143(3)Section 147Section 148Section 250

notice u/s 148 of the Act. The Assesseeby such letter dated 04.04.2016 and thereafter vide letter dated 21.05.2016, also requested to provide the reasons recorded for issuing notice u/s 148 of the Act. 5. The Assessing Officer [in short “the Ld.AO”]without providing the reasons for reopening as sought ... assessment proceedings by issuing notice dated 01.07.2016 u/s 142(1) of the Act. 5.1 However the AO thereaftervide letter dated 15.07.2016 issued/communicated/forwarded the reasons recorded for reopening of assessment u/s 147 of the Act, to the Assessee. And without waiting for the Assessee to file objectionsif any, to the reopening

Rswm Limited, Rajasthan vs. Dy. Commissioner of Income Tax, Central Circle-31, Delhi

In the result, the appeal of the assessee is partly allowed

ITA 4876/DEL/2025[2012-13]Status: DisposedITAT Delhi11 Mar 2026AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshrswm Ltd, Vs. Dcit, Kharigram, Gulabpur, Central Circle-31, Bhilwara, Rajasthan Delhi (Appellant) (Respondent) Pan: Aaacr9700M Assessee By : Shri Satyajeet Goyal, Ca Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 13/01/2026 Date Of Pronouncement 11/03/2026

For Appellant: Shri Satyajeet Goyal, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 132Section 139(1)Section 142(1)Section 143(3)Section 147Section 148Section 153ASection 37

declaring total income of Rs. Nil and claiming current year’s loss of Rs. 74,95,70,726/- to be carried forward. The reasons recorded for reopening the assessment was sought for and the same was provided to the assessee on 22.05.2019. The objections were filed by the assessee

Alok & Co LLP, Delhi vs. DCIT, Central Circle-28, Delhi

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

ITA 2736/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 153CSection 153DSection 65BSection 69A

Addl CIT on 26.03.2023 and the approval was granted on 27.03.2023. Therefore, the approval granted is mechanical. 7. Further, it was submitted that reasons recorded is different to the additions made by the AO. In this regard, it is brought to our notice the additions made by the AO relates

Alok & Co LLP, Delhi vs. DCIT, Central Circle-28, Delhi

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

ITA 2735/DEL/2025[2016-17]Status: DisposedITAT Delhi11 Mar 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 153CSection 153DSection 65BSection 69A

Addl CIT on 26.03.2023 and the approval was granted on 27.03.2023. Therefore, the approval granted is mechanical. 7. Further, it was submitted that reasons recorded is different to the additions made by the AO. In this regard, it is brought to our notice the additions made by the AO relates

Shri Gandhi Maulana Azad Shramjivi Ashra, Kutch vs. Income Tax Officer, Exemption Ward 1, Rajkot

In the result, appeals of the assessee, are allowed

ITA 612/RJT/2025[2016-17]Status: DisposedITAT Rajkot10 Mar 2026AY 2016-17

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

consider such reply filed by assessee and passed order under section 148A(d) along with notice under section 148 - It was clear that from reasons recorded in notices issued under section 148A(a) and section 148A(b) that there was no cash deposit made by assessee in any of bank ... said approval is invalid and bad-in-law due to the non-application of mind by the designated authority before granting approval. 2. The reasons recorded by the designated authority while granting the approval nowhere suggests that, he has perused all the details and documents available on record before granting

Shri Gandhi Maulana Azad Shramjivi Ashra, Kutch vs. Income Tax Officer, Exemption Ward 1, Rajkot

In the result, appeals of the assessee, are allowed

ITA 611/RJT/2025[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

consider such reply filed by assessee and passed order under section 148A(d) along with notice under section 148 - It was clear that from reasons recorded in notices issued under section 148A(a) and section 148A(b) that there was no cash deposit made by assessee in any of bank ... said approval is invalid and bad-in-law due to the non-application of mind by the designated authority before granting approval. 2. The reasons recorded by the designated authority while granting the approval nowhere suggests that, he has perused all the details and documents available on record before granting

Deputy Commissioner of Income Tax, Yamunanagar vs. M/S the Ved Parkash Mukand Lal, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 833/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

water. 8. The Ld. AR has further argued that the case of the assessee has been reopened at the behest of audit objections. The reasons recorded by Ld. AO to reopen the case for AY 2005-06 has been placed on record at Page Nos.74 to 76 of the paper

DCIT vs. M/S the Ved Parkash Mukand Lal, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 832/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

water. 8. The Ld. AR has further argued that the case of the assessee has been reopened at the behest of audit objections. The reasons recorded by Ld. AO to reopen the case for AY 2005-06 has been placed on record at Page Nos.74 to 76 of the paper

The Ved Prakash Mukand Lal Educational Society, Yamunanagar vs. DCIT, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 825/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

water. 8. The Ld. AR has further argued that the case of the assessee has been reopened at the behest of audit objections. The reasons recorded by Ld. AO to reopen the case for AY 2005-06 has been placed on record at Page Nos.74 to 76 of the paper

The Ved Prakash Mukand Lal Educational Society, Yamunanagar vs. DCIT, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 824/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

water. 8. The Ld. AR has further argued that the case of the assessee has been reopened at the behest of audit objections. The reasons recorded by Ld. AO to reopen the case for AY 2005-06 has been placed on record at Page Nos.74 to 76 of the paper

Infinity International, Ahmedabad vs. NFAC, Delhi Present Juris. the ITO, Ward-3(3)(1), Ahmedabad

In the result, appeal of the assessee is dismissed

ITA 518/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalinfinity International, Nfac, Delhi Vs. H-611, Titanium City Centre, Present Jurisdiction 100 Ft. Anandnagar Road, Ito, Ward 3(3)(1), Satellite, Ahmedabad-380015 Ahmedabad [Pan: Aaefi 2610 J] (Appellant) .. (Respondent) Appellant By: Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ar Respondent By: Shri Alpesh Parmar, Cit-Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 10.03.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147Section 148Section 153(3)Section 250Section 68

based merely on borrowed satisfaction from the Investigation Wing without independent application of mind by the Assessing Officer. It was contended that the reasons recorded do not specify the nature of the alleged escapement of income and do not demonstrate any independent inquiry conducted by the Assessing Officer prior ... that the assessee had received accommodation entries in the form of unsecured loans from M/s Orange Tradex Pvt. Ltd. and M/s Krrish Enterprise. The reasons recorded reveal that the Assessing Officer referred to the information received and the statement of Shri Chandresh Vyas and thereafter recorded that income chargeable

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Oasys Cybermatics Pvt Ltd, Chennai

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

ITA 3102/CHNY/2025[2016-17]Status: DisposedITAT Chennai09 Mar 2026AY 2016-17

Bench: MS. PADMAVATHY S (Accountant Member), SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Mr. ARV Srinivasan, CIT for Mr. Bipin C. N., CITFor Respondent: Mr. Ravi Kannan &
Section 143(2)Section 143(3)Section 147Section 148Section 36(1)(va)Section 5(3)

issuing notice u/s. 148 dated 26.03.2021. In response, the assessee filed return of income on 15.04.2021 and sought the reasons recorded for reopening. The assessee raised objections to the reopening vide letter dated 31.08.2021 which came to be rejected by :: 3 :: the National Faceless Assessment Centre (NFAC) vide order dated

N N M Securities Private Limited, Mumbai vs. Assessing Officer, National Faceless Assessment Centre

In the result, the Assessee’s Appeal is allowed for statistical purposes

ITA 1506/MUM/2025[2013-2014]Status: DisposedITAT Mumbai09 Mar 2026AY 2013-2014

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2013-14 Nnm Securities Private Assessing Officer, Limited, 1111, Stock Mumbai, Maharashtra – Vs. Exchange Tower, Dalal 400020. Street, Maharashtra - 400023. (Appellant) (Respondent) Pan: Aaacn 8070 G Present For: Assessee By : Shri Hansaraj Sanghavi Revenue By : Shri.Leyaqat Ali Aafaqui, (Sr.A.R) Date Of Hearing : 09.01.2026 Date Of Pronouncement : 09.03.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 02.01.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2013-14. 2. In This Case, The Assessee Had Declared Its Income At Rs.12,41,210/- By Filing Its Return Of Income On Dated 28.09.2013 Which Was Processed & Completed U/S 143(3) Of The Act, On 17.02.2016. Thereafter The Following Information Was Received By The Assessing Officer.

For Appellant: Shri Hansaraj SanghaviFor Respondent: Shri.Leyaqat Ali Aafaqui, (SR.A.R)
Section 143(3)Section 144Section 144B(1)(xi)Section 147Section 148Section 250Section 68

completed u/s 143(3) of the Act, on 17.02.2016. Thereafter the following information was received by the Assessing Officer. 2 NNM Securities Private Limited REASONS RECORDED FOR RE-OPENING THE ASSESSMENT U/S 147 OF THE INCOME TAX ACT, 1963 In this case, assessee has e-filed ROI on 28.09.2013 declaring