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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

M/S. Sharda Exports, Meerut vs. The Assistant Commissioner of Income Tax, Central Circle, Dehradun

In the result, appeal of the Assessee in ITA No

ITA 40/DDN/2022[2006-07]Status: DisposedITAT Dehradun26 Sept 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

jurisdiction by the A.O. 5. We have heard both the parties and perused the material available on record. On perusal of the reasons recorded placed in the paper books, it is found that nowhere the Ld. A.O. whispered about ‘failure on the part of the Assessee on disclosed fully ... amounting to Rs. 2,72,99,429/- as not eligible for deduction u/s 80IC of the Act. The Assessee filed objections to the said reasons recorded which were not disposed of by the ld AO by passing a speaking order. 7. Later, a second notice

Neeraj Kumar Sethi, Delhi vs. ITO, National Faceless Appeal Centre (NFAC)

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

ITA 9/ASR/2024[2014-15]Status: DisposedITAT Amritsar26 Sept 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashwani Kalia, C.A
Section 139Section 143(3)Section 144BSection 147Section 148Section 250Section 68

basis of recorded reasons, but a third entity (M/s Parth International Prop Anuj Gupta PAN AGJPG3975B) is also brought into the fold of the reasons recorded and it is not clear as to how Mr. Ashok Gupta’s statement covers transaction of M/s Parth international, which is operating under ... been no further effort by the AO to produce the departments witness for cross examination , even though the entire reopening proceedings commencing from reasons recorded to assessment has been solely and wholly based on the statement of the person Mr. Ashok Kumar Gupta. 9. Subsequently assessment completed with an addition

Nasa Agro Industries Private Limited, Fazilka vs. Deputy Commissioner of Income Tax Circle-II, Bathinda

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

ITA 236/ASR/2023[2011-12]Status: DisposedITAT Amritsar26 Sept 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Y. K. Sud & Sh. P. K. Anand, CAs
Section 132Section 142(1)Section 143(3)Section 148Section 153cSection 250

purchased immovable property and reopened the assessment after recording the reason that the assessee failed to explain the source of investment in the property-Reasons recorded nowhere reflected as what information and corroborative materials/records regarding this have been independently examined and verified by the AO-There is nothing to suggest ... shifting of profit outside India, without independently applying his own mind to form any belief that assessee's income has escaped assessment, the reasons recorded by the AO do not justify the reopening of the assessment. 6. 210 TTJ (Chd) (UO) 26 Century Fiscal Services Ltd vs ITO Reassessment-Reason

Shri Vikramsinh Thakorbhai Ravat, Valsad vs. ACIT Valsad Circle, Valsad

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

ITA 206/SRT/2025[2011-12]Status: DisposedITAT Surat26 Sept 2025AY 2011-12

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.206/Srt/2025 Assessment Year: 2011-12 (Hybrid Hearing) Shri Vikramsinh Thakorbhai Assistant Commissioner Of बनाम/ Ravat Income-Tax, Circle-Valsad, 208 Vs. 117/Ravat Falia/ Bhutsar/ Palak Arcade, Shantinagar, Tithal Taluka/ Dist. Valsad-396 005 Road, Valsad-396 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Alcpr 4584 K (अपीलाथ"/Appellant) (""थ" /Respondent) "नधा"रती क" ओर से /Appellant By Shri Rajesh Upadhyay, Ar राज"व क" ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई क" तार"ख/Date Of Hearing 22/07/2025 उ"घोषणा क" तार"ख/Date Of Pronouncement 26/09/2025

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

paper book containing copy of submission made before the CIT(A), copy of ITR and computation of income, copy of notice u/s.148 and reasons recorded for reopening, submissions made before the AO, copy of purchase deed dated 23.07.2010, copy of agreement to sale dated 09.07.2008, copy of power of attorney

Anil Radheshyam Sharma, Surat vs. ITO, Ward 2(3)(1), Surat

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

ITA 888/SRT/2024[2011-12]Status: DisposedITAT Surat26 Sept 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.888/Srt/2024 Assessment Year: 2011-12 (Hybrid Hearing) Anil Radheshyam Sharma, Income Tax Officer, Ward – बनाम/ 73, Shyamal Dham Row 2(3)(1), Surat Vs. House, Godadara, Surat – 395 012 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bdhps8135D (""थ"/Respondent) (अपीलाथ"/Appellant)

Section 139(1)Section 143(2)Section 143(3)Section 148Section 250Section 44A

perused the materials available on record. We have also deliberated upon the decisions relied on by the Ld. AR. We have also perused the reasons recorded for reopening. It is well-settled law that at the stage of reopening, only a prima facie belief is required and not conclusive evidence

Shreyansh Anilkumar Shah, Na vs. Arivs.Income Tax Officer, Ward - 5, Navsari

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

ITA 727/SRT/2023[2010-11]Status: DisposedITAT Surat26 Sept 2025AY 2010-11

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.727/Srt/2023 Assessment Year: 2010-11 (Hybrid Hearing) Shreyansh Anilkumar Shah Income Tax Officer, Ward-5, बनाम/ 504, Rushabh Residency, Navsari, Income T Ax Office, Vs. Maneklal Road, Near Charpool, Awabaug, Navsari-396 Telephone Exchange, Navsari- 445 396 445 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aiqps 6441 P (अपीलाथ"/Appellant) (""थ" /Respondent) "नधा"रती क" ओर से /Appellant By Shri Rasesh Shah, Ca राज"व क" ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई क" तार"ख/Date Of Hearing 22/07/2025 उ"घोषणा क" तार"ख/Date Of Pronouncement 26/09/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: This Appeal By The Assessee Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act’) Dated 26.07.2023 By The National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax Appeal [In Short, The ‘Cit(A)’] For The Assessment Year (Ay) 2010-11, Which In Turn Arises Out Of Assessment Order Passed By The Assessing Officer (In Short, ‘Ao’) U/S 143(3) R.W.S. 147 Of The Act On 27.10.2017. 2. Grounds Of Appeal Raised By The Assessee For The Appeal Are As Under: “1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Ld. Ao Has Erred In Reopening Assessment U/S.147 By Issuing Notice U/S.148 Of The It Act, 1961. 2. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Ld. Cit(A) Has Erred In Confirming The Action Of Ao In Making Addition Of Rs.32,53,637/- U/S 68 Of The Act On Account Of Alleged Unexplained Cash Credits.

Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 226(3)Section 250Section 68

paper book containing copy of submission made before the CIT(A), copy of ITR and computation of income, copy of notice u/s.148 and reasons recorded for reopening, objections raised against reopening, submissions made before the AO, order by AO disposing off the objections raised against reopening, show cause notice issued ... upon by him. ITA No.727/Srt/2023 A.Y 10-11 Shreyansh A Shah 6.1 The Ld. AR contended that in the instant case, AO in the reasons recorded for reopening, proceeded on the erroneous footing that the assessee had not filed any return of income at all. Since, the very first premise

Raghav Dangayach, Jaipur vs. ITO Ward 4(1) Jpr, Jaipur

15. As a result, the application seeking condonation of delay is hereby dismissed

ITA 993/JPR/2025[2021-22]Status: DisposedITAT Jaipur26 Sept 2025AY 2021-22

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri S.B. Natani, C.AFor Respondent: Shri Gaurav Awasthi, JCIT
Section 143(1)Section 250

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

Jaipur Sahakari Kraya Vikraya Samiti, Jaipur vs. I.T.O. Ward 5(2), Jaipur

ITA 991/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur26 Sept 2025

Bench: The Registry On 30-06-2025. By Way Of First Mentioned Appeal, Assessee Has Challenged Order Dated 18-03-2025 Passed By Ld. Cit(A), Nfac, Delhi, Relating To The Assessment Year 2018-19, Whereby Appeal Filed By Assessee Challenging The Assessment Order Dated 31-03-2021 Passed Under Section 143(3) Of The Act, Has Been Dismissed, As Not 2

For Appellant: Shri G.M. Mehta, CAFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR
Section 143(3)Section 147Section 80P

specified in Column No. 14 and 15 that there was delay in filing of the appeals before ld. CIT(A) for the reasons recorded therein and accordingly, prayer was made for the condonation of said delay. 11. It may be mentioned here that appeal relating to assessment order passed

Jaipur Sahakari Krya Vikraya Samiti, Jaipur vs. ITO, WD 5(2) Jaipur, Jaipur

ITA 990/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur26 Sept 2025

Bench: The Registry On 30-06-2025. By Way Of First Mentioned Appeal, Assessee Has Challenged Order Dated 18-03-2025 Passed By Ld. Cit(A), Nfac, Delhi, Relating To The Assessment Year 2018-19, Whereby Appeal Filed By Assessee Challenging The Assessment Order Dated 31-03-2021 Passed Under Section 143(3) Of The Act, Has Been Dismissed, As Not 2

For Appellant: Shri G.M. Mehta, CAFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR
Section 143(3)Section 147Section 80P

specified in Column No. 14 and 15 that there was delay in filing of the appeals before ld. CIT(A) for the reasons recorded therein and accordingly, prayer was made for the condonation of said delay. 11. It may be mentioned here that appeal relating to assessment order passed

Surender Kumar, Alwar vs. ITO, Ward-1(1), Alwar

ITA 787/JPR/2025[2011-12]Status: DisposedITAT Jaipur26 Sept 2025AY 2011-12

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: NoneFor Respondent: Shri Gautam Singh Choudhary, Addl.CIT
Section 142(1)Section 144Section 148Section 250

Learned CIT(A) is a reasoned order whereby addition due to unexplained cash deposits of Rs. 7,96,000/-, has been upheld, for the reasons recorded therein, and as such the appeal deserves to be dismissed. 4. As is available from the impugned order, Learned CIT(A) issued notices

Income Tax Officer, Ward-3(3)(1), Ahmedabad vs. Ambalia Hitesh Chhaganlal HUF, Ahmedabad

In the result, both the appeals of the Revenue are dismissed

ITA 1429/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad26 Sept 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamble

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri B.P. Srivastava, Sr DR
Section 115BSection 147Section 148Section 148ASection 151Section 250Section 68

Mumbai, as evident from the notice u/s 148 and the order u/s 148A(d) of the Act. Even at this juncture, the reasons recorded cannot be improved upon notwithstanding that the approval u/s 151 of the Act. 7. Section 151(ii), with effect from 01.04.2021, reads as under:- [Sanction

Income Tax Officer, Ward-3(3)(1), Ahmedabad vs. Ambalia Hitesh Chhaganlal HUF, Ahmedabad

In the result, both the appeals of the Revenue are dismissed

ITA 1428/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad26 Sept 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamble

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri B.P. Srivastava, Sr DR
Section 115BSection 147Section 148Section 148ASection 151Section 250Section 68

Mumbai, as evident from the notice u/s 148 and the order u/s 148A(d) of the Act. Even at this juncture, the reasons recorded cannot be improved upon notwithstanding that the approval u/s 151 of the Act. 7. Section 151(ii), with effect from 01.04.2021, reads as under:- [Sanction

Prakash Cotton Mills Pvt Ltd, Mumbai vs. Dy CIT, Circle 8(2)(1), Mumbai

In the result, ground No. 9 to 14 is allowed

ITA 2639/MUM/2025[2012-13]Status: DisposedITAT Mumbai26 Sept 2025AY 2012-13
Section 143(3)Section 147Section 148Section 254(1)Section 45(4)Section 48

formation of belief of Ld. Assessing Officer [in\nshort Ld. A.O.] was not based on any tangible material as prima facie\nascertained from the reasons recorded for issuing impugned Notice under\nSection 148 of the Act and hence, mandatory condition for meeting\njurisdictional requirement is absent for formation of belief

DCIT Central Circle-27, New Delhi vs. Nrp Packers Private Limited, New Delhi

The appeal is dismissed

ITA 1269/DEL/2020[2012-13]Status: DisposedITAT Delhi26 Sept 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2012-13]

Section 147Section 148Section 69A

balance of disputed two accounts and thereafter in the hands of the assessee, which though stood settled under VSVS. In fact, as per the reasons recorded and approval u/s 151, the income escaping assessment was considered at Rs. 53,20,266/-being peak balance of both the bank accounts ... having confirmed the same, there remains no grievance as per the reasons recorded by the assessing officer himself and as such the order of CIT(A) does not call for any interference. Accordingly, the grounds raised by the revenue have no merit and are hereby dismissed

Income Tax Officer 1(1)(1), Kanpur vs. Ajay Kumar Gupta, Kanpur

In the result, ITA No.427/LKW/2024 is allowed for statistical purposes while CO No

ITA 427/LKW/2024[2017-18]Status: DisposedITAT Lucknow25 Sept 2025AY 2017-18

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2017-18 Income Tax Officer-1(1)(1), Vs. Ajay Kumar Gupta, Kanpur, U.P. 51/92C, Naya Ganj, Kanpur Pan: Abkpg5651J (Appellant) (Respondent) C.O. No.26/Lkw/2024 In A.Y. 2017-18 Ajay Kumar Gupta, Vs. Income Tax Officer-1(1)(1), 51/92C, Naya Ganj, Kanpur Kanpur, U.P. Pan: Abkpg5651J (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 04.09.2025 Date Of Pronouncement: 25.09.2025 O R D E R Per Nikhil Choudhary, A.M.: [ This Appeal & Cross Objection Have Been Filed By The Revenue & The Assessee Respectively, Against The Orders Of The Ld. Cit, Nfac Passed Under Section 250 Of The Income Tax Act, 1961 On 10.05.2024, Wherein The Ld. Cit(A) Has Allowed The Appeal Of The Assessee Against The Orders Of The Ao Under Section 147 R.W.S. 144 Passed On 30.03.2022. The Grounds Of Appeal Are As Under:- “1. Ld. Commissioner Of Income Tax (Appeal) Has Erred In Law & On Facts In Accepting The Contention Of The Assessee That The Proceedings Made U/S 147 Is Not In Accordance With Law. 2. Ld. Commissioner Of Income Tax (Appeal) Has Erred In Law & On Facts In Deleting The Addition Made By The Ao On Account Of Unexplained Money U/S 69A Of Income Tax Act, 1961 Deposited During The F.Y.2016-17 Without Appreciating That The Ao Has 1 Co No.26/Lkw/2024 Ajay Kumar Gupta A.Y. 2017-18

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR
Section 142(1)Section 144Section 144BSection 147Section 148Section 250Section 69A

Borrowed Satisfaction. 2. That the L.D A.O Erred In Law as Well As On Facts in not considering the fact that the reasons Recorded in the case of the appellant do not constitute a valid "Reason To Believe". 3. That the L.D A.O Erred In Law as Well ... Facts in not considering the fact that the reasons recorded constitute a "Reason To Suspect" and not a "Reason To Believe". 4. That the Ld. A.O. erred in law as well as on facts in re-opening the assessment without obtaining proper approval from the Pr. CIT as the form

Mft Builders and Developers, Gulbarga Karnataka vs. Deputy Commissioner of Income Tax, Central Circle, Bellary

In the result, both the appeals filed by the assessees are allowed

ITA 1178/BANG/2024[2015-16]Status: DisposedITAT Bangalore25 Sept 2025AY 2015-16

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.

For Appellant: Shri Rajkumar Hanchnal, CAFor Respondent: Shri Murali Mohan M, CIT-DR
Section 127Section 132Section 142(1)Section 143(2)Section 153ASection 153B

granted to the assessee. The Ld.AR further submitted that no notice has been issued before passing the order u/s. 127 and also reasons recorded by the Ld.CIT(A), Kalaburagi (Gulbarga) for transferring the jurisdiction from Kalaburagi (Gulbarga) to Belagavi (Belgaum) was not communicated to the Page ... till date. The Ld.AR further submitted that the Ld.DR may be directed to give a report about the service of the notice and the reasons recorded by the Ld.CIT for transferring the case from Kalaburagi (Gulbarga) to Belagavi (Belgaum) before passing the order u/s. 127 of the Act on 03/07/2018

Mohammed Abdul Najeeb, Gulbarga, Karnataka vs. Deputy Commissioner of Income Tax, Central Circle, Bellary, Karnataka

In the result, both the appeals filed by the assessees are allowed

ITA 1176/BANG/2024[2016-17]Status: DisposedITAT Bangalore25 Sept 2025AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.

For Appellant: Shri Rajkumar Hanchnal, CAFor Respondent: Shri Murali Mohan M, CIT-DR
Section 127Section 132Section 142(1)Section 143(2)Section 153ASection 153B

granted to the assessee. The Ld.AR further submitted that no notice has been issued before passing the order u/s. 127 and also reasons recorded by the Ld.CIT(A), Kalaburagi (Gulbarga) for transferring the jurisdiction from Kalaburagi (Gulbarga) to Belagavi (Belgaum) was not communicated to the Page ... till date. The Ld.AR further submitted that the Ld.DR may be directed to give a report about the service of the notice and the reasons recorded by the Ld.CIT for transferring the case from Kalaburagi (Gulbarga) to Belagavi (Belgaum) before passing the order u/s. 127 of the Act on 03/07/2018

Acharya Balkrishna, Haridwar vs. DCIT, Dehradun

In the result appeal of the assessee is allowed

ITA 112/DDN/2025[2015-16]Status: DisposedITAT Dehradun24 Sept 2025AY 2015-16

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 144Section 147Section 148Section 148ASection 149Section 151Section 250Section 68Section 69Section 69C

with no fresh tangible material and were issued at the behest of superior authority, further, there were many factual and legal inaccuracies in the reasons recorded which also shows total non-application of mind by superior authority in granting approval for reopening of assessment, as such, the reassessment proceedings

S K N Sikshan Sansthan, Bhadhadhar vs. Dy. Commissioner Income Tax (Central)-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 445/JPR/2025[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

Bench: Shri Gagan Goyal & Shri Narinder Kumarskn Shikshan Sansthan, 1, N. H. 11 Bhadhadar Sikar 332 315 Pan No.: Aamts 1103L ...... Appellant Vs.

For Appellant: Mr. Shafi Mohammad, Adv., Ld. ARFor Respondent: Mr. Gautam Singh Choudhary, Addl. CIT
Section 10Section 115BSection 12ASection 143(3)Section 147Section 148Section 250Section 57

therefore, had nothing before him which would enable him to record his belief that any such escapement had taken place. In the circumstances, the reasons recorded and which pertain to all the assessment years prior and subsequent to the survey could not satisfy the requirement in law. This ... make the assessment. In the case of MGM Export (323 ITR 331) the Hon’ble Gujarat High Court, found that upon receipt of the reasons recorded, the assessee preferred objections, both on jurisdiction and on the merits, that the assessee passed the assessment order without disposing the objections

Whole Sale Cloth Merchant Association, Kota vs. Deputy Commissioner of Income Tax Central Circle Kota, Kota

ITA 962/JPR/2024[2015-2016]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-2016
For Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 11Section 11(2)Section 143(3)Section 147Section 40

facts and in the circumstances and in law of the case, the ld Assessing Officer grossly erred in making the addition beyond the reason recorded which is not permissible under the law and ld. CIT(Appeal) erred in confirming the same. 2. That on the facts and in the circumstances ... facts and in the circumstances and in law of the case, the ld Assessing Officer grossly erred in making the addition beyond the reason recorded which is not permissible under the law and ld. CIT(Appeal) erred in confirming the same. 2. That on the facts and in the circumstances