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

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

151 by simply writing "Yes, I am Satisfied" is also invalid; reopening of assessment and consequent reassessment are quashed. 11. 426 ITR 228 (Bom) Gateway Leasing Pvt Ltd vs ACIT & Others REASSESSMENT-NOTICE-ONLY REASONS RECORDED BY ASSESSING OFFICER TO BE CONSIDERED-INFORMATION RECEIVED FROM INVESTIGATION WING SHOWING THAT ASSESSEE HAD TRADED IN SHARES WITH BENEFICIARY OF SEARCHED BOGUS COMPANY

KHURSHID AHMAD DAR,JAMMU AND KASHMIR, INDIA vs. ITO WARD, UDHAMPUR, UDHAMPUR

In the result, the appeal of the assessee is allowed

Bench: Dr. Mitha Lalmeena, Hon'Ble & Shri Udayan Das Gupta, Hon'Blekhurshid Ahmad Dar Vs. Ito, Ward, Nully Poshwari Turkawangam, Udhampur Shopia, 192305, Jammu & Kashmir, India.Pin 192305. Pan No. Awmpd5664K Assessee By Shri Rohit Kapoor, Adv. & Shri V.S. Aggarwal, Itp. Revenue By Mrs. Roshanta Kumari Meena, Cit Dr. Date Of Hearing 23.09.2025. Date Of Pronouncement To. [1 .2025. Order Dr. Mitha Lal Meena, A.M.:

151 were amended vide Finance Act of 2021, with effect from 1-4-2021 - Since there was a regime change with respect to law of limitation coming into effect from 1-4-2021, which curtailed time limit for reopening of assessment from 6 years to 3 years, revenue, with a view to avail limitation prescribed under unamended section 149, generated

M/S BLUE CITY TOWNSHIP & COLONIZERS,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment proceeding cannot be initiated under section 147 for the purpose of enquiry and verification. 3. That on the facts and in the circumstances of-the case, CIT did not recorded satisfaction under Section 151

SH. ARASHPREET SINGH S/O LATE SH. GURMAIL SINGH,SHRI MUKATSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

LATE. SH. GURMAIL SINGH S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

LATE. SH. GURMAIL. SINGH. S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

LATE. SH. GURMAIL. SINGH S/O. SH. LAL SINGH,SHRI MUKAT SAR vs. DY. COMMISSIONER OF 9INCOME TAX. CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

LATE. SH. GURMAIL SINGH.S/O. LATE SH. LAL SINGH,SRI MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SH. ARASHPREET SINGH. S/O.LATE.SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX .CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CERCLE- II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SH. ARSPREET SINGH . S/O. LATE. SH. GURMAIL SINGH ,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE .II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

LATE. SH. GUMAIL SINGH . S/O. SH. LAL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151(2) of the Income Tax Act, 1961 which provides Late Sh. Gurmail Singh v. Dy. CIT & Ors for recording of satisfaction that it was a fit case for issue of notice under section 148 on the reasons recorded by the ld. Assessing Officer. 10. That in the facts and circumstances of the case, the Ld. Commissioner of Income

SMT..ANURADHA,PATHANKOT vs. INCOME TAX OFFICER WARD-6(1), PATHANKOT

In the result the appeal of the assessee is allowed

Bench: Sh. Udayan Dasgupta & Sh. Brajesh Kumar Singh

Section 151 of the Act clearly stipulates that the CIT (A), who is the competent authority to authorize the reassessment

MANDEEP SINGH S/O SH. NARINDER SINGH VILLAGE AND POST OFFICE TARMALA MALOUT DISTRICT MUKTSAR,MUKTSAR vs. THE INCOME TAX OFFICER WARD 2(5) MUKTSAR JAO INCOME TAX OFFICER WARD 2(2) MUKTSAR, MUKTSAR

In the result appeal of the assessee is allowed

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

151 of the I. T Act, 1961. c) That the Ld. CIT(A) NFAC Delhi has failed to appreciate that the notice u/s 148 was not served upon the assessee in the manned prescribed u/s 282 of the Act and thus the completion of assessment by the Assessing Officer is invalid and needs to be quashed. 3. Notwithstanding the above

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151 can also be subject of jurisdictional challenge to reopening notice—It is an elementary law that whenever any statutory obligation is casted upon any statutory authority such authority is required to discharge its obligation not mechanically, not even formally but after due application of mind — Thus, obligation of granting Approval acts as an inbuilt protection to taxpayer against arbitrary

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151 can also be subject of jurisdictional challenge to reopening notice—It is an elementary law that whenever any statutory obligation is casted upon any statutory authority such authority is required to discharge its obligation not mechanically, not even formally but after due application of mind — Thus, obligation of granting Approval acts as an inbuilt protection to taxpayer against arbitrary

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

151 can also be subject of jurisdictional challenge to reopening notice—It is an elementary law that whenever any statutory obligation is casted upon any statutory authority such authority is required to discharge its obligation not mechanically, not even formally but after due application of mind — Thus, obligation of granting Approval acts as an inbuilt protection to taxpayer against arbitrary