JAGJIT SINGH,PANIPAT vs. PR.CIT, KARNAL

In the result, appeal of Assessee allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

reassessment proceedings under section 148/143(3) accepting the return of income of the assessee. The Ld. Pr. CIT on perusal of the assessment 3 ITA.No.2777/Del./2018 Shri Jagjit Singh, Panipat. record and relevant material on record found certain apparent discrepancies and errors. Accordingly, show cause notice under section 263 of the Income-Tax Act was issued to the assessee

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Appeals of the assessee are allowed

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of sub-section (1) of section 153A, or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner.” 8. provision

VANSHIKA MOTORS (P) LTD.,MEERUT vs. ACIT, CIRCLE- 2, MEERUT

Appeals of the assessee are allowed

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of sub-section (1) of section 153A, or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner.” 8. provision

DCIT, NEW DELHI vs. M/S KHEMKA STUART LEISURE LTD.,, NEW DELHI

Appeals of the assessee are allowed

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of sub-section (1) of section 153A, or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner.” 8. provision

KRISHNA DEVI,NEW DELHI vs. ITO, WARD- 38(3), NEW DELHI

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 6356/Del/2019 : Asstt. Year : 2014-15 Krishna Devi, Vs Income Tax Officer, F-26/124, Sector-7, Rohini, Ward-38(3), New Delhi-110085 New Delhi-110002 (Appellant) (Respondent) Pan No. Abrpd0875E Assessee By : Sh. Kapil Goel, Adv. Revenue By : Sh. Umesh Takyar, Sr. Dr Date Of Hearing: 08.10.2021 Date Of Pronouncement: 04.01.2022

section 148 of the Income-tax Act, 1961, only if on the basis of specific, reliable and relevant information coming to his possession subsequently, he has reasons, which he must; record, to believe that, by reason of omission or failure on the part of the assessee to make a true and full disclosure of all material facts necessary

ACIT, CENTRAL CRCLE-18, NEW DELHI vs. SHIMMER DEVELOPERS P.LTD, NEW DELHI

In the result, appeal of the Revenue is dismissed

Bench: Pradip Kumar Kedia & Shri Anubhav Sharma

reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word "reason" in the phrase "reason to believe" would mean cause or justification, If the Assessing Officer has couse or justification to know or suppose that income had escaped assessment, it can he said to have reason to believe

AKN DEVELOPERS PVT. LTD.,NEW DELHI vs. ACIT CC- 26, NEW DELHI

In the result, all the appeals preferred by the assessee on this common ground are allowed

Bench: Shri Shamim Yahya & Ms. Madhumita Roy

reassessment order under Section 153A(1)(b) or 153B(2)(b) of the Act. 16. That such an approval of a superior officer cannot be a mechanical exercise has been emphasized in several decisions. Illustratively, in the context of Section 142 (2-A) which empowers an AO to direct a special audit. The obtaining of the prior approval was held

AKN DEVELOPERS PVT. LTD.,NEW DELHI vs. ACIT CC- 26, NEW DELHI

In the result, all the appeals preferred by the assessee on this common ground are allowed

Bench: Shri Shamim Yahya & Ms. Madhumita Roy

reassessment order under Section 153A(1)(b) or 153B(2)(b) of the Act. 16. That such an approval of a superior officer cannot be a mechanical exercise has been emphasized in several decisions. Illustratively, in the context of Section 142 (2-A) which empowers an AO to direct a special audit. The obtaining of the prior approval was held

AKN DEVELOPERS PVT. LTD.,NEW DELHI vs. ACIT CC- 26, NEW DELHI

In the result, all the appeals preferred by the assessee on this common ground are allowed

Bench: Shri Shamim Yahya & Ms. Madhumita Roy

reassessment order under Section 153A(1)(b) or 153B(2)(b) of the Act. 16. That such an approval of a superior officer cannot be a mechanical exercise has been emphasized in several decisions. Illustratively, in the context of Section 142 (2-A) which empowers an AO to direct a special audit. The obtaining of the prior approval was held

AKN DEVELOPERS PVT. LTD.,NEW DELHI vs. ACIT CC- 26, NEW DELHI

In the result, all the appeals preferred by the assessee on this common ground are allowed

Bench: Shri Shamim Yahya & Ms. Madhumita Roy

reassessment order under Section 153A(1)(b) or 153B(2)(b) of the Act. 16. That such an approval of a superior officer cannot be a mechanical exercise has been emphasized in several decisions. Illustratively, in the context of Section 142 (2-A) which empowers an AO to direct a special audit. The obtaining of the prior approval was held

AKN DEVELOPERS PVT. LTD.,NEW DELHI vs. ACIT CC- 26, NEW DELHI

In the result, all the appeals preferred by the assessee on this common ground are allowed

Bench: Shri Shamim Yahya & Ms. Madhumita Roy

reassessment order under Section 153A(1)(b) or 153B(2)(b) of the Act. 16. That such an approval of a superior officer cannot be a mechanical exercise has been emphasized in several decisions. Illustratively, in the context of Section 142 (2-A) which empowers an AO to direct a special audit. The obtaining of the prior approval was held

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

reassessment order under Section 153A(1)(b) or 153B(2)(b) of the Act. 16. That such an approval of a superior officer cannot be a mechanical exercise has been emphasized in several decisions. Illustratively, in the context of Section 142 (2-A) which empowers an AO to direct a special audit. The obtaining of the prior approval was held

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

reassessment order under Section 153A(1)(b) or 153B(2)(b) of the Act. 16. That such an approval of a superior officer cannot be a mechanical exercise has been emphasized in several decisions. Illustratively, in the context of Section 142 (2-A) which empowers an AO to direct a special audit. The obtaining of the prior approval was held

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

reassessment order under Section 153A(1)(b) or 153B(2)(b) of the Act. 16. That such an approval of a superior officer cannot be a mechanical exercise has been emphasized in several decisions. Illustratively, in the context of Section 142 (2-A) which empowers an AO to direct a special audit. The obtaining of the prior approval was held

DHEERAJ CHAUDHARY,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8, NEW DELHI

Bench: Shri Mahavir Singh(), Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

reassessment order under Section 153A(1)(b) or 153B(2)(b) of the Act. 16. That such an approval of a superior officer cannot be a mechanical exercise has been emphasized in several decisions. Illustratively, in the context of Section 142 (2-A) which empowers an AO to direct a special audit. The obtaining of the prior approval was held

SH. SANJAY DALMIA,NEW DELHI vs. DCIT, NEW DELHI

In the result all the appeal filed by the assessee are dismissed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates as applicable to such assessment year. ‖ 3. Thus, under the presently applicable provisions, the CBDT itself is not stating that notices u/ss 143/142 of the Act to be issued as was required under the earlier block assessment scheme

CIT vs. AMBIENCE DEVELOPERS & INFRASTRUCTURE PVT LTD

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.V.EASWAR

reassessment under this Act, where an estimate of the value of any investment referred to in section 69 or section 69B or the value of any bullion, jewellery or other valuable article referred to in section 69A or section 69B is required to be made, the Assessing Officer may require the Valuation Officer to make an estimate of such value

DILEEP K GUPTA,DELHI vs. DCIT CC-31, DELHI

In the result, the appeals of the assessee are allowed

Bench: Shri C. N. Prasad & Shri M. Balaganesh

reassessment passed under clause (b) of section 153A in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 1324. The provision has also been made applicable to orders of assessment passed under clause