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325 results for “reassessment u/s 147”+ Section 264clear

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Key Topics

Section 148152Section 147128Section 6885Section 153D85Addition to Income74Section 143(3)70Section 153A56Section 13244Section 148A

DCIT, NEW DELHI vs. M/S. DHARAMPAL SATYAPAL LTD., DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 5611/DEL/2013[2004-05]Status: DisposedITAT Delhi08 Jan 2016AY 2004-05

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

For Appellant: Shri R.S. Singhvi, CA and Shri Satyajeet Goel, CAFor Respondent: Ms. Nandita Kanchan, CIT DR
Section 115JSection 132Section 143(3)Section 14ASection 264Section 80I

reassessment proceedings are not in conformity with proviso to section 147. For ready reference, proviso to section 147 which is extracted hereunder: Proviso to Section 147 Provided that where an assessment under sub-section f? i of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after

Showing 1–20 of 325 · Page 1 of 17

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Reassessment40
Search & Seizure27
Limitation/Time-bar21

M/S. DHARAMPAL SATYAPAL LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 5581/DEL/2013[2004-05]Status: DisposedITAT Delhi08 Jan 2016AY 2004-05

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

For Appellant: Shri R.S. Singhvi, CA and Shri Satyajeet Goel, CAFor Respondent: Ms. Nandita Kanchan, CIT DR
Section 115JSection 132Section 143(3)Section 14ASection 264Section 80I

reassessment proceedings are not in conformity with proviso to section 147. For ready reference, proviso to section 147 which is extracted hereunder: Proviso to Section 147 Provided that where an assessment under sub-section f? i of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after

ACIT CIRCLE-59(1), NEW DELHI vs. NEERAJ KUMAR SINGHAL, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 283/DEL/2021[2009-10]Status: DisposedITAT Delhi13 Sept 2023AY 2009-10

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

For Appellant: Shri Shri Amit Goel, CAFor Respondent: Ms. Smita Singh, Sr.DR
Section 139Section 143(3)Section 147Section 148Section 151(1)

reassessment proceedings initiated by the AO is bad in law and void ab initio, therefore, the same is quashed.” 10. The genesis of the controversy towards jurisdiction in the present case are the reasons recorded under Section 148(2) of the Act therefore, it may be relevant to reproduce the reasons recorded for ready reference. “Reasons for the belief that

BSES YAMUNA POWER LTD.,NEW DELHI vs. DCIT, CIRCLE- 5(1), NEW DELHI

The appeal of the assessee is allowed on legal issues

ITA 4852/DEL/2017[2007-08]Status: DisposedITAT Delhi16 Apr 2025AY 2007-08

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

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

147 / 143(3) as passed without jurisdiction, mere change of opinion and barred by limitation thus bad in law and void-ab- initio. 11. Before us, the ld. AR argued that the assessment in the case of the assessee was originally completed u/s 143(3) and the reassessment proceedings had been initiated in terms of the notice issued

BSES YAMUNA POWER LTD,DELHI vs. ACIT, CIRCLE-5(1), NEW DEL;HI

The appeal of the assessee is allowed on legal issues

ITA 4853/DEL/2017[2008-09]Status: DisposedITAT Delhi16 Apr 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

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

147 / 143(3) as passed without jurisdiction, mere change of opinion and barred by limitation thus bad in law and void-ab- initio. 11. Before us, the ld. AR argued that the assessment in the case of the assessee was originally completed u/s 143(3) and the reassessment proceedings had been initiated in terms of the notice issued

DCIT CENTRAL CIRCLE-14, NEW DELHI vs. SH. VIJAY KUMAR SONI, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

ITA 2144/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Sept 2024AY 2017-18

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. Anil Jain, CAFor Respondent: Ms. Monika Dhami, CIT-DR
Section 139Section 143Section 143(3)Section 144Section 147Section 148Section 153CSection 254Section 263Section 264

u/s 143(3). 5. In this regard, the provisions of Section 153C are as under: “Time limit for completion of assessment, reassessment and re- computation. 153. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

BIJAY KUMAR SONI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-14, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

ITA 1883/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Sept 2024AY 2017-18

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. Anil Jain, CAFor Respondent: Ms. Monika Dhami, CIT-DR
Section 139Section 143Section 143(3)Section 144Section 147Section 148Section 153CSection 254Section 263Section 264

u/s 143(3). 5. In this regard, the provisions of Section 153C are as under: “Time limit for completion of assessment, reassessment and re- computation. 153. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which

ADDL. CIT, NEW DELHI vs. M/S. IRCON INTERNATIONAL LTD., NEW DELHI

In the result, the appeal of the Revenue is accordingly dismissed

ITA 3768/DEL/2017[2009-10]Status: DisposedITAT Delhi22 Jan 2021AY 2009-10

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

Section 143(3)Section 148

reassessment proceedings has to be governed by the provisions of section 147 to 151 as substituted (amended) w.e.f. 01/04/1989. Still, power u/s 147 of the Act, though very wide but no plenary. We are aware that Hon’ble Gujarat High Court in Praful Chunilal Patel: Vasant Chunilal Patel vs ACIT (1999) 236 ITR 82, 840 (Guj.) even went

LASCO CHEMIE PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD-15(2), NEW DELHI, DELHI

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

ITA 3811/DEL/2025[2012-13]Status: DisposedITAT Delhi08 Apr 2026AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarlasco Chemie Private Vs. Income Tax Officer, Limited, Ward-15(2), Delhi 10489 Kalptaru, Sadar Thana Road Motia Khan, New Delhi 110055 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcl 3502 E Appellant .. Respondent

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 147Section 148Section 149Section 151Section 250

u/s 148 of the Act was issued. Ld. AO noted that, the assessee company was beneficiary of client code modification and the broker M/s Ashlar Commodities (P) Ltd. modified the name from original client M/s B B Portfolio (P) Ltd to the assessee company M/s Lasco P a g e | 3 Lasco Chemie (P) Ltd. (AY 2012-13) Chemie

RAJESH KUMAR,SONEPAT vs. ACIT, CENTRAL CIRCLE-2, GURGAON

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

ITA 61/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Aug 2024AY 2018-19

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2018-19] Rajesh Kumar, Vs Acit, C/O-Shiva Constructions Co., Central Circle-2, Plot No.69, Sidharth Enclave, Gurgaon. Delhi Road Sonipat, Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent [Assessment Year : 2018-19] Dcit, Vs Rajesh Kumar, Gurgaon. C/O-Shiva Constructions Co., Plot No.69, Sidharth Enclave, Delhi Road,Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent Appellant By Shri Umesh Takkar, Ca & Shri Saurabh Nagpal, Ca Respondent By Shri P N Barnwal, Sr.Dr Date Of Hearing 03.07.2024 Date Of Pronouncement 07.08.2024 Order Per Kul Bharat, Jm : These Two Cross-Appeals Filed By The Assessee & The Revenue, Are Directed Against The Order Passed By Ld. Commissioner Of Income Tax(Appeals) [“Ld.Cit(A)”]-3, Gurgaon Dated 31.10.2022 For The Assessment Year 2018-19. Both Appeals Of The Assessee & The Revenue Are Heard Together & Are Being Disposed Off By Way Of Common Order For The Sake Of Brevity.

Section 133ASection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 40Section 41(1)Section 43BSection 68

264 (Madras), we are of the considered view that the initiation of reassessment proceedings under section 147 of the Act were invalid in law so long as they time-limit for issuance of notice under section 143(2) of the Act had not yet expired. Interpretation of clause b to explanation 2 of section 147 of the Income

DCIT, GURUGRAM vs. RAJESH KUMAR, SONEPAT

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

ITA 82/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Aug 2024AY 2018-19

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2018-19] Rajesh Kumar, Vs Acit, C/O-Shiva Constructions Co., Central Circle-2, Plot No.69, Sidharth Enclave, Gurgaon. Delhi Road Sonipat, Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent [Assessment Year : 2018-19] Dcit, Vs Rajesh Kumar, Gurgaon. C/O-Shiva Constructions Co., Plot No.69, Sidharth Enclave, Delhi Road,Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent Appellant By Shri Umesh Takkar, Ca & Shri Saurabh Nagpal, Ca Respondent By Shri P N Barnwal, Sr.Dr Date Of Hearing 03.07.2024 Date Of Pronouncement 07.08.2024 Order Per Kul Bharat, Jm : These Two Cross-Appeals Filed By The Assessee & The Revenue, Are Directed Against The Order Passed By Ld. Commissioner Of Income Tax(Appeals) [“Ld.Cit(A)”]-3, Gurgaon Dated 31.10.2022 For The Assessment Year 2018-19. Both Appeals Of The Assessee & The Revenue Are Heard Together & Are Being Disposed Off By Way Of Common Order For The Sake Of Brevity.

Section 133ASection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 40Section 41(1)Section 43BSection 68

264 (Madras), we are of the considered view that the initiation of reassessment proceedings under section 147 of the Act were invalid in law so long as they time-limit for issuance of notice under section 143(2) of the Act had not yet expired. Interpretation of clause b to explanation 2 of section 147 of the Income

MAHARASHTRA FEEDS P. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE, FARIDABAD

In the result, the appeals of the assessee are allowed

ITA 1254/DEL/2021[2015-16]Status: DisposedITAT Delhi06 Feb 2024AY 2015-16

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. K. Sampath, Adv. &For Respondent: Ms. Smita Singh, Sr. DR
Section 153ASection 154Section 208Section 234ASection 234CSection 243CSection 245CSection 245DSection 245D(1)Section 245D(4)

264 or an order of the Settlement Commission under sub-section (4) of section 245D, the amount on which interest was payable under sub-section (1) or sub- section (3) has been increased or reduced, as the case may be, the interest shall be increased or reduced accordingly, and-- (i) in a case where the interest is increased, the Assessing

MAHARASHTRA FEEDS P. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE, FARIDABAD

In the result, the appeals of the assessee are allowed

ITA 1253/DEL/2021[2014-15]Status: DisposedITAT Delhi06 Feb 2024AY 2014-15

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. K. Sampath, Adv. &For Respondent: Ms. Smita Singh, Sr. DR
Section 153ASection 154Section 208Section 234ASection 234CSection 243CSection 245CSection 245DSection 245D(1)Section 245D(4)

264 or an order of the Settlement Commission under sub-section (4) of section 245D, the amount on which interest was payable under sub-section (1) or sub- section (3) has been increased or reduced, as the case may be, the interest shall be increased or reduced accordingly, and-- (i) in a case where the interest is increased, the Assessing

DCIT, NEW DELHI vs. M/S CHOTTI LEASING & FINANCE PVT. LTD.,, NEW DELHI

In the result, the appeals filed by the Revenue in ITA No

ITA 6213/DEL/2015[2009-10]Status: DisposedITAT Delhi23 Jan 2023AY 2009-10

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 147Section 250Section 4

section 147 to 151 of the Act. 2. That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the action of Ld. AO in framing impugned reassessment order u/s 147/143(3) is beyond jurisdiction, bad in law and against the facts and circumstances of the case. 3. In any view

DCIT, NEW DELHI vs. M/S CHOTTI LEASING & FINANCE PVT. LTD.,, NEW DELHI

In the result, the appeals filed by the Revenue in ITA No

ITA 6212/DEL/2015[2008-09]Status: DisposedITAT Delhi23 Jan 2023AY 2008-09

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 147Section 250Section 4

section 147 to 151 of the Act. 2. That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the action of Ld. AO in framing impugned reassessment order u/s 147/143(3) is beyond jurisdiction, bad in law and against the facts and circumstances of the case. 3. In any view

DCIT, NEW DELHI vs. M/S CHOTTI LEASING & FINANCE PVT. LTD.,, NEW DELHI

In the result, the appeals filed by the Revenue in ITA No

ITA 6214/DEL/2015[2010-11]Status: DisposedITAT Delhi23 Jan 2023AY 2010-11

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 147Section 250Section 4

section 147 to 151 of the Act. 2. That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the action of Ld. AO in framing impugned reassessment order u/s 147/143(3) is beyond jurisdiction, bad in law and against the facts and circumstances of the case. 3. In any view

DCIT, NEW DELHI vs. M/S CHOTTI LEASING & FINANCE PVT. LTD.,, NEW DELHI

In the result, the appeals filed by the Revenue in ITA No

ITA 6211/DEL/2015[2007-08]Status: DisposedITAT Delhi23 Jan 2023AY 2007-08

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 147Section 250Section 4

section 147 to 151 of the Act. 2. That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the action of Ld. AO in framing impugned reassessment order u/s 147/143(3) is beyond jurisdiction, bad in law and against the facts and circumstances of the case. 3. In any view

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during