This Digest of case laws is prepared by KSA Legal and AIFTP from judgements reported in BCAJ, CTR, DTR, ITD, ITR, ITR (Trib), Chamber's Journal, SOT, Taxman, TTJ, BCAJ, ACAJ, www.itatonline.org and other journals
Click here to download the pdf versions of the Digest of case laws

S. 147 : Reassessment-Not made any addition pertaining to three-folded reasons for reopening the assessment-Cash credits-Reassessment order is bad in law.[S. 68, 148, 254(1)]

ITO v. Hassab Realty Pvt. Ltd. (2022) 99 ITR 315 (Pune) (Trib)

S. 147 : Reassessment-Best Judgment Assessment-Natural justice-Notice issued u/s 143(2)-Assessee was out of station-Not attended-Order was passed under section 144-Matter remanded for re-adjudication. [S.50C, 143(2),144, 148]

Gopi Kishan Pandey v.ITO (2022) 99 ITR 203 (Trib) (Lucknow)(Trib)

S. 147 : Reassessment-With in four years-Subsequent decision of High Court-Reassessment is valid [S. 148]

Dy. CIT v. Clarion Technologies (P) Ltd. (2022) 216 TTJ 23 (UO) (Pune)(Trib)

S. 147 : Reassessment-With in four years-Assessment year 2005-06 was the initial assessment year-Substantial expansion-No suppression of material-Reassessment is held to be bad in law [S. 80IC, 143(3), 148]

Valco Industries Ltd. v. ACIT (2022) 215 DTR 181 /218 TTJ 628 (Chd)(Trib)

S. 147 : Reassessment-Setting aside Tribunal’s order by high court revives appeal from date of inception-Jurisdiction open to question as matter not final. [S. 144C]

YCH Logistics (India) Pvt. Ltd. v. Dy. CIT (2022) 98 ITR 467 (Chennai) (Trib)

S. 147 : Reassessment-Information relating to cash deposit and purchase of property-Addition was made on account of expenditure-Reasons for initiation of reassessment proceedings ceased to survive-Reassessment is bad in law.[S. 37(1), 148]

Manish Mittal v. ITO (2022) 98 ITR 18 (SN)(Delhi) (Trib)

S. 147 : Reassessment-No addition was made on grounds on which notice is issued-Other additions do not survive-Reassessment was quashed. [S. 92C, 133A, 148]

Edelweiss Rural and Corporate Services Pvt. Ltd. v. CIT (2022) 98 ITR 69 (SN) (Mum)(Trib)

S. 147 : Reassessment-Notice-Additions made on the ground different from reassessment grounds-Reassessment not sustainable. [S.148]

Jeet Singh v. ITO (2022) 98 ITR 331 (Delhi) (Trib)

S. 147 : Reassessment-Additions made for issues different from ground of reassessment-Additions not sustainable. [S. 148]

Pushpa Singh v. PCIT (2022)98 ITR 79 /(2023) 224 TTJ 20(Pat) (Trib)

S. 147 : Reassessment-After the expiry of four years-Cash credits-No failure to disclose material facts-Reassessment is invalid. [S. 68, 148]

Dy. CIT v. Pacharia Exports Pvt. Ltd. (2022)95 ITR 13 (Kol) (Trib)