Back
INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
OM PRAKASH KANT, Accountant Member, SANDEEP SINGH KARHAIL, Judicial Member
Export Import Bank of India – Appellant
Versus
Assistant Commissioner of Income Tax – Respondent
| Table of Content |
|---|
| 1. validity of reassessment u/s 147/148 challenged for lack of new material. (Para 2 , 3 , 4 , 5 , 6 , 7) |
| 2. parties' arguments on reopening and borrowed satisfaction. (Para 8 , 9 , 10) |
| 3. no failure to disclose facts; reopening based on existing records invalid. (Para 11 , 12 , 13 , 14 , 15 , 16) |
| 4. precedents confirm change of opinion bars reassessment after 4 years. (Para 17 , 18 , 19) |
| 5. assessee's appeal allowed; revenue's dismissed. (Para 20 , 21 , 22 , 23) |
ORDER
PER SANDEEP SINGH KARHAIL, J.M.
The assessee and the Revenue have filed the present cross-appeal against the impugned order dated 03/10/2025, passed under section 250 of the Income Tax Act, 1961 (“the Act”), by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2012-13.
ITA No. 9465/Mum/2025 Assessee’s appeal – A.Y. 2012-13
2. In this appeal, the assessee has raised the following grounds: -
“1. In the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in holding that the reassessment done by the AO by issuing notice dated 30.03.2019 w/s. 148 of the Act is valid notwithstanding the following facts:
a) The as
An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers
Please visit our Training & Support
Center or Contact Us for assistance
Scan Me!
India’s Legal research and Law Firm App, Download now!
For Daily Legal Updates, Join us on :
Back to top
