394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO

338 ITR 51High Court2011#256 most cited

What is 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO authority for?

Reassessment proceedings require the Assessing Officer to apply independent mind to form 'reasons to believe' that income has escaped assessment; a mere list of alleged transactions from an investigation report is insufficient.

295

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also referred to as

Varshaben S. Patel v. ITO · Section 147 · Section 148 · reasons to believe · escapement of income · reopening assessment · mere annexure · investigation report · independent application of mind · sufficiency of reasons · accommodation entries

Sections most often in play

Section 147Section 148Section 143(3)Section 68Section 133(6)Section 142(1)Section 143(1)Section 151

Issues it is cited on

undisclosed foreign income and assetssection 149(1)(c)section 4(2)section 201(3)section 158basection 150unexplained jewellerysection 70beyond four yearssection 18section 149(1)(b)statement under section 132(4)

Judgments citing 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO

ABHISHEKBHAI ASHOKBHAI PATEL,KADI vs. THE ITO, WARD 1, MEHSANA

In the result, the appeal of the assessee is partly allowed

ITA 1803/AHD/2025[2010-11]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2010-11

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Deepak, ARFor Respondent: Smt. Ananya Kulshresth, Sr. DR
Section 133(6)Section 144Section 147Section 69A

…deposits irrespective of taxable income. The CIT(Appeals) further observed that no evidence such as demat statements, contract notes, or broker details were furnished. Placing reliance on judicial precedents including Signature Hotels (P) Ltd. vs. ITO (2011) 338 ITR 51 (Del) and Roshan Di Hatti vs. CIT (1977) 107 ITR 938 (SC), the CIT(Appeals) dismissed Ground No. 2. Accordingly, the appeal of the assessee was dismissed in entirety. 5. The assessee is in appeal before us against the order passed by the CIT(Appeals) dismissing the appeal of the assessee. Shri Abhishekbhai Ashokbhai Patel vs. ITO Asst. Year –2010…

G S BUILDWELL PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD 10(1), DELHI, DELHI

In the result, appeal of the assessee is allowed

ITA 6581/DEL/2025[2012-13]Status: DisposedITAT Delhi08 Apr 2026AY 2012-13

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwal[Assessment Year : 2012-13] G.S.Buildwell Pvt.Ltd. Vs Ito A-12, Swasthya Vihar, Ward-10(1) East Delhi, Delhi-110092. Delhi Pan-Aaccg1781H Appellant Respondent Appellant By Shri Suresh Kumar Gupta, Ca Respondent By Shri Rajesh Kr. Dhanistha, Sr.Dr Date Of Hearing 17.02.2026 Date Of Pronouncement 08.04.2026

Section 132Section 133(6)Section 143(3)Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “B” BENCH: NEW DELHI BEFORE SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2012-13] G.S.Buildwell Pvt.Ltd. vs ITO A-12, Swasthya Vihar, Ward-10(1) East Delhi, Delhi-110092. Delhi PAN-AACCG1781H APPELLANT RESPONDENT Appellant by Shri Suresh Kumar Gupta, CA Respondent by Shri Rajesh Kr. Dhanistha, Sr.DR Date of Hearing 17.02.2026 Date of Pronouncement 08.04.2026 ORDER PER MANISH AGARWAL, AM : This appeal is filed by the assessee against the order of ld. Commissioner of Income Tax, National Faceless Appeal Centre, New…

SINGHAL FASTENERS COMPANY PRIVATE LIMITED,NEW DELHI vs. ITO WARD - 23(4), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 1992/DEL/2020[2006-07]Status: DisposedITAT Delhi09 Jan 2026AY 2006-07

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2006-07 Vs M/S Singhal Fasteners Company Ito Ward-8(4) New Delhi Private Limited 67-68 Rampuri Govind Puri Kalkaji New Delhi-19 Pan No. Aaacs1428H (Respondent) (Appellant)

Section 147Section 148

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’, NEW DELHI BEFORE SH. S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER Assessment Year: 2006-07 Vs M/s Singhal Fasteners Company ITO ward-8(4) New Delhi Private Limited 67-68 Rampuri Govind Puri Kalkaji New Delhi-19 Pan No. AAACS1428H (RESPONDENT) (APPELLANT) Shri Abhishek Mathur, CA Appellants by Respondent by Ms. Harpreet Kaur Hansra, Sr. DR. 06/01/2026 Date of hearing: 09/01/2026 Date of Pronouncement: ORDER PER SUDHIR KUMAR, JM: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appea…

HARDAYAL MILK PRODUCTS PRIVATE LIMITED,SHIKOHABAD vs. DCIT, CIRCLE-2(2)(1), FIROZABAD, FIROZABAD

In the result, both the appeals filed by assessee are allowed

ITA 344/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68

…tion entries in share capital. Hon’ble Delhi High Court held that reopening was invalid as the AO had already scrutinized the issue and accepted it after calling for and examining evidence during original assessment. d)Signature Hotels Pvt. Ltd. v. ITO [2011] 338 ITR 51 (Del HC) :In this case, reopening was based on generic information from the Investigation Wing alleging accommodation entries, without independent application of mind by the Assessing Officer. The Hon’ble Court quashed the reassessment, noting that there was no independent verification or inquiry by the AO. It amounted to borrowed satisfaction. e)…

HARDAYAL MILK PRODUCTS PRIVATE LIMITED,SHIKOHABAD vs. DCIT, CIRCLE-2(2)(1), FIROZABAD, FIROZABAD

In the result, both the appeals filed by assessee are allowed

ITA 343/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68

…tion entries in share capital. Hon’ble Delhi High Court held that reopening was invalid as the AO had already scrutinized the issue and accepted it after calling for and examining evidence during original assessment. d)Signature Hotels Pvt. Ltd. v. ITO [2011] 338 ITR 51 (Del HC) :In this case, reopening was based on generic information from the Investigation Wing alleging accommodation entries, without independent application of mind by the Assessing Officer. The Hon’ble Court quashed the reassessment, noting that there was no independent verification or inquiry by the AO. It amounted to borrowed satisfaction. e)…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), KOLKATA, KOLKATA vs. SIDDHESHWARI VYAPAAR PRIVATE LIMITED, KOLKATA

In the result, appeal of the revenue is dismissed

ITA 2280/KOL/2025[2012-13]Status: DisposedITAT Kolkata23 Dec 2025AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.2280/Kol/2025 (निर्धारणवर्ा/Assessment Years :2012-2013) Dcit, Central Circle-1(2), Vs Siddheshwarivyapaar Pvt Ltd Kolkata 2Nd Floor, 159, Ravindra Sarani Kolkata-700007 Pan No. :Aancs 2337 J (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) रधजस्वकीओरसे /Revenue By : Shri Sanat Kumar Raha, Cit-Dr निर्धाररतीकीओरसे /Assessee By : Shrisoumitra Choudhury & Rainak Jain, Advocates सुनवाई की तारीख / Date Of Hearing : 09/12/2025 घोषणा की तारीख/Date Of Pronouncement : 23.12.2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Revenueagainst The Order Passed By The Ld. Cit(A), Kolkata-20, Dated 06.05.2025For The Assessment Year2012-2013. 2. The Appeal Of The Revenue Is Barred By 69 Days. Considering The Submissions Of The Ld. Cit-Dr & Looking To The Facts Of The Case, We Condone The Delay Of 69 Days In Filing The Present Appeal By The Revenue & The Appeal Is Admitted For Hearing. 3. The Only Issue Raised In This Appeal Is Against The Order Of The Ld. Cit(A) In Deleting The Addition Of Rs.6,82,00,000/- Made U/S.68 Of The Act On Account Of Unexplained Cash Credits Received From Shell Entities In The Guise Of Share Capital.

For Appellant: ShriSoumitra Choudhury and Rainak Jain, AdvocatesFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 131Section 133(6)Section 143(2)Section 143(3)Section 148Section 68

…the legal requirements for forming a valid belief that income has escaped assessment. Similarly, the ld.CIT(A) relied on the decision of the Hon’ble Delhi High Court in the case of Signature Hotels P. Ltd., reported in [2012] 20 taxmann.com 797 (Delhi)/[2011] 338 ITR 51 (Delhi), wherein the Hon’ble High Court has held that while analyzing the reasons recorded for reopening the case based on vague information, held that the reasons provided by the Assessing Officer must be specific and based on tangible material. It was also observed by the Hon’ble High Court that reopening based on generalized or unclear informat…

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

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

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

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA 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. and Shri Shivam Gupta, CA Department by Sh. Mukesh Jha, CIT DR and 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…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA 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. and Shri Shivam Gupta, CA Department by Sh. Mukesh Jha, CIT DR and 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…

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

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

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

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA 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. and Shri Shivam Gupta, CA Department by Sh. Mukesh Jha, CIT DR and 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…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA 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. and Shri Shivam Gupta, CA Department by Sh. Mukesh Jha, CIT DR and 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…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA 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. and Shri Shivam Gupta, CA Department by Sh. Mukesh Jha, CIT DR and 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…

BRIJ GOPAL CONSTRUCTION COMPANY (P) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-3, DELHI

In the result, assessee’s appeal is allowed

ITA 4800/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri M Balaganesh & Ms. Madhumita Royassessment Year: 2017-18

Section 1Section 143Section 143(3)Section 270ASection 270A(2)(a)

…Ltd HIGH COURT i) ITA No. 335/2015 (Del) Pr. CIT vs M/s N.C. Cables Ltd. ii) 333 ITR 237 (Del) Central India Electric Supply Co. Ltd. vs ITO 27 iii) 258 ITR 317 (Del) United Electrical Co. P. Ltd. vs. CIT iv) 319 ITR 221 (Del) Shipra Srivastava vs. ACIT v) 338 ITR 51 (Del) Signature Hotels (P) Ltd. vs. ITO vi) 231 Taxman 73 (MP) CIT v. S. Goyanka Lime & Chemical Ltd. affirmed by the Apex Court in the case of CIT. reported in 237 Taxman 378 vii) 218 ITR 730 (MP) CIT v. Man Mohan Das viii) 400 ITR 397 (Chattisgarh) Maruti Clean Coal & Power Ltd. vs. ACIT ix) 267 ITR 716 (P&H) Mohinder Singh Malik vs. CCIT ix) 12…

INCOME TAX OFFICER WARD 1(1), FARIDABAD, FARIDABAD vs. BHIKSHU PORTFOLIO PRIVATE LIMITED, FARIDABAD

ITA 4252/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

…l of alleged transactions is referred in the investigation report in the table form. Said list itself cannot lead to any inference against the assessee, placing reliance on judgement of Hon’ble Delhi High Court in the form of Signature Hotels (P.) Ltd. v. ITO 338 ITR 51 wherein it was held that ‘annexure is not a pointer and does not indicate escapement of income’.” 19 | P a g e ITA No.4205, 4206, 4207, 4251 & 4252/Del/2025 C.O. Nos. 214 to 218/Del/2025 5.15.2. The appellant has also pointed out that there was inconsistency in the ‘reasons recorded’ for the purpose of reopening. It is pleaded by the appellant…

INCOME TAX OFFICER WARD 1(1), FARIDABAD, FARIDABAD vs. BHIKSHU PORTFOLIO PRIVATE LIMITED, FARIDABAD

ITA 4251/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

…l of alleged transactions is referred in the investigation report in the table form. Said list itself cannot lead to any inference against the assessee, placing reliance on judgement of Hon’ble Delhi High Court in the form of Signature Hotels (P.) Ltd. v. ITO 338 ITR 51 wherein it was held that ‘annexure is not a pointer and does not indicate escapement of income’.” 19 | P a g e ITA No.4205, 4206, 4207, 4251 & 4252/Del/2025 C.O. Nos. 214 to 218/Del/2025 5.15.2. The appellant has also pointed out that there was inconsistency in the ‘reasons recorded’ for the purpose of reopening. It is pleaded by the appellant…

INCOME TAX OFFICER WARD 1(1), FARIDABAD, FARIDABAD vs. BHIKSHU PORTFOLIO PRIVATE LIMITED, FARIDABAD

ITA 4207/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Nov 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

…l of alleged transactions is referred in the investigation report in the table form. Said list itself cannot lead to any inference against the assessee, placing reliance on judgement of Hon’ble Delhi High Court in the form of Signature Hotels (P.) Ltd. v. ITO 338 ITR 51 wherein it was held that ‘annexure is not a pointer and does not indicate escapement of income’.” 19 | P a g e ITA No.4205, 4206, 4207, 4251 & 4252/Del/2025 C.O. Nos. 214 to 218/Del/2025 5.15.2. The appellant has also pointed out that there was inconsistency in the ‘reasons recorded’ for the purpose of reopening. It is pleaded by the appellant…

INCOME TAX OFFICER, FARIDABAD vs. BHIKSHU PORTFOLIO PRIVATE LIMITED, FARIDABAD

ITA 4206/DEL/2025[2014-15]Status: DisposedITAT Delhi17 Nov 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

…l of alleged transactions is referred in the investigation report in the table form. Said list itself cannot lead to any inference against the assessee, placing reliance on judgement of Hon’ble Delhi High Court in the form of Signature Hotels (P.) Ltd. v. ITO 338 ITR 51 wherein it was held that ‘annexure is not a pointer and does not indicate escapement of income’.” 19 | P a g e ITA No.4205, 4206, 4207, 4251 & 4252/Del/2025 C.O. Nos. 214 to 218/Del/2025 5.15.2. The appellant has also pointed out that there was inconsistency in the ‘reasons recorded’ for the purpose of reopening. It is pleaded by the appellant…

INCOME TAX OFFICER, FARIDABAD vs. BHIKSHU PORTFOLIO PRIVATE LIMITED, FARIDABAD

ITA 4205/DEL/2025[2013]Status: DisposedITAT Delhi17 Nov 2025

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

…l of alleged transactions is referred in the investigation report in the table form. Said list itself cannot lead to any inference against the assessee, placing reliance on judgement of Hon’ble Delhi High Court in the form of Signature Hotels (P.) Ltd. v. ITO 338 ITR 51 wherein it was held that ‘annexure is not a pointer and does not indicate escapement of income’.” 19 | P a g e ITA No.4205, 4206, 4207, 4251 & 4252/Del/2025 C.O. Nos. 214 to 218/Del/2025 5.15.2. The appellant has also pointed out that there was inconsistency in the ‘reasons recorded’ for the purpose of reopening. It is pleaded by the appellant…

RITIKA GEMS PRIVATE LIMITED,MUMBAI vs. ITO-5(3)(1), MUMBAI, MUMBAI

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 4495/MUM/2025[2014-15]Status: DisposedITAT Mumbai03 Nov 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 68

…Capital Gain Statement Copy of Broker Notes Note on Business Activities Details Party wise Sales along with Copy of Invoice Details of Party wise Purchase along with Copy of Invoice xxvii. Similarly in Signature Hotels (P) Ltd. vs. ITO and another reported in 338 ITR 51 (Del) has held under similar circumstances follows: have 'reason believe that income "Section 147 of the Income- tax Act, 1961, is wide but not plenary. The Assessing Officer chargeable tax has escaped assessment. This is mandatory and the 'reason believe' required be recorded in writing by the Assessing Officer. one A notice under can be quashed…

PRAMOD GUPTA,GURGAON vs. ITO WARD - 46(5), NEW DELHI

Accordingly the appeal of the assessee succeeds. The same is allowed

ITA 3648/DEL/2019[2010-11]Status: DisposedITAT Delhi30 Sept 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaassessment Year: 2010-11 Pramod Gupta, Vs Ito, B-44, Pinnacle, Sector-43, Ward-46(5), Dlf Phase-05, New Delhi. Gurgaon – 122 009. Pan: Aanpg2866P (Appellant) (Respondent) Assessee By : Shri K. Sampath, Advocate & Shri V. Rajakumar, Advocate Revenue By : Ms Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 30.07.2025 Date Of Pronouncement : 30.09.2025

For Appellant: Shri K. Sampath, Advocate &For Respondent: Ms Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 147Section 148Section 151Section 68Section 69C

…on the decisions in:- (i) ITO vs. Lakhmani Mewal Das (1976) 103 ITR 437 (SC); (ii) ITO vs. Parashuram Pottery Works Co. Ltd. (1977) 106 ITR 1 (SC); (iii) CIT vs. Kelvinator of India Ltd. (20101) 320 ITR 561 (SC); (iv) ITO vs. Signature Hotels Pvt. Ltd. (2011) 338 ITR 51 (Del); (v) PCIT vs. G & G Pharma India Ltd. (2016) 384 ITR 147 (Del); (vi) PCIT vs. Meenakshi Overseas Pvt. Ltd. (2017) 395 ITR 677 (Del); & (vii) CCE vs. Andaman timber Industries (2015) 62 taxmann.com 3 (SC) 8. In the light of the aforesaid discussion, we are inclined to allow ground No.(i). As the reopening is vitiated, the assessment is liabl…

BRAND INDIA REAL ESTATE PRIVATE LIMITED,JAIPUR vs. INCOME TAX OFFICER WARD 6(1), JAIPUR

In the result, appeal of the assessee is allowed

ITA 514/JPR/2025[2012-2013]Status: DisposedITAT Jaipur29 Sept 2025AY 2012-2013
For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Dharam Singh Meena, JCIT
Section 132Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

…{ "clean_text": "आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर\nIN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR\nडा० एस. सीतालक्ष्मी, न्यायिक सदस्य एवं श्री गगन गोयल, लेखा सदस्य, के समक्ष\nBEFORE: DR. S. SEETHALAKSHMI, JM & SHRI GAGAN GOYAL, AM\nआयकर अपील सं./ITA No. 514/JPR/2025\nनिर्धारण वर्ष / Assessment Years : 2012-13\nBrand India Real Estate Pvt. Ltd.\n262, C Block Malviya Nagar, Jaipur.\nVs.\nIncome Tax Officer,\nWard-6(1),\nJaipur.\nस्थायीलेखा सं. / जीआईआर सं./PAN/GIR No.: AADCP7925K\nअपीलार्थी / Appellant\nप्रत्यर्थी / Respondent\nनिर्धारिती की ओरसे / Assesseeby : Shri Siddharth Ranka, Adv.…

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