How many judgments cite 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO?

295 judgments on BharatTax cite 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO (338 ITR 51), spanning 2012 to 2026.

Which sections of the Income Tax Act does 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 68, Section 133(6), Section 142(1).

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

338 ITR 51High Court2011#263 most cited

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

Reasons for reopening an assessment must be specific and not vague, scanty, or based on borrowed satisfaction. The Assessing Officer must quantify the escaped income.

295

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2012 to 2026.

Also referred to as

Varshaben S. Patel v. ITO · section 147 · section 148 · reassessment notice · vague reasons · borrowed satisfaction · escaped income

Sections most often in play

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

Issues it is cited on

undisclosed foreign income and assets section 149(1)(c)section 4(2)section 201(3)section 158ba section 150 unexplained jewellery section 70 beyond four years section 18 section 149(1)(b)statement under section 132(4)

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

Yadav Rice Mills, Muktsar vs. Deputy Commissioner of Income Tax, Circle-2, Bathinda

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

ITA 415/ASR/2024[2012-13]Status: DisposedITAT Amritsar17 Sept 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashwani Kumar, Ms. Deepali Aggarwal

Section 131Section 143(1)Section 143(3)Section 147Section 148Section 151Section 250Section 68Section 69C

…3 ITR (Trib.) 95 (ITAT Agra) 14 I.T.A. No. 415/Asr/2024 Assessment Year: 2012-13 CIT v. Smt. Paramjit Kaur v. CIT [2009] 311 ITR 38 (P&H) S P Agarwalla Alias Sukhdeo Prasad Agarwala v. ITO [1983] 140 ITR 1010 (Cal) Signature Hotels (P) Ltd. v. ITO [2011] 338 ITR 51 (Delhi HC ) CIT v. SFIL Stock Broking Ltd. [2010] 325 ITR 285 (Del) CIT v. Meenakshi Overseas Pvt. Ltd. [2017] 99CCH 0028 (Delhi HC)” 16. The Ld AR relying on the above decisions on legal grounds against the initiation of proceedings u/s 148 and also on the merits of the case arising out of the facts discussed above, he prayed for deletion of t…

Anusha Finvest Pvt Ltd, Jaipur vs. Assistant Commissioner of Income Tax Circle 1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 985/JPR/2024[2010-2011]Status: DisposedITAT Jaipur10 Sept 2025AY 2010-2011

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Saurav Harsh, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 142(1)Section 143(1)Section 143(2)Section 147Section 148

…ssessing Officer till fag end of the reassessment proceedings, a fact admitted by the Assessing Officer himself in the assessment order. Consequently, the reopening is not valid (Sarthak Securities Pvt. Ltd vs. ITO 329 ITR 110 (Del), Signature Hotels Pvt. Ltd 338 ITR 51 (Del) & CIT vs. SFIL Stockbroking Co 325 ITR 285 (Del) followed) c. 2022 (8) TMI 576 - ITAT CHANDIGARH Rajnish Garg Versus The Asst. Cit Tax Circle-6, Ludhiana Reopening of assessment u/s 147 - investment in trade market through broker and manipulated his income by shifting in losses / shifting in profit - HELD THAT:- As the reopening was done on…

Narayan Suppliers Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(3), Kolkata

In the result, appeal of the assessee is dismissed

ITA 1077/KOL/2024[2011-2012]Status: DisposedITAT Kolkata08 Sept 2025AY 2011-2012

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri Avijit Ghoshal, ARFor Respondent: Shri Raja Sengputa, CIT-DR

Section 10(38)

…view expressed by the Tribunal. No substantial question of law arises for our consideration. The appeals are dismissed. There shall be no order as to costs. The Hon'ble Delhi High Court in the case of Signature Hotels (P) Ltd. vs ITO and another, reported in 338 ITR 51 (Delhi) under similar circumstances held as follows: "For the A.Y. 2003-04, the return of income of the assessee company was accepted u/s 143(1) of the Income-tax Act, 1961 and was not selected for scrutiny. Subsequently, the Assessing Officer issued notice u/s 148 which was objected by the assessee. The Assessing Officer rejected the objections.…

Ultra Modern Exports Pvt. Ltd., New Delhi vs. ITO Ward - 27(1), New Delhi

ITA 527/DEL/2020[2011-12]Status: DisposedITAT Delhi06 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 143(3)Section 147Section 148Section 68

…ad to a formation of belief as to escapement of income in the case of the assessee company. Reliance in this regard has been rightly placed on the decision of Hon'ble Jurisdictional High Court in the case of Signature Hotels Private Limited vs ITO reported in 338 ITR 51 (Del) wherein it was held as under:- “4. The aforesaid section is wide but it is not plenary. We have to consider and examine the crucial expression…

Amit Behal, New Delhi vs. ACIT, Circle Int. Taxation 1(1) (2), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 923/DEL/2024[2015-16]Status: DisposedITAT Delhi18 Jul 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Tushar Hemani, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT-DR

Section 148Section 148ASection 69Section 69A

…ingh v UOI-(2024) 165 taxmann.com 114 (P& 5. Secondly, the ld AR attacked the order u/s 148A(d) as vague, scanty and non-specific and that the reopening is merely based on borrowed satisfaction. The ld AR relied on ➤ Signature Hotels P. Ltd. vs. ITO – (2012) 338 ITR 51 (Delhi); ➤ Harikishan S. Virmani vs DCIT– (2017) 394 ITR 146 (Guj); ➤ Paresh Babubhai Bhalani vs. ITO – SCA 922 of 2022 and Ors. (Guj); Page 4 of 13 ITA No. 923/DEL/2024 [A.Y. 2015-16] Amit Behal Vs. ACIT 6. The ld AR further argued that the "Jurisdictional facts", based on which AO has assumed jurisdiction under section 147 of the Act, are "inc…

ACIT, New Delhi vs. M/S. Alodie Estates Pvt. Ltd., New Delhi

In the result, the appeal of the revenue is dismissed

ITA 1730/DEL/2016[2011-12]Status: DisposedITAT Delhi18 Jul 2025AY 2011-12

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2011-12 Asstt. Commissioner Of Vs. M/S. Alodie Estates Pvt. Ltd. 2Nd Income Tax, Central B-4/43, Floor, Safdarjung Circle-2, New Delhi Enclave, New Delhi-110029 Pan No.Aaica1782G (Appellant) (Respondent)

Section 132Section 139Section 147Section 148Section 68

…to establish the vital link between the reasons and the evidence, and that this vital link is the safeguard against arbitrary re-opening of a concluded assessment"; in CIT vs SFIL Stock Broking Ltd. (2010) 325 ITR 285 (Del), Signature Hotels Pvt. Ltd. Vs ITO 338 ITR 51 (Del), (Pr.CIT v India Business Network Ltd.) and Pr. CIT v G&G Pharma India Ltd. (ITA No. 545/2015) Delhi High Court order dated 08.10.2015 it has been held that "mere information received from DDIT(Inv) cannot constitute valid reasons for initiating reassessment proceedings in the absence of anything to show that A.O. had independently applied h…

Jaiprakash Yadav, Alwar vs. Income Tax Officer, WD, Behror

In the result, the appeal of the assessee is allowed

ITA 18/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Pranav Yadav, Adv. (Thr.VC)For Respondent: Shri Gaurav Awasthi, JCIT, Sr. DR

Section 147Section 148Section 151Section 56(2)(vii)Section 69Section 69A

…nstitute valid reasons for initiating reassessment proceedings in the absence of anything to show that A.O. had independently applied his mind to arrive at a belief that the income had escaped assessment. 2.3. In the case of Signature Hotels Pvt. Ltd. Vs ITO 338 ITR 51 (Del) notice u/s 148 issued based upon the report from investigation wing has been held to be invalid where the notice was issued by the A.O. without examining evidence. The head note of the judgement read as under :- Reassessment Condition Precedent Reason to believe that income had escaped assessment - Notice based on report from Director of In…

Ram Singh, District Kaithal, Haryana vs. Income Tax Officer, Ward-1, Kaithal, Income Tax Office, Ambala Road

The appeal of the assessee is dismissed

ITA 920/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh30 Jun 2025AY 2012-13

Bench: The Appeal Is Finally Heard Or Disposed Of.

For Appellant: Shri Nikhil Goyal, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 143(1)Section 143(3)Section 147Section 148Section 234ASection 69

…mind to the information, which is absent in this case. Reliance was placed on the following judicial precedents: a. PCIT v. G&G Pharma India Ltd. [384 ITR 147 (Del)] b. Meenakshi Overseas Pvt. Ltd. [395 ITR 677 (Del)] c. Signature Hotels Pvt. Ltd. v. ITO [338 ITR 51 (Del)] 5. On the merits of the addition, the Ld. AR submitted that: The assessee had duly filed a cash flow statement explaining sources of cash deposits. The cash deposits were out of earlier year’s withdrawals, agricultural income, and loans and advances from family and friends. The assessee is residing in a rural area and is engaged in traditi…

ACIT, New Delhi vs. M/S. A & D Estates Pvt. Ltd., New Delhi

In the result we upheld the decision of the Ld

ITA 1729/DEL/2016[2012-13]Status: DisposedITAT Delhi25 Jun 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Manish Agarwalassessment Year: 2012-13

Section 132Section 143(2)Section 143(3)Section 148Section 68

ACIT, New Delhi vs. M/S. Sea Point Trading & Builders Pvt. Ltd., New Delhi

In the result, the appeal of the assessee is dismissed

ITA 1731/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Jun 2025AY 2012-13

Bench: Ms. Madhumita Roy, Judical Member & Shri Manish Agarwalasst. Commissioner Of M/S. Sea Point Trading & Income Tax, Builders Pvt. Ltd. Central Circle-2, Vs. B-4/43, 2Nd Floor, New Delhi. Safdarjung Enclave, New Delhi-110029. Pan: Aabcs0741C (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Department By Shri Virender Kumar Singh, Sr. Dr Date Of Hearing 07/05/2025 Date Of Pronouncement 18/06/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Revenue Against The Order Of Learned Commissioner Of Income Tax (Appeals)-23, New Delhi [Ld. Cit(A), In Short], Dt. 29.01.2026 In Appeal No. 16/2015-16 For Assessment Year 2012-13 Passed U/S 250 Of The Income Tax Act, 1961 (The Act, In Short). 2. The Revenue Has Taken The Following Grounds Of Appeal: “1. The Order Of Ld. Cit(A) Is Not Correct In Law & On Facts. 2. On The Facts & Circumstances Of The Case, The Ld. Cit(A) Has Erred In Laws In Deleting The Addition Of Rs.6,35,00,000/- Made By Ao On Account Of Unexplained Cash Credit U/S 68 Of The Act Received From M/S Manan Merchandise Pvt. Ltd.”

Section 127Section 132Section 147Section 148Section 250Section 68

…to establish the vital lin k between the reasons and the evidence, and that this vital link is the safeguard against arbitrary re-opening of a concluded assessment: in CIT vs SFIL Stock Broking Ltd. (2010) 325 ITR 285 (Del), Signature Hotels Pvt. Ltd. Vs ITO 338 ITR 51 (Del), (Pr.CIT v India Business Network Ltd.) and Pr. CIT v G&G Pharma India Ltd. (ITA No. 545/2015) Delhi High Court order dated 08.10.2015 it has been held that 'mere information received from DDIT(Inv) cannot constitute valid reasons for initiating reassessment proceedings in the absence of anything to show that A.O. had independently applied h…

ACIT, New Delhi vs. M/S. Belisma Buildcon Pvt. Ltd., Gurgaon

In the result, the appeal of the Revenue is dismissed

ITA 1728/DEL/2016[2011-12]Status: DisposedITAT Delhi18 Jun 2025AY 2011-12

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2011-12] Acit, Vs M/S. Belisma Buildcon Central Circle-2, Pvt.Ltd.,77, Ss House, Sector-44, New Delhi Gurgaon, Haryana-122003. Pan-Aadcb9647C Appellant Respondent Appellant By Dr. Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Respondent By Shri Virender Kumar Singh, Sr.Dr Date Of Hearing 07.05.2025 Date Of Pronouncement 18.06.2025 Order

Section 132Section 147Section 148Section 250Section 68

…ITA No.1728/Del/2016 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “E” BENCH: NEW DELHI BEFORE MS.MADHUMITA ROY, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2011-12] ACIT, vs M/s. Belisma Buildcon Central Circle-2, Pvt.Ltd.,77, SS House, Sector-44, New Delhi Gurgaon, Haryana-122003. PAN-AADCB9647C APPELLANT RESPONDENT Appellant by Dr. Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Respondent by Shri Virender Kumar Singh, Sr.DR Date of Hearing 07.05.2025 Date of Pronouncement 18.06.2025 ORDER PER MANISH AGARWAL, AM : The present appeal has been filed by the…

DCIT, New Delhi vs. M/S Sahara India Mass Communication Ltd., Mumbai

In the result, the appeal of the revenue stands dismissed as above

ITA 3130/DEL/2011[2003-04]Status: DisposedITAT Delhi30 May 2025AY 2003-04

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(3)Section 147Section 148

…in it had been held that the reopening done on the basis of report/information received from the investigation wing without application of mind or to undertake the roving and fishing enquiries by the AO was void-ab-initio:  Signature Hotels P. Ltd. vs. ITO: 338 ITR 51 (Del. HC)  Sarthak Securities vs. ITO: 329 ITR 110 (Del. HC)  Girdhar Gopal Dalmia v. Uol and Ors: 451 ITR 320 (Cal HC)  PCIT. GRD Commodities Ltd.: 149 taxmann.com 233 (Cal HC)  Eveready Industries India Lad vs. JCIT 243 ITR 540 (Gauhati)  CIT vs. Smt Paramjit Jaur: 168 Taxman 39 (P&H HC)  Sterlite Industries (India) Lituted vs. ACIT: 305 I…

Laxmidhan Tradelink Pvt. Ltd., Kolkata vs. ITO, Ward-2(2), Kolkata

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

ITA 1428/KOL/2023[2011-12]Status: DisposedITAT Kolkata23 May 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 11Section 147Section 148Section 250Section 68

…ssioner of Income-tax, IV vs. Insecticides (India) Ltd. [2013] 38 taxmann.com 403 (Delhi)/[2013] 219 Taxman 111 (Delhi) (Mag.)/[2013] 357 ITR 330 (Delhi)[20-05-2013] x) Signature Hotels (P.) Ltd. vs. Income-tax Officer [2012] 20 taxmann.com 797 (Delhi)/[2011] 338 ITR 51 (Delhi)[21-07-2011] xi) Commissioner of Income-tax vs. Atul Jain [2008] 299 ITR 383 (Delhi)[23-05- 2007] xii) Commissioner of Income-tax vs. SFIL Stock Broking Ltd. [2010] 325 ITR 285 (Delhi)/[2010] 233 CTR 69 (Delhi)[27-04-2010] xiii) Assistant Commissioner of Income-tax vs. Rajesh Jhaveri Stock Brokers (P.) Ltd. [2007] 161 Taxman 316 (SC)/[2007]…

DCIT, Central Circle-28, New Delhi vs. Manish Uppal, Delhi

In the result, assessee’s appeal in ITA No

ITA 3061/DEL/2022[2013-14]Status: DisposedITAT Delhi16 May 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2013-14

Section 132(1)Section 143(1)Section 147Section 148Section 153ASection 68

…not justified; • PCIT vs. RMG Polyvinyl (1) Ltd. reported in 2017] 396 ITR 5 • CIT Vs. Multiplex Trading & Industrial Co. Ltd. in ITA No.356/2013 dated 22.09.2015 (Hon'ble Delhi High Court); • Signature Hotels P. Ltd. Vs. Income Tax Officer reported in [2011] 338 ITR 51, • Sarthak Securities Company Private Limited versus Income Tax Officer, reported in 329 ITR 110 (Delhi), • CIT Vs. Insecticides (India) Ltd. 357 ITR 330 (Delhi) • Pr. CIT vs. Meenakshi Overseas Ltd. reported in 395 ITR 677 (Del) PROPOSITION 4 ON MERITS: FAILURE TO PROVIDE CROSS EXAMINATION OF SH. ASHISH BEGWANI, THOUGH STATEMENT RELIED BY AO IN T…

Malkiat Agro Industries 01, Cantt Road, Nabha 147201, Punjab vs. Lovish Shelley the DCIT Circle Mandigobind Garh Jao Income Tax Officer Nabha, Punjab

In the result, assessee’s appeal is allowed

ITA 485/CHANDI/2024[2012-2013]Status: DisposedITAT Chandigarh01 Apr 2025AY 2012-2013

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri K.K. Singla, C.AFor Respondent: Smt. Kusum Bansal, CIT DR

Section 133Section 133(6)Section 143(1)Section 148

…his mind, but has merely relied upon the information available with the department and which reopening is not valid in view of the Judgement of Delhi High Court in the Meenakshi Overseas, reported in 395 ITR 677, Signature Hotels (P) Ltd. Vs ITO, reported in 338 ITR 51 and Judgement of ITAT, Amritsar Bench, Amritsar in the case of M/s Holyfaith International Pvt. Ltd. c). That the Ld. ITO, Ward Nabha has failed to consider and apply his mind to the detailed reply submitted during the course of proceedings u/s 133 (6) prior to the issue of notice u/s 148 and, thus, the very basis of formation of reason to believe…

Deepak Kakar, Ferozpur vs. Income Tax Officer, Ward 3(1), Ferozpur

In the result, Assessee’s appeal is allowed

ITA 409/ASR/2024[2014-15]Status: DisposedITAT Amritsar24 Mar 2025AY 2014-15

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayxsftrtot U/Ita No. 409/Asr/2024 / Assessment Year : 2014-15 Deepak Kakar, The Ito, <Shw Mohalla Dhanwala Wala, Ward-3(1), Closed Street, Ferozepur Ferozepur City, Punjab 152002 Tt./Pan No: Ctzpk1764P H^L^Ff/Respondent 3| 4] Cl |'4F/Appellant ( Hybridhearing ) <Ivjcj?! $/ Revenue By :Shri Davinder Pal Singh, Sr. Dr 3{N Tf/Assessee By : Shri Parikshit Aggarwal, Ca

For Appellant: Shri Parikshit Aggarwal, CAFor Respondent: Shri Davinder Pal Singh, Sr. DR

Section 144Section 147Section 148Section 194ASection 195

…the reassessment proceedings were based on belief that income chargeable to tax has escaped, assessment—Therefore, issuance of notice under s. 148 was not valid" Ganga saran & Sons (P) Ltd, v. ITO, 130 ITR 1 (SC) • • Signature Hotels (P) Ltd, vs ITO&, ANR. (338 ITR 51) 12011) (Del. HC • Pr. CIT vs. G & G Pharma India Ltd (2016) 384 ITR 147 (DelHC) CIT vs. Indo Arab Air Services (2016) 130 DTR 78/ • 283 CTR 92 (Del. HC) We find that there are various judicial pronouncements which clearly and categorically say that a notice issued by a non- , residentjurisdictional Assessing Officer and later on assessment made…

DCIT, Central Circle, Dehradun vs. R.B. Enterprises, Dehradun

ITA 4/DDN/2019[2010-11]Status: DisposedITAT Dehradun27 Jan 2025AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

Section 143(3)Section 147Section 148Section 153A(1)(b)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DEHRADUN BENCH “DB”, DEHRADUN BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER (THROUGH VIDEO CONFERENCING) ITA Nos.3500 & 3501/Del/2017 Assessment Years: 2003-04 & 2008-09 Vs. DCIT, M/s. R.B. Enterprises, 7, Saharanpur Road, Central Circle, Dehradun Dehradun PAN :AADFR7892D (Appellant) (Respondent) With Assessment Year: 2010-11 Vs. M/s. R.B. Enterprises, DCIT, Central Circle, 7, Saharanpur Road, Dehradun Dehradun PAN :AADFR7892D (Appellant) (Respondent) Assessee by Ms. Ananya Kapoor, Adv. Department by Sh. S.K. Chaterjee, CIT(DR) D…

M/S. R.B. Enterprises, Dehradun vs. DCIT, Dehradun

ITA 3501/DEL/2017[2008-09]Status: DisposedITAT Dehradun27 Jan 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

Section 143(3)Section 147Section 148Section 153A(1)(b)

M/S. R.B. Enterprises, Dehradun vs. DCIT, Dehradun

ITA 3500/DEL/2017[2003-04]Status: DisposedITAT Dehradun27 Jan 2025AY 2003-04

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

Section 143(3)Section 147Section 148Section 153A(1)(b)

Achla Malhotra, Delhi vs. ITO, Ward-24(1), Delhi

ITA 4252/DEL/2024[2014-15]Status: DisposedITAT Delhi23 Jan 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…