Central Provinces Manganese Ore Co. Ltd. v. ITO

191 ITR 662Supreme Court of India1991#464 most cited

What is Central Provinces Manganese Ore Co. Ltd. v. ITO authority for?

For the initiation of reassessment proceedings under section 147(a), it is essential to have 'reason to believe' that income has escaped assessment, based on relevant material. The AO's subjective satisfaction and the final outcome of the proceedings are not relevant at the initiation stage.

200

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2010 to 2025.

Also referred to as

Central Provinces Manganese Ore Co. Ltd. v. ITO · Section 147(a) · Section 148 · reason to believe · escapement of income · initiation of reassessment · relevant material · subjective satisfaction · change of opinion

Also reported as

59 Taxmann 17

Sections most often in play

Section 147Section 148Section 143(3)Section 142(1)Section 151Section 133(6)Section 68Section 115JB
Read the full judgment

Issues it is cited on

section 147(a)full and true disclosurematerial facts necessary for assessmentlive linkincome escaping assessmentescapement of incomereason to believemere change of opinionchange of opiniontangible materialkelvinatorviolation of natural justice

Judgments citing Central Provinces Manganese Ore Co. Ltd. v. ITO

DCIT(CC)-8(3), Mumbai vs. Jsw Steel Limited, Mumbai

In the result, all the above appeals of the assessee are

ITA 5615/MUM/2024[2014-15]Status: DisposedITAT Mumbai08 Dec 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263

…8 of the Act, by the AO, we are of the considered opinion that the AO had sufficient ‘reason to believe' for reopening of the case u/s 147 by issuing notice u/s 148 of the Act. We may place reliance on the case of Central Provinces Manganese Ore Company ltd. (191 ITR 662 SC), wherein the Apex Court interpreted the word "reason to believe". It was held that, the words "reason" in the phrase "reason to believe" in section 147of the Act, would mean cause or justification. If the AO has cause or jurisdiction to know or suppose that income has escaped assessment, he can be said to have reason to believe that income ha…

DCIT(CC)-8(3), Mumbai vs. Jsw Steel Limited, Mumbai

In the result, all the above appeals of the assessee are

ITA 5601/MUM/2024[2015-16]Status: DisposedITAT Mumbai08 Dec 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263

…8 of the Act, by the AO, we are of the considered opinion that the AO had sufficient ‘reason to believe' for reopening of the case u/s 147 by issuing notice u/s 148 of the Act. We may place reliance on the case of Central Provinces Manganese Ore Company ltd. (191 ITR 662 SC), wherein the Apex Court interpreted the word "reason to believe". It was held that, the words "reason" in the phrase "reason to believe" in section 147of the Act, would mean cause or justification. If the AO has cause or jurisdiction to know or suppose that income has escaped assessment, he can be said to have reason to believe that income ha…

DCIT(CC)-8(3), Mumbai vs. Jsw Steel Limited, Mumbai

In the result, all the above appeals of the assessee are partly allowed and Cross appeals of the Revenue are dismissed

ITA 5599/MUM/2024[2013-14]Status: DisposedITAT Mumbai08 Dec 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263

…8 of the Act, by the AO, we are of the considered opinion that the AO had sufficient ‘reason to believe’ for reopening of the case u/s 147 by issuing notice u/s 148 of the Act. We may place reliance on the case of Central Provinces Manganese Ore Company ltd. (191 ITR 662 SC), wherein the Apex Court interpreted the word "reason to believe". It was held that, the words "reason" in the phrase "reason to believe" in section 147of the Act, would mean cause or justification. If the AO has cause or jurisdiction to know or suppose that income has escaped assessment, he can be said to have reason to believe that income ha…

M/S. Jsw Steel Limited, Mumbai vs. DCIT, Central Circle 8(3), Mumbai

In the result, all the above appeals of the assessee are

ITA 5586/MUM/2024[2015-16]Status: DisposedITAT Mumbai08 Dec 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263

…8 of the Act, by the AO, we are of the considered opinion that the AO had sufficient ‘reason to believe' for reopening of the case u/s 147 by issuing notice u/s 148 of the Act. We may place reliance on the case of Central Provinces Manganese Ore Company ltd. (191 ITR 662 SC), wherein the Apex Court interpreted the word "reason to believe". It was held that, the words "reason" in the phrase "reason to believe" in section 147of the Act, would mean cause or justification. If the AO has cause or jurisdiction to know or suppose that income has escaped assessment, he can be said to have reason to believe that income ha…

M/S. Jsw Steel Limited, Mumbai vs. DCIT, Central Circle -8(3), Mumbai

In the result, all the above appeals of the assessee are partly allowed and Cross appeals of the Revenue are dismissed

ITA 5585/MUM/2024[2014-15]Status: DisposedITAT Mumbai08 Dec 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263

…8 of the Act, by the AO, we are of the considered opinion that the AO had sufficient ‘reason to believe’ for reopening of the case u/s 147 by issuing notice u/s 148 of the Act. We may place reliance on the case of Central Provinces Manganese Ore Company ltd. (191 ITR 662 SC), wherein the Apex Court interpreted the word "reason to believe". It was held that, the words "reason" in the phrase "reason to believe" in section 147of the Act, would mean cause or justification. If the AO has cause or jurisdiction to know or suppose that income has escaped assessment, he can be said to have reason to believe that income ha…

M/S. Jsw Steel Limited, Mumbai vs. DCIT, Central Circle -8(3), Mumbai

In the result, all the above appeals of the assessee are

ITA 5584/MUM/2024[2013-14]Status: DisposedITAT Mumbai08 Dec 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263Section 44A

…8 of the Act, by the AO, we are of the considered opinion that the AO had sufficient ‘reason to believe' for reopening of the case u/s 147 by issuing notice u/s 148 of the Act. We may place reliance on the case of Central Provinces Manganese Ore Company ltd. (191 ITR 662 SC), wherein the Apex Court interpreted the word "reason to believe". It was held that, the words "reason" in the phrase "reason to believe" in section 147of the Act, would mean cause or justification. If the AO has cause or jurisdiction to know or suppose that income has escaped assessment, he can be said to have reason to believe that income ha…

DCIT, Central Circle-8(1), Mumbai vs. Jainam Investments, Mumbai

In the result, both the appeal of the Revenue as well as cross-

ITA 794/MUM/2025[2016-17]Status: DisposedITAT Mumbai25 Nov 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Respondent: Mr. Suchek Anchaliay
Section 132(4)Section 147

…r conclusion. The function of the Assessing Officer is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers. As observed by the Supreme Court in Central Provinces Manganese Ore Co. Ltd. v. ITO [1991] 191 ITR 662, for initiation of action under section 147 (a) (as the provision stood at the relevant time) fulfilment of the two requisite conditions in that regard is essential. At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is "reason to believe", but not the established fact of…

Samir Patodia (HUF), Fadia Building, Ramwadi, Mumbai vs. DCIT-CC-7(2), Mumbai, Aayakar Bhawan

In the result, assessee's appeal is dismissed

ITA 5733/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarsamir Patodia (Huf), V/S. Deputy Commissioner Of Fadia Building No. 3, Caval बनाम Income Tax, Central Circle – Cross Lane 4 Ramwaldi, 7(2), Aayakar Bhavan, Kalbadevi Road, Mumbai – Mumbai – 400020, 400 002, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aajhs8769K Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Prateek Jain,ARFor Respondent: Shri Bhagirath Ramawat (Sr. DR)
Section 131Section 147Section 148

…8 of the Act, by the AO, we are of the considered opinion that the AO had sufficient ‘reason to believe’ for reopening of the case u/s 147 by issuing notice u/s 148 of the Act. We may place reliance on the case of Central Provinces Manganese Ore Company ltd. (191 ITR 662 SC), wherein the Apex Court interpreted the word “reason to believe”. It was held that, the words “reason” in the phrase “reason to believe” in section 147of the Act, would mean cause or justification. If the AO has cause or P a g e | 5 A.Y. 2018-19 Samir Patodia(HUF) jurisdiction to know or suppose that income has escaped assessment, he can be…

Sunil Patodia (HUF), Ramwaldi, Kalbadevi Rd. Mumbai vs. DCIT-CC-7(2), Mumbai, Aayakar Bhawan

In the result, assessee's appeal is dismissed

ITA 5732/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Prateek Jain,ARFor Respondent: Shri Bhagirath Ramawat, (Sr. DR)
Section 131Section 147Section 148

…the Act, by the AO, we are of the considered opinion that the AO had sufficient ‘reason to believe' for reopening of the case u/s 147 by issuing notice u/s 148 of the Act. We may also place reliance on the case of Central Provinces Manganese Ore Company ltd. (191 ITR 662 SC), wherein the Apex Court interpreted the word “reason to believe”. It was held that, the words “reason” in the phrase “reason to believe” in section 147 of the Act, would mean cause or justification. If the AO has cause or jurisdiction to know or suppose that income has escaped assessment, he can be said to have reason to believe that income h…

Jayantilal Rajmal Seth, Mumbai vs. DCIT-CC-4(3), Mumbai

ITA 3260/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Jayantilal Rajmal Seth, Dcit-Cc-4(3), A-3, Saibaba Shopping Centre, Bkc, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. Pan No. Agepj 0499 E Appellant Respondent

For Appellant: Mr. Vivek Perampurna, CIT-DRFor Respondent: Mr. Jayant Bhat
Section 139(5)Section 148Section 263

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) Assessment Year: 2018-19 Jayantilal Rajmal Seth, DCIT-CC-4(3), A-3, Saibaba Shopping Centre, BKC, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. PAN NO. AGEPJ 0499 E Appellant Respondent : Mr. Jayant Bhat Assessee by : Mr. Vivek Perampurna, CIT-DR Revenue by : 18/09/2025 Date of Hearing : 22/09/2025 Date of pronouncement ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against revisional order dated 30.03.2025 passed by the Ld. Princip…

M/S Real Time Consultants Pvt. Ltd., Mumbai vs. ITO 15(3)(1), Mumbai

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

ITA 3290/MUM/2019[2011-12]Status: DisposedITAT Mumbai05 Sept 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Prabhash Shankar

For Appellant: Shri Rushabh Mehta,ARFor Respondent: Shri Uma Shankar Prasad, (CIT DR)
Section 131Section 133(6)Section 143(3)Section 147Section 148

…12 M/s Real Time Consultants Pvt. Ltd. considered opinion that the AO had sufficient ‘reason to believe' for reopening of the case u/s 147 by issuing notice u/s 148 of the Act. We may place reliance on the case of Central Provinces Manganese Ore Company ltd. (191 ITR 662 SC), wherein the Apex Court interpreted the word "reason to believe". It was held that, the words "reason" in the phrase "reason to believe" in section 147 of the Act, would mean cause or justification. If the AO has cause or jurisdiction to know or suppose that income has escaped assessment, he can be said to have reason to believe that income h…

Chetan Seth, New Delhi vs. ITO, Ward-15(3), Delhi

ITA 1808/DEL/2023[2004-05]Status: DisposedITAT Delhi25 Jun 2025AY 2004-05

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

…gal evidence or conclusion. The function of the AO is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers. As observed by the Supreme Court in Central Provinces Manganese Ore Co. Ltd. v. Il O [1991] 191 ITR 662, for initiation of action under section 147(a) (as the provision stood at the relevant time) fulfilment of the two requisite conditions in that regard is essential At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is ‘reason to believe", but not the established fact of es…

Shri Chetan Seth, New Delhi vs. ITO, New Delhi

ITA 2985/DEL/2015[2007-08]Status: DisposedITAT Delhi25 Jun 2025AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

…gal evidence or conclusion. The function of the AO is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers. As observed by the Supreme Court in Central Provinces Manganese Ore Co. Ltd. v. Il O [1991] 191 ITR 662, for initiation of action under section 147(a) (as the provision stood at the relevant time) fulfilment of the two requisite conditions in that regard is essential At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is ‘reason to believe", but not the established fact of es…

Shri Chetan Seth, New Delhi vs. ITO, New Delhi

ITA 2983/DEL/2015[2005-06]Status: DisposedITAT Delhi25 Jun 2025AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

…gal evidence or conclusion. The function of the AO is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers. As observed by the Supreme Court in Central Provinces Manganese Ore Co. Ltd. v. Il O [1991] 191 ITR 662, for initiation of action under section 147(a) (as the provision stood at the relevant time) fulfilment of the two requisite conditions in that regard is essential At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is ‘reason to believe", but not the established fact of es…

Calance Software Private Limited, New Delhi vs. ACIT, Circle-5(2), New Delhi

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

ITA 1441/DEL/2024[2012-13]Status: DisposedITAT Delhi02 Jun 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2012-13] Calance Software Pvt. Ltd., Vs Acit, 14/34 & 36, Dda Shopping Circle-5(2), Complex, Nangalraya, Delhi New Delhi-110046. Pan-Aaccc5176A Appellant Respondent Appellant By Shri Harish Choudhary, Ca, Shri Mohit Choudhary, Ca & Mitika Choudhary, Adv. Respondent By Ms. Suman Malik, Cit Dr Date Of Hearing 02.06.2025 Date Of Pronouncement 02.06.2025 Order

Section 143(3)Section 147Section 250Section 68Section 69C

…r conclusion. The function of the Assessing Officer is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers. As observed by the Supreme Court in Central Provinces Manganese Ore Co. Ltd. v. ITO [1991] 191 ITR 662, for initiation of action under section 147(a) (as the provision stood at the relevant time) fulfilment of the two requisite conditions in that regard is essential. At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is "reason to believe", but not the established fact of e…

Kumar Ramesh Sahu, Rajkot, Gujarat vs. ACIT, Circle-2(2), Rajkot, Gujarat

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 336/RJT/2023[2009-10]Status: DisposedITAT Rajkot04 Apr 2025AY 2009-10

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.336/Rjt/2023 (िनधा"रण वष" / Assessment Year : 2009-10) Kumar Ramesh Sahu बनाम/ The Acit, Sundaram, 72/3, New Cirtcle-2(3) Vs. College Wadi Rajkot – 60 001 150Ft5. Ring Road Opp. Meera Apartment Rajkot – 360 005 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aesps 5531 C (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri M.N. Manvar, Ld. Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing 13/01/2025 घोषणा की तारीख /Date Of Pronouncement 04/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha:

For Appellant: Shri M.N. Manvar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 271(1)Section 54Section 68

…AO is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers As observed by the Delhi High Court (sic--Supreme Court) in Central Provinces Manganese Ore Co. Ltd. vs. ITO (1991) 98 CTR (SC) 161: (1991) 191 ITR 662 (SC), for initiation of action under s. 147(a) (as the provision stood at the relevant time) fulfilment of the two requisite conditions in that regard is essential. At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is reason to believe, but not the established fact of esc…

Commr of Income Tax [TDS], Hyderabad vs. M/S Jayadarshini Housing Pvt Ltd., Hyderabad

ITTA/65/2014HC Telangana26 Mar 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 901/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA Nos. 872 to 875 & 901/JP/2024 fu/kZkj.k o"kZ@Assessment Years : 2012-13 to 2016-17 cuke Income Tax Officer, Kedia Builders and Colonizers Vs. Jaipur Pvt. Ltd., A-6-10, Shyam Nagar, Benad Road, Nadi Ka Phatak Jhotwara, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAFCA 4547 C vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@…

Winsome Textile Industries Limited, Chandigarh vs. Asstt. Commissioner of Income Tax, Circle-4(1), Chandigarh

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 528/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh27 Feb 2025AY 2011-12

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Ved Parkash Kalia Sr. DR
Section 115JSection 143(1)Section 143(3)Section 147Section 148

…r conclusion. The function of the Assessing Officer is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers. As observed by the Supreme Court in Central Provinces Manganese Ore Co. Ltd. v. ITO [1991] 191 ITR 662, for initiation of action under section 147(a) (as the provision stood at the relevant time) fulfilment of the two requisite conditions in that regard is essential. At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is "reason to believe", but not the established fact of e…

Cle Private Limited, Mumbai vs. DCIT Central Circle -3(4), Mumbai

In the result, appeal of the Revenue is dismissed and cross objection of the assessee is allowed

ITA 6270/MUM/2024[2017-18]Status: DisposedITAT Mumbai17 Feb 2025AY 2017-18

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Shri Niraj Sheth a/w Jitendra SanghviFor Respondent: Shri R.A. Dhyani, CIT/DR &
Section 115JSection 133(6)Section 143(3)Section 147Section 68

…following judicial pronouncements: “a. Kalyan Mavji v CIT (SC) 102 ITR 287 b. ITO v Lakhmani Mewal Das (SC) 103 ITR 437 c. Phool Chand Bajranj v ITO (SC) 203 ITR 456 d. Sri Krishna (P) Ltd. v CIT (SC) 221 ITR 538 e. Central Provinces Manganese Ore v ITO (SC) 191 ITR 662” The ld. DR further submitted that speaking order u/s 148A(d) was passed after informing the assessee and giving opportunity to submit its objection. 7. Heard both the sides and perused the material on record in respect of reopening of assessment. The original return of income was filed on 30.09.2015. Thereafter scrutiny assessment was complete…