How many judgments cite CIT v. Suren International?

51 judgments on BharatTax cite CIT v. Suren International (357 ITR 24), spanning 2015 to 2025.

Which sections of the Income Tax Act does CIT v. Suren International come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 143(1), Section 151, Section 139.

CIT v. Suren International

357 ITR 24High Court2013#2268 most cited

What is CIT v. Suren International authority for?

Reassessment proceedings initiated under Section 147 are invalid if the Assessing Officer records reasons without proper application of mind, such as repeating alleged accommodation entries, indicating a mechanical or callous approach. The reasons recorded must establish a genuine belief that income has escaped assessment, not a borrowed or superficial one.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. Suren International · Section 147 · Section 148 · reasons to believe · application of mind · reassessment validity · accommodation entries · income escaping assessment · mechanical recording of reasons · borrowed satisfaction

Sections most often in play

Section 147 Section 148 Section 143(3)Section 143(1)Section 151 Section 139 Section 143(2)Section 68

Issues it is cited on

full and true disclosure section 148(1)first proviso to section 147 true and full disclosure material facts necessary for assessment section 148(2)sanctioning authority beyond four years live link borrowed satisfaction section 80ic income escaping assessment

Judgments citing CIT v. Suren International

MARIGOLD MERCHANDISE PRIVATE LIMITED ,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeal of the Assessee is partly allowed

ITA 1256/DEL/2025[2012-13]Status: DisposedITAT Delhi26 Nov 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Marigold Merchandise Vs Assistant Commissioner Of Private Limited Income Tax, Central Circle-Ii, Shop No. 4/36, Dda Market, Faridabad, Haryana-121001 Dakshin Puri Extension, New Delhi-110062 Pan: Aaecm0483E Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms. Suman Malik, Cit(Dr) Date Of Hearing 08/09/2025 Date Of Pronouncement 26/11/2025 Order

Section 143(2)Section 147Section 148Section 151Section 153C

…from those alleged accommodation entries transactions. 13. The Hon’ble Jurisdictional High Court in the case of PCIT vs. RMG Polyvinyl (I) Ltd. (396 ITR 5). “10. In this context the following observations of this Court in CIT v. Suren International (2013) 357 ITR 24 (Del)are relevant: “....In the first instance, we do not find the reasons as recorded by the Assessing Officer to be reasons in law, at all. A bare perusal of the table of alleged accommodation entries included in the reasons as recorded, discloses that the same entries have been repeated six times. This is clearly indicative of the callous manne…

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, appeal of the Assessee in ITA No

ITA 45/DDN/2022[2007-08]Status: DisposedITAT Dehradun26 Sept 2025AY 2007-08

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

…hed. Reliance in this regard has been rightly placed by the ld AO on the decision of the Hon’ble Jurisdictional High Court in the case of Haryana Acrylic Manufacturing Company Vs. CIT reported in 308 ITR 38 and CIT Vs. Suren International Pvt. Ltd reported in 357 ITR 24 ( Delhi). M/s Sharda Export Vs. the ACIT 10. We find that the ld AO had adjudicated the reasons recorded for both the notices issued u/s 148 of the Act in a single reassessment order and completely denied the deduction u/s 80IC of the Act. Admittedly, for the first notice u/s 148 dated 17.08.2010, neither the same was withdrawn by the ld AO nor a…

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, appeal of the Assessee in ITA No

ITA 44/DDN/2022[2006-07]Status: DisposedITAT Dehradun26 Sept 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

M/S. SHARDA EXPORTS,MEERUT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE , DEHRADUN

In the result, appeal of the Assessee in ITA No

ITA 41/DDN/2022[2007-2008]Status: DisposedITAT Dehradun26 Sept 2025AY 2007-2008

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

M/S. SHARDA EXPORTS,MEERUT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the Assessee in ITA No

ITA 40/DDN/2022[2006-07]Status: DisposedITAT Dehradun26 Sept 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

SANTOSH RANI LEGAL HEIR OF LATE SH PARVEEN KALYAN,KURUKSHETRA vs. INCOME TAX OFFICER, WARD 1, KARNAL, KARNAL

In the result, appeal of the assessee is allowed

ITA 4770/DEL/2024[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2011-12] Santosh Rani Vs Ito, Legal Heir Of Late Shri Parveen Ward-1, Karnal, Kalyan, Krishna Nagar, Gamri, Haryana-132001. Thanesar, Distt.-Kurukshetra, Haryana-136118. Pan-Awhpr4944D Appellant Respondent Appellant By Shri Suresh K.Gupta, Ca Respondent By Shri Dheeraj Kumar Jaiswal, Sr.Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 19.09.2025 Order

Section 144Section 147Section 148Section 151Section 250

….12544/2018 dt: 26.03.2021 (Del);  Shamshad Khan vs ACIT 395 ITR 265 (Del);  Pr CIT vs M/S SNG Developers Ltd404 ITR 312 (Del) approved by Hon'ble Apex Court by dismissing SLP of revenue in SLP 42379/2017 Dt: 09.02.2018;  CIT vs Suren International Pvt Ltd 357 ITR 24 (Del);  Pr. CIT vs. RMG Polyvinyl (1) Ltd (2017) 396 ITR 5 (Del);  CIT vs., Atlas Cycle industries (1989) 180 ITR 319 (P&H);  Siemens Information System Ltd., vs. ACIT 293 ITR 548 (Bom.);  Ankita A. Choksey vs. Income Tax Officer 411 ITR 207 (Bom);  DCIT vs M/s KLA Foods (India) Ltd and others ITA No.2846/Del/2015 dt: 08.04.2019, M/s Superior…

GOLD PLAZA INDIA (PVT)LTD,THRISSUR vs. ITO. WARD 1(1), THRISSUR

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

ITA 973/COCH/2024[2006-07]Status: DisposedITAT Cochin31 Jul 2025AY 2006-07

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2006-07 Gold Plaza India (Pvt) Ltd. .......... Appellant Cresent House, Manoor P.O., Kaladi Malappuram 679582 [Pan: Aabcg8869K] Vs. The Income Tax Officer, Wd-1(1), Thrissur .......... Respondent Appellant By: Shri K. Kittu, Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 10.06.2025 Date Of Pronouncement: 31.07.2025

For Appellant: Shri K. Kittu, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 147Section 148

…to the following judgements: - i. Imperial Consultants and Securities Ltd. v. DCIT (2025) 473 ITR 217. ii. Dull Chand Singhania v. ACIT 269 ITR 192 (P&H) iii. General Motors India Pvt. Ltd. v. DCIT 360 ITR 527 (Guj.) iv. CIT v. Suren International Pvt. Ltd. 357 ITR 24 (Del) v. CIT v. Fibres & Fabrics Pvt. Ltd. ITA No. 310/2014 dated 22.09.2015 (Kar HC) vi. Kotarki Constructions Pvt. Ltd. v. ACIT WP No. 61671 of 2016 dated 02.01.2018 (Kar HC) In view of this settled position of law, we hold that since there was not even an allegation by the AO that there was failure on the part of the assessee to disclose truly…

ITO, WARD-18(), NEW DELHI vs. NIVIA AGENCIES PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1009/DEL/2021[2002-03]Status: DisposedITAT Delhi09 Jul 2025AY 2002-03

Bench: MS. MADHUMITA ROY (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 142Section 143(1)Section 144Section 148Section 250(6)Section 68

…the point. The question is of application of mind by the AO to the material available with him before deciding to reopen the assessment under Section 147 of the Act. In this context the following observations of this Court in CIT v. Suren International (2013) 357 ITR 24 (Del)are relevant: "....In the first instance, we do not find the reasons as recorded by the Assessing Officer to be reasons in law, at all. A bare perusal of the table of alleged accommodation entries included in the reasons as recorded, discloses that the same entries have been repeated six times. This is clearly indicative of the callous manner…

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

…1 DCIT v. Manish Uppal IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “E”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER Assessment Year: 2013-14 DCIT, Central Circle-28, Vs Manish Uppal, New Delhi. 1206, Golf Links, Kasturba Nagar, South East Delhi-110003. PAN: AAAPU 3996 P APPELLANT RESPONDENT Assessee represented by Shri Salil Aggarwal, Sr. Adv.; Shri Shailesh Gupta, Adv.; & Shri Madhur Aggarwal, Adv. Department represented by Sh. Sanjeev Kaushal, CIT(DR) Date of hearing 13.03.2025 Date of pronouncement 16.05.2025 O R D E R PER Ms. MADHUMITA ROY, JM: 1 Th…

YENKEY ROLLER FLOUR MILLS,CALICUT vs. DCIT C-1(1), KOZHIKKODE

In the result, the appeal filed by the appellant stands allowed

ITA 522/COCH/2023[2006-2007]Status: DisposedITAT Cochin14 May 2025AY 2006-2007

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 147Section 148Section 149

…relevant material facts necessary for assessment purposes placing reliance on the following judgments: - i) Dull Chand Singhania v. ACIT 269 ITR 192 (P&H) ii) General Motors India Pvt. Ltd. v. DCIT 360 ITR 527 (Guj.) iii) CIT v. Suren International Pvt. Ltd. 357 ITR 24 (Del) iv) CIT v. Fibres & Fabrics Pvt. Ltd. ITA No. 310/2014 dated 22.09.2015 (Kar HC) 4 Yenkey Roller Flour Mills v) Kotarki Constructions Pvt. Ltd. v. ACIT WP No. 61671 of 2016 dated 02.01.2018 (Kar HC) 7. On the other hand, the ld. Sr. DR, relying of the orders of the lower authorities, submits that no interference is called for. 8. We have…

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, 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

…point. The question is of application of mind by the AO to the material available with him before deciding to reopen the assessment under Section 147 of the Act. 10. In this context the following observations of this Court in CIT v. Suren International (2013) 357 ITR 24 (Del)are relevant: "....In the first instance, we do not find the reasons as recorded by the Assessing Officer to be reasons in law, at all. A bare perusal of the table of alleged accommodation entries included in the reasons as recorded, discloses that the same entries have been repeated six times. This is clearly indicative of the callous manner…

JAYANTILAL SANGHVI,INDORE vs. ACIT 4(1), INDORE

Appeal is partly allowed for statistical purpose

ITA 539/IND/2023[A.Y. 2012-13]Status: DisposedITAT Indore27 Jun 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2012-13 Jayantilal Sanghvi, Acit, 8/10, Warehouse Road, 4(1), बनाम/ Patel Bridge, Indore. Vs. Indore. (Assessee/Appellant) (Revenue/Respondent) Pan: Agtps5825Q Assessee By Shri Venus Rawka, C.A. Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.06.2024 Date Of Pronouncement .06.2024

Section 143(3)Section 147Section 148

…s is fortified by the view taken in the following judgments: (i) CIT v. Kelvinator of India Ltd. MANU/SC/0047/2010/[2010] 187 Taxman 312/320 ITR 561 (SC). (ii) CIT v. Suren International (P.) Ltd. [2013] 35 taxmann.com 398/[2014] 225 Taxman 88 (Mag.)/[2013] 357 ITR 24 (Delhi) (iii) Wel Intertrade (P.) Ltd. v. ITO [2009] 178 Taxman 27/308 ITR 22 (Delhi). 20. Thus, for the foregoing reasons, we are not inclined to interfere with the impugned judgment passed by the Tribunal. According to us, no substantial question of law arises, in the present appeal, for our consideration. 21. The appeal is, accordingly, dismi…

NISHA GOEL,DELHI vs. INCOME TAX OFFICER, WARD 52(3), WARD

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

ITA 2767/DEL/2023[2012-13]Status: DisposedITAT Delhi04 Jun 2024AY 2012-13

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadिनधा"रणवष"/Assessment Year: 2012-13

Section 144Section 147Section 151

…ITAA.No.2767/Del/2023 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “E” NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER िनधा"रणवष"/Assessment Year: 2012-13 NISHA GOEL, Vs. Income Tax Officer, DU-10, Pitampura, Ward 52(3), Delhi. Civic Centre, Minto Road, New Delhi. PAN No. AIFPG0671A अपीलाथ" Appellant ""यथ"/Respondent Shri Suresh Kumar Gupta, CA िनधा"रतीक"ओरसे /Assessee by Shri Amit Katoch, Sr. DR राज"वक"ओरसे /Revenue by सुनवाईक"तारीख/ Date of hearing: 31.05.2024 04.06.2024 उ"ोषणाक"तारीख/Pronouncement on आदेश /O R D E R PER C.N. PRASAD, J.M. This appea…

ITO WARD - 4, ROHTAK vs. SURENDER DALAL, ROHTAK

In the result, appeal of the Assessee is partly allowed as

ITA 7714/DEL/2019[2009-10]Status: DisposedITAT Delhi30 Jan 2024AY 2009-10

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.7714/Del/2019 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Ito, Surender Dalal, Ward-4, Vs. Dalal Bhawan, Aayakar Bhawan, Rohtak, Haryana Near Petrol Pump, Gohana Road, Rohtak, Haryana. Pan No.Aqlps2166C अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.7490/Del/2019 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Surender Dalal, Ito, Dalal Bhawan, Vs. Ward-4, Near Petrol Pump, Aayakar Bhawan, Gohana Road, Rohtak, Haryana Rohtak, Haryana. Pan No.Aqlps2166C अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 151Section 69

…point. The question is of application of mind by the AO to the material available with him before deciding to reopen the assessment under Section 147 of the Act. 10. In this context the following observations of this Court in CIT v. Suren international (2013) 357 ITR 24 (Del) are relevant: “....In the first instance, we do not find the reasons as recorded by the Assessing Officer to, be reasons in law, at all. A bare perusal of the table of alleged accommodation entries included in the reasons as recorded, discloses that the same entries have been repeated six times. This is clearly indicative of the callous mann…

SURENDER DALAL,ROHTAK vs. ITO WARD - 4, ROHTAK

In the result, appeal of the Assessee is partly allowed as

ITA 7490/DEL/2019[2009-10]Status: DisposedITAT Delhi30 Jan 2024AY 2009-10

Section 147Section 148Section 151Section 69

…point. The question is of application of mind by the AO to the material available with him before deciding to reopen the assessment under Section 147 of the Act. 10. In this context the following observations of this Court in CIT v. Suren international (2013) 357 ITR 24 (Del) are relevant: “....In the first instance, we do not find the reasons as recorded by the Assessing Officer to, be reasons in law, at all. A bare perusal of the table of alleged accommodation entries included in the reasons as recorded, discloses that the same entries have been repeated six times. This is clearly indicative of the callous mann…

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, the appeal of the Assessee is allowed and the appeal of the revenue is dismissed

ITA 43/DDN/2022[2005-06]Status: DisposedITAT Dehradun15 Sept 2023AY 2005-06

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) M/S. Sharda Exports, Vs. Ito, C/O. Sh. Jitendra Kumar Gupta, Ward-1(3)(3), 219, Railway Road, Meerut Haridawar (Appellant) (Respondent) Pan: Aayfs1694N Dcit, Vs. M/S. Sharda Exports, Central Circle, C/O. Sh. Jitendra Kumar Gupta, Dehradun 219, Railway Road, Meerut (Appellant) (Respondent) Pan: Aayfs1694N

For Appellant: Shri Raj Kumar, CAFor Respondent: Shri Amar Singh Rana, Sr. DR

Section 147Section 148Section 151Section 80Section 80I

…hed. Reliance in this regard has been rightly placed by the ld AO on the decision of the Hon’ble Jurisdictional High Court in the case of Haryana Acrylic Manufacturing Company Vs. CIT reported in 308 ITR 38 and CIT Vs. Suren International Pvt. Ltd reported in 357 ITR 24 ( Delhi). 10. We find that the ld AO had adjudicated the reasons recorded for both the notices issued u/s 148 of the Act in a single reassessment order and completely denied the deduction u/s 80IC of the Act. Admittedly, for the first notice u/s 148 dated 17.08.2010, neither the same was withdrawn by the ld AO nor any reassessment was framed for…

M/S. SHARDA EXPORTS,MEERUT vs. THE INCOME TAX OFFICER, WARD-1(3)(3), HARIDWAR

In the result, the appeal of the Assessee is allowed and the appeal of the revenue is dismissed

ITA 39/DDN/2022[2005-2006]Status: DisposedITAT Dehradun15 Sept 2023AY 2005-2006

For Appellant: Shri Raj Kumar, CAFor Respondent: Shri Amar Singh Rana, Sr. DR

Section 147Section 148Section 151Section 80Section 80I

…hed. Reliance in this regard has been rightly placed by the ld AO on the decision of the Hon’ble Jurisdictional High Court in the case of Haryana Acrylic Manufacturing Company Vs. CIT reported in 308 ITR 38 and CIT Vs. Suren International Pvt. Ltd reported in 357 ITR 24 ( Delhi). 10. We find that the ld AO had adjudicated the reasons recorded for both the notices issued u/s 148 of the Act in a single reassessment order and completely denied the deduction u/s 80IC of the Act. Admittedly, for the first notice u/s 148 dated 17.08.2010, neither the same was withdrawn by the ld AO nor any reassessment was framed for…

STANDARD TELE TOWERS PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-24(2), NEW DELHI

ITA 9761/DEL/2019[2010-11]Status: DisposedITAT Delhi19 Jul 2023AY 2010-11

Bench: Sh. N.K.Billaiya & Sh.Anubhav Sharma

Section 132(4)Section 143(3)Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘G’ : NEW DELHI) BEFORE SH. N.K.BILLAIYA, ACCOUNTANT MEMBER AND SH.ANUBHAV SHARMA, JUDICIAL MEMBER ITA No. 9761/Del/2019, A.Y. 2010-11 M/s. Standard Tele Towers Pvt. Vs. DCIT, Ltd. , C-37, Ground Floor, Circle 24(2), East of Kailash, New Delhi New Delhi PAN : AAJCS9262N Appellant Respondent Appellant by Dr. Rakesh Gupta, Adv. Shri Somil Agarwal, Adv. & Sh. Deepesh Garg, Adv. Respondent by Ms. Kajal Singh, Sr. DR Date of hearing: 20.06.2023 Date of Pronouncement: 19.07.2023 ORDER Per Anubhav Sharma, JM : The appeal has been preferred by the Assessee against th…

K R PACKAGING (P) LTD,NEW DELHI vs. ACIT CIRCLE-5(1), NEW DELHI

In the result the appeal of the assessee in ITA No

ITA 71/DEL/2021[2003-04]Status: DisposedITAT Delhi07 Jul 2023AY 2003-04

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Om Prakash, Sr. DR

Section 143(2)Section 147Section 148Section 234BSection 68

…oint. The question is of application of mind by the AO to the material available with him before deciding to reopen the assessment under Section 147 of the Act. 10. In this context the following observations of this Court in CIT v. Suren International (2013) 357 ITR 24 (Del)are relevant: "....In the first instance, we do not find the reasons as recorded by the Assessing Officer to be reasons in law, at all. A bare perusal of the table of alleged accommodation entries included in the reasons as recorded, discloses that the same entries have been repeated six times. This is clearly indicative of the callous manne…

SH. NIRBHAY TREHAN,JAMMU vs. DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, JAMMU

In the result, the appeals of the assessee bearing ITA Nos

ITA 184/ASR/2019[2013-14]Status: DisposedITAT Amritsar20 Mar 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 139Section 144Section 147Section 148Section 2Section 250

…/2019 17 I.T.A. Nos. 183 & 184/Asr/2019 explained in detail by the Hon’ble Punjab and Haryana High court in the case of Duilichand Singhania Vs ACIT 269 ITR 192 (P&H). Similar view was taken by Hon'ble Delhi High Court In Case of Suren International Pvt. Ltd 357 ITR 24. iii. That a precondition for reopening the assessment is that there must be income chargeable to tax and which should have escaped assessment. As per reasons recorded, the Ld. AO has treated the cash deposit in bank a/c as income of the assessee. But the deposit of cash in bank a/c itself is not income within meaning of “income” as per provisions…

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