Gurpal Singh v. ITO

159 ITD 797Income Tax Appellate Tribunal2016#1999 most cited

What is Gurpal Singh v. ITO authority for?

Mere cash deposits in a bank account, without the Assessing Officer's independent application of mind on reasons to believe, are not sufficient grounds to invoke jurisdiction under Section 147 for reassessment proceedings.

58

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

Gurpal Singh v. ITO · Section 147 · Section 148 · reassessment validity · reopening assessment · mere cash deposits · insufficient reasons to believe · application of mind AO · borrowed satisfaction · escaped income

Also reported as

71 Taxmann.com 108

Sections most often in play

Section 133(6)Section 143(3)Section 147Section 148Section 148A(d)Section 151(1)Section 250

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 Gurpal Singh v. ITO

SMT..ANURADHA,PATHANKOT vs. INCOME TAX OFFICER WARD-6(1), PATHANKOT

In the result the appeal of the assessee is allowed

ITA 437/ASR/2024[2012-13]Status: DisposedITAT Amritsar24 Jun 2025AY 2012-13

Bench: Sh. Udayan Dasgupta & Sh. Brajesh Kumar Singh

Section 133(6)Section 147Section 148Section 151(1)Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE SH. UDAYAN DASGUPTA, JUDICIAL MEMBER AND SH. BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER I.T.A. No. 437/Asr/2024 Assessment Year: 2012-13 Anuradha, Jaini Tharial Vs. ITO, Ward-6(1), Madhopur Pathankot Punjab. Pathankot. [PAN:-ASFPA8837N] (Appellant) (Respondent) Appellant by Sh. Swaran Singh, CA. Respondent by Sh. Charan Dass, Sr. DR Date of Hearing 29.05.025 24.06.2025 Date of Pronouncement ORDER Per: Udayan Dasgupta, J.M.: This appeal filed by assessee against order of Ld. CIT (A), NFAC, Delhi, passed u/s 250 dated 15.04.2024 emanated from…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 50/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2016-17

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 49/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2009-10

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 48/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2008-09

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 47/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2007-08

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 46/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2006-07

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 45/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2005-06

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 44/AHD/2020[2004-05]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2004-05

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 43/AHD/2020[2002-03]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2002-03

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 42/AHD/2020[2001-02]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2001-02

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 41/AHD/2020[2000-01]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2000-01

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 40/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2016-17

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 39/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2009-10

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 38/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2008-09

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 37/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2007-08

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 36/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2006-07

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 35/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2005-06

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 34/AHD/2020[2004-05]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2004-05

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 33/AHD/2020[2002-03]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2002-03

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 32/AHD/2020[2001-02]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2001-02

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…essment and can’t be a ground for resorting to reopening. In this regard, reliance was placed on the following decisions: 1. Mariyam Ismail Rajwani in ITA No. 676/Ahd/2016 2. Bir Bahadur Singh vs. ITO, [2015] 53 taxmann.com 366 (Del.) 3. Gurpal Singh vs. ITO, 159 ITD 797 (Amritsar) 4. Amrik Singh vs. ITO, 159 ITD 329 (Amritsar) (B) Reopening was based on borrowed satisfaction: – The Ld. Sr. Counsel submitted that the cases were reopened merely on the basis of the details received from the FT&TR Division of CBDT and there was no independent application of mind by the AO. He submitted that the reopening 25 I.T.A…

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