ITO v. Selected Dalurband Coal Co. (P.) Ltd.

217 ITR 597Supreme Court of India1996#533 most cited

What is ITO v. Selected Dalurband Coal Co. (P.) Ltd. authority for?

The Assessing Officer's formation of 'reason to believe' that income has escaped assessment under Section 147 is a subjective satisfaction, and the materials available do not need to conclusively prove the escapement at the initiation stage.

180

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2008 to 2025.

Also referred to as

ITO v. Selected Dalurband Coal Co. (P.) Ltd. · Section 147 · Section 148 · reason to believe · subjective satisfaction · income escaping assessment · reassessment jurisdiction · old Section 147(a) · escapement of income

Sections most often in play

Section 147Section 148Section 143(3)Section 151Section 133(6)Section 142(1)Section 271(1)(c)Section 131

Issues it is cited on

section 147(a)full and true disclosurematerial facts necessary for assessmentescapement of incomeborrowed satisfactionincome escaping assessmentmere change of opinionlive linkreason to believetangible materialchange of opinionkelvinator

Judgments citing ITO v. Selected Dalurband Coal Co. (P.) Ltd.

DCIT(CC)-8(3), MUMBAI vs. JSW STEEL LIMITED, MUMBAI

In the result, all the above appeals of the assessee are\npartly allowed and Cross appeals of the Revenue are\ndismissed

ITA 5615/MUM/2024[2014-15]Status: DisposedITAT Mumbai08 Dec 2025AY 2014-15
Section 143(3)Section 144Section 147Section 251Section 263

…d is \"reason to\nbelieve\", and not to establish fact of escapement of income. This is so\nbecause the formation of belief by the Assessing Officer is within the\nrealm of subjective satisfaction as held in ITO v. Selected Dalurband\nCoal Co. (P.) Ltd. [1996]217 ITR 597 (SC)., (Sheo Nath Singh 82 ITR\n147)(SC) & Bhagwan Industrial P.Ltd 31STC 293 (SC). The Hon'ble Apex\nCourt in the case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd.\n(2007) (291 ITR 500) has categorically stated that “reason to believe”\ndoes not mean that the reason for re-opening should have been factually\nascertained by legal evidence o…

DCIT(CC)-8(3), MUMBAI vs. JSW STEEL LIMITED, MUMBAI

In the result, all the above appeals of the assessee are\npartly allowed and Cross appeals of the Revenue are\ndismissed

ITA 5601/MUM/2024[2015-16]Status: DisposedITAT Mumbai08 Dec 2025AY 2015-16
Section 143(3)Section 144Section 147Section 251Section 263

…d is \"reason to\nbelieve\", and not to establish fact of escapement of income. This is so\nbecause the formation of belief by the Assessing Officer is within the\nrealm of subjective satisfaction as held in ITO v. Selected Dalurband\nCoal Co. (P.) Ltd. [1996]217 ITR 597 (SC)., (Sheo Nath Singh 82 ITR\n147)(SC) & Bhagwan Industrial P.Ltd 31STC 293 (SC). The Hon'ble Apex\nCourt in the case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd.\n(2007) (291 ITR 500) has categorically stated that “reason to believe”\ndoes not mean that the reason for re-opening should have been factually\nascertained by legal evidence o…

DCIT(CC)-8(3), MUMBAI , 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

…equired is "reason to believe", and not to establish fact of escapement of income. This is so because the formation of belief by the Assessing Officer is within the realm of subjective satisfaction as held in ITO v. Selected Dalurband Coal Co. (P.) Ltd. [1996]217 ITR 597 (SC).,(Sheo Nath Singh 82 ITR 147)(SC) & Bhagwan Industrial P.Ltd 31STC 293 (SC). The Hon’ble Apex Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd. (2007) (291 ITR 500) has categorically stated that “reason to believe” does not mean that the reason for re-opening should have been factually ascertained by legal evidence or conc…

M/S. JSW STEEL LIMITED ,MUMBAI vs. DCIT, CENTRAL CIRCLE 8(3), MUMBAI

In the result, all the above appeals of the assessee are\npartly allowed and Cross appeals of the Revenue are\ndismissed

ITA 5586/MUM/2024[2015-16]Status: DisposedITAT Mumbai08 Dec 2025AY 2015-16
Section 143(3)Section 147Section 251Section 263

…d is \"reason to\nbelieve\", and not to establish fact of escapement of income. This is so\nbecause the formation of belief by the Assessing Officer is within the\nrealm of subjective satisfaction as held in ITO v. Selected Dalurband\nCoal Co. (P.) Ltd. [1996]217 ITR 597 (SC)., (Sheo Nath Singh 82 ITR\n147)(SC) & Bhagwan Industrial P.Ltd 31STC 293 (SC). The Hon'ble Apex\nCourt in the case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd.\n(2007) (291 ITR 500) has categorically stated that “reason to believe”\ndoes not mean that the reason for re-opening should have been factually\nascertained by legal evidence o…

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

…equired is "reason to believe", and not to establish fact of escapement of income. This is so because the formation of belief by the Assessing Officer is within the realm of subjective satisfaction as held in ITO v. Selected Dalurband Coal Co. (P.) Ltd. [1996]217 ITR 597 (SC).,(Sheo Nath Singh 82 ITR 147)(SC) & Bhagwan Industrial P.Ltd 31STC 293 (SC). The Hon’ble Apex Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd. (2007) (291 ITR 500) has categorically stated that “reason to believe” does not mean that the reason for re-opening should have been factually ascertained by legal evidence or conc…

M/S. JSW STEEL LIMITED ,MUMBAI vs. DCIT, CENTRAL CIRCLE -8(3), MUMBAI

In the result, all the above appeals of the assessee are\npartly allowed and Cross appeals of the Revenue are\ndismissed

ITA 5584/MUM/2024[2013-14]Status: DisposedITAT Mumbai08 Dec 2025AY 2013-14
Section 143(3)Section 144Section 147Section 251Section 263

…d is \"reason to\nbelieve\", and not to establish fact of escapement of income. This is so\nbecause the formation of belief by the Assessing Officer is within the\nrealm of subjective satisfaction as held in ITO v. Selected Dalurband\nCoal Co. (P.) Ltd. [1996]217 ITR 597 (SC)., (Sheo Nath Singh 82 ITR\n147)(SC) & Bhagwan Industrial P.Ltd 31STC 293 (SC). The Hon'ble Apex\nCourt in the case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd.\n(2007) (291 ITR 500) has categorically stated that “reason to believe”\ndoes not mean that the reason for re-opening should have been factually\nascertained by legal evidence o…

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. JAINAM INVESTMENTS, MUMBAI

In the result, both the appeal of the Revenue as well as cross-\nobjection of the assessee are dismissed

ITA 794/MUM/2025[2016-17]Status: DisposedITAT Mumbai25 Nov 2025AY 2016-17
Section 132(4)Section 147

…not the established fact of\nescapement of income. This is so because the formation of\nbelief by the Assessing Officer is within the realm of subjective\nsatisfaction, as held by the Hon'ble Apex Court in ITO v.\nSelected Dalurband Coal Co. (P.) Ltd. [1996] 217 ITR 597\n(SC)and in the case of Raymond Woollen Mills Ltd. v. ITO\n[1999] 236 ITR 34 (SC).\n\n11. The Hon'ble Apex Court in the case of ACIT vs. Rajesh\nJhaveri Stock Brokers Pvt. Ltd. (2007) (291 ITR 500) has\ncategorically stated that \"reason to believe\" does not mean that\nthe reason for re-opening should have been factually\nascertained by legal ev…

JAYANTILAL RAJMAL SETH,MUMBAI vs. DCIT-CC-4(3), MUMBAI, 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…

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)

…site belief. Whether the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the AO is within the realm of subjective satisfaction ITO v. Selected Dalurband Coal Co. (P) Ltd. [1996] 217 ITR 597 (SC); Raymond Woollen Mills Ltd. vs. ITO [1999] 236 ITR 34 (SC). 17. The scope and effect of section 147 as substituted with effect from 1-4-1989, as also sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the…

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)

…site belief. Whether the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the AO is within the realm of subjective satisfaction ITO v. Selected Dalurband Coal Co. (P) Ltd. [1996] 217 ITR 597 (SC); Raymond Woollen Mills Ltd. vs. ITO [1999] 236 ITR 34 (SC). 17. The scope and effect of section 147 as substituted with effect from 1-4-1989, as also sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the…

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)

…site belief. Whether the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the AO is within the realm of subjective satisfaction ITO v. Selected Dalurband Coal Co. (P) Ltd. [1996] 217 ITR 597 (SC); Raymond Woollen Mills Ltd. vs. ITO [1999] 236 ITR 34 (SC). 17. The scope and effect of section 147 as substituted with effect from 1-4-1989, as also sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the…

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 the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the Assessing Officer is within the realm of subjective satisfaction (see ITO v. Selected Dalurband Coal Co. P. Ltd. [1996] 217 ITR 597 (SC); Raymond Woollen Mills Ltd. v. ITO [1999] 236 ITR 34 (SC). After initiation of proceedings, the A.O. could conclude on the basis of other information and explanation of the appellant that no income had escaped assessment, yet for acquiring the jurisdiction, the A.O. could still have valid basis on the basis of information available at the ti…

KUMAR RAMESH SAHU,RAJKOT, GUJARAT vs. ACIT, CIRCLE-2(2), RAJKOT, 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

…als would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the AO is within the realm of subjective satisfaction [see ITO vs. Selected Dalurband Coal Co. (P) Ltd. (1996) 132 CTR (SC) 162: (1996) 217 ITR 597 (SC); ITA No.336 /RJT/2023 Kumar Ramesh Sahu vs. ACIT Asst.Year - 2009-10 Raymond Woollen Mills Ltd. vs. ITO (1999) 152 CTR (SC) 418: (1999) 236 ITR 34 (SC)]. 15. It would, thus, emerge that even in case of reopening of an assessment which was previously accepted under s. 143(1) of the Act without scrutiny, the AO would have power to reopen t…

COMMR OF INCOME TAX [TDS], HYDERABAD vs. M/S JAYADARSHINI HOUSING PVT LTD., HYDERABAD

Appeals are hereby dismissed by

ITTA/65/2014HC Telangana26 Mar 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 10Section 10ASection 143(3)Section 148Section 260

…e escapement is not the concern at that stage. This is so because the formation of belief by the Assessing Officer is within the realm of subjective satisfaction (see ITO v. Selected Dalurband Coal Co. Pvt. Ltd. [(1996) 132 CTR (SC) 162: (1996) 217 ITR 597 (SC)]; Raymond Woollen Mills Ltd. v. ITO [(1999) 152 CTR (SC) 418: (1999) 236 ITR 34 (SC)]. 17. The scope and effect of section 147 as substituted with effect from 1st April, 1989, as also Sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of Section 1…

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

…ther the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the Assessing Officer is within the realm of subjective satisfaction ITO v. Selected Dalurband Coal Co. (P.) Ltd. [1996] 217 ITR 597 (SC); Raymond Woollen Mills Ltd. v. ITO [1999] 236 ITR 34 (SC)." 5.7 The Hon'ble Gujarat High Court in the case of Pushpak Bullion Ltd. Vs DCIT in Special Civil Application No. 3279 of 2016has held that reopening of assessment was justified as investigation wing of department had during course of investigation case of a third party found that he…

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

…ther the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the Assessing Officer is within the realm of subjective satisfaction ITO v. Selected Dalurband Coal Co. (P.) Ltd. [1996] 217 ITR 597 (SC); Raymond Woollen Mills Ltd. v. ITO [1999] 236 ITR 34 (SC). 17. The scope and effect of section 147 as substituted with effect from 1-4-1989, as also sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the…

SUSHILA CHOUDHARY,JAIPUR vs. INCOME TAX OFFICER, NFAC, NFAC, DELHI

ITA 638/JPR/2024[2013-14]Status: DisposedITAT Jaipur12 Feb 2025AY 2013-14
For Appellant: Shri Nikhilesh Katariya, C.AFor Respondent: Shri Dinesh Badgujar, Addl.CIT (Thr. V.C.)
Section 139(1)Section 144BSection 147Section 148Section 292BSection 69A

…the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the Assessing Officer is within the realm of subjective satisfaction (see ITO v. Selected Dalurband Coal Co. Pvt. Ltd. [1996 217 ITR 597 (SC)]: Raymond Woollen Mills Ltd. v. ITO 1999 236 ITR 34 (SC). 17. The scope and effect of section 147 as substituted with effect from April 1, 1989, as also sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down…

RAJNISH BHARTI HUF,MUMBAI vs. THE INCOME TAX OFFICER 20(3)(1), MUMBAI , LALBAUG, MUMBAI

In the result, both the appeals of the In the result, both the appeals of the assessee are dismissed assessee are dismissed whereas appeals of the Revenue are allowed

ITA 3941/MUM/2023[2010-11]Status: DisposedITAT Mumbai30 Jan 2025AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mrs. Sanyogita Nagpal, CIT-DRFor Respondent: Mr. C.V. Jain
Section 143(3)Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SUNIL KUMAR SINGH (JUDICIAL MEMBER) ITA Nos. 3912 & 3941/MUM/2023 Assessment Years: 2009-10 & 2010-11 Rajnish Bharti HUF, ITO, Circle 20(3)(1), 4/281, Opp. Britannia Biscuit Piramal Chambers Lalbaug, Vs. Company, Reay Road, Darukhana, Mumbai. Mumbai-10. PAN NO. AAEHR 6595 K Appellant Respondent ITA Nos. 4378 & 4377/MUM/2023 Assessment Years: 2009-10 & 2010-11 ITO-41(3)(3), BKC Rajnish Bharti HUF, 436, 4th floor, Kautaliya Bhavan, 4/281, Opp. Britannia Biscuit Mumbai-400051. Vs. Company, Reay R…

RAJNISH BHARTI HUF,MUMBAI vs. THE INCOME TAX OFFICER 20(3)(1), MUMBAI, LALBAUG, MUMBAI

In the result, both the appeals of the In the result, both the appeals of the assessee are dismissed assessee are dismissed whereas appeals of the Revenue are allowed

ITA 3912/MUM/2023[2009-10]Status: DisposedITAT Mumbai30 Jan 2025AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mrs. Sanyogita Nagpal, CIT-DRFor Respondent: Mr. C.V. Jain
Section 143(3)Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SUNIL KUMAR SINGH (JUDICIAL MEMBER) ITA Nos. 3912 & 3941/MUM/2023 Assessment Years: 2009-10 & 2010-11 Rajnish Bharti HUF, ITO, Circle 20(3)(1), 4/281, Opp. Britannia Biscuit Piramal Chambers Lalbaug, Vs. Company, Reay Road, Darukhana, Mumbai. Mumbai-10. PAN NO. AAEHR 6595 K Appellant Respondent ITA Nos. 4378 & 4377/MUM/2023 Assessment Years: 2009-10 & 2010-11 ITO-41(3)(3), BKC Rajnish Bharti HUF, 436, 4th floor, Kautaliya Bhavan, 4/281, Opp. Britannia Biscuit Mumbai-400051. Vs. Company, Reay R…

ISWAR CHAND DUBEY,DELHI vs. ITO,WARD-68 (1), DELHI

ITA 2985/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

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

…site belief. Whether the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the AO is within the realm of subjective satisfaction ITO v. Selected Dalurband Coal Co. (P) Ltd. [1996] 217 ITR 597 (SC); Raymond Woollen Mills Ltd. vs. ITO [1999] 236 ITR 34 (SC). 17. The scope and effect of section 147 as substituted with effect from 1-4-1989, as also sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the…

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ITO v. Selected Dalurband Coal Co. (P.) Ltd. (217 ITR 597) — Cited in 180 Judgments | BharatTax