Perla Krishna Rao v. ITO

159 ITR 299High Court#16851 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 361,821 Indian tax judgments — from 2020 to 2025.

Sections most often in play

Section 10(38)Section 115JBSection 143(3)Section 147Section 148Section 14ASection 195Section 37

Issues it is cited on

section 40(1)section 102section 114within four yearsfresh tangible materialfull and true disclosurefirst proviso to section 147prohibited by lawmaterial facts necessary for assessmentkelvinatormere change of opinionlive link

Judgments citing Perla Krishna Rao v. ITO

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2830/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

…ef. A reason to believe is what is relevant not an established fact of escapement of income. 52. We note that in this connection, the Assessee had also relied upon the judgment of the Hon’ble Andhra Pradesh High Court in the case of Perla Krishna Rao vs. ITO 159 ITR 299. We are of the view that the aforesaid judgment of the Hon’ble Andhra Pradesh High Court supports the case of the Revenue.In the aforesaid case search was conducted by Excise Officers of Cuttack Division which resulted in recovery of gold from two persons who recorded the statement that the gold belonged to the assessee in that case. On the basis…

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2823/MUM/2024[2019-20]Status: DisposedITAT Mumbai21 Nov 2025AY 2019-20

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

…ef. A reason to believe is what is relevant not an established fact of escapement of income. 52. We note that in this connection, the Assessee had also relied upon the judgment of the Hon’ble Andhra Pradesh High Court in the case of Perla Krishna Rao vs. ITO 159 ITR 299. We are of the view that the aforesaid judgment of the Hon’ble Andhra Pradesh High Court supports the case of the Revenue.In the aforesaid case search was conducted by Excise Officers of Cuttack Division which resulted in recovery of gold from two persons who recorded the statement that the gold belonged to the assessee in that case. On the basis…

The New India Assurance Co Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(2)(2), Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2622/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

…ef. A reason to believe is what is relevant not an established fact of escapement of income. 52. We note that in this connection, the Assessee had also relied upon the judgment of the Hon’ble Andhra Pradesh High Court in the case of Perla Krishna Rao vs. ITO 159 ITR 299. We are of the view that the aforesaid judgment of the Hon’ble Andhra Pradesh High Court supports the case of the Revenue.In the aforesaid case search was conducted by Excise Officers of Cuttack Division which resulted in recovery of gold from two persons who recorded the statement that the gold belonged to the assessee in that case. On the basis…

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(2)(2), Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2616/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Nov 2025AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

…ef. A reason to believe is what is relevant not an established fact of escapement of income. 52. We note that in this connection, the Assessee had also relied upon the judgment of the Hon’ble Andhra Pradesh High Court in the case of Perla Krishna Rao vs. ITO 159 ITR 299. We are of the view that the aforesaid judgment of the Hon’ble Andhra Pradesh High Court supports the case of the Revenue.In the aforesaid case search was conducted by Excise Officers of Cuttack Division which resulted in recovery of gold from two persons who recorded the statement that the gold belonged to the assessee in that case. On the basis…

Palaparthy Srilakshmi, Secunderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

In the result, assessee’s appeal is partly allowed

ITA 951/HYD/2019[2010-11]Status: DisposedITAT Hyderabad11 Jun 2020AY 2010-11

Bench: Smt. P. Madhavi Devi

For Appellant: Shri G.Kalyan Das, A.RFor Respondent: Sh. Kiran Katta, D.R
Section 144Section 147Section 148Section 68

…e Gujarat High Court in the case of CIT vs Mohmed Juned Dadani reported in 355 ITR 172 (Guj.). iv. Dr Devendra Gupta vs. ITO reported in 282 ITR (A.T.) 18 (ITAT)(Jodh.). v. Hon’ble AP High Court in the case of Perla Krishna Rao vs. ITO and another reported in 159 ITR 299 (AP). 9. Ld.DR, on the other hand, supported the order of the AO and submitted that the AO had received information that the assessee has made transactions worth Rs.43,96,84,412/- and there was sufficient material before him to believe that there is escapement of income since the assessee had not filed her return of income. He submitted that sin…

Perla Krishna Rao v. ITO (159 ITR 299) — Cited in 5 Judgments | BharatTax