Phool Chand Bajrang Lal v. ITO

203 ITR 456Supreme Court of India1993#186 most cited

What is Phool Chand Bajrang Lal v. ITO authority for?

Reassessment proceedings under Section 147 are valid even after a scrutiny assessment under Section 143(3), provided the Assessing Officer forms a reason to believe, based on definite, specific, and reliable information, that income escaped assessment due to the assessee's failure to fully and truly disclose material facts.

396

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2026.

Also referred to as

Phool Chand Bajrang Lal · Section 147 reassessment · Section 148 notice · reason to believe income escaped · full and true disclosure failure · definite and reliable information · reopening after 143(3) assessment · validity of reassessment proceedings · income escaping assessment reason to believe · SC judgment reopening assessment

Also reported as

69 Taxmann 6274 SCC 7769 Taxmann.com 627

Sections most often in play

Section 147Section 148Section 143(3)Section 142(1)Section 151Section 68Section 139Section 133(6)

Issues it is cited on

section 147(a)true and full disclosurefull and true disclosurebeyond four yearslive linkmaterial facts necessary for assessmentkelvinatorborrowed satisfactionmere change of opinionincome escaping assessmentreason to believeescapement of income

Judgments citing Phool Chand Bajrang Lal v. ITO

MARK STEELS LIMITED,KOLKATA vs. DCIT, CIRCLE 3(1),, KOLKATA

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

ITA 2603/KOL/2025[2011-2012]Status: DisposedITAT Kolkata26 Feb 2026AY 2011-2012

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 147Section 148Section 250Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘C’ BENCH AT KOLKATA Before SHRI GEORGE MATHAN, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER ITA No(s).: 2603/KOL/2025 Assessment Year(s): 2011-12 Mark Steels Limited DCIT, Circle-3(1), Kolkata Vs. (Appellant) (Respondent) PAN: AACCM8187B Appearances: Assessee represented by : S.K. Tulsiyan Adv. and Lata Goyal, CA. Department represented by : Ruchika Sharma, Sr. DR. Date of concluding the hearing : 15-January-2026 Date of pronouncing the order : 26-February-2026 ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the orde…

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND Ms. ASTHA CHANDRA, JUDICIAL MEMBER Assessment year : 2017-18 ITO, Ward 2(2), Pune Sagar Construction Company Vs. BA Gateway, Sakal Nagar, Baner Road, Aundh, Pune – 411020 PAN: ABAFS4929D (Appellant) (Respondent) CO No.43/PUN/2025 Assessment year : 2017-18 Sagar Construction Company ITO, Ward 2(2), Pune BA Gateway, Sakal Nagar, Baner Vs. Road, Aundh, Pune – 411020 PAN: ABAFS4929D (Appellant) (Respondent) Assessee by : Shri Suhas Bora and Riya Oswal Department by : Shri S. Sadananda Singh, JCIT Date of hearin…

JAP OVERSEAS PRIVATE LIMITED,MUMBAI vs. ITO WARD, 10 (2)(1), MUMBAI , MUMBAI

In the result, the appeal by the assessee is allowed

ITA 7228/MUM/2025[2010 - 11]Status: DisposedITAT Mumbai06 Jan 2026

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethjap Overseas Private Vs. Ito Ward, 10(2)(1) Limited Room No. 573, Aayakar Bhawan, B-102, Twinkle Maharishi Karve Road, New Marine Lines, Apartments, New Link Mumbai-400020. Road, Lokhandwala Complex, Andheri (W), Mumbai-400053. Pan/Gir No: Aaacj1573C (Appellant) (Respondent)

Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 69C

…pening he has relied on a number of decisions of the Hon’ble Supreme Court and various High Courts including the decisions in cases of Rajesh Jhaveri Stock Broker (P.) Ltd. (2007) 161 Taxman 316/291 ITR 500 (SC) Vs. ACIT, Phool Chand Bajrang Lal Vs. ITO(1993)203 ITR 456 Raymond Woollen Mills Ltd. Vs. ITO(1993) 236 ITR 34 (SC) etc., which are at para 5.4 to 5.22 of the appellate order. He has also confirmed the disallowance of loss of Rs.53,88,134/- and addition of commission expenses of Rs.1,07,763/-. 5. Further aggrieved, the assessee has filed the present appeal before the Tribunal on the grounds mentioned…

NAGARAJAN JAYA,KANCHEEPURAM vs. ITO, WARD-1,, KANCHIPURAM

In the result the appeal of the Assessee is allowed

ITA 1815/CHNY/2025[2011-12]Status: DisposedITAT Chennai05 Jan 2026AY 2011-12

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. P. Chidambaram, AdvocateFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 143(3)Section 147Section 148Section 264

…ent has been made but the income assessable to tax has been undressed then the same can be subjected to reassessment. 14. The Ld DR has also relied on various case laws as under: 1. CIT Vs PVS Beedies (P) Ltd 237 ITR 13 (SC) 2. Phool Chand Bajrang Lal Vs ITO 203 ITR 456 (SC) 3. ITO Vs TechSpan India (P) Ltd [2018] 92 taxmann.com 361 (SC) 4. Multi Commodity Exchange of India Ltd Vs DCIT 423 ITR 445 (SC) 5. Multi Commodity Exchange of India Ltd Vs DCIT [2018] 91 taxmann.com 265 (Bombay) (HC) 6. S.Subrahmanyan Constructions Co (P) Ltd Vs ACIT [2021] 131 taxmann.com 76 (Madras) (HC) 15. We have perused all these ca…

HITESHBHAI RAMESHBHAI PATEL,SURAT vs. ITO WARD,2, BARDOLI, BARDOLI

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

ITA 484/SRT/2025[2012-13]Status: DisposedITAT Surat23 Dec 2025AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-13 Hiteshbhai Rameshbhai Patel Income Tax Officer, 466 Kanbivad, Goddha Mahuwa, Ward-2, Bardoli, Income Tax Taluka Valod, Dist. Surat 394630 Vs. Office, 2Nd Floor, Bsnl Gujarat, Building, Opp. Jalaram Temple, Station Road, Bardoli- 394601 Pan No. Avdpp 6788 Q Appellant Respondent Assessee By : Mr. Sakar Sharma, Ar Revenue By : Mr. J.K. Chandani, Sr-Dr

For Appellant: Mr. Sakar Sharma, ARFor Respondent: Mr. J.K. Chandani, Sr-DR
Section 143(3)Section 147Section 148Section 151(1)Section 68

…reason to believe” that income chargeable to tax has escaped assessment, and not to conclusively establish such escapement. As consistently held by the Hon‟ble Supreme Court in Raymond Woollen Mills Ltd. v. ITO (236 ITR 34) and Phool Chand Bajrang Lal v. ITO (203 ITR 456), the adequacy or sufficiency of the material on which such belief is formed is not open to judicial scrutiny at this stage; what is required is the existence of some tangible material having a live nexus with the formation of belief. In the present case, information Hiteshbhai Rameshbhai Patel 7 regarding substantial cash deposits coupled with…

IMRAN AHMAD,MORADABAD, UTTAR PRADESH vs. INCOME TAX OFFICER, MORADABAD

Appeal is partly allowed

ITA 3490/DEL/2025[2013-2014]Status: DisposedITAT Delhi03 Dec 2025AY 2013-2014
Section 139Section 147Section 148

…ce. Reliance is hereby placed upon the decisions of Hon’ble Supreme Court in the case ofRAYMOND WOLLEN MILLS LTD. Vs. ITO 236 ITR 34 (SC) and ACIT VS. RAJESH JHAVERI STOCK BROKERS (P) LTD. 291 ITR 500 (SC), PHOOL CHAND BAJRANG LAL AND ANOTHER VS. ITO &ANOTHER 203 ITR 456 (SC) and Hon’ble Madras High Court in the case of STERLITE INDUSTRIES (INDIA) LTD. v ASSISTANT COMMISSIONER OF INCOME-TAX AND ANOTHER [2008] 302 ITR 275 (MAD.). It has been held by Hon’ble Supreme Court in the case of ITO vs. PurshotamDassBangur (1997) 224 ITR 362 (SC) that the information received from the Deputy Director (Inv.) constitutes vali…

DCIT, CIRCLE-4(2), NEW DELHI vs. CDS INFRA PROJECTS LTD., NEW DELHI

In the result, the appeal of Revenue and cross-objection of Assessee are dismissed

ITA 1445/DEL/2023[2012-13]Status: DisposedITAT Delhi24 Nov 2025AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2012-13 Deputy Commissioner Of Income Vs. M/S. Cds Infra Projects Ltd., B-94, Tax, Circle 4(2), Okhla Industrial Area, Phase-Ii, New Delhi. New Delhi-110020 Pan :Aadcc0273D (Appellant) (Respondent)

Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)Section 271(1)(b)

…Ltd. vs. Additional Commissioner of Income-tax [2011] 9 taxmann.com 62 (Delhi)/[2011] 197 Taxman 177 (Delhi)/[2011] 333 1TR 146 (Delhi)/[2011] 239 CTR 378 (Delhi) [07.01.2011] 3. Phool Chand Bajrang Lal vs. Income-tax Officer [1993] 69 Taxman 627 (SC)/[1993] 203 ITR 456 (SC)/ [1993] 113 CTR 436 (SC) [13-07- 1993], 4. Ess Ess Kay Engineering Co. (P) Ltd. v. CIT (2000) 247 ITR 818 (SC); & 5. Raymond Woollen Mills Ltd. vs. Income-tax Officer [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC)[17-12-1997]. 6.1 The demand for cross-examination of witnesses & parties from whom information is collected under Sections 131 or…

KAJAL BATRA,DELHI vs. ACIT,CIRCLE-52(1), DELHI

In the result, the appeal of the assessee stands dismissed as above

ITA 2419/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 151Section 68Section 69A

…n the cases and sufficiency of reason for forming the belief is not for the assessee to judge. The reliance is placed on following judicial pronouncements- 1. ITO Vs Lakhmani Mewal Das (SC) 103 ITR 437 2. Phool Chand Bajrang Lal and Another Vs ITO & Anr. (SC) 203 ITR 456 3. Raymond Woollen Mills Vs ITO & Anr. (SC) 236 ITR 34 4. Desh Raj Udyog Vs ITO (All) 318 ITR 6 j. Therefore, considering the facts and circumstance of the case, submission made by the assessee and the decisions as quoted supra, the assessing officer has rightly initiated the reassessment proceedings in the case of the assessee on the basis of in…

EXCELLENCE FINANCE PVT LTD,MUMBAI vs. DCIT CENTRAL CIRCLE 6(4), MUMBAI

In the result, all the aforesaid appeals of the assessee are\npartly allowed

ITA 208/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Oct 2025AY 2016-17
For Appellant: Shri Snehal Shah, ARFor Respondent: Shri Himanshu Joshi, (Sr. DR)
Section 143(2)Section 147Section 148Section 68

…nfinal ender. At this stage the Assessing officer was not required to\nhold conclusively that additions variably be made. He truly had to\nform a bona fide belief that income had escaped assessment.\n8.4 In Phool Chand Bajrang Lal v. ITΟ [1993] 69 Taxman\n627/203 ITR 456 hon'ble Supreme Courtheld that sufficiency of such\nreasons is not subject to judicial review, the only caveat being that the\ncourt can examine the record, if such material existed, it was held that\nthe facts disclosed in the return, & found later to be unfounded or false,\ncon always be the basis of a re-opening of assessment appears to us to\…

EXCELLENCE FINANCE PVT LTD,MUMBAI vs. DCIT, CENTRAL CIRCLE 6(4), MUMBAI

In the result, all the aforesaid appeals of the assessee are\npartly allowed

ITA 207/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Oct 2025AY 2015-16
For Appellant: Shri Snehal Shah, ARFor Respondent: Shri Himanshu Joshi, (Sr. DR)
Section 143(2)Section 147Section 148Section 68

…nfinal ender. At this stage the Assessing officer was not required to\nhold conclusively that additions variably be made. He truly had to\nform a bona fide belief that income had escaped assessment.\n8.4 In Phool Chand Bajrang Lal v. ITΟ [1993] 69 Taxman\n627/203 ITR 456 hon'ble Supreme Courtheld that sufficiency of such\nreasons is not subject to judicial review, the only caveat being that the\ncourt can examine the record, if such material existed, it was held that\nthe facts disclosed in the return, & found later to be unfounded or false,\ncon always be the basis of a re-opening of assessment appears to us to\…

EXCELLENCE FINANCE PVT LTD,MUMBAI vs. DCIT, CENTRAL CIRCLE 6(4), MUMBAI

In the result, all the aforesaid appeals of the assessee are\npartly allowed

ITA 206/MUM/2025[2014-15]Status: DisposedITAT Mumbai28 Oct 2025AY 2014-15
For Appellant: Shri Snehal Shah, ARFor Respondent: Shri Himanshu Joshi, (Sr. DR)
Section 143(2)Section 147Section 148Section 68

…nfinal ender. At this stage the Assessing officer was not required to\nhold conclusively that additions variably be made. He truly had to\nform a bona fide belief that income had escaped assessment.\n8.4 In Phool Chand Bajrang Lal v. ITΟ [1993] 69 Taxman\n627/203 ITR 456 hon'ble Supreme Courtheld that sufficiency of such\nreasons is not subject to judicial review, the only caveat being that the\ncourt can examine the record, if such material existed, it was held that\nthe facts disclosed in the return, & found later to be unfounded or false,\ncon always be the basis of a re-opening of assessment appears to us to\…

ABHISHEK GOURASARIA,JAMSHEDPUR vs. ACIT , JAMSHEDPUR

In the result, consequential assessment order also stands quashed

ITA 43/RAN/2023[2013-14]Status: DisposedITAT Ranchi06 Oct 2025AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayabhishek Gourasaria, A.C.I.T., 118, Flat No. 2B, Surabhi Apartment, K Jamshedpur Vs. Road, Bistupur, Jamshedpur-831001. Pan No. Adwpg 2149 R Appellant/ Assessee Respondent/ Revenue

Section 139Section 147Section 148Section 149Section 151Section 153Section 153ASection 153C

…voked on the borrowed information from the Investigation Wing of the Dept. 1. ACIT Vs. Dhariya Construction Co. (2010) 328ITR 515 S.C. 2. CIT v. India Terminal Connector System-Ltd. ITA No. 6430 of 2011. 3. Phool Chand Bajrang Lal V. Income-tax Officer (1993) 203 ITR 456 SC: 4. CIT V. Pradeep Kumar Gupta (2008) 303 ITR 95; Sec 153C read as under- "Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that, (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs t…

JAGDISH MALHOTRA,NEW DELHI vs. ACIT, CIRCLE-16(1), JHANDEWALAN

ITA 4546/DEL/2025[2012-13]Status: DisposedITAT Delhi26 Sept 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Gaurav Jain, Adv. &For Respondent: Sh. Shrikant Namdeo, CIT, DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

…notice u/s 148, the merits of the matter are not relevant and the Assessing Officer at that stage is required to form a prima facie belief or opinion that income chargeable to tax has escaped assessment" 15.2 Also, in the case of Phoolchand Bajrang Lal v. ITO 203 ITR 456 (SC), the Hon'ble Apex Court has held that:- “An assessment completed us 143(3) bur later on information received which was indefinite, specific and reliable and the AO duly recorded the reasons for his belief that the assessee had not fully and truly disclosed particulars of his income and hence there was escapement of income. Held that the reop…

SUBHASH SHAH,FARIDABAD vs. ITO, WARD-2(4), FARIDABAD

In the result, the assessee’s appeal stand allowed in the aforesaid manner

ITA 1021/DEL/2019[2010-11]Status: DisposedITAT Delhi24 Sept 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singhsubhash Shah, Vs. Ito, Ward 2(4), Prop. M/S Fancy Cloth House, Faridabad, Haryana Mfc 5842, Sanjay Colony, Sector-23, Faridabad Haryana (Pan: Aynps4924N) (Appellant) (Respondent) Appellant By : Sh. Akul Agarwal, Fca Respondent By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 22.09.2025 Date Of Pronouncement 24.09.2025 Order Per Mahavir Singh: This Appeal Has Been Filed By The Assessee Against The Order Dated 31.12.2018 Passed By The Ld. Cit(A), Faridabad Relating To Assessment Years 2010-11. 2. The First Issue In This Appeal Of The Assessee Is As Regards To The Action Of The Assessing Officer In Assuming Jurisdiction U/S. 147 R.W.S. 148 Of The Act As The Same Is Without Forming Reasonable Belief While

For Appellant: Sh. Akul Agarwal, FCAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(2)Section 147Section 148

…inference. Reliance is placed upon the decision of Hon'ble Supreme Court in the case of RAYMOND WOLLEN MILLS LTD. Vs. ITO 236 ITR 34 (SC) and ACIT VS. RAJESH JHAVERI STOCK BROKERS (P) LTD. 291 ITR 500 (SC), PHOOL CHAND BAJRANG LAL AND ANOTHER VS. ITO &ANOTHER 203 ITR 456 (SC) and Hon'ble Madras High Court in the case of STERLITE INDUSTRIES 4 | P a g e (INDIA) LTD. V ASSISTANTCOMMISSIONER OF INCOME-TAX AND ANOTHER [2008| 302 ITR275 (MAD.). It is further noted that the Pr. CIT has given his approval after application of mind and after consideration of the information on the record as required in the section 151 of…

SH. HARI PRAKASH GUPTA,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

The appeal stands allowed

ITA 772/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

…ed appearance of authorised representative of the assessee. Apropos reasons recorded for reopening, the impugned bogus entry was found in the books of the assessee it has been held by the hon'ble apex court in the case of Phool Chand Bajrang Lal v. ITO [1993] 203 ITR 456 (SC) that it is not for the court to judge the suf ficiency of reasons recorded for forming the belief which is the initial stage of income escaping assessment. The Assessing Officer had valid information in his possession which is placed on the record. It is pleaded that the learned Commissioner of Income- tax (Appeals) erred in holding that the…

SH. HARI PRAKASH GUPTA,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

The appeal stands allowed

ITA 771/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11
For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

…ed appearance of authorised representative of the assessee. Apropos reasons recorded for reopening, the impugned bogus entry was found in the books of the assessee it has been held by the hon'ble apex court in the case of Phool Chand Bajrang Lal v. ITO [1993] 203 ITR 456 (SC) that it is not for the court to judge the suf ficiency of reasons recorded for forming the belief which is the initial stage of income escaping assessment. The Assessing Officer had valid information in his possession which is placed on the record. It is pleaded that the learned Commissioner of Income- tax (Appeals) erred in holding that the…

DCIT, CIRCLE-14(2), NEW DELHI vs. KOHINOOR FOODS LTD., FARIDABAD

In the result, the Revenue’s appeal as well as Assessee’s Appeal stand dismissed in the aforesaid manner

ITA 587/DEL/2020[2011-12]Status: DisposedITAT Delhi17 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Dcit, Circle-14(2), New Delhi Vs. M/S Kohinoor Foods Ltd. 10Th Floor, Pinnacle Room No. 323, C.R. Building, New Delhi – 2 Business Tower, Suraj Kund Road, Faridabad Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) & M/S Kohinoor Foods Ltd. Vs. Acit, Circle 14(2), 10Th Floor, Pinnacle New Delhi Business Tower, Suraj Kund Road, Faridabad, Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) Assessee By : S/Sh. Salil Kapoor, Utkarsha Kumar Gupta, Ms. Soumya Singh, Advocates Department By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 28.08.2025 Date Of Pronouncement 17.09.2025

For Appellant: S/Sh. Salil Kapoor, Utkarsha KumarFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 147Section 68Section 92C

…ima facie there has been some document/information which lead to the reopening of case after forming believe that income has escaped assessment. Reliance was placed on the decision by Hon'ble Supreme Court in the case of Phool Chand Bajrang Lal vs. ITS (1993) 203 ITR 456, Raymond Woolen Mills Ltd. vs. ITO (1999) 236 ITR 34 (SC), Bawa Abhay Singh vs. DCIT 253 ITR 83 (Del.) and other cases where it is held that it is to be seen whether any prima facie material is available, based on which the Department could reopen the case. Since in this case the cogent information was available regarding bogus purchase shown by…

KOHINOOR FOODS LTD.,FARIDABAD vs. ACIT, CIRCLE-14(2), NEW DELHI

In the result, the Revenue’s appeal as well as Assessee’s Appeal stand dismissed in the aforesaid manner

ITA 149/DEL/2020[2011-12]Status: DisposedITAT Delhi17 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Dcit, Circle-14(2), New Delhi Vs. M/S Kohinoor Foods Ltd. 10Th Floor, Pinnacle Room No. 323, C.R. Building, New Delhi – 2 Business Tower, Suraj Kund Road, Faridabad Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) & M/S Kohinoor Foods Ltd. Vs. Acit, Circle 14(2), 10Th Floor, Pinnacle New Delhi Business Tower, Suraj Kund Road, Faridabad, Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) Assessee By : S/Sh. Salil Kapoor, Utkarsha Kumar Gupta, Ms. Soumya Singh, Advocates Department By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 28.08.2025 Date Of Pronouncement 17.09.2025

For Appellant: S/Sh. Salil Kapoor, Utkarsha KumarFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 147Section 68Section 92C

…ima facie there has been some document/information which lead to the reopening of case after forming believe that income has escaped assessment. Reliance was placed on the decision by Hon'ble Supreme Court in the case of Phool Chand Bajrang Lal vs. ITS (1993) 203 ITR 456, Raymond Woolen Mills Ltd. vs. ITO (1999) 236 ITR 34 (SC), Bawa Abhay Singh vs. DCIT 253 ITR 83 (Del.) and other cases where it is held that it is to be seen whether any prima facie material is available, based on which the Department could reopen the case. Since in this case the cogent information was available regarding bogus purchase shown by…

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), BAREILLY vs. VARUNARJUN TRUST, LUCKNOW

In the result, both the appeals are dismissed

ITA 620/LKW/2024[2016-17]Status: DisposedITAT Lucknow07 Aug 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

…t of the matter and made re-assessment notice void ab-initio. The AO has grossly erred in law in not taking cognizance of assessment order and issued notice against the mandate of law. In Phool Chand Bajrang Lal and another Vs. Income Tax Officer and another, 203 ITR 456 the Supreme Court held:- "From a combined review of the judgments of this Court, it follows that an Income-tax Officer acquires jurisdiction to reopen assessment under Section 147(a) read with Section 148 of the Income Tax 1961 only if on the basis of specific, reliable and relevant information coming to his possession subsequently, he has reaso…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. VARUNARJUN TRUST, LUCKNOW

In the result, both the appeals are dismissed

ITA 619/LKW/2024[2015-16]Status: DisposedITAT Lucknow07 Aug 2025AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

…t of the matter and made re-assessment notice void ab-initio. The AO has grossly erred in law in not taking cognizance of assessment order and issued notice against the mandate of law. In Phool Chand Bajrang Lal and another Vs. Income Tax Officer and another, 203 ITR 456 the Supreme Court held:- "From a combined review of the judgments of this Court, it follows that an Income-tax Officer acquires jurisdiction to reopen assessment under Section 147(a) read with Section 148 of the Income Tax 1961 only if on the basis of specific, reliable and relevant information coming to his possession subsequently, he has reaso…

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Phool Chand Bajrang Lal v. ITO (203 ITR 456) — Cited in 396 Judgments | BharatTax