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.

How many judgments cite Phool Chand Bajrang Lal v. ITO?

396 judgments on BharatTax cite Phool Chand Bajrang Lal v. ITO (203 ITR 456), spanning 2007 to 2026.

Which sections of the Income Tax Act does Phool Chand Bajrang Lal v. ITO come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 142(1), Section 151, Section 68.

Phool Chand Bajrang Lal v. ITO (203 ITR 456)

Shri Dinesh Sethi, Ludhiana vs. ITO, Ludhiana

The appeals are dismissed

ITA 338/CHANDI/2017[2006-07]Status: DisposedITAT Chandigarh04 Aug 2025AY 2006-07

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR

Section 131Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 69A

…eld by Hon'ble Punjab & Haryana High Court in the case of Gurera Gas Cylinders Pvt. Ltd. Vs. CIT (258 ITR 170) and in case of Swaraj Engine Ltd. Vs. ACIT (260 ITR 202) following the judgment of Hon'ble Supreme Court in cash of Phool Chand Bajrang Lai Vs. ITO (203 ITR 456). The ratio of the decisions relied upon by the Ld. Counsel would, therefore, not help the case of the appellant. As discussed above on receiving the information regarding the credit entries in the bank account, the AO compared the same with the records available and noted that no return had been filed by the appellant for the assessment year und…

Sh. Dinesh Sethi, Ludhiana vs. ITO, Ludhiana

The appeals are dismissed

ITA 376/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh04 Aug 2025AY 2006-07

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR

Section 131Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 69A

…eld by Hon'ble Punjab & Haryana High Court in the case of Gurera Gas Cylinders Pvt. Ltd. Vs. CIT (258 ITR 170) and in case of Swaraj Engine Ltd. Vs. ACIT (260 ITR 202) following the judgment of Hon'ble Supreme Court in cash of Phool Chand Bajrang Lai Vs. ITO (203 ITR 456). The ratio of the decisions relied upon by the Ld. Counsel would, therefore, not help the case of the appellant. As discussed above on receiving the information regarding the credit entries in the bank account, the AO compared the same with the records available and noted that no return had been filed by the appellant for the assessment year und…

Deputy Commissioner of Income Tax, Circle-1(3)(1), Mumbai vs. Tmf Holdings Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 2983/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Jul 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhrideputy Commissioner Of Vs Tmf Holdings Limited 14, 4Th Floor, Sir H C Dinshaw Income Tax, Circle 1(3)(1), Mumbai Building, 16, Horniman Circle, Fort, Room No.535, 5Th Floor, Aaykar Mumbai-400 001 Bhavan, M.K. Road, Mumbai- Pan: Aacct4644A 400 020 Appellant Respondent

For Appellant: Shri Rajan Vora a/w Shri Nikhil TiwariFor Respondent: Shri Ritesh Mishra, CIT DR

Section 115JSection 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

…2025 In this regard and in continuation to the Respondent's brief synopsis, please find below our reply to the learned departmental representative's written submissions Distinguishing reliance placed on the decision in case of Phooichand Bajrang Lal (1993) 203 ITR 456 (SC)] and Consolidated Photo and Finvest Ltd. (2006) 281 ITR 394 (Delhi HC)] 1 With regards to the above, it is humbly submitted that the learned CIT(A) in his order under section 250 of the Act dated 26 February 2025 (refer page nos. 12 to 8 ITA 2983/Mum /2025 CO 132/Mum/2025 TMF Limited 62 of the Respondent's cross objections) has relied upon…

Principal Commissioner of Income Tax 1 Kolkata vs. Tanuj Properties Private Limited

The appeal stands disposed of with the above direction

ITAT/116/2025HC Calcutta14 Jul 2025

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 14Th July, 2025.

Section 260A

…: “1. Whether the Learned Income Tax Appellate Tribunal has committed substantial error in law in quashing the reopening of the assessment, ignoring the ratio laid down by the Hon'ble Supreme Court in the case of (i) Phool Chand Bajranj Lal vs. ITO (1993) 203 ITR 456 (SC), (ii) Raymond Woolen Mills Ltd. vs. ITO (1999) 236 ITR 34 (SC) and (iii) Jurisdictional Hon'ble Calcutta High Court in the case of Mulchand Rampuria vs. ITO(2000) 252 ITR 758 (Cal) with stated that while 2 considering the validity of the commencement of reassessment proceedings, it is only necessary to determine whether there was s…

ACIT, New Delhi vs. M/S. A & D Estates Pvt. Ltd., New Delhi

In the result we upheld the decision of the Ld

ITA 1729/DEL/2016[2012-13]Status: DisposedITAT Delhi25 Jun 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Manish Agarwalassessment Year: 2012-13

Section 132Section 143(2)Section 143(3)Section 148Section 68

…n. It is open to an assessee to establish that there in fact existed no belief or that the belief was not at all bonafide or was based on vague, irrelevant & non- specific information as was held by Supreme Court in the case of Phool Chand Bajrang Lal Vs. ITO 203 ITR 456. 7 ACIT v. A&D Estates (P) Ltd. A.Y. 2012-13 "Reason to believe" is not the same thing as "reason to suspect" as was held in Indian Oil Corporation Vs. ITO 159 ITR 956, 970 (SC) and mere suspicion cannot be made the basis for issuance of reassessment notice as was held in CIT Vs. Ram Lal Manohar Lal 158 ITR 9, 11(Del). It is equally settled law…

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…

Btl Holding Co. Ltd, Faridabad vs. DCIT Central Circle-II, Faridabad

In the result, ITA No.7429/Del/2019 for A

ITA 7429/DEL/2019[2014-15]Status: DisposedITAT Delhi21 Mar 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Amitabh Shukla

For Appellant: Sh. Somil Aggarwal, AdvocateFor Respondent: Sh. Ashish Tripathi, Sr. DR

Section 139Section 147Section 148Section 153A

…he respondents, supported the issuance of the notice under section 148 as well as the speaking order dated 02.03.2005 disposing of the petitioner‟s objections. She submitted that the decision of the Supreme Court in the case of Phool Chand Bajrang Lal v. ITO: 203 ITR 456 squarely applied to the present case. Mrs Bansal contended that in this decision the Supreme Court made it clear that the observations in the Burlop case (supra) were not of universal application but were limited to the fact situation in that case. In the Burlop case (supra), the Supreme Court had observed as under:- "The assessee had disclosed…

Btl Holding Co. Ltd, Faridabad vs. DCIT Central Circle-II, Faridabad

In the result, ITA No.7429/Del/2019 for A

ITA 7428/DEL/2019[2011-12]Status: DisposedITAT Delhi21 Mar 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Amitabh Shukla

For Appellant: Sh. Somil Aggarwal, AdvocateFor Respondent: Sh. Ashish Tripathi, Sr. DR

Section 139Section 147Section 148Section 153A

…he respondents, supported the issuance of the notice under section 148 as well as the speaking order dated 02.03.2005 disposing of the petitioner‟s objections. She submitted that the decision of the Supreme Court in the case of Phool Chand Bajrang Lal v. ITO: 203 ITR 456 squarely applied to the present case. Mrs Bansal contended that in this decision the Supreme Court made it clear that the observations in the Burlop case (supra) were not of universal application but were limited to the fact situation in that case. In the Burlop case (supra), the Supreme Court had observed as under:- "The assessee had disclosed…

Btl Holding Co. Ltd, Faridabad vs. DCIT Central Circle-II, Faridabad

In the result, ITA No.7429/Del/2019 for A

ITA 7427/DEL/2019[2010-11]Status: DisposedITAT Delhi21 Mar 2025AY 2010-11

Bench: Shri Vikas Awasthy & Shri Amitabh Shukla

For Appellant: Sh. Somil Aggarwal, AdvocateFor Respondent: Sh. Ashish Tripathi, Sr. DR

Section 139Section 147Section 148Section 153A

…he respondents, supported the issuance of the notice under section 148 as well as the speaking order dated 02.03.2005 disposing of the petitioner‟s objections. She submitted that the decision of the Supreme Court in the case of Phool Chand Bajrang Lal v. ITO: 203 ITR 456 squarely applied to the present case. Mrs Bansal contended that in this decision the Supreme Court made it clear that the observations in the Burlop case (supra) were not of universal application but were limited to the fact situation in that case. In the Burlop case (supra), the Supreme Court had observed as under:- "The assessee had disclosed…

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 there was prima facie some material on the basis of which department could reopen the case. The sufficiency or correctness of the material is not a thing to be considered at this stage. 5.9 In the case of Phool Chand Bajrang Lal and another v ITO (1993) 203 ITR 456 (SC) where Assessing Officer located at Ajamgarh in UP after receiving information of accommodation entry from the ITO Calcutta re-opened the case u/s 147 of the Act, Hon'ble Supreme Court approved the decision of the AO to issue notice u/s 148 of the Act and has held as under: "Since, the belief is that of the income-tax Officer, the sufficienc…

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 875/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Mar 2025AY 2016-17

For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 143(3)Section 147

…bogus purchases. Thus reopening of assessment itself is bad in law for having not recorded independent “reason to believe” that income has escaped assessment. Decided in favour of assessee. 5.9 In the case of Phool Chand Bajrang Lal and another v ITO (1993) 203 ITR 456 (SC) where Assessing Officer located at Ajamgarh in UP after receiving information of accommodation entry from the ITO Calcutta re-opened the case u/s 147 of the Act, Hon'ble Supreme Court approved the decision of the AO to issue notice u/s 148 of the Act and has held as under: "Since, the belief is that of the income-tax Officer, the sufficienc…

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 872/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Mar 2025AY 2012-13

For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 143(3)Section 147

…n bogus purchases. Thus reopening of assessment itself is bad in law for having not recorded independent “reason to believe” that income has escaped assessment. Decided in favour of assessee. 5.9 In the case of Phool Chand Bajrang Lal and another v ITO (1993) 203 ITR 456 (SC) where Assessing Officer located at Ajamgarh in UP after receiving information of accommodation entry from the ITO Calcutta re-opened the case u/s 147 of the Act, Hon'ble Supreme Court approved the decision of the AO to issue notice u/s 148 of the Act and has held as under: "Since, the belief is that of the income-tax Officer, the sufficiency…

Shah Rukh Khan, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, the appeal by the assessee is allowed

ITA 6312/MUM/2024[A. Y. 2012-13 ]Status: DisposedITAT Mumbai04 Mar 2025

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalshah Rukh Khan, 44, Mannat, Bj Road, Bandstand, Bandra, Mumbai - 400050 Pan: Aahpk3293L ……………. Appellant V/S Dcit, Central Circle – 4(2) Kautilya Bhavan, Bandra Kurla Complex, Bandra East, ……………. Respondent Mumbai - 400050 Maharashtra

For Appellant: Shri Aditya AjgaonkarFor Respondent: Ms. Kavitha Kaushik, Sr. DR

Section 148Section 250

…nder section 90 of the Act, after noting that partial relief was granted to the assessee vide order dated 16/03/2015 passed under section 143(3) of the Act. Thus, the decision of the Hon’ble Supreme Court in Phool Chand Bajrang Lal v/s ITO, reported in (1993) 203 ITR 456 (SC), relied upon by the learned DR, also does not support the submissions of the Revenue as, in the present case, there were neither any fresh facts nor some information with regard to the facts previously disclosed, which came to the possession of the AO after conclusion of the scrutiny assessment proceedings, and the entire re-assessment proce…

Cle Private Limited, Mumbai vs. DCIT Central Circle -3(4), Mumbai

In the result, appeal of the Revenue is dismissed and cross objection of the assessee is allowed

ITA 6270/MUM/2024[2017-18]Status: DisposedITAT Mumbai17 Feb 2025AY 2017-18

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Shri Niraj Sheth a/w Jitendra SanghviFor Respondent: Shri R.A. Dhyani, CIT/DR &

Section 115JSection 133(6)Section 143(3)Section 147Section 68

…reasons for reopening courts cannot go into the aspect of sufficiency of those reasons. He also referred following judicial pronouncements: “a. Kalyan Mavji v CIT (SC) 102 ITR 287 b. ITO v Lakhmani Mewal Das (SC) 103 ITR 437 c. Phool Chand Bajranj v ITO (SC) 203 ITR 456 d. Sri Krishna (P) Ltd. v CIT (SC) 221 ITR 538 e. Central Provinces Manganese Ore v ITO (SC) 191 ITR 662” The ld. DR further submitted that speaking order u/s 148A(d) was passed after informing the assessee and giving opportunity to submit its objection. 7. Heard both the sides and perused the material on record in respect of reopening of asses…

Cle Pvt Ltd, Mumbai vs. DCIT Central Circle 3(4), Mumbai

In the result, appeal of the Revenue is dismissed and cross objection of the assessee is allowed

ITA 6269/MUM/2024[2015-16]Status: DisposedITAT Mumbai17 Feb 2025AY 2015-16

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Shri Niraj Sheth a/w Jitendra SanghviFor Respondent: Shri R.A. Dhyani, CIT/DR &

Section 115JSection 133(6)Section 143(3)Section 147Section 68

…reasons for reopening courts cannot go into the aspect of sufficiency of those reasons. He also referred following judicial pronouncements: “a. Kalyan Mavji v CIT (SC) 102 ITR 287 b. ITO v Lakhmani Mewal Das (SC) 103 ITR 437 c. Phool Chand Bajranj v ITO (SC) 203 ITR 456 d. Sri Krishna (P) Ltd. v CIT (SC) 221 ITR 538 e. Central Provinces Manganese Ore v ITO (SC) 191 ITR 662” The ld. DR further submitted that speaking order u/s 148A(d) was passed after informing the assessee and giving opportunity to submit its objection. 7. Heard both the sides and perused the material on record in respect of reopening of asses…

Sunita Jajoo, Surat vs. ITO Ward 2(2)(4), Surat

In the result, assessee’s appeal is allowed

ITA 882/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

…lusion that the assessee is engaged in penny stock transaction. (clearly meaning that what was disclosed in the return of income by the assessee was false and untruthful). 20. The Hon'ble Supreme Court in the case of Phul Chand Bajrang Lal and another vs. ITO 203 ITR 456, was considering the question of reassessment beyond the period of four years in the case of an assessee firm; and had held that in case of acquiring fresh information specific in nature and reliable, relating to the concluded assessment, which went to falsify the statement made by the assessee at the time of original assessment and, therefore, h…

Rambilash Rajaram Jajoo, Surat vs. Income Tax Officer Ward-2(2)(4), Surat

ITA 552/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) Rambilash Rajaram Jajoo (Physical Court Hearing) 429-432, Golden Point, Falsawadi, Ring Road, Surat City, Surat-395 002 [Pan : Aampj 0040 K] अपीलार्थी/Appellant Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 प्रत्यर्थी / Respondent आयकर अपील सं./Ita No. 882/Srt/2024 (Ay 2011-12) Sunita Jajoo 429-432, Golden Point, Near Bsnl Office, Falsawadi, Ring Road, Surat-395 002 [Pan: Aampj 0040 K] बनाम Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 अपीलार्थी/Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से /Assessee By Ms. Richa Toshniwal. Ca राजस्व की ओर से /Revenue By Shri Minal Kamble, Sr. Dr सुनवाई की तारीख/Date Of Hearing 23.01.2025 उद्घोषणा की तारीख/Date Of Pronouncement 10.02.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. These Two Appeals By Separate Assessee Are Directed Against The Separate Orders Of Addl/Jcit(A)-7, Kolkata/National Faceless Appeal Centre, Delhi [For Short To As "Nfac/Ld.Cit(A)] Dated 21.03.2024 & 21.04.2023 For Same

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

…lusion that the assessee is engaged in penny stock transaction. (clearly meaning that what was disclosed in the return of income by the assessee was false and untruthful). 20. The Hon'ble Supreme Court in the case of Phul Chand Bajrang Lal and another vs. ITO 203 ITR 456, was considering the question of reassessment beyond the period of four years in the case of an assessee firm; and had held that in case of acquiring fresh information specific in nature and reliable, relating to the concluded assessment, which went to falsify the statement made by the assessee at the time of original assessment and, therefore, h…

Tijaria Polypipes Limited, Jaipur vs. DCIT Cirlce 4, Jaipur

ITA 616/JPR/2024[2013-14]Status: DisposedITAT Jaipur30 Jan 2025AY 2013-14

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Anoop Singh, Addl.CIT-DR

Section 143(3)Section 147Section 148Section 68

…459 (Mumbai Trib), Praful Chunilal Patel 148 CTR (Guj.). The sufficiency of reasons cannot be looked into by courts and there must be recording of prima facie belief has also been held in cases of Raymond woollen mills 236 ITR 34 (SC), Phool Chand Bjaranglal 203 ITR 456 (SC), K R Sadayappan 63 ITR 219 (SC). In case of Multi Screen Media (P) Ltd. 324 ITR 54 (Bom) the Bombay High Court after considering the decision in case of CIT vs. Kelvinator of India Ltd. (2010) 320 ITR 561 (SC) has observed as under: "where the AO purports to exercise power under s.147 within a period of four years from the end of the relevan…

Mack Star Marketing Private Limited, Mumbai vs. Deputy Commissioner of Income Tax 2(2)(1), Mumbai

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

ITA 4994/MUM/2024[2013-14]Status: DisposedITAT Mumbai21 Jan 2025AY 2013-14

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

For Appellant: Mr. Yash VarmaniFor Respondent: Mr. R.R. Makwana, Sr. DR

Section 144BSection 147

…t in determining whether commencement of the reassessment proceedings was valid it has only to be seen whether there was prima facie some material on the basis of which the Department could reopen the case. In the case of Phool Chand Bajrang Lal v. ITO [1993] 203 ITR 456 (SC) held that there must exist reasons for holding believe for escapement of income although the question whether reasons adequate or sufficient is not for the courts to decide. Further the Hon'ble Delhi High Court in the case of SMCC Construction v. ACIT [2014] 220 Taxman 354 (Delhi) held that where the reasons to believe recorded does not refe…

Best Realtrech India P.Ltd, New Delhi vs. ITO, Ward-4(3), New Delhi

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

ITA 390/DEL/2020[2011-12]Status: DisposedITAT Delhi27 Dec 2024AY 2011-12

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmanm/S Best Realtrech Income Tax Officer, (India) Pvt. Ltd., Ward-4(3), New Delhi H-8, First Floor, Vs. Best Plaza, Netaji Subhash Place, Pitampura, Delhi-110034 Pan:Aadcb1848D (Appellant) (Respondent)

Section 132Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 153CSection 68

…ty of the investor could not translate into a satisfaction with regard to creditworthiness of the investor. We have perused the audited financial statement and the return of income filed by the Petitioners. In the case of Phool Chand Bajrang Lal v. ΙΤΟ [1993] 203 ITR 456 it was held by the Supreme Court that "where the transaction itself on the basis of subsequent information, is found to be a bogus transaction, the mere disclosure of the "true" and "full" facts in the case and the Income Tax Officer would have the jurisdiction to reopen the concluded assessment in such a case". In the present case, the return of…

Phool Chand Bajrang Lal v. ITO

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

Also referred to as

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Sections most often in play

Issues it is cited on

Judgments citing Phool Chand Bajrang Lal v. ITO

Shri Dinesh Sethi, Ludhiana vs. ITO, Ludhiana

Sh. Dinesh Sethi, Ludhiana vs. ITO, Ludhiana

Deputy Commissioner of Income Tax, Circle-1(3)(1), Mumbai vs. Tmf Holdings Limited, Mumbai

Principal Commissioner of Income Tax 1 Kolkata vs. Tanuj Properties Private Limited

ACIT, New Delhi vs. M/S. A & D Estates Pvt. Ltd., New Delhi

DCIT, Central Circle-28, New Delhi vs. Manish Uppal, Delhi

Btl Holding Co. Ltd, Faridabad vs. DCIT Central Circle-II, Faridabad

Btl Holding Co. Ltd, Faridabad vs. DCIT Central Circle-II, Faridabad

Btl Holding Co. Ltd, Faridabad vs. DCIT Central Circle-II, Faridabad

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

Shah Rukh Khan, Mumbai vs. DCIT Central Circle 4(2), Mumbai

Cle Private Limited, Mumbai vs. DCIT Central Circle -3(4), Mumbai

Cle Pvt Ltd, Mumbai vs. DCIT Central Circle 3(4), Mumbai

Sunita Jajoo, Surat vs. ITO Ward 2(2)(4), Surat

Rambilash Rajaram Jajoo, Surat vs. Income Tax Officer Ward-2(2)(4), Surat

Tijaria Polypipes Limited, Jaipur vs. DCIT Cirlce 4, Jaipur

Mack Star Marketing Private Limited, Mumbai vs. Deputy Commissioner of Income Tax 2(2)(1), Mumbai

Best Realtrech India P.Ltd, New Delhi vs. ITO, Ward-4(3), New Delhi