Raymond Woolen Mills Ltd. v. ITO And Others, the Hon'ble Supreme Court

152 CTR 418Supreme Court of India1999#7254 most cited

What is Raymond Woolen Mills Ltd. v. ITO And Others, the Hon'ble Supreme Court authority for?

The validity of reassessment proceedings only requires the department to show prima facie material indicating that income has escaped assessment. The sufficiency or correctness of this material is not a consideration at the stage of initiating reassessment.

15

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2021 to 2025.

Also referred to as

Raymond Woolen Mills Ltd. v. ITO · reassessment proceedings · reopening of assessment · prima facie material · income escaped assessment · section 147 · section 148 · section 145(3)

Sections most often in play

Section 1961Section 147Section 148Section 133(6)Section 144Section 250Section 131Section 132

Issues it is cited on

section 145(3)reopening of assessmentaccommodation entrytangible materialescapement of incomesection 145reason to believereassessment proceedingssection 250(6)cross objectionassistant commissionerincome-tax officer

Judgments citing Raymond Woolen Mills Ltd. v. ITO And Others, the Hon'ble Supreme Court

Anant Electricals and Engineers, Thane vs. DCIT, Circle 1, Thane

In the result, the appeal is allowed for statistical purposes

ITA 5454/MUM/2025[2013-14]Status: DisposedITAT Mumbai22 Dec 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Subodh Ratnaparkhi, ARFor Respondent: Shri Surendra Mohan, (Sr. DR)
Section 143(3)Section 147Section 148Section 40

…pies of documentary evidence/explanations have been thoroughly examined. In respect of validity of reopening, the ld.CIT(A) relying on the decision of Hon'ble Apex Court in the case of Raymond Woollen Mills Ltd. v. ITO And Others [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC)],held that the action taken by the Assessing Officer was right and thus, ground of appeal was dismissed. 4.1 As far as merits of the case are concerned, he observed that the income of Interest on FDRs is covered under the head “Income from Other Sources and is computed in the manner laid down in Chapter IV-F of the Act. Also, the assessee ha…

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

…g accommodation entries and bogus bills, and assessee had made sizeable purchases from him, reopening notice against assessee was justified. 1. The Hon’ble Supreme Court in the case of Raymond Woollen Mills Ltd. v. ITO And Others [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC) wherein it was held that in determining whether commencement of 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. The sufficiency or correctness of the material is not a thing to be considered at this stage. 1. The Hon’ble Gujarat…

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)

…-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 133(6) based on which additions are proposed where the incriminating material had already been provided by the Courts is unjustified. 6.2 On the issue of cross examination, the Hon'ble SC in the case of Ayubkhan N…

DCIT, Circle-1, Bathinda vs. Dmr Builders Pvt Ltd, Bathinda

In the result the appeal of the revenue is dismissed being devoid of merits

ITA 293/ASR/2024[2017-18]Status: DisposedITAT Amritsar16 Jun 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. Nos. 292 & 293/Asr/2024 Assessment Years: 2016-17 & 2017-18

Section 133(6)Section 143(3)Section 148Section 250(6)

…t warranted.” 5. The Ld. CIT(A) has erred in holding notice issued u/s 148 of the Income-tax Act, 1961 as invalid and illegal by not appreciating the Hon’ble Apex Court’s judgement in Raymond Woollen Mills Ltd. v. ITO And Others ([1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC)) in which the Hon’ble Apex Court held that in determining whether commencement of reassessment proceedings was valid it has only to I.T.A. Nos. 292 & 293/Asr/2024 4 And C.O. Nos. 01 & 02/Asr/2025 be seen whether there was prima facie some material on the basis of which the department could reopen the case. The sufficiency or correctness o…

DCIT, Circle-1, Bathinda vs. Dmr Builders Pvt Ltd, Bathinda

In the result the appeal of the revenue is dismissed being devoid of merits

ITA 292/ASR/2024[2016-17]Status: DisposedITAT Amritsar16 Jun 2025AY 2016-17

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. Nos. 292 & 293/Asr/2024 Assessment Years: 2016-17 & 2017-18

Section 133(6)Section 143(3)Section 148Section 250(6)

…t warranted.” 5. The Ld. CIT(A) has erred in holding notice issued u/s 148 of the Income-tax Act, 1961 as invalid and illegal by not appreciating the Hon’ble Apex Court’s judgement in Raymond Woollen Mills Ltd. v. ITO And Others ([1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC)) in which the Hon’ble Apex Court held that in determining whether commencement of reassessment proceedings was valid it has only to I.T.A. Nos. 292 & 293/Asr/2024 4 And C.O. Nos. 01 & 02/Asr/2025 be seen whether there was prima facie some material on the basis of which the department could reopen the case. The sufficiency or correctness o…

Assistant Commissioner of Income Tax, Central Circle 4(1), Kolkata vs. Ritu Kejriwal, Kolkata

In the result, the appeal filed by the Revenue is dismissed

ITA 2223/KOL/2024[2018]Status: DisposedITAT Kolkata18 Feb 2025

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 132Section 132(4)Section 147Section 148Section 250

…the hands of the assessee. Aggrieved with the assessment order the assessee filed the appeal before the Ld. CIT(A) who relied upon the decision of Hon'ble Supreme Court in the case of Raymond Woollen Mills Ltd. v. ITO And Others [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC) and in the case of Nickunj Eximp Enterprises (P.) Ltd [2014] I.T.A. No.: 2223/KOL/2024 Assessment Year: 2018-19 Ritu Kejriwal. 48 taxmann. com 20 (Bombay)/ [2015] 229 Taxman 99 (Bombay)/ [2014] 270 CTR 494 (Bombay) and upheld the reopening of the assessment. As regards the quantum of addition, since the assessee himself in its sworn statemen…

Shri Khandelwal Diamonds Private Limited, Jaipur vs. ACIT, Circle 1, Jaipur

In the result, appeal of the assessee is partly allowed

ITA 375/JPR/2023[2012-13]Status: DisposedITAT Jaipur30 Oct 2023AY 2012-13

Bench: Him On The Reason Of Issuing Notice U/S 148 On Borrowed Satisfaction Of Another Wing Of The Department.

For Appellant: Sh. Mukesh Khandelwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT) a
Section 143(3)Section 148

…330 (SC) SUPREME COURT OF INDIA Suman Poddar v. Income Tax Officer 7 49-54 [1995] 80 Taxman 89 (SC)/[1995] 214 ITR 801 (SC)/[1995] 125 ...[1995] 80 Taxman 89 (SC)SUPREME COURT OF INDIA Sumati Dayal v. Commissioner of ncome-tax 8 [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC)[17-12-1997] 55-56 [1999] 236ITR34 (SC) SUPREME COURT OF INDIA Raymond Woollen Mills Ltd. v. Income-tax Officer 57-116 [2022] 139 taxmann.com 352 (Calcutta) HIGH COURT OF CALCUTTA Principal 9. Commissioner of Income-tax v. SwatiBajaj 10 [1995] 82 TAXMAN 31 (CAL.) HIGH COURT OF CALCUTTA 117- Commissioner of Income-tax v. Precision Finance (P.)…

Shri Arun Agrawal, Raipur vs. Assistant Commissioner of Income Tax-3(1), Raipur

In the result, the appeal of the assessee is allowed in terms of the aforesaid observations

ITA 214/RPR/2023[2010-11]Status: DisposedITAT Raipur16 Oct 2023AY 2010-11

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No. 214/Rpr/2023 "नधा"रण वष" / Assessment Year : 2010-11 Shri Arun Agrawal 85, Pandri Textile Market, Raipur-492 001 (C.G.) Pan :Acjpa2323D .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-3(1), Raipur (C.G.)

For Appellant: Shri Veekaas S. Sharma, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 132Section 147Section 148Section 153CSection 69

…s 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. The sufficiency or correctness of the material is not a thing to be considered at this stage." [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC)] (ii) In the case of Yogendra Kumar Gupta Vs. ITO, Hon'ble SC held that "Where subsequent to completion of original assessment, Assessing Officer, on basis of search carried out in case of another person, came to know that loan transactions of assessee with a finance company were bogus as said company was engaged in providing accommodation e…

Dr Deepak Arjundas, Chennai vs. ACIT, Chennai

In the result, appeals filed by the assessee for all the assessment

ITA 929/CHNY/2022[2016-2017]Status: DisposedITAT Chennai15 Mar 2023AY 2016-2017

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.924 To 929/Chny/2022 िनधा"रण वष" /Assessment Years: 2011-12 To 2016-17 Dr.Deepak Arjundas, V. The Asst. Commissioner- No.228-A, Kilpauk Garden Road, Of Income Tax, Chennai-600 010. Non-Corporate Circle-10(1), Chennai. [Pan: Aafpd 1050 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.S.Sundaraman, Ca ""यथ" क" ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.03.2023 घोषणा क" तारीख /Date Of Pronouncement : 15.03.2023 आदेश / O R D E R Per Bench: This Bunch Of Appeals Filed By The Assessee Are Directed Against

For Respondent: Mr.P.Sajit Kumar, JCIT
Section 139(5)Section 147Section 148Section 28

…at income escaped assessment & is not required to establish the same beyond reasonable doubt. Similarly, in ITA Nos.924 to 929/Chny/2022 :: 6 :: the case of Raymond Woolen Mills Ltd. v. ITO And Others, the Hon'ble Supreme Court [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC), held that in determining whether commencement of 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. The sufficiency or correctness of the material is not a thing to be considered at this stage. Similarly, in the case of Raymond Woo…

Dr Deepak Arjundas, Chennai vs. ACIT, Chennai

In the result, appeals filed by the assessee for all the assessment

ITA 928/CHNY/2022[2015-2016]Status: DisposedITAT Chennai15 Mar 2023AY 2015-2016

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.924 To 929/Chny/2022 िनधा"रण वष" /Assessment Years: 2011-12 To 2016-17 Dr.Deepak Arjundas, V. The Asst. Commissioner- No.228-A, Kilpauk Garden Road, Of Income Tax, Chennai-600 010. Non-Corporate Circle-10(1), Chennai. [Pan: Aafpd 1050 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.S.Sundaraman, Ca ""यथ" क" ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.03.2023 घोषणा क" तारीख /Date Of Pronouncement : 15.03.2023 आदेश / O R D E R Per Bench: This Bunch Of Appeals Filed By The Assessee Are Directed Against

For Respondent: Mr.P.Sajit Kumar, JCIT
Section 139(5)Section 147Section 148Section 28

…at income escaped assessment & is not required to establish the same beyond reasonable doubt. Similarly, in ITA Nos.924 to 929/Chny/2022 :: 6 :: the case of Raymond Woolen Mills Ltd. v. ITO And Others, the Hon'ble Supreme Court [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC), held that in determining whether commencement of 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. The sufficiency or correctness of the material is not a thing to be considered at this stage. Similarly, in the case of Raymond Woo…

Dr Deepak Arjundas, Chennai vs. ACIT, Chennai

In the result, appeals filed by the assessee for all the assessment

ITA 927/CHNY/2022[2014-2015]Status: DisposedITAT Chennai15 Mar 2023AY 2014-2015

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.924 To 929/Chny/2022 िनधा"रण वष" /Assessment Years: 2011-12 To 2016-17 Dr.Deepak Arjundas, V. The Asst. Commissioner- No.228-A, Kilpauk Garden Road, Of Income Tax, Chennai-600 010. Non-Corporate Circle-10(1), Chennai. [Pan: Aafpd 1050 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.S.Sundaraman, Ca ""यथ" क" ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.03.2023 घोषणा क" तारीख /Date Of Pronouncement : 15.03.2023 आदेश / O R D E R Per Bench: This Bunch Of Appeals Filed By The Assessee Are Directed Against

For Respondent: Mr.P.Sajit Kumar, JCIT
Section 139(5)Section 147Section 148Section 28

…at income escaped assessment & is not required to establish the same beyond reasonable doubt. Similarly, in ITA Nos.924 to 929/Chny/2022 :: 6 :: the case of Raymond Woolen Mills Ltd. v. ITO And Others, the Hon'ble Supreme Court [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC), held that in determining whether commencement of 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. The sufficiency or correctness of the material is not a thing to be considered at this stage. Similarly, in the case of Raymond Woo…

Dr Deepak Arjundas, Chennai vs. ACIT, Chennai

In the result, appeals filed by the assessee for all the assessment

ITA 926/CHNY/2022[2013-2014]Status: DisposedITAT Chennai15 Mar 2023AY 2013-2014

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.924 To 929/Chny/2022 िनधा"रण वष" /Assessment Years: 2011-12 To 2016-17 Dr.Deepak Arjundas, V. The Asst. Commissioner- No.228-A, Kilpauk Garden Road, Of Income Tax, Chennai-600 010. Non-Corporate Circle-10(1), Chennai. [Pan: Aafpd 1050 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.S.Sundaraman, Ca ""यथ" क" ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.03.2023 घोषणा क" तारीख /Date Of Pronouncement : 15.03.2023 आदेश / O R D E R Per Bench: This Bunch Of Appeals Filed By The Assessee Are Directed Against

For Respondent: Mr.P.Sajit Kumar, JCIT
Section 139(5)Section 147Section 148Section 28

…at income escaped assessment & is not required to establish the same beyond reasonable doubt. Similarly, in ITA Nos.924 to 929/Chny/2022 :: 6 :: the case of Raymond Woolen Mills Ltd. v. ITO And Others, the Hon'ble Supreme Court [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC), held that in determining whether commencement of 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. The sufficiency or correctness of the material is not a thing to be considered at this stage. Similarly, in the case of Raymond Woo…

Dr Deepak Arjundas, Chennai vs. ACIT, Chennai

In the result, appeals filed by the assessee for all the assessment

ITA 925/CHNY/2022[2012-2013]Status: DisposedITAT Chennai15 Mar 2023AY 2012-2013

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.924 To 929/Chny/2022 िनधा"रण वष" /Assessment Years: 2011-12 To 2016-17 Dr.Deepak Arjundas, V. The Asst. Commissioner- No.228-A, Kilpauk Garden Road, Of Income Tax, Chennai-600 010. Non-Corporate Circle-10(1), Chennai. [Pan: Aafpd 1050 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.S.Sundaraman, Ca ""यथ" क" ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.03.2023 घोषणा क" तारीख /Date Of Pronouncement : 15.03.2023 आदेश / O R D E R Per Bench: This Bunch Of Appeals Filed By The Assessee Are Directed Against

For Respondent: Mr.P.Sajit Kumar, JCIT
Section 139(5)Section 147Section 148Section 28

…at income escaped assessment & is not required to establish the same beyond reasonable doubt. Similarly, in ITA Nos.924 to 929/Chny/2022 :: 6 :: the case of Raymond Woolen Mills Ltd. v. ITO And Others, the Hon'ble Supreme Court [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC), held that in determining whether commencement of 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. The sufficiency or correctness of the material is not a thing to be considered at this stage. Similarly, in the case of Raymond Woo…

Dr Deepak Arjundas, Chennai vs. ACIT, Chennai

In the result, appeals filed by the assessee for all the assessment

ITA 924/CHNY/2022[2011-2012]Status: DisposedITAT Chennai15 Mar 2023AY 2011-2012

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.924 To 929/Chny/2022 िनधा"रण वष" /Assessment Years: 2011-12 To 2016-17 Dr.Deepak Arjundas, V. The Asst. Commissioner- No.228-A, Kilpauk Garden Road, Of Income Tax, Chennai-600 010. Non-Corporate Circle-10(1), Chennai. [Pan: Aafpd 1050 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.S.Sundaraman, Ca ""यथ" क" ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.03.2023 घोषणा क" तारीख /Date Of Pronouncement : 15.03.2023 आदेश / O R D E R Per Bench: This Bunch Of Appeals Filed By The Assessee Are Directed Against

For Respondent: Mr.P.Sajit Kumar, JCIT
Section 139(5)Section 147Section 148Section 28

…at income escaped assessment & is not required to establish the same beyond reasonable doubt. Similarly, in ITA Nos.924 to 929/Chny/2022 :: 6 :: the case of Raymond Woolen Mills Ltd. v. ITO And Others, the Hon'ble Supreme Court [1999] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC), held that in determining whether commencement of 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. The sufficiency or correctness of the material is not a thing to be considered at this stage. Similarly, in the case of Raymond Woo…

Late Sh. Raj Kumar Wadhwa Through L/H Smt. Usha Wadhwa, Patiala vs. DCIT, Circle, Patiala

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

ITA 1335/CHANDI/2019[2008-09]Status: DisposedITAT Chandigarh14 Jun 2021AY 2008-09

Bench: The Appeal Is Finally Heard Or Disposed Off.” 3. Ground No 1 & 4 Being General In Nature Need No Adjudication.

For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Ashok Khanna, Addl.CIT
Section 143(1)Section 147Section 148Section 250(6)

…jective satisfaction in the Ld AO which was predicted on cogent information that lead to Reason to believe. Reliance is placed on the judgment of the Hon'ble Apex Court in the case of Raymond Woollen Mills Ltd. v. ITO And Others [19991] 236 ITR 34 (SC)/[1999] 152 CTR 418 (SC) where the Apex Court has held as under: In determining whether commencement of reassessment proceedings was valid it has only to be seen whether there was prima fade some material on the basis of which the department could reopen the case. The sufficiency or correctness of the material is not a thing to be considered at this stage.” 8. We ha…