Raymond Woollen Mills Ltd. v. ITO

236 ITR 34Supreme Court of India1999#58 most cited

What is Raymond Woollen Mills Ltd. v. ITO authority for?

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

841

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

Raymond Woollen Mills Ltd. v. ITO · Section 147 · Section 148 · reason to believe · escapement of income · reopening of assessment · prima facie material · sufficiency of material · correctness of material · notice under section 148 · scope of reassessment

Sections most often in play

Section 147Section 148Section 143(3)Section 68Section 151Section 142(1)Section 131Section 133(6)

Issues it is cited on

section 147(a)fresh tangible materialfull and true disclosurebeyond four yearskelvinatorlive linkmere change of opinionmaterial facts necessary for assessmenttangible materialchange of opinionborrowed satisfactionescapement of income

Judgments citing Raymond Woollen Mills Ltd. v. ITO

M/S AMBICA TIMBER TRADE PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER WARD 2(1) CR BUILDING NEW DELHI 110002, DELHI

The appeal of the assessee is allowed and the impugned reassessment order is quashed

ITA 6095/DEL/2025[2011-12]Status: DisposedITAT Delhi08 Apr 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklam/S Ambica Timber Trade Vs. Ito, Ward, 2(1) Private Limited Cr Building Y-402, New Delhi – 110002 Siddarthaappartment, Mp Enclave Pitampura Delhi – 110034 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajca0443P Appellant .. Respondent

For Appellant: Sh. PranshuSinghal, CAFor Respondent: Sh. Manish Gupta, Sr. DR
Section 147Section 148

…. Ld. DR could not dispute the aforesaid facts emanating from the material before us and relied on the decision of Hon’ble Delhi High Court in ChetanSabharwal Vs. ACIT, Circle 28(1) (2019) 110 taxmann.com 57 (Delhi) and ReymondWollenMills Ltd. Vs. ITO, (1999) 236 ITR 34 (SC) to contend that investigation report can be relied for reopening. However, we P a g e | 4 M/s Ambica Timber Trade Pvt. Ltd. (AY: 2011-12) are of the considered view that in the reason as has been recorded the assessing officer has time and again mentioned that reopening is being done for verification of the facts mentioned in the investigati…

BABITA CHELAWAT,INDORE vs. DCIT/ACIT 1(1), INDORE, INDORE

The appeal of the assessee is allowed & the impugned order is set aside

ITA 611/IND/2025[2012-13]Status: DisposedITAT Indore27 Mar 2026AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250Section 253

…penny stock used for accommodation entries. It is also pertinent to note that what is required before the re-opening the case is prime facie belief that income has escaped assessment. The Hon'ble Supreme Court in Raymond Woollen Mills Ltd. v. ITO [(1999) 236 ITR 34 (SC)] held that reopening is valid if the AO forms a prima facie belief of income escaping assessment. On examination of all the material in the case of the appellant, it is found that A.O has tangible and sufficient material to form the opinion that income has escaped assessment and hence he has issued the notice for re-opening. In light of thi…

DEPUTY COMMISSIONER OF INCOME TAX, YAMUNANAGAR vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 833/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

…holding that reopening on the basis of error pointed out by the audit partywas valid. Similar was the decision of Hon’ble Madras High Court in the case of CIT vs. First leasing Co. of India Ltd. (241 ITR 248).In the case of Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the 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 material is not a thing to be considered at this stage. In the…

DCIT vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 832/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

…holding that reopening on the basis of error pointed out by the audit partywas valid. Similar was the decision of Hon’ble Madras High Court in the case of CIT vs. First leasing Co. of India Ltd. (241 ITR 248).In the case of Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the 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 material is not a thing to be considered at this stage. In the…

THE VED PRAKASH MUKAND LAL EDUCATIONAL SOCIETY,YAMUNANAGAR vs. DCIT, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 825/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

…holding that reopening on the basis of error pointed out by the audit partywas valid. Similar was the decision of Hon’ble Madras High Court in the case of CIT vs. First leasing Co. of India Ltd. (241 ITR 248).In the case of Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the 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 material is not a thing to be considered at this stage. In the…

THE VED PRAKASH MUKAND LAL EDUCATIONAL SOCIETY,YAMUNANAGAR vs. DCIT, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 824/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

…holding that reopening on the basis of error pointed out by the audit partywas valid. Similar was the decision of Hon’ble Madras High Court in the case of CIT vs. First leasing Co. of India Ltd. (241 ITR 248).In the case of Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the 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 material is not a thing to be considered at this stage. In the…

INFINITY INTERNATIONAL,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. THE ITO, WARD-3(3)(1), AHMEDABAD

In the result, appeal of the assessee is dismissed

ITA 518/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalinfinity International, Nfac, Delhi Vs. H-611, Titanium City Centre, Present Jurisdiction 100 Ft. Anandnagar Road, Ito, Ward 3(3)(1), Satellite, Ahmedabad-380015 Ahmedabad [Pan: Aaefi 2610 J] (Appellant) .. (Respondent) Appellant By: Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ar Respondent By: Shri Alpesh Parmar, Cit-Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 10.03.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147Section 148Section 153(3)Section 250Section 68

…case by quoting VAT clause, visit of inspector, Ardor Group clause, statement of Chandresh Vyas etc. is not tenable and therefore rejected. 12. Reliance is also placed on the Hon'ble Supreme Court judgment in the case of Raymond Woollen Mills vs. ITO (1999) 236 ITR 34 (SC) in which the Hon'ble Apex Court has held that the Court can only consider whether there was a prima facie cause for reopening the assessment, and sufficiency of material cannot be considered at the stage of issuing the notice u/s 148 of the Act. In determining whether commencement and reassessment proceedings was valid, it has only to be seen…

HEMALATHA CHERVU,HYDERABAD vs. ITO, WARD - 15(1), HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 1966/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Feb 2026AY 2015-16

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1966/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Smt. Hemalatha Chervu Vs. Income Tax Officer Hyderabad Ward 15 (1) Pan:Aodpc8304C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Akash Deshpande, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 25/02/2026 घोषणा की तारीख/Pronouncement: 26/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 06/11/2025, For The A.Y 2015-16. 2. The Brief Facts Of The Case Are That The Assessee, An Individual, Not Filed Her Return Of Income For The A.Y 2015-16. The Page 1 Of 11

For Appellant: Shri Akash Deshpande, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133(6)Section 142(1)Section 147Section 148Section 149(1)(b)Section 69A

…equired to be seen is the prima facie material available to the A.O., but the A.O. is not required to prove the escapement of income. In this regard, he relied upon the decision of Hon'ble Supreme Court in the case of Raymond Woollen Mills Ltd. Vs. ITO (1999) 236 ITR 34 (SC). The learned Senior A.R. further submitted that, there is no merit in the other legal grounds taken by the assessee because the A.O. had issued notice under Section 148 of the Act as per the amended provisions of Section 149(1)(b) of the Act and as per the said provision, where the income escaped assessment is more than Rs. 50 lakhs, the A.O.…

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

…erator entities, which constitutes tangible material for forming "reason to believe," and sufficiency of such material is not justiciable at the initiation stage. The Hon'ble Supreme Court in the case of Raymond Woollen Mills Ltd. v. Income-tax Officer (1999) 236 ITR 34 (SC) held that at the stage of issuing notice, the court only examines the existence of prima facie material, not its sufficiency or correctness. The Hon'ble Supreme Court in the case Phool Chand Bajrang Lal v. Income-tax Officer [1993] 69 Taxman 627 (SC) clarified that reassessment is permissible when fresh, specific information comes to light in…

MEENA JEWELS AND PEARLS,HYDERABAD vs. ACIT., CIRCLE-5(1), HYDERABAD

ITA 1225/HYD/2024[2010-11]Status: DisposedITAT Hyderabad25 Feb 2026AY 2010-11
For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(3)Section 147Section 148

…pened the assessment to assess the income escaped assessment on account of bogus purchases made by the assessee from KIPL. In support of his contention, he has relied upon the Judgment of Hon'ble Supreme Court in the case of Raymond Woollen Mills Ltd., [1999] 236 ITR 34 (SC) and submitted that at the time of issuing the notice u/sec.148 the Assessing Officer has to see whether there was prima facie some material on the basis of which the department could reopen the case and sufficiency or correctness to the material was not a thing to be considered at this stage. The learned DR has also relied upon the following…

PALAK DESIGNER DIAMOND JEWELLERY,MAHIDHARPURA, SURAT vs. LD. AO, NFAC, DELHI

In the result, the appeal of the assessee for AY 2016-17 is dismissed

ITA 955/SRT/2024[2018-19]Status: DisposedITAT Surat23 Feb 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 147Section 148Section 250

…can certainly examine whether the reasons are relevant and have a bearing on the matters in regard to which he is required to entertain the belief before he can issue notice under section 147. The Hon’ble Supreme Court in case of Raymond Woolen Mills vs. ITO (236 ITR 34) held that: “3. In this case, we do not have to give a final decision as to whether there is suppression of material facts by the assessee or not. We have only to see 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…

PALAK DESIGNER DIAMOND JEWELLERY,MAHIDHARPURA, SURAT vs. LD. AO, NFAC, DELHI

In the result, the appeal of the assessee for AY 2016-17 is dismissed

ITA 954/SRT/2024[2017-18]Status: DisposedITAT Surat23 Feb 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 147Section 148Section 250

…can certainly examine whether the reasons are relevant and have a bearing on the matters in regard to which he is required to entertain the belief before he can issue notice under section 147. The Hon’ble Supreme Court in case of Raymond Woolen Mills vs. ITO (236 ITR 34) held that: “3. In this case, we do not have to give a final decision as to whether there is suppression of material facts by the assessee or not. We have only to see 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…

PALAK DESIGNER DIAMOND JEWELLERY,MAHIDHARPURA SURAT vs. LD. AO, NFAC, DELHI

In the result, the appeal of the assessee for AY 2016-17 is dismissed

ITA 953/SRT/2024[2016-17]Status: DisposedITAT Surat23 Feb 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 147Section 148Section 250

…can certainly examine whether the reasons are relevant and have a bearing on the matters in regard to which he is required to entertain the belief before he can issue notice under section 147. The Hon’ble Supreme Court in case of Raymond Woolen Mills vs. ITO (236 ITR 34) held that: “3. In this case, we do not have to give a final decision as to whether there is suppression of material facts by the assessee or not. We have only to see 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…

ROHITKUMAR CHINUBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

ITA 1961/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

…nt if there exists prima facie material leading to formation of such belief. This legal position is well settled by the Hon’ble Supreme Court in CIT v. Rajesh Jhaveri Stock Brokers (P.) Ltd. (2007) 291 ITR 500 (SC) and Raymond Woollen Mills Ltd. v. ITO (1999) 236 ITR 34 (SC). Therefore, the reopening of assessment in the present case cannot be said to be invalid or based on a mere change of opinion. 19. As regards the contention that the Department is taking contradictory stands by rejecting the purchaser’s claim of deduction under section 54B of ITA Nos. 1961 & 1960/Ahd/2025 Rohitkumar Chinubhai Modi & Saurabh…

SAURABHBHAI ROHITBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

ITA 1960/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

…nt if there exists prima facie material leading to formation of such belief. This legal position is well settled by the Hon’ble Supreme Court in CIT v. Rajesh Jhaveri Stock Brokers (P.) Ltd. (2007) 291 ITR 500 (SC) and Raymond Woollen Mills Ltd. v. ITO (1999) 236 ITR 34 (SC). Therefore, the reopening of assessment in the present case cannot be said to be invalid or based on a mere change of opinion. 19. As regards the contention that the Department is taking contradictory stands by rejecting the purchaser’s claim of deduction under section 54B of ITA Nos. 1961 & 1960/Ahd/2025 Rohitkumar Chinubhai Modi & Saurabh…

JETHABHAI GOKULBHAI GOL,BANASKATHA vs. ITO, WARD 1, PALANPUR, BANASKANTHA

Accordingly, the appeal filed by the assessee is dismissed

ITA 2668/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad19 Feb 2026AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 142(1)Section 144BSection 147Section 148Section 69

…escaped assessment. We also note that at the stage of reopening, the Assessing Officer is not required to finally establish escapement of income. This legal position has been reiterated by the Hon’ble Supreme Court in Raymond Woollen Mills Ltd. v. ITO [1999] 236 ITR 34 (SC), wherein it was held that what is required at the stage of reopening is only a prima facie belief and not conclusive proof. In the present case, the belief formed by the Assessing Officer clearly meets this threshold. 13. In view of the above discussion, we hold that the reassessment proceedings were validly initiated under section 147 of th…

VITHAL LEASEFIN(P) LTD ,MUMBAI vs. DCIT, CIRCLE WARD 1(3)(2), MUMBAI

ITA 7745/MUM/2025[2012-13]Status: DisposedITAT Mumbai19 Feb 2026AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Bijayananda Pruseth

Section 142Section 143(1)Section 147Section 148Section 250Section 68

…y that the material before the court should conclusively prove or establish that income has escaped assessment, and a reason to believe at the stage of reopening is all that is relevant. The Hon'ble Supreme Court in the case of Raymond Woollen Mills Ltd v ITO 236 ITR 34(SC) has 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, and that the sufficiency or correctness of the material is not a thing to be considered at the stage of reopening. Hence, the re…

ABHIMANYU NATH,NEW DELHI vs. ITO WARD 30(1), DELHI

In the result, appeal of assessee in ITA No

ITA 4930/DEL/2025[2012-13]Status: DisposedITAT Delhi11 Feb 2026AY 2012-13

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Ms. Roli Choubey, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 147Section 148

…of income which was never scrutinized before. We are of the view therefore that at this Page 5 of 9 [A.Y 2012-13] Shri Abhimanyu Nath Vs ITO stage the AO formed a prima facie belief of income escapement and as held in Raymond Woollen Mills Ltd. v. ITO[1999] 236 ITR 34 (SC) and Asstt. CIT v. Rajesh Jhaveri Stock Brokers (P.) Ltd. [2007] 291 ITR 500 (SC),the sufficiency of reasons cannot be questioned at the stage of reopening-only the presence of relevant material and rational connection is required. The inability of M/s Keshav Cloth to respond to summons, its non- existence at the declared address, and the asse…

PEDA SUBBA RAO UNNAM,ADDANKI vs. ITO , WARD-1, ONGOLE

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

ITA 1664/HYD/2025[2015-16]Status: DisposedITAT Hyderabad28 Jan 2026AY 2015-16

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 147Section 148Section 149Section 149(1)(a)Section 69A

…s the prima facie material available to the A.O., but the A.O. is not 14 Peda Subba Rao required to prove the escapement of income. In this regard, she relied upon the decision of Hon'ble Supreme Court in the case of Raymond Woollen Mills Ltd. Vs. ITO (1999) 236 ITR 34 (SC). The learned Senior A.R. further submitted that, there is no merit in the other legal grounds taken by the assessee because the A.O. had issued notice under Section 148 of the Act as per the amended provisions of Section 149(1)(a) of the Act and as per the said provision, where the income escaped assessment is more than Rs. 50 lakhs, the A.O.…

NATHARAM PANAJI CHOUDHARY,PUNE vs. I.T.O. WARD 8(1), PUNE, PUNE

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

ITA 1826/PUN/2024[2016-17]Status: DisposedITAT Pune21 Jan 2026AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Bharat Kumar (Virtually)For Respondent: Shri Amol Khairnar
Section 132Section 142(1)Section 147Section 148Section 69A

…& Company (2010) – TIOL 464 ITAT Mumbai. It is also relevant to mention that information obtained in assessment proceedings of subsequent year, can also be utilized for reopening of the completing assessment refer Raymond Woolens Mills Ltd. vs. ITO and Other 236 ITR 34 (SC) and Revathy C.P. Equipment Ltd. vs. DCIT AND ors. 241 ITR 856 (Mad). 4.3.4 In the interest of natural justice, the Assessing officer has given several opportunities of hearing have been provided to the appellant to submit explanation / evidence. In the present proceedings also, the appellant has not filed any evidence for the nature and sourc…

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