Sheo Nath Singh v. AAC

82 ITR 147Supreme Court of India1971#798 most cited

What is Sheo Nath Singh v. AAC authority for?

To initiate reassessment under Section 147/148, the Income Tax Officer must have an honest and reasonable 'reason to believe' that income has escaped assessment, based on cogent grounds and not mere suspicion. Reassessment is invalid if based only on a lack of analysis during the original assessment without new material.

129

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also referred to as

Sheo Nath Singh v. AAC · 82 ITR 147 · Section 147 · Section 148 · reason to believe · income escaping assessment · reopening of assessment · mere suspicion · cogent grounds · lack of analysis · reassessment validity · mechanical approval

Sections most often in play

Section 147Section 148Section 139(1)Section 133ASection 143(3)Section 151Section 131Section 144

Issues it is cited on

live linkthird party informationsection 148(2)jdasection 158bcreason to believeescapement of incomekelvinatorinterest u/s 234aincome escaping assessmentreopening of assessmentchange of opinion

Judgments citing Sheo Nath Singh v. AAC

M/S. SAGUN SALES PVT. LTD.,KOLKATA vs. I.T.O., WARD - 4(1), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

ITA 1194/KOL/2024[2011-2012]Status: DisposedITAT Kolkata13 Jan 2026AY 2011-2012

Bench: Shri George Mathan

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Abhijit Adhikary, Sr. DR
Section 147Section 148

…आयकर अपीलीय अधिकरण, “एस.एम.सी” न्यायपीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH KOLKATA श्री जाजज माथन, न्याययक सदस्य के समक्ष । BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER आयकर अपील सं/ITA No.1194/KOL/2024 (नििाारण वर्ा / Assessment Year :2011-2012) M/s Sagun Sales Private Limited, Vs ITO Ward-4(1), Kolkata Unit 3-B, 3rd Floor 24 Anuj Chamber, Park Street, Kolkata-700016 PAN No. :AALCS 0017 R (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee by : Shri S.M.Surana, Advocate राजस्व की ओर से /Revenue by : Shri Abhijit Adhikary, Sr. DR सुनवाई की तारीख / Date of Hear…

NAVEEN SINGH,JAMSHEDPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, JAMSHEDPUR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

ITA 413/RAN/2024[2017-18]Status: DisposedITAT Ranchi06 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.413/Ran/2024 Assessment Year: 2017-18 Naveen Singh………...…………….…….…............................……….……Appellant M-9 Old, Adityapur Jamshedpur, Jharkhand- 831013. [Pan: Adkps4229A] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri P. S. Paul, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 12.09.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For Assessment Year 2017–18 Declaring A Total Income Of ₹43,99,340/- Under Section 139(1) Of The Act. The Return Was Processed Under Section 143(1) Accepting The Income As Declared. Subsequently, The Ao Issued A Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Sanction From The Competent Authority. The Assessee Did Not Respond To The Notice Under Section 148. Thereafter, Multiple Notices Under Section 142(1) Were Issued, Including Final Opportunity Notices, Which Were Duly Served But Remained Unanswered.

Section 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 56(2)(x)

…on, gossip or rumour. The Ld. AO would be acting without jurisdiction, if the reason for the belief that the conditions required to be satisfied do not exist or is not material or relevant to the belief required by the section [SHEO NATH SINGH VS. AAC. (1971) 82 ITR 147 (SC). 7.2 In the case of PCIT Vs. Meenakshi Overseas (P) Ltd. [2017] 82 taxmann.com 300 (Del.) wherein it has been held as under: “where reassessment was resorted to on basis of information from DIT (Investigation) that assessee had received accommodation entry but and there was no independent application of mind by Assessing Officer to tangible m…

DCIT(CC)-8(3), MUMBAI , MUMBAI vs. JSW STEEL LIMITED, MUMBAI

In the result, all the above appeals of the assessee are partly allowed and Cross appeals of the Revenue are dismissed

ITA 5599/MUM/2024[2013-14]Status: DisposedITAT Mumbai08 Dec 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263

…IN THE INCOME-TAX APPELLATE TRIBUNAL“F” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No. 5585/MUM/2024 (A.Y. 2014-15) M/s JSW Steel Limited v/s. Deputy Commissioner of Income JSW Centre, Bandra Kurla बनाम Tax, Central Circle-8(3) Complex, Bandra (East), Aaykar Bhavan, 6th Floor, Room Mumbai – 400 051, No. 659, Maharishi Karve Road, Maharashtra Mumbai – 400 020, Maharashtra स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AAACJ4323N Appellant/अपीलाथी .. Respondent/प्रतिवादी ITA No. 5615/MUM/2024 (A.Y. 2014-15) Deputy Commissioner of Income v/s. M/s JSW St…

M/S. JSW STEEL LIMITED ,MUMBAI vs. DCIT, CENTRAL CIRCLE -8(3), MUMBAI

In the result, all the above appeals of the assessee are partly allowed and Cross appeals of the Revenue are dismissed

ITA 5585/MUM/2024[2014-15]Status: DisposedITAT Mumbai08 Dec 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 147Section 251Section 263

…IN THE INCOME-TAX APPELLATE TRIBUNAL“F” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No. 5585/MUM/2024 (A.Y. 2014-15) M/s JSW Steel Limited v/s. Deputy Commissioner of Income JSW Centre, Bandra Kurla बनाम Tax, Central Circle-8(3) Complex, Bandra (East), Aaykar Bhavan, 6th Floor, Room Mumbai – 400 051, No. 659, Maharishi Karve Road, Maharashtra Mumbai – 400 020, Maharashtra स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AAACJ4323N Appellant/अपीलाथी .. Respondent/प्रतिवादी ITA No. 5615/MUM/2024 (A.Y. 2014-15) Deputy Commissioner of Income v/s. M/s JSW St…

ACIT, CIRCLE 3, LUCKNOW, LUCKNOW vs. ANSHUMAN SINGH, LUCKNOW

In the result, the appeal of Revenue is allowed

ITA 342/LKW/2025[2017-18]Status: DisposedITAT Lucknow04 Dec 2025AY 2017-18
Section 139Section 142Section 142(1)Section 143Section 143(3)Section 144Section 147Section 148

…pparent from the assessment records. The whole exercise is based on suspicion and surmise. The issue in this regard is well settled by judgments of the Hon'ble Apex Court/High Courts in the case of (a) Sheonath Singh v. Appellate Assistant Commissioner (1971) 82 ITR 147 (SC); (b) ITO v. Lakhmani Mawal Das (1976) 103 ITR 437 (SC); (c) Ganga Saran & Sons (P) Ltd. v. ITO (1981) 130 ITR 1 (SC); and(d) K. M. Bansal v. CIT (1992) 195 ITR 247 (All); 79 ITR 603 [Chungamal Rajpal V/s S P Chellia]. \\\nj. The decision of the Hon'ble Delhi High Court in the case of Commissioner of Income Tax v. G&G Pharma (2015) 384 ITR 147…

MADINA RICE MILL PVT. LTD.,HOOGHLY vs. A.C.I.T., CC - 4(4), KOLKATA

In the result, the appeals of the assessee are allowed

ITA 2471/KOL/2024[2017-2018]Status: DisposedITAT Kolkata26 Nov 2025AY 2017-2018

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

…ant to such approval is bad in law and so is the consequent assessment framed by the AO. In defense of his argument, the ld. AR relied on series of decision namely; (i) Chhugamal Rajpal Vs. S.P. Chaliha & Ors on 21.01.1971, (ii) Sheo Nath Singh Vs. AAC (1971) 82 ITR 147 (SC) (iii) S Narayanaappa Vs. CIT (1967) 63 ITR 219 (SC) (iv) Ganga Saran & Sons Pvt. ltd. Vs. ITO (1981) 130 ITR 1 (SC). ITA No.2467 to 2471/KOL/2024 Madina Rice Mill Private Limited; A.Y. 2013-14 to 2017-18 4.4. The ld. AR also relied on the decision Capital Broadways Pvt. Ltd. Vs. ITO in WP(C) 4303/ 2017 dated 03.10.2024, wherein the Hon'ble co…

MADINA RICE MILL PVT. LTD.,HOOGHLY vs. A.C.I.T., CC - 4(4), KOLKATA

In the result, the appeals of the assessee are allowed

ITA 2470/KOL/2024[2016-2017]Status: DisposedITAT Kolkata26 Nov 2025AY 2016-2017

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

…ant to such approval is bad in law and so is the consequent assessment framed by the AO. In defense of his argument, the ld. AR relied on series of decision namely; (i) Chhugamal Rajpal Vs. S.P. Chaliha & Ors on 21.01.1971, (ii) Sheo Nath Singh Vs. AAC (1971) 82 ITR 147 (SC) (iii) S Narayanaappa Vs. CIT (1967) 63 ITR 219 (SC) (iv) Ganga Saran & Sons Pvt. ltd. Vs. ITO (1981) 130 ITR 1 (SC). ITA No.2467 to 2471/KOL/2024 Madina Rice Mill Private Limited; A.Y. 2013-14 to 2017-18 4.4. The ld. AR also relied on the decision Capital Broadways Pvt. Ltd. Vs. ITO in WP(C) 4303/ 2017 dated 03.10.2024, wherein the Hon'ble co…

MADINA RICE MILL PVT. LTD.,HOOGHLY vs. A.C.I.T., CENTRAL CIRCLE - 4(4), KOLKATA

In the result, the appeals of the assessee are allowed

ITA 2469/KOL/2024[2015-2016]Status: DisposedITAT Kolkata26 Nov 2025AY 2015-2016

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

…ant to such approval is bad in law and so is the consequent assessment framed by the AO. In defense of his argument, the ld. AR relied on series of decision namely; (i) Chhugamal Rajpal Vs. S.P. Chaliha & Ors on 21.01.1971, (ii) Sheo Nath Singh Vs. AAC (1971) 82 ITR 147 (SC) (iii) S Narayanaappa Vs. CIT (1967) 63 ITR 219 (SC) (iv) Ganga Saran & Sons Pvt. ltd. Vs. ITO (1981) 130 ITR 1 (SC). ITA No.2467 to 2471/KOL/2024 Madina Rice Mill Private Limited; A.Y. 2013-14 to 2017-18 4.4. The ld. AR also relied on the decision Capital Broadways Pvt. Ltd. Vs. ITO in WP(C) 4303/ 2017 dated 03.10.2024, wherein the Hon'ble co…

MADINA RICE MILL PVT. LTD.,HOOGHLY vs. A.C.I.T., CC - 4(4), KOLKATA

In the result, the appeals of the assessee are allowed

ITA 2468/KOL/2024[2014-2015]Status: DisposedITAT Kolkata26 Nov 2025AY 2014-2015

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

…ant to such approval is bad in law and so is the consequent assessment framed by the AO. In defense of his argument, the ld. AR relied on series of decision namely; (i) Chhugamal Rajpal Vs. S.P. Chaliha & Ors on 21.01.1971, (ii) Sheo Nath Singh Vs. AAC (1971) 82 ITR 147 (SC) (iii) S Narayanaappa Vs. CIT (1967) 63 ITR 219 (SC) (iv) Ganga Saran & Sons Pvt. ltd. Vs. ITO (1981) 130 ITR 1 (SC). ITA No.2467 to 2471/KOL/2024 Madina Rice Mill Private Limited; A.Y. 2013-14 to 2017-18 4.4. The ld. AR also relied on the decision Capital Broadways Pvt. Ltd. Vs. ITO in WP(C) 4303/ 2017 dated 03.10.2024, wherein the Hon'ble co…

MADINA RICE MILL PVT. LTD.,HOOGHLY vs. A.C.I.T., CC - 4(4), KOLKATA

In the result, the appeals of the assessee are allowed

ITA 2467/KOL/2024[2013-2014]Status: DisposedITAT Kolkata26 Nov 2025AY 2013-2014

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

…ant to such approval is bad in law and so is the consequent assessment framed by the AO. In defense of his argument, the ld. AR relied on series of decision namely; (i) Chhugamal Rajpal Vs. S.P. Chaliha & Ors on 21.01.1971, (ii) Sheo Nath Singh Vs. AAC (1971) 82 ITR 147 (SC) (iii) S Narayanaappa Vs. CIT (1967) 63 ITR 219 (SC) (iv) Ganga Saran & Sons Pvt. ltd. Vs. ITO (1981) 130 ITR 1 (SC). ITA No.2467 to 2471/KOL/2024 Madina Rice Mill Private Limited; A.Y. 2013-14 to 2017-18 4.4. The ld. AR also relied on the decision Capital Broadways Pvt. Ltd. Vs. ITO in WP(C) 4303/ 2017 dated 03.10.2024, wherein the Hon'ble co…

SHEETAL BATHLA,KOTA vs. INCOME TAX OFFICER WARD 1(2) KOTA, KOTA

In the result, appeal of the assessee is allowed

ITA 215/JPR/2025[2012-13]Status: DisposedITAT Jaipur17 Nov 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shsrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT
Section 142(1)Section 147Section 148Section 234ASection 250

…a product of imagination or speculation. There must be reason to induce the belief. The Court can always examine this aspect though the declaration or sufficiency of the reasons for the belief cannot be investigated by the Court (SheoNath Singh v. AAC, (1971) 82 ITR 147 (SC). As on perusal of the above para 1 it shows that the ld. AO has proceeded on reasons to suspect not reason to believe and failed to understand the scope of audit, a blind observation cannot be used in reasons. 9 Sheetal Bathla, Jaipur. 3.3 No application of mined on the information received from DDIT: Further the ld. AO issued Notice u/s 1…

VIJIT SINGH,JAIPUR vs. ITO WARD 3(2) JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1246/JPR/2025[2009-10]Status: DisposedITAT Jaipur17 Nov 2025AY 2009-10
For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT
Section 147Section 234ASection 250

…roduct of imagination or speculation. There must be\nreason to induce the belief. The Court can always examine this aspect\nthough the declaration or sufficiency of the reasons for the belief cannot be\ninvestigated by the Court (SheoNath Singh v. AAC, (1971) 82 ITR 147 (SC).\nIn the case of MukeshModi&Ors.vs. DCIT 366 ITR 418 (Raj) held that\nEvasion of tax was menace to society but Assessee contributing to the\nexchequer in form of tax could not be allowed to suffer on mere pretence that\nit had evaded payment of tax. Rowing and fishing enquiry in hands of AO on\nmere suspicion or change of opinion could not sa…

THE PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. BOOTHNATH VINTRADE PRIVATE LIMITED

In the result, the appeal of the assessee is allowed

ITAT/297/2024HC Calcutta14 Nov 2025

Bench: HON'BLE JUSTICE RAJARSHI BHARADWAJ,HON'BLE JUSTICE UDAY KUMAR

Section 147Section 148

…ossip or rumour. The Ld. AO would be acting without jurisdiction, if the reason for the belief that the conditions required to be satisfied do not exist or is not material or relevant to the belief required by the section [SHEO NATH SINGH VS. AAC. (1971) 82 ITR 147 (SC). In the case of PCIT Vs. Meenakshi Overseas (P) Ltd. [2017] 82 taxmann.com 300 (Del.) wherein it has been held as under: “where reassessment was resorted to on basis of information from DIT (Investigation) that assessee had received accommodation entry but and there was no independent application of mind by Assessing Officer to ta…

MAYA KUMARI,JAIPUR vs. ITO WARD 2(2), JAIPUR, JAIPUR

In the result, appeal of the assessee is allowed

ITA 581/JPR/2025[2012-13]Status: DisposedITAT Jaipur03 Nov 2025AY 2012-13
For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh choudhary, Addl. CIT
Section 147Section 148Section 234ASection 250Section 69

…roduct of imagination or speculation. There must be reason to induce the\nbelief. The Court can always examine this aspect though the declaration or sufficiency of\nthe reasons for the belief cannot be investigated by the Court (SheoNath Singh v. AAC,\n(1971) 82 ITR 147 (SC).\nIn the case of MukeshModi&Ors.vs. DCIT 366 ITR 418 (Raj) held that Evasion of tax\nwas menace to society but Assessee contributing to the exchequer in form of tax could\nnot be allowed to suffer on mere pretence that it had evaded payment of tax. Rowing and\nfishing enquiry in hands of AO on mere suspicion or change of opinion could not sat…

MO. SHARIPH KURESHI,SIKAR vs. ITO WARD-4 SIKAR, SIKAR

In the result, the appeal of the assessee is allowed

ITA 366/JPR/2025[2013-14]Status: DisposedITAT Jaipur18 Sept 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 234ASection 271(1)(c)

…xist or is not material or relevant to the belief required by the provision of law. The Court can always examine this aspect though the declaration or sufficiency of the reasons for the belief cannot be investigated by the Court (SheoNath Singh v. AAC, (1971) 82 ITR 147 (SC). In the case of Mukesh Modi &Ors. vs. DCIT 366 ITR 418 (Raj) held that Evasion of tax was menace to society but Assessee contributing to the exchequer in form of tax could not be allowed to suffer on mere pretence that it had evaded payment of tax. Rowing and fishing enquiry in hands of AO on mere suspicion or change of opinion could not sat…

JITENDRA SHARMA, ACIT, CIRCLE-19(1), MUMBAI, MUMBAI vs. KASHYAP MAHESH VORA, MUMBAI

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

ITA 4322/MUM/2024[2012]Status: DisposedITAT Mumbai10 Jul 2025

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member), SMT. RENU JAUHRI (Accountant Member)

For Appellant: Shri K. Gopal a/w Shri AkhileshFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(3)Section 147Section 250Section 68Section 69C

…d relating to applicability of Sec 147, the Assessee contends that the re-assessment proceedings are untenable in law as they have been made on the basis of mere conjecture as opposed to cogent basis. The Hon’ble Supreme Court in the case of Sheo Nath Singh [82 ITR 147] has laid down that the words “reason to believe” suggest that the belief must be that of an honest and reasonable person based upon reasonable grounds and that the Income Tax Officer may act on direct or circumstantial evidence but not on mere suspicion, gossip or rumour. When so-called reasons are in the nature of beliefs, it leads to an obvious…

RAMA SHANKER PAREEK,JAIPUR vs. INCOME TAX OFFICER, WARD NO. 7(2), JAIPUR

In the result, appeal of the assessee is allowed

ITA 253/JPR/2025[2010-11]Status: DisposedITAT Jaipur24 Jun 2025AY 2010-11
For Appellant: Shri Shrawan Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, Addl.CIT
Section 142(1)Section 147Section 148Section 234ASection 250Section 69CSection 80C

…t or is not material or relevant to the belief required by the\nprovision of law. The Court can always examine this aspect though the\ndeclaration or sufficiency of the reasons for the belief cannot be investigated by\nthe Court (SheoNath Singh v. AAC, (1971) 82 ITR 147 (SC).\nIn the case of Mukesh Modi &Ors. vs. DCIT 366 ITR 418 (Raj) held that\nEvasion of tax was menace to society but Assesseecontributing to the exchequer\nin form of tax could not be allowed to suffer on mere pretence that it had evaded\npayment of tax. Rowing and fishing enquiry in hands of AO on mere suspicion or\nchange of opinion could not…

INSTITUTE MANAGEMENT COMMITTEE ITI JHALAWAR,JHALAWAR vs. ITO WARD JHALAWAR, JHALAWAR

The appeals of the assessee are hereby allowed

ITA 41/JPR/2025[2014-15]Status: DisposedITAT Jaipur05 May 2025AY 2014-15
For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 10Section 144Section 147Section 151Section 234

…oduct of imagination or speculation. There must be reason to\ninduce the belief. The Court can always examine this aspect though the\ndeclaration or sufficiency of the reasons for the belief cannot be investigated by\nthe Court (Sheo Nath Singh v. AAC, (1971) 82 ITR 147 (SC).\nIn the case of Mukesh Modi & Ors. vs. DCIT 366 ITR 418 (Raj) held that Evasion\nof tax was menace to society but Assessee contributing to the exchequer\nin form of tax could not be allowed to suffer on mere pretence that it had evaded\npayment of tax. Rowing and fishing enquiry in hands of AO on mere suspicion or\nchange of opinion could no…

INSTITUTE MANAGEMENT COMMITTEE ITI JHALAWAR ,JHALAWAR vs. ITO WARD JHALAWAR, JHALAWAR

The appeals of the assessee are hereby allowed

ITA 39/JPR/2025[2013-14]Status: DisposedITAT Jaipur05 May 2025AY 2013-14
For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 10Section 144Section 147Section 151Section 234

…oduct of imagination or speculation. There must be reason to\ninduce the belief. The Court can always examine this aspect though the\ndeclaration or sufficiency of the reasons for the belief cannot be investigated by\nthe Court (Sheo Nath Singh v. AAC, (1971) 82 ITR 147 (SC).\nIn the case of Mukesh Modi & Ors. vs. DCIT 366 ITR 418 (Raj) held that Evasion\nof tax was menace to society but Assessee contributing to the exchequer\nin form of tax could not be allowed to suffer on mere pretence that it had evaded\npayment of tax. Rowing and fishing enquiry in hands of AO on mere suspicion or\nchange of opinion could no…

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. M/S CHOLAMANDALAM INVESTMENT & FINANCE COMPANY LTD, CHENNAI

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

ITA 2836/CHNY/2024[2014-15]Status: DisposedITAT Chennai28 Apr 2025AY 2014-15

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

For Appellant: Mr. Ajith Kumar Jain CA & Mr. Kunal Shah, CAFor Respondent: Mr. R. Clement Ramesh Kumar, CIT &
Section 143(3)Section 250Section 43(5)

…Foramer - France [2003] 264 ITR 566 (SC) :-24-: ITA. Nos:2613,2732,2820, 2835&2836/Chny/2024 - The Hon’ble Supreme Court in the case of LakhmaniMewal Das (103 ITR 437) The Hon’ble Supreme Court in the case of Sheo Nath Singh - v. Appellate Asstt. CIT [1971] 82 ITR 147 • Lack of analysis during assessment cannot justify reassessment under Section 147: Where it was held that nothing new has come before the purview of the learned AO and order for reassessment is issued because of the lack of analysis at the time of assessment proceedings. In this connection the Ld.AR placed reliance on below judicial precedents T…

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