Raghavan Nambath Menon, Bengaluru vs. ITO, Ward Intl. Taxation 1(2), Bmtc Building, Koramangala, Bengaluru
In the result, I pass the following:-
ITA 278/BANG/2025[2015-16]Status: DisposedITAT Bangalore06 Feb 2026AY 2015-16
Bench: Shri Prashant Maharishi & Shri Keshav Dubey
For Appellant: CA Suresh Muthukrishnan, A.RFor Respondent: Dr. Divya K.J., CIT D.R
Section 143(2)Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 68
…ce to be issued u/s 148 of the Act. By saying so, we take a guidance & support from the decision of Hon’ble Jurisdictional High Court of Karnataka in the case of Smt. Vasanthi Ramdas Pai, and Dr. Ramdas Madhava Pai v. The Income Tax Officer reported in (2024) 470 ITR 536. Thus, we are of the considered opinion that merely based on the reason to believe, the AO should not have proceeded to reopen the case of the assessee under section 147 of the Act unless the escapement has been established with concrete information. More particularly, for invoking the extended period, the AO must have in his possession books of…