United Electrical Company Pvt. Ltd. v. CIT

236 ITR 832High Court1999#1065 most cited

What is United Electrical Company Pvt. Ltd. v. CIT authority for?

For initiating reassessment proceedings under Section 147 read with Section 148, the Assessing Officer must have reason to believe that income has escaped assessment. At the initiation stage, the formation of a reasonable belief is sufficient, not a conclusive finding of facts.

102

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2010 to 2025.

Also referred to as

United Electrical Company Pvt. Ltd. v. CIT · Section 147 · Section 148 · reason to believe · escapement of income · reassessment proceedings · formation of reasonable belief

Sections most often in play

Section 143(3)Section 147Section 148Section 131Section 142(1)Section 144BSection 14ASection 250

Issues it is cited on

full and true disclosuremere change of opinionkelvinatorchange of opinionprincipal officerlive linkincome escaping assessmentsection 144c(1)reason to believeescapement of incomeborrowed satisfactiontangible material

Judgments citing United Electrical Company Pvt. Ltd. v. CIT

The Commissioner of Income Tax vs. M.G. Motors

ITA/1355/2010HC Delhi13 Sept 2010

Bench: The Commissioner Of Income Tax (Appeals) [In Short, “Cit(A)”] Was Dismissed.

Section 139Section 142Section 143Section 143(3)Section 147Section 148Section 260ASection 263

…uld have been that he had reason to believe that any income chargeable to tax has escaped assessment. The CIT(A) has relied upon the decision of Hon’ble Gujarat High Court in the case of Prafful Chunni Lal Patel : Basant Chunni Lal Patel Vs. ACIT (1999) 236 ITR 832 (Guj.), which was rendered in the context of re-opening of the assessment within the period of four years from the end of the relevant assessment year, and the question about applicability of the proviso to section 147 was not a subject matter of consideration in that case. Thus, the decision of Hon’ble Gujarat High Court in the case of Pr…

CIT vs. Mg Motors

ITA - 1355 / 2010HC Delhi13 Sept 2010

Bench: The Commissioner Of Income Tax (Appeals) [In Short, “Cit(A)”] Was Dismissed.

Section 139Section 142Section 143Section 143(3)Section 147Section 148Section 260ASection 263

…uld have been that he had reason to believe that any income chargeable to tax has escaped assessment. The CIT(A) has relied upon the decision of Hon’ble Gujarat High Court in the case of Prafful Chunni Lal Patel : Basant Chunni Lal Patel Vs. ACIT (1999) 236 ITR 832 (Guj.), which was rendered in the context of re-opening of the assessment within the period of four years from the end of the relevant assessment year, and the question about applicability of the proviso to section 147 was not a subject matter of consideration in that case. Thus, the decision of Hon’ble Gujarat High Court in the case of Pr…