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“reassessment proceedings”

ReassessmentSections 147-151Sections 147-1518,150 judgments

The decision most relied on for reassessment proceedings is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on reassessment proceedings

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

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.

ITO v. Lakhmani Mewal Das
103 ITR 437 · 1976 · Supreme Court
721
citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

PCIT v. Meenakshi Overseas Pvt. Ltd.
395 ITR 677 · 2017 · High Court
471
citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Ranbaxy Laboratories Ltd. v. CIT
336 ITR 136 · 2011 · High Court
398
citing judgments

In reassessment proceedings under Section 147/148, the Assessing Officer can assess other income not specified in the original notice if the initial ground for reopening assessment is found to be valid. However, if the income for which the assessment was initially reopened is found not to have escaped assessment, the Assessing Officer cannot proceed to assess any other income.

Judgments citing reassessment proceedings

Sunil Hanamant Naikwad, Belgaum vs. Income Tax Officer, Ward - 2, Belagavi

The appeal is ALLOWED as above

ITA 220/PAN/2024[2012-13]Status: DisposedITAT Panaji22 Apr 2025AY 2012-13

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2012-13 Sunil Hanmantsa Naikwad 1156, Saraf Galli, Shahapur, Belgaum Pan:Abeph0397N . . . . . . . Appellant V/S Income Tax Officer, Ward-2, Belgaum. . . . . . . . Respondent

For Appellant: Mr JD Kalpavruksha [‘Ld. AR’]For Respondent: Mr Ravindra Hattalli [‘Ld. DR’]
Section 139Section 143(3)Section 147Section 250Section 4

survival of former independent addition made without there being any nexus on addition made on recorded reasons which solely triggered the invocation of reassessment proceedings? 8. This legal issue in view ‘CIT Vs Jet Airways (I) Ltd.’ (supra) pressed into service by the appellant is no more res-integra that

Shri Bharatbhai Raysinh Vala, Devali Deda, Kodinar, Dist. Junagadh vs. The ITO, Ward-3(1)(4), Amreli

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

ITA 603/RJT/2024[2018-19]Status: DisposedITAT Rajkot22 Apr 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Mehul Thakkar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 147Section 148A

file an income tax return for the A.Y. 2018-19. 4. That as a consequence of non-filing, the Assessing Officer (AO) initiated reassessment proceedings under Section 147 of the Income Tax Act. 1961. The various notices under section 142(1) were issued to pareshdodiyal177@gmail.com, which is an email ... necessary compliance requirements. 6. That in March 2024, my tax consultant checked my profile on the Income Tax e-filing portal and discovered that reassessment proceedings had been initiated and concluded against me. Upon further review, he informed me about the adverse order passed and advised me about my right

Champubhai Desabhai Vala, Amreli vs. The I.T.O., Ward 3(1)(4), Amreli

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

ITA 206/RJT/2024[2013-14]Status: DisposedITAT Rajkot22 Apr 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhahahaha /Ita No. 206 /Rit/ 2024

For Appellant: Ms. Devina Patel, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 115BSection 144Section 144rSection 147Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN

Iliyas, Khargone vs. Income Tax Officer, Delhi

Appeal of the assessee is allowed for statistical purpose

ITA 445/IND/2024[2013-2014]Status: DisposedITAT Indore22 Apr 2025AY 2013-2014

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshiiliyas, Nfac, बनाम/ 56, Khargone Road Bedia, Delhi Vs. Khargone

Section 05Section 07Section 142(1)Section 143(2)Section 144Section 147Section 148Section 24Section 250Section 253

आयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND

Gujarat Technological University, Ahmedabad, Gujarat vs. Commissioner of Income Tax, Exemption, Ahmedabad, Gujarat

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

ITA 935/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad22 Apr 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Amrin Pathan, A.RFor Respondent: Shri V. Nandakumar, CIT DR
Section 11Section 12ASection 147Section 148Section 263

issue of allowance of exemption u/s11 of the Act despite that fact that said issue was not subject matter of reassessment proceedings u/s 147 of the Act. 4. The learned CIT(E) erred in fact and in law in invoking revision power u/s 263 of the Act on an issue

R D Tea Limited, Kolkata vs. A.C.I.T., Circle - 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1555/KOL/2024[2012-2013]Status: DisposedITAT Kolkata22 Apr 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.1555/Kol/2024 Assessment Year: 2012-13 R D Tea Limited……………………..……………………………..………….……Appellant Dhandhania House, 2Nd Floor, 4, Middleton Street, Kolkata – 700071. [Pan: Aabcr3010M] Vs. Acit, Circle-4(1), Kolkata…..……....….….. ……………….........……...…..…..Respondent Appearances By: Shri A. K. Tibrewal, Ar, Appeared On Behalf Of The Appellant. Shri Rajat Datta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 28, 2025 Date Of Pronouncing The Order : April 22, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 14.06.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is Company Filed Its Original Return Of Income For The Assessment Year 2012-13 On 30.09.2012 By Declaring A Total Income Of Rs.67,34,990/-. The Case Of The Assessee Was Assessed U/S 143(3) Of The Act Vide Order Dated 19.03.2015 By Assessing Total Income Of Rs.86,23,780/- Which Was Subsequently Rectified U/S 154 Of The Act On 27.04.2015 By Assessing Total Income Of Rs.83,90,960/-. Thereafter, The Case Of The Assessee Was Reopened U/S 147 Of The Act By Issuing A Notice U/S 148 Of The Act On 27.03.2019 After Obtaining Approval From The Competent Authority. In Response To Such Notice, The Assessee Filed Its Return Of Income Again Declaring The Same Income As Earlier I.E. Rs.67,34,990/-. During The

Section 143(2)Section 143(3)Section 147Section 148Section 154Section 250Section 68

above order, the assessee is in appeal before this Tribunal raising various grounds. However, the primary contention of the ld. counsel is that the reassessment proceedings initiated u/s 148 are barred by limitation and the notice u/s 148 was issued beyond the four years from the end of the relevant

Highland Tardelink (P) Ltd., Kolkata vs. A.O, NFAC.Delhi., Delhi

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

ITA 1104/KOL/2023[2009-2010]Status: DisposedITAT Kolkata22 Apr 2025AY 2009-2010

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 147Section 148Section 151Section 263

instant case approval had been given by PCIT-1 Kol, though PCIT Kol-1,was not entitled to give approval as the reassessment proceedings were initiated within four years and it was the Joint Commissioner of Income Tax being the specified authority to grant approval. The Ld. Counsel submits that ... Court as well as Co-ordinate Bench of Kolkata, we find force in the argument of the Ld. Counsel of the assessee that entire reassessment proceedings is bad in law as approval had not been taken by the competent authority as a result of which the appeal of the assessee

Mr. Viren Rohitkumar Shah, Mumbai vs. ITO Ward 32(2)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 90/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Apr 2025AY 2016-17

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalmr. Viren Rohitkumar Shah, 02/009 Om Heera Pana Mall, Oshiwara, Andheri (W), Mumbai - 400102 ............... Appellant Pan : Aaqps2809B V/S

For Appellant: Shri Hitesh JainFor Respondent: Ms. Kavitha Kaushik, Sr.DR
Section 147Section 148Section 148ASection 151Section 234BSection 250Section 271(1)(c)Section 69

without the understanding the fact that amendment u/s 148 was made effective from 01/04/2023 whereas the reassessment proceedings were initiated during FY 2022-23 vide notice dated 31/07/2022. 2. On the facts and circumstances of the case and in law, the Ld. A.O. has erred by passing the order ... erred in taking approval from Pr. CIT-17 vide order sheet entry dated 31/07/2022 for initiation of the reassessment proceedings in mechanical manner without understanding the facts of the case that approval was required to be taken from Pr. CCIT u/s 151(ii) of the I.T. Act, 1961 as against

Income Tax Officer -1(1), Raipur vs. Suresh Kumar Jethwani, Raipur

The appeal of the revenue is partly allowed for statistical purposes

ITA 451/RPR/2024[2011-12]Status: DisposedITAT Raipur21 Apr 2025AY 2011-12

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.451/Rpr/2024 Co. No.18/Rpr/2024 "नधा"रण वष" / Assessment Year : 2011-12 The Income Tax Officer-1(1), Raipur (C.G.) ........अपीलाथ" / Appellant बनाम / V/S. Suresh Kumar Jethwani Prop. Reena Electronics, Oppo. Manju Mamta, M.G.Road, Raipur (C.G.)-492 001 Pan: Aebpj7686N ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 133(6)Section 143(2)Section 147Section 148Section 250(4)Section 69A

addition deleted on merits, Ld. CIT(A) erred in dismissing following grounds taken before him:- i) Assumption of jurisdiction by AO, initiation of reassessment proceedings and consequent reassessment order passed by the AO is illegal, invalid, void ab initio. There was no formation of 3 CO No.18/RPR/2024 belief of escapement ... There was no escapement within the meaning of sec. 147. ii) The A.O erred in violating principles of natural justice during the reassessment proceedings and in denying due and proper opportunity of hearing to the appellant. Violation of principles of natural justice has rendered the reassessment order illegal and unsustainable

International Customer Related Management Services Pvt Ltd, Chandigarh vs. Income Tax Officer, Ward-6(1), Mohali

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

ITA 557/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh21 Apr 2025AY 2012-13

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(2)Section 144Section 147Section 148Section 69C

deletion or amendment in the grounds of appeal on or before the disposal of the same. 3. In this case, the Ld. AO initiated reassessment proceedings by issuing notice u/s 148 of the Income Tax Act, 1961, alleging escapement of income. The assessee filed its return of income ... response to the notice, declaring a loss of Rs. 37,545/-. 4. During the reassessment proceedings, the Assessing Officer completed the assessment under Section 144 read with Section 147 of the Income Tax Act, as per the order dated 05.11.2019. The assessment primarily resulted in the following additions: an amount

ITO Ward 4(1), Kolkata vs. Tribute Trading and Finance Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 11/KOL/2025[2013-14]Status: DisposedITAT Kolkata21 Apr 2025AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 148

various beneficiaries – On basis of said investigation report, Assessing officer taking a view that loan transactions of assessee with ‘B’ were bogus, initiated reassessment proceedings – Whether since assumption of jurisdiction on part of Assessing Officer was based on fresh information, validity of impugned reassessment proceedings deserved to be upheld- Held

Navin Kumar Chaudhary, Delhi vs. ITO, Delhi

Appeal is allowed for statistical purposes

ITA 118/DEL/2025[2013-14]Status: DisposedITAT Delhi21 Apr 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara

For Appellant: NoneFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 143(3)Section 147Section 148Section 250(6)

section 143(3) which was completed on 08/03/2016 and no addition was made on this account in the original assessment order. Therefore, initiation of reassessment proceedings under section 147 is not valid and moreover approval given by the Pr. Commissioner of Income Tax-20 New Delhi is also not valid

Chandrakala Narala, Bengaluru vs. Income Tax Officer, Ward-5(3)(3), Bangalore

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 2575/BANG/2024[2016-17]Status: DisposedITAT Bangalore21 Apr 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2016-17

For Appellant: Shri. Pranit Tanna, CAFor Respondent: Smt. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 144Section 147Section 148Section 234BSection 249(4)(b)Section 250Section 271(1)(b)Section 282ASection 69A

income within 30 days from the receipt of the notice. However, there was no response from the assessee’s side. During the course of reassessment proceedings, various notices were issued to the assessee. But there was no compliance and the notices were delivered to the assessee’s registered email

Income Tax Officer -5(3)(1), Mumbai vs. M/S. Shree Sundha Steels Private Limited, Mumbai

In the result, the appeal filed by the revenue bearing ITA 1756/Mum/2025

ITA 1756/MUM/2025[2008]Status: HeardITAT Mumbai21 Apr 2025

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeincome-Tax Officer -5(3)(1), Vs M/S Shree Sundha Steels Private Mumbai, Limited, 5Th Room No.526, Floor, 15/16, D-Wing,Groundfloor, Gora Aayakar Bhawan, Mumbai-400 Gandhi Palace, 122, Khetwadi Back 020 Road, Khetwadi, Mumbai-400 004 Pan: Aaics1816M Appellant Respondent

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Asif Karmali (SR. DR.)
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 250

assessee during the relevant assessment year. The assessee is engaged in the business of trading in ferrous and non-ferrous metals. During the reassessment proceedings, the Assessing Officer determined the value of alleged bogus purchases at Rs.2,80,57,630/-. After deducting the VAT component of Rs.10

Innocent Infrastructure Private Limited, Mumbai vs. ITO Ward 12(2)(4), Mumbai

ITA 1236/MUM/2025[2014-15]Status: DisposedITAT Mumbai21 Apr 2025AY 2014-15

Bench: SHRI PAWAN SINGH (Judicial Member)

Section 143(3)Section 147Section 243(3)Section 250Section 254(1)

considering that the assumption of jurisdiction by the Ld. A.O. is bad in law as the conditions laid down under the Act for initiating reassessment proceeding u/s 147 of the Act have not been fulfilled. 2. On the facts and circumstances of the case and in law, the Ld. NFAC ... erred in not holding that the initiation of reassessment proceedings u/s 147 of the Act was bad in law as it was based on mere change of opinion because all relevant details relating to the impugned unsecured loan were available with the Ld. A.O. at the time of the original

M/S. Kishor D Naik (HUF), Mumbai vs. ACIT, Central Circle -2, Thane

In the result, the appeal of the assessee is accordingly allowed

ITA 5587/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Apr 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 132Section 139(1)Section 143(3)Section 153CSection 292C

misreporting of income by way misrepresentation and suppression of facts. (Addition - Rs.50,00,000/-) 4.1 On further appeal, the assessee challenged validity of the reassessment proceedings u/s 153C of the Act as well as additions sustained on merit, but, the Ld. CIT(A) rejected both the legal as well ... assessed person and not by the AO of the searched person and he ignored the above two contentions of the assessee and therefore, the reassessment proceedings u/s 153C read with section 153A of the Act being not in accordance with provisions of law are liable to be set-aside

DCIT, Circle 42(1)(1), Income Tax Department vs. Ghanshyam Rasiklal Shah, Mumbai

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

ITA 4707/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Apr 2025AY 2012-13

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeedcit, Circle 42(1)(1), Mumbai Vs Ghanshyam Rasiklal Shah Room 732, 7Th Floor, B-1408, Shankar Park, Agrawal Kautilya Bhavan, Bkc, Bandra Residency, Shankar Lane, Kandivali East, Mumbai-400 051 West, Mumbai-400 067 Pan: Aafps1306Q Appellant Respondent

For Appellant: Shri Subodh Ratnaparkhi - CAFor Respondent: Shri BhangepatilPushkaraj Ramesh
Section 132Section 143(3)Section 147Section 148Section 153CSection 250Section 69A

reasonable belief coupled with some material which suggest the escapement of income. Once the conditions precedent for assumption of jurisdiction to commence the reassessment proceedings, he has to cross the hurdles attached with reassessment by way reasons for 7 ITA No. 4707/Mum/2024 &CO- 208/Mum/2024 Ghanshyam Rashiklal Shah reopening of assessment ... heard the rival submission and perused the documents available on record. The legal issue is agitated before us whether the initiation of reassessment proceedings under Section 147 of the Act, is not legally sustainable in the present case. The foundation of the reopening rests entirely on documents seized during

ACIT-24(1), Mumbai vs. Dipti Sureshchandra Bajaj, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 3769/MUM/2024[2014]Status: DisposedITAT Mumbai21 Apr 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 10(38)Section 143(3)Section 147Section 148Section 14A

under:- “1. On the facts and circumstances of the case and in law, Ld. CIT(A) has erred in holding that the initiation of reassessment proceedings was based on vague and incorrect facts and therefore, the order is void ab-initio without appreciating the fact that the case was reopened ... sanction before issue of notice u/s 148 of the Act. He just revised the reasons while disposing objections of the appellant. This vitiates the reassessment proceedings. When initiation/start is wrong what follows is also wrong. Since initiation of reassessment proceedings was based on vague and incorrect facts, the Order

ACIT-24(1), Mumbai vs. Dipti Sureshchandra Bajaj, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 3767/MUM/2024[2015-16]Status: DisposedITAT Mumbai21 Apr 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 10(38)Section 143(3)Section 147Section 148Section 14A

under:- “1. On the facts and circumstances of the case and in law, Ld. CIT(A) has erred in holding that the initiation of reassessment proceedings was based on vague and incorrect facts and therefore, the order is void ab-initio without appreciating the fact that the case was reopened ... sanction before issue of notice u/s 148 of the Act. He just revised the reasons while disposing objections of the appellant. This vitiates the reassessment proceedings. When initiation/start is wrong what follows is also wrong. Since initiation of reassessment proceedings was based on vague and incorrect facts, the Order

Madhu Goyal, Raipur vs. Income Tax Officer, Ward-2(1), Raipur

In the result, appeal of the assessee is allowed

ITA 496/RPR/2024[2014-15]Status: HeardITAT Raipur17 Apr 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.496/Rpr/2024 "नधा"रण वष" /Assessment Year : 2014-15 Smt. Madhu Goyal D-36, Wallfort City, Bhatagaon, Raipur-492 001 (C.G) Pan: Aeypg1038E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-4(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Sakshi Gopal Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 10(38)Section 143(2)Section 143(3)Section 144BSection 148Section 68

contended by the Ld. Counsel that the A.O has not arrived at any satisfaction forming the “reasons to believe” for invoking the reassessment proceedings u/s.147/148 of the Act. The entire reasons recorded are based on wrong facts. 5. The Ld. Counsel in this regard appraised the bench that ... from M/s. Tilak Venture Ltd. and therefore, as per the contention of the Ld. Sr. DR, the “reasons to believe” are well founded for reassessment proceedings since there is escapement of income. 7. The Ld. Counsel for the assessee countering the afore-stated contention submitted that the return of income