“reason to believe”

PBG INTERNATIONAL PRIVATE LIMITED,NEW DELHI vs. INCOME TAX OFFICER , DELHI, DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarpbg International Private Income Tax Officer, Limited, Ward-19(1), C.R. Building, Cb-4B, Dda Flats, Vs. Delhi-110002. Munirka, Delhi-110067. Pan-Aabcp8752E (Appellant) (Respondent) Assessee By Shri Anil Goyal, Ca Ms. Harpreet Kaur Hansra Sr. Dr Department By 20.01.2026 Date Of Hearing Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: This Appeal Filed By The Assessee Is Against Order Dated 29.04.2024 Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As 'The Ld. Cit(A)'] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As 'The Act'] Arising Out Of Assessment Order Dated 25.03.2022 Of The Ld. Assessing Officer U/S 147 R.W.S 144B Of The Act For Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Filed His Original Return Of Income On 14.10.2016 Declaring Total Income Of Rs.4,42,670/- Along With Computation Of Income, Auditors' Report & Audited Accounts Of The Assessee. Ld. Ao On Basis Of Incriminating & Tangible Information & After Following Due Process, Re-Opened Pbg International Pvt. Ltd. Vs. Ito

basis of Information available on the 'Insight portal of the department, without doing any independent enquiry at his end, and without forming his "reason to believe 6.2 The learned AO has passed order without providing the assessee copies of all the documents in his possession being report of DDIT