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“reason to believe”

ReassessmentSection 147Section 1474,202 judgments

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

Leading authorities on reason to believe

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.

CIT v. Durga Prasad More
82 ITR 540 · 1971 · Supreme Court
1,579
citing judgments

Tax authorities must judge evidence using the test of human probabilities and consider the apparent as real until there are reasons to believe it is not. They can rely on circumstantial evidence and the preponderance of probabilities to determine the genuineness of transactions.

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.

CIT v. Jet Airways (I) Ltd.
331 ITR 236 · 2011 · High Court
694
citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

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.

CIT v. Kelvinator of India Ltd.
256 ITR 1 · 2002 · High Court
439
citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

Judgments citing reason to believe

Sky Blue Infotech Pvt Ltd, New Delhi vs. ITO Ward - 23(4), New Delhi

In the result, appeal of the assessee is partly allowed as

ITA 438/DEL/2020[2010-11]Status: DisposedITAT Delhi13 Dec 2024AY 2010-11

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.438/Del/2020 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Sky Blue Infotech Pvt. Ltd. Income Tax Officer 206, Hans Bhawan, 1, Vs. Ward-23(4), Bahadurshah Zafar Marg, Room No.246, C.R. Bldg., New Delhi. I.P. Estate, New Delhi. Pan No. Aalcs1584K अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 151Section 271(1)(c)Section 68Section 69C

actually assessee's own money (cash) which was rotated through such channel. This cash was out of his unaccounted income. I have reasons to believe that an amount of Rs.1.93 crores has escaped from the Assessment for the A.Y. 2009-10 which was chargeable to tax. I am also satisfied ... entry operators as mentioned in the chart above and same was not offered for taxation. Having perused and considered the information, I have reason to believe that income of the assessment company to the extent of Rs.193 Lakh has escaped assessment for the Assessment Year 2009-10. Therefore, proceedings under

Prashant, Kanpur vs. ITO Ward 1(1)(3), Kanpur

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

ITA 514/LKW/2024[2012-13]Status: DisposedITAT Lucknow12 Dec 2024AY 2012-13

Bench: Shri Anadee Nath Misshraprashant, V. The Income Tax Officer, Ward-1(1)(3) 2-B, Wazidpur, Jajmau, Kanpur-208010. Aaykar Bhawan, 16/69, Civil Lines, Kanpur- 208001. Pan:Admpk9965F (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Adv Respondent By: Shri Sunil Kumar Rajwanshi, Addl. Cit(Dr) Date Of Hearing: 10 12 2024 O R D E R

For Appellant: Shri Ashish Jaiswal, AdvFor Respondent: Shri Sunil Kumar Rajwanshi, Addl
Section 147Section 148Section 149Section 151Section 250Section 254(3)Section 50C

under: - “1. That the Id.AO has erred in reopening the assessment u/s 147 of the Income Tax Act, 1961 without forming reason to believe as to escapement of income from tax u/s 149 of the Income Tax Act, 1961. 2. That the Ld. AO has erred in completing reassessment without

Dayal Cotspin Limited, Akola vs. ACIT, Akola Circle, Akola

In the result, appeal filed by the assessee is allowed

ITA 87/NAG/2024[2012-13]Status: DisposedITAT Nagpur12 Dec 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Abhay Y. Marathe
Section 132(1)Section 142(1)Section 143Section 143(3)Section 147Section 148Section 154Section 234ASection 68

provided. In view of above credible information revealed in search & seizure action u/s 132 in the case of Mr. Shirish Shah, I have reason to believe that M/s Dayal Cotspins Ltd. has taken bogus accommodation entries regarding investment in shares and thus the income to the extent of Rs.1

Vikram Agrawal, Nagpur vs. ITO Ward 4(4), Nagpur

In the result, appeal is dismissed

ITA 321/NAG/2023[2017 18]Status: DisposedITAT Nagpur12 Dec 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 147Section 148

relevant material on the basis of which a reasonable person could have formed a belief that income had escaped assessment. Thus, there was reason to believe that income of the appellant company had escaped assessment on account of failure on the part of the appellant to disclose fully and truly ... taxmann.com 185 (Gujarat), it was held that what is required at stage of issuing notice under section 148 is a reason to believe and not established fact of escapement of income and, therefore, looking to the scope of section 147 as also sections 148 to 152 even if scrutiny assessment

Vikram Agrawal, Nagpur vs. ITO Ward 4 (4), Nagpur

In the result, appeal is dismissed

ITA 320/NAG/2023[2016 17]Status: DisposedITAT Nagpur12 Dec 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 147Section 148

relevant material on the basis of which a reasonable person could have formed a belief that income had escaped assessment. Thus, there was reason to believe that income of the appellant company had escaped assessment on account of failure on the part of the appellant to disclose fully and truly ... taxmann.com 185 (Gujarat), it was held that what is required at stage of issuing notice under section 148 is a reason to believe and not established fact of escapement of income and, therefore, looking to the scope of section 147 as also sections 148 to 152 even if scrutiny assessment

Vikram Agrawal, Nagpur vs. ITO Ward 4(4), Nagpur

In the result, appeal is dismissed

ITA 319/NAG/2023[2015 16]Status: DisposedITAT Nagpur12 Dec 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 147Section 148

relevant material on the basis of which a reasonable person could have formed a belief that income had escaped assessment. Thus, there was reason to believe that income of the appellant company had escaped assessment on account of failure on the part of the appellant to disclose fully and truly ... taxmann.com 185 (Gujarat), it was held that what is required at stage of issuing notice under section 148 is a reason to believe and not established fact of escapement of income and, therefore, looking to the scope of section 147 as also sections 148 to 152 even if scrutiny assessment

Gaurika Multitrade Private Limited, Mumbai vs. PCIT, Mumbai-8, Mumbai

In the result, appeal of the assessee is allowed

ITA 1977/MUM/2024[2017-18]Status: DisposedITAT Mumbai12 Dec 2024AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member)

Section 133(6)Section 133ASection 144Section 147Section 148Section 2(23)Section 263

Despite such information having made available, notice u/s.148 was issued to the assessee and the case was reopened u/s.147 that there was a reason to believe that income of Rs.2,22,94,944/- chargeable to tax has escaped assessment. During the course of assessment proceedings u/s 147/143

Ebrahim Essa Developers Private Limited, Mumbai vs. ITO-9(2)(4), Mumbai

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

ITA 1188/MUM/2024[2012-13]Status: DisposedITAT Mumbai11 Dec 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13 Ebrahim Essa Developers Pvt. Ltd., Ito-9(2)(4), 115 Dathawala Wstate, Sv Road, Aayakar Bhavan, Vs. Jogeshwari West, 400 102. Mumbai-400020. Pan No. Aacce 4720 E Appellant Respondent

For Appellant: Mr. Hemanshu Joshi, DRFor Respondent: Mr. Prateek Jain
Section 147Section 148Section 68

M/.s Santoshima Tradelink bills through 347 companies including M/.s Santosh bills through 347 companies including M/.s Santosh Ltd. Accordingly, the Assessing Officer recorded reasons to believe Ltd. Accordingly, the Assessing Officer recorded reasons to believe Ltd. Accordingly, the Assessing Officer recorded reasons to believe that income escaped assessment and issued ... information from the investigation wing and the AO has applied his mind on such information and formed a reason to believe applied his mind on such information and formed a reason to believe applied his mind on such information and formed a reason to believe that income has escaped assessment

Amrrut Shavjjibhai Gada, Mumbai vs. Dycit, Circle-13(2)(1), Mumbai

In the result, both the appeals are partly allowed for statistical purposes

ITA 3825/MUM/2023[2011-12]Status: DisposedITAT Mumbai11 Dec 2024AY 2011-12

Bench: Anikesh Banerjee, Hon’Ble

For Appellant: Dr. Prayag Jha & Shri Prateek Jha, A/RsFor Respondent: Dr. K.R. Subhash, CIT, D/R & Shri Ram Krishn Kedia, Sr
Section 132(4)Section 142(1)Section 144Section 147Section 148Section 68

that the Ld AO had reopened the assessment for A Y 2011-12 under section 147 after expiry of four years without having reason to believe that income chargeable to tax had escaped assessment and the impugned Assessment Order was bad in law. 2. The Ld CIT(A), NFAC, erred ... reopening of the assessment was strongly challenged before the ld. CIT(A) contending that the AO had no reason to believe that income chargeable to tax in the hands of the assessee in AY 2011-12, had escaped assessment and the AO had no concrete material or documents

Amrrut Shavjjibhai Gada, Mumbai vs. Dycit, Circle-13(2)(1), Mumbai

In the result, both the appeals are partly allowed for statistical purposes

ITA 3824/MUM/2023[2013-14]Status: DisposedITAT Mumbai11 Dec 2024AY 2013-14

Bench: Anikesh Banerjee, Hon’Ble

For Appellant: Dr. Prayag Jha & Shri Prateek Jha, A/RsFor Respondent: Dr. K.R. Subhash, CIT, D/R & Shri Ram Krishn Kedia, Sr
Section 132(4)Section 142(1)Section 144Section 147Section 148Section 68

that the Ld AO had reopened the assessment for A Y 2011-12 under section 147 after expiry of four years without having reason to believe that income chargeable to tax had escaped assessment and the impugned Assessment Order was bad in law. 2. The Ld CIT(A), NFAC, erred ... reopening of the assessment was strongly challenged before the ld. CIT(A) contending that the AO had no reason to believe that income chargeable to tax in the hands of the assessee in AY 2011-12, had escaped assessment and the AO had no concrete material or documents

Income Tax Officer, Ward 7(2)(1), Mumbai vs. Magnetic Properties Exim Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 2617/MUM/2023[2011-12]Status: DisposedITAT Mumbai11 Dec 2024AY 2011-12

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaranassessment Year : 2011-12 Income Tax Officer, Magnetic Properties Exim Pvt. Ward-7(2)(1), Ltd., Room No. 126-H, Vs. 477, Babyloan Building, Aayakar Bhavan, Adenwala Road, Maharshi Karve Road, Matunga, Mumbai. Mumbai. Pan : Aagcm8999K (Appellant) (Respondent) For Assessee : Shri Neelkanth Khandelwal For Revenue : Shri R.R. Makwana, Sr.Dr Date Of Hearing : 05-12-2024 Date Of Pronouncement : 11-12-2024 O R D E R Per B.R. Baskaran, A.M :

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri R.R. Makwana, Sr.DR
Section 147Section 148Section 68

Duke Business Pvt Ltd. AABCJ6245N 1,05,00,000 (JKP Trading) TOTAL 2,05,00,000 In view of the above, I have reason to believe that an amount of Rs. 2,05,00,000/- chargeable to tax has escaped assessment for A.Y. 2011-12, by reason of the failure ... stands and without adding (sic) deducting from the words used by Parliament, it is clear that upon (sic) formation of a reason to believe u/s 147 and following the issuance of a notice u/s 148, the Assessing Officer has the power assess or reassess the income which he has reason

Purushottamlal Singhania, Kolkata vs. ITO, Ward 36(5), Kolkata

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

ITA 731/KOL/2024[2012-13]Status: DisposedITAT Kolkata10 Dec 2024AY 2012-13

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 147Section 148

challenged the very reopening of the instant case by issuing notice u/s 148 of the Act as according to him, there was no reason to believe that income had escaped assessment. The ld. Counsel submits that before initiating the re-assessment proceedings, the ld. AO did not apply his independent ... case of Ganga Saran & Sons (P.) Ltd. (supra) has held as under: “The important words under Section 147(a) are ‘has reason to believe’ and these words are stronger than the words ‘is satisfied’. The belief entertained by the Income Tax Officer must not be arbitrary or irrational. It must

Indus Towers Limited (Formerly Known As Bharti Infratel Ltd and As Successor in Interest of Erstwhile Indus Tower Ltd), Gurugram, Haryana vs. DCIT, Circle 12(1), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 2762/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

block of assets of the assessee at Nil consideration and without payment of due taxes. In view of this there is reason to believe that the colourable device created through a scheme of De-merger and Amalgamation is only for tax evasion and no taxes on these transactions have been ... were transferred at book value at Rs. 1622,77,60,000/-through a scheme of De-merger and subsequent Amalgamation. Therefore, I have reason to believe that the difference of Rs. 5707,97,96,000/- (Rs.7330,75,56,000 -Rs.1622,77,60,000) is the value of benefit received

ACIT, Circle 10, New Delhi vs. Indus Tower Limited, Gurgaon

In the result, the appeal of the revenue is dismissed

ITA 2212/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

block of assets of the assessee at Nil consideration and without payment of due taxes. In view of this there is reason to believe that the colourable device created through a scheme of De-merger and Amalgamation is only for tax evasion and no taxes on these transactions have been ... were transferred at book value at Rs. 1622,77,60,000/-through a scheme of De-merger and subsequent Amalgamation. Therefore, I have reason to believe that the difference of Rs. 5707,97,96,000/- (Rs.7330,75,56,000 -Rs.1622,77,60,000) is the value of benefit received

Indus Towers Ltd., Gurgaon vs. DCIT Circle 12(1), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 1962/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

block of assets of the assessee at Nil consideration and without payment of due taxes. In view of this there is reason to believe that the colourable device created through a scheme of De-merger and Amalgamation is only for tax evasion and no taxes on these transactions have been ... were transferred at book value at Rs. 1622,77,60,000/-through a scheme of De-merger and subsequent Amalgamation. Therefore, I have reason to believe that the difference of Rs. 5707,97,96,000/- (Rs.7330,75,56,000 -Rs.1622,77,60,000) is the value of benefit received

Ashok Kumar Gupta, Delhi vs. ITO Ward 56(4), Delhi

In the result, the appeal of the assessee is allowed

ITA 3657/DEL/2019[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshashok Kumar Gupta, Vs. Ito, B-3, West Gorkh Park, Ward-56(4), Shahadra, Delhi New Delhi (Appellant) (Respondent) Pan: Agjpg4741M

For Appellant: Shri Prince Mohan Singh, AdvFor Respondent: Shri Poojan Rana, Sr. DR
Section 143(3)Section 147

making bogus purchases from non existed entity. In view of the above facts and observation, I have reason to believe that income of Rs. 7,88,910/- the assessee for A.Y. 2010-11 has escaped assessment because of the reason on the part of the assessee for not providing

Girjan Co-Op Marketing Society Limited, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, four appeals filed by the assessee are allowed for statistical purposes as indicated hereinabove

ITA 274/VIZ/2024[2016-17S]Status: DisposedITAT Visakhapatnam09 Dec 2024

Bench: Shri K.Narasimha Chary & Shri S. Balakrishnan

For Appellant: Shri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 10Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 154Section 271(1)(c)

return of income for the AY 2016-17. During the assessment proceedings, learned Assessing Officer (“learned AO”) observed that there was a reason to believe that income chargeable to tax has escaped assessment. Therefore, after recording the reasons and obtaining the approval from the competent authority, the learned AO reopened

Girjan Co-Op Marketing Society Limited, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, four appeals filed by the assessee are allowed for statistical purposes as indicated hereinabove

ITA 273/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam09 Dec 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri S. Balakrishnan

For Appellant: Shri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 10Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 154Section 271(1)(c)

return of income for the AY 2016-17. During the assessment proceedings, learned Assessing Officer (“learned AO”) observed that there was a reason to believe that income chargeable to tax has escaped assessment. Therefore, after recording the reasons and obtaining the approval from the competent authority, the learned AO reopened

Girijan Co-Op Marketing Society Limited, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, four appeals filed by the assessee are allowed for statistical purposes as indicated hereinabove

ITA 272/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam09 Dec 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri S. Balakrishnan

For Appellant: Shri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 10Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 154Section 271(1)(c)

return of income for the AY 2016-17. During the assessment proceedings, learned Assessing Officer (“learned AO”) observed that there was a reason to believe that income chargeable to tax has escaped assessment. Therefore, after recording the reasons and obtaining the approval from the competent authority, the learned AO reopened

Girijan Co-Op Markrting Society Limited, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, four appeals filed by the assessee are allowed for statistical purposes as indicated hereinabove

ITA 271/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam09 Dec 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri S. Balakrishnan

For Appellant: Shri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 10Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 154Section 271(1)(c)

return of income for the AY 2016-17. During the assessment proceedings, learned Assessing Officer (“learned AO”) observed that there was a reason to believe that income chargeable to tax has escaped assessment. Therefore, after recording the reasons and obtaining the approval from the competent authority, the learned AO reopened