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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

M/S Union Bank of India, Mumbai vs. Deputy Commissioner of India, Circle-(Ltu)-2, Mumbai

In the result, the appeal of the a In the result, the appeal of the assessee for assessment year ssessee for assessment year

ITA 1676/MUM/2024[2017-18]Status: DisposedITAT Mumbai11 Jul 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Respondent: Mr. C Naresh
Section 144B

assessment was reopened by way of issue of notice u/s 148 of the Act after recording reasons t Act after recording reasons to believe that income escaped o believe that income escaped assessment. Thereafter, statutory notices were issued and after assessment. Thereafter, statutory notices were issue assessment. Thereafter, statutory notices ... Assessing Officer. The Assessing Officer has reopened the assessment as he has reason t reopened the assessment as he has reason to believe that income o believe that income M/s Union Bank of India M/s Union Bank of India ITA Nos. 1677 & 1676/MUM/2024 1959/MUM/2024 chargeable to tax has escaped assessment

M/S Innovtive Microfinance for Poverty Alleviation, Chennai vs. DCIT(Exemptions), Chennai Circle, Chennai

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

ITA 164/CHNY/2024[2013-14]Status: DisposedITAT Chennai10 Jul 2024AY 2013-14

Bench: Shri Mahavir Singhand Shri Jagadish

For Appellant: Shri M.V. Swaroop, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 11Section 12ASection 13(8)Section 143(3)Section 2(15)

previous years and therefore the, Hon'ble ITAT rightly upheld the charitable character of the assessee as there was no reason to believe that the assessee was benefiting at the cost of the beneficiaries and there was profit intent. Again, the fact and circumstances of this case do not provide

DCIT Central Circle 2(1), Chennai vs. M/S. Kag India Pvt. Ltd, Chennai

The appeal stand dismissed

ITA 669/CHNY/2023[2012-13]Status: DisposedITAT Chennai10 Jul 2024AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपीलसं./ Ita No.669/Chny/2023 (िनधा9रणवष9 / Assessment Year: 2012-13) Dcit M/S. Kag India Private Limited बनाम/ Central Circle-2(1), 264/15-1, Sathiyanathan Complex, Chennai. Velachery Road,East Tambaram, Vs. Chennai-600 059. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aadck-5381-Q (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Y. Sridhar (Fca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-06-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-07-2024 आदेश / O R D E R

For Appellant: Shri Y. Sridhar (FCA)- Ld.ARFor Respondent: Shri Nilay Baran Som (CIT)-Ld. DR
Section 143(3)Section 153ASection 153A(1)Section 68

view of the above, l have reason to believe that the entire amount introduced into M/s. KAG India Pvt Ltd through shell companies as share capital and share premium are out of undisclosed income earned, including unaccounted sales in cash, which represent the undisclosed asset. This undisclosed asset has been

Nikki Pachisia, Jaipur vs. Income Tax Officer, Ward-5(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 615/JPR/2024[2011-12]Status: DisposedITAT Jaipur10 Jul 2024AY 2011-12

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri S.R. Sharma CA, &For Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 143Section 143(3)Section 147Section 148Section 68Section 69C

mind by the AO to tangible materials and reasons and the AO failed to demonstrate Live link between tangible material and formation of reason to believe that Income had escape assessment. On this preposition I find that the similar issue had also been addressed by the Hon'ble High Courts ... mind by the AO to tangible materials and reasons and the AO failed to demonstrate live link between tangible material and formation of reason to believe that income had escaped assessment. 15. In view of the above, we hold that the reassessment made in the section 143(3) read with

M/S. Steer America Inc., United States vs. The Deputy Commissioner of Income Tax, International Taxation Circle -1(2), Bengaluru

In the result, both the appeals of the assessee are partly allowed

ITA 833/BANG/2024[2014-15]Status: DisposedITAT Bangalore10 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri Vasanth Kumar, A.RFor Respondent: Ms. Anjala Sahu, D.R
Section 144CSection 147Section 148

liable to be quashed. 2. Issuing notice under section 148 and passing the assessment order in the absence of 'reason to believe' as contemplated u/s 147. The notice u/s 148 issued and order so passed on mere suspicion, conjecture or surmise without any 'reason to believe' that income has escaped ... there being no 'live link' between the material relied on and the formation of belief that income has escaped assessment, the requirements of 'reason to believe' are not satisfied and consequently the' assessment order passed is bad in law and liable to be quashed. 4. The lower authorities have erred

M/S. Steer America Inc., United States vs. The Deputy Commissioner of Income Tax, International Taxation Circle -1(2), Bengaluru

In the result, both the appeals of the assessee are partly allowed

ITA 832/BANG/2024[2013-14]Status: DisposedITAT Bangalore10 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri Vasanth Kumar, A.RFor Respondent: Ms. Anjala Sahu, D.R
Section 144CSection 147Section 148

liable to be quashed. 2. Issuing notice under section 148 and passing the assessment order in the absence of 'reason to believe' as contemplated u/s 147. The notice u/s 148 issued and order so passed on mere suspicion, conjecture or surmise without any 'reason to believe' that income has escaped ... there being no 'live link' between the material relied on and the formation of belief that income has escaped assessment, the requirements of 'reason to believe' are not satisfied and consequently the' assessment order passed is bad in law and liable to be quashed. 4. The lower authorities have erred

Shri Robert Paul Raj, Mumbai vs. ITO 42(3)(1), Mumbai

In the result, appeal filed by the Assessee stands allowed for statistical purposes

ITA 509/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Jul 2024AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2018-19

For Appellant: Shri Harshal Ajmera, A.RFor Respondent: Smt Mahita Nair, Sr. D.R
Section 143(3)Section 250Section 270ASection 274Section 56(2)(vii)

determined at Rs.25,11,980/- and penalty proceedings under section 270A read with section 274 of the Act were initiated on the reason to believe that the violation/omission on the basis of which additions were made tantamount to under reporting of income in consequence of misreporting whereof within the meaning

Antony Leo Sequeira, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle-2(1), Mumbai

In the result, Grounds taken by the assessee are dismissed

ITA 2010/MUM/2023[2014-2015]Status: DisposedITAT Mumbai10 Jul 2024AY 2014-2015

Bench: Shri Anikesh Banerjee & Shri Gagan Goyal

For Appellant: Shri K. Gopal & Shri Om Kandalkar , Ld. ARFor Respondent: Shri Ajay Chandra & Shri Manoj Kumar
Section 132Section 148Section 250Section 68

tangible material available on record to suggest that income chargeable to tax has escaped assessment. Therefore, in the absence of any reason to believe' that income chargeable to tax has escaped assessment, the order passed by the Ld. CIT (A) is unlawful, bad in law and the same

Shubhradeep Nigam, Ghaziabad vs. ITO Ward 2 (2)(3), New Delhi

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 3735/DEL/2023[2012-13]Status: DisposedITAT Delhi10 Jul 2024AY 2012-13

Bench: Shri G.S. Pannu & Shri Vimal Kumarita Nos. 3734 & 3735/Del/2023 Asstt. Year : 2012-13 Sh. Shubhradeep Nigam, Vs. Ito, Ward-2(2)(3), 1206, Gaur Global Village, Ghaziabad Crossing Republik U.P. 201 002 Chipiyana, Ghaziabad U.P. – 201 106 (Pan: Acbpn9476A) (Appellant) (Respondent) Appellant By : Shri Vineet Garg, Ca. Respondent By : Shri Ram Dhan Meena, Sr. Dr Date Of Hearing 20.06.2024 Date Of Pronouncement 10.07.2024

For Appellant: Shri Vineet Garg, CAFor Respondent: Shri Ram Dhan Meena, Sr. DR
Section 144Section 147Section 250

because the reassessment has been made merely on the basis of some information. There is no cogent material for forming reason to believe and to make an assessment u/s. 147. 4. That the ld. CIT(A) has erred on facts and in law in upholding the reassessment made

Shubhradeep Nigam, Ghaziabad vs. ITO Ward 2(2)(3), Ghaziabad

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 3734/DEL/2023[2012-13]Status: DisposedITAT Delhi10 Jul 2024AY 2012-13

Bench: Shri G.S. Pannu & Shri Vimal Kumarita Nos. 3734 & 3735/Del/2023 Asstt. Year : 2012-13 Sh. Shubhradeep Nigam, Vs. Ito, Ward-2(2)(3), 1206, Gaur Global Village, Ghaziabad Crossing Republik U.P. 201 002 Chipiyana, Ghaziabad U.P. – 201 106 (Pan: Acbpn9476A) (Appellant) (Respondent) Appellant By : Shri Vineet Garg, Ca. Respondent By : Shri Ram Dhan Meena, Sr. Dr Date Of Hearing 20.06.2024 Date Of Pronouncement 10.07.2024

For Appellant: Shri Vineet Garg, CAFor Respondent: Shri Ram Dhan Meena, Sr. DR
Section 144Section 147Section 250

because the reassessment has been made merely on the basis of some information. There is no cogent material for forming reason to believe and to make an assessment u/s. 147. 4. That the ld. CIT(A) has erred on facts and in law in upholding the reassessment made

Shish Pali, Noida vs. ITO Ward 3(4), Noida

In the result, appeal is allowed for statistical purposes

ITA 3400/DEL/2019[2009-10]Status: DisposedITAT Delhi10 Jul 2024AY 2009-10

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

Section 133(6)Section 144Section 147Section 148Section 249(4)(b)Section 271(1)(c)

section 133(6) of the Act to the assessee seeking information relating to aforesaid transactions. However, the assessee did not comply. Therefore, having reason to believe 2 | P a g e ITA No.3399 & 3400/Del/2019 AY: 2009-10 that the income chargeable to tax has escaped assessment, the Assessing Officer reopened

Shish Pali, Noida vs. ITO Ward 3(4), Noida

In the result, appeal is allowed for statistical purposes

ITA 3399/DEL/2019[2009-10]Status: DisposedITAT Delhi10 Jul 2024AY 2009-10

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

Section 133(6)Section 144Section 147Section 148Section 249(4)(b)Section 271(1)(c)

section 133(6) of the Act to the assessee seeking information relating to aforesaid transactions. However, the assessee did not comply. Therefore, having reason to believe 2 | P a g e ITA No.3399 & 3400/Del/2019 AY: 2009-10 that the income chargeable to tax has escaped assessment, the Assessing Officer reopened

Laxman Gore Shreshtha, Mumbai vs. Dy Commissioner of Income Tax, Circle-22(1), Mumbai

In the result, both the appeals of the assessee bearing ITA Nos

ITA 1909/MUM/2024[2013-14]Status: DisposedITAT Mumbai09 Jul 2024AY 2013-14

Bench: Shri Prashant Maharishi & Shri Anikesh Banerjee

For Appellant: Shri J.P. Bairagra& Ms. Rupa NandaFor Respondent: ShriManoj Kumar Sinha (SR.DR.)
Section 10Section 143(3)Section 147Section 151Section 250Section 57Section 80C

taxation u/s. 80CCC(2) of the IT Act, 1961m the FY 2011-12 relevant to AY 2012-13. 4. I have, thus, reason to believe that, in this case, for the AY 2012-13, the assessee has escaped income to the extent of Rs.3,03,01,478/- within the meaning

Laxman Gore Shreshtha, Mumbai vs. Deputy Commissioner of Income Tax, Circle 22(1), Mumbai

In the result, both the appeals of the assessee bearing ITA Nos

ITA 1908/MUM/2024[2012-13]Status: DisposedITAT Mumbai09 Jul 2024AY 2012-13

Bench: Shri Prashant Maharishi & Shri Anikesh Banerjee

For Appellant: Shri J.P. Bairagra& Ms. Rupa NandaFor Respondent: ShriManoj Kumar Sinha (SR.DR.)
Section 10Section 143(3)Section 147Section 151Section 250Section 57Section 80C

taxation u/s. 80CCC(2) of the IT Act, 1961m the FY 2011-12 relevant to AY 2012-13. 4. I have, thus, reason to believe that, in this case, for the AY 2012-13, the assessee has escaped income to the extent of Rs.3,03,01,478/- within the meaning

Alcoa Trading Pvt Ltd, Mumbai vs. Pr. Commissioner of Income Tax-2, Mumbai

In the result, appeal of the assessee is allowed

ITA 1225/MUM/2024[2014-15]Status: DisposedITAT Mumbai09 Jul 2024AY 2014-15

Bench: Shri Amarjit Singh & Shri Rahul Chaudharyassessment Year: 2014-15 Alcoa Trading Pvt. Ltd. Ito, Ward-2(1)(1), Mumbai Monaji Building, 3Rd Floor, Room No. 54, Champa Gali, Vs. M.J. Market, Kalbadevi Road, Mumbai-400002. Pan: Aaica 3535 D (Appellant) (Respondent) Present For: Assessee By : Shri Prakash Jhunjhunwala Revenue By : Shri Ajay Chandra, Cit/Dr

For Appellant: Shri Prakash JhunjhunwalaFor Respondent: Shri Ajay Chandra, CIT/DR
Section 147Section 148Section 263

Delhi High Court held that if assessing officer did not bring to tax the amount on the basis of which reason to believe was framed then the PCIT could not have triggered proceedings u/s 263 of the Act. 8.3. The ITAT Mumbai Bench ‘A’ in the case of Aishwarya ... recorded reasons on the basis of which reassessment was initiated but did not make any additions in reassessment proceedings, in such case primary reason to believe that income had escaped assessment would fail and reassessment could not be treated as valid order and said invalid order could not be subject

Alosha Marketing Pvt. Ltd., Kolkata vs. ACIT, Cir. 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 356/KOL/2024[2011-12]Status: DisposedITAT Kolkata08 Jul 2024AY 2011-12

Bench: Dr. Manish Borad (Accountant Member)

Section 143(1)(a)Section 143(2)Section 147Section 148

learnt to have booked STCL of Rs 3531930/- from the same scrip in the same year. In view of this, I have reason to believe that an income of Rs.4079679/- chargeable to tax has escaped assessment within the meaning of sec 147. 5. In reply, the assessee filed objection against ... learnt to have booked STCL of Rs 3531930/- from the same scrip in the same year. In view of this, I have reason to believe that an income of Rs.4079679/- chargeable to tax has escaped assessment within the meaning of sec 147. 9. Perusal of the reasons reveals that

Alosha Marketing Pvt. Ltd., Kolkata vs. ACIT, Cir. 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 313/KOL/2024[2013-14]Status: DisposedITAT Kolkata08 Jul 2024AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. No. 313/Kol/2024 Assessment Year: 2013-2014 Alosha Marketing Pvt. Ltd.,……………..………Appellant 62A, Hazra Road, Kolkata-700019 [Pan:Aacca1930G] -Vs.- Assistant Commissioner Of Income Tax,.…Respondent Circle-4(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri N.S. Saini, A.R. & Priyanka Salarpuria, A.R., Appeared On Behalf Of The Assessee Shri Manas Mondal, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : April 30, 2024 Date Of Pronouncing The Order : July 08, 2024 O R D E R

Section 143(2)Section 147Section 148Section 68

Honourable Supreme Court has observed:- "It is true that an apparent must be considered to be real until it is shown there are reasons to believe that the apparent is not the real. In a case of the present kind a party who relies on a recital in a deed ... been passed on for verification in respect of source of fund or genuineness of the transaction and further necessary action. So, I have reason to believe with the materials on record that Rs.1,65,00,000/- has escaped assessment within the meaning of section

M/S. Shanker Logistices (P) Ltd., Kolkata vs. DCIT, Cir-7(1), Kolkata

The appeal of the assessee stands allowed

ITA 829/KOL/2023[2012-13]Status: DisposedITAT Kolkata08 Jul 2024AY 2012-13

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.829/Kol/2023 Assessment Year: 2012-13 M/S Shankar Logistics (P) Ltd.….…….…............…...……………....Appellant 207, Maharshi Divendra Road, West Bengal-700007. [Pan: Aajcs8693P] Vs. Dcit, Circle-7(1), Kolkata….....…........................................…..…..... Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : April 10, 2024 Date Of Pronouncing The Order : July 08, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 23.06.2023 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. The Assessee In This Appeal Has Agitated Against The Confirmation Of Addition Of Rs.85,98,795/- By The Ld. Cit(A) As Made By The Assessing Officer Treating The Unsecured Loans Taken By The Assessee As Bogus & Thereby Making The Addition Of The Aforesaid Amount As Unexplained Income Of The Assessee. The Assessee Apart From Challenging The Additions On Merits Has Also Contested The Validity Of The Reopening Of The Assessment.

Section 143(3)Section 147Section 148Section 250

commission basis by their directors. In the third page, the Assessing Officer has mentioned the analysis of information vis-à-vis, the reasons to believe that the assessee has received an accommodation entry of Rs.20,00,000/- and that he has reasons to believe that the income of the assessee ... back in the books without paying any tax by taking bogus purchases or payment entries from these shell companies. 4. Basis of Forming reason to believe and details of escapement of income: There is specific information that the aforementioned companies are shell companies which provide accommodation entries to the various

Pukhraj Bhomaji Mutha, Mumbai vs. ITO-19(2)(5), Mumbai

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

ITA 2150/MUM/2024[2012-13]Status: DisposedITAT Mumbai08 Jul 2024AY 2012-13

Bench: Shri Pavan Kumar Gadale & Shri Omkareshwar Chidaravs. Ito -19(2)(5), Pukhraj Bhomaji Mutha, Piramal Chambers, 1605, Siddesh Darshan, Lalbaug, 10Th Khetwadi, Mumbai-400012. Mumbai – 400004. Pan/Gir No. Aacpm4077H (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 144Section 148

assessee has not disclosed the capital gains in the return of income filed.. Therefore the AO reason to believe that the assessment has escaped assessment and issued notice u/sec 148 of the Act. 10 Pukhraj Bhomaji Mutha, Mumbai Subsequently the assessee was issued notice

Seema Arora, Meerut vs. ITO Ward 2(3), Meerut

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

ITA 3932/DEL/2023[2012-13]Status: DisposedITAT Delhi08 Jul 2024AY 2012-13

Bench: Shri G.S. Pannu & Shri Vimal Kumarasstt. Year : 2012-13 Ms. Seema Arora, Vs. Ito, Ward-2(3), B-267, Shastri Nagar, Meerut Meerut Aayakar Bhawan, U.P. – 250004 Bhansali Ground, Delhi Road, (Pan: Abmpa8033G) Meerut, U.P.-250001 (Appellant) (Respondent) Appellant By : Shri P.S. Kashyap, Adv. Respondent By : Shri Ram Dhan Meena, Sr. Dr Date Of Hearing 20.06.2024 Date Of Pronouncement 08.07.2024

For Appellant: Shri P.S. Kashyap, AdvFor Respondent: Shri Ram Dhan Meena, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 148Section 151(2)Section 68

grounds:- “1. That on facts and in law re-opening of case under section 148 is totally unjustified and illegal. AO has no reason to believe for reopening the case. AO just relied on AIR information before reopening the case. Notice u/s. 148 is a invalid notice as statutory notice