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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

Rvr Technologies Ltd., Mandideep vs. Addl. CIT-Range-3, Bhopal

In the result, appeal for A

ITA 276/IND/2023[2009-10]Status: DisposedITAT Indore30 May 2024AY 2009-10

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 271E

there was no business operation, the exp. was not an allowable expenditure, and should be added back. In view of above, I have reason to believe that an income of Rs. 4265430/- Chargeable 10 tax has escaped assessment for A.Y. 2008-09 within the meaning of section

Rvr Technologies Ltd., Mandideep vs. ACIT-3(1), Bhopal

In the result, appeal for A

ITA 275/IND/2023[2008-09]Status: DisposedITAT Indore30 May 2024AY 2008-09

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 271E

there was no business operation, the exp. was not an allowable expenditure, and should be added back. In view of above, I have reason to believe that an income of Rs. 4265430/- Chargeable 10 tax has escaped assessment for A.Y. 2008-09 within the meaning of section

Assistant Commissioner of Income Tax, Circle-1, Tirunelveli vs. Ms.Aarthi Scans, Kovilpatti

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

ITA 75/CHNY/2024[2012-13]Status: DisposedITAT Chennai30 May 2024AY 2012-13

Bench: Shri Mahavir Singhand Shri Jagadish

For Appellant: Shri P. Sajit Kumar, JCITFor Respondent: Shri Vijay Kumar, CA
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

Subsequently, notice u/s.148 of the Act was issued on 25.03.2019 and according to AO, as there was reason to believe that income chargeable to tax has escaped assessment. The AO in lieu of that issued notice u/s.143(2) of the Act dated 10.12.2019 and reassessment was completed u/s.143(3) r.w.s ... held that reopening is bad in law by observing in para 5.3.4 as under:- “5.3.4 I have carefully perused the recording a reason to believe by the AO which is part of the submissions made by the assessee. There are 5 grounds on the basis of which the reason

Jesudason Biji, Chennai vs. Office of Income Tax Officer Int. Taxn Ward1(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 567/CHNY/2024[2014-15]Status: DisposedITAT Chennai30 May 2024AY 2014-15

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Shri M.V.Swaroop, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT
Section 119(2)(b)Section 139(1)Section 139(5)Section 147Section 148Section 148ASection 149Section 54ESection 54F

coming into force of the Finance Act, 2021 was governed by the following provisions: - “Income escaping assessment- 147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections ... CBDT. During the process of sending a report to CBDT, the AO noticed that the deduction u/s 54F was unsupportive. Therefore, having formed reason to believe that income has escaped assessment a notice u/s 148 of the Act was issued on 30-06-2021 considering the extension of time

Trio Mercantile & Trading Limited, Mumbai vs. Income Tax Officer 13(3)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 4650/MUM/2023[2014-15]Status: DisposedITAT Mumbai30 May 2024AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 132Section 133ASection 143(1)Section 143(3)Section 147Section 148

different entities from accommodation entries provided by Shri Hasmukh Mehta. 3. In light of verifying the material facts available on record, I have reason to believe that the income of 3,08,47,239/- changeable to tax has escaped assessment by reason of the failure on part of the assessee

Rajeev Suresh Patodia, Mumbai vs. Income Tax Officer - 26(3)(6), Mumbai

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

ITA 4317/MUM/2023[2012-13]Status: DisposedITAT Mumbai30 May 2024AY 2012-13

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhariassessment Year: 2012-13

For Appellant: Shri Neelkanth Khandelwal, A.RFor Respondent: Shri Himanshu Kumar, D.R
Section 147Section 148Section 250

details of other immovable property held during the relevant period. 2.1 The assessee filed no response and therefore the AO formed a reason to believe that the assessee had escaped assessment of income exceeding Rs.1,00,000/- and accordingly reopened the case under section 147 of the Act and consequently

Krishna Developers Pvt Ltd., Mumbai vs. Assistant Commissioner of Income Tax, Circle -10(1)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4292/MUM/2023[2009-10]Status: DisposedITAT Mumbai30 May 2024AY 2009-10

Bench: Shri B.R. Baskaran & Ms.Kavitha Rajagopalassessment Year : 2009-10 M/S. Krishna Developers Pvt. Ltd. 508, Gundecha Chambers, Nagindas Master Road, Fort, Mumbai – 400 023. Pan: Aabck-5678-G ---- Appellant Vs. Assistant Commissioner Of Income Tax, Circle – 10(1)(2), Mumbai Room No.651, 6Th Floor, Aaykar Bhavan, M.K. Road, Mumbai – 400 020. --- Respondent

For Appellant: Shri Rakesh JoshiFor Respondent: Shri P.D. Chougule, Sr. DR
Section 115JSection 133ASection 143(1)Section 143(3)Section 148Section 68

additional income over and above normal income for A Y 2009-10. 5. Under these circumstances, I have reason to believe that income to the tune of Rs.7,49,70,000/- has escaped assessment in terms of section 147 of the I T Act, 1961. Accordingly, the assessment ... provision for diminution in the value of investment. In view of the retrospective amendment of law by Parliament, the Assessing Officer may have reason to believe that income has escaped assessment. But that in itself is not sufficient for reopening an assessment beyond the period of four years. Beyond

M/S Gujarat Realtores, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 1, Thane

In the result, the appeal for assessment year 2009

ITA 3525/MUM/2023[2013-14]Status: DisposedITAT Mumbai30 May 2024AY 2013-14

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3523 To 3525/Mum/2023 Assessment Years: 2009-10, 2012-13, 2013-14 M/S Gujarat Realtors, Dy. Cit Central Circle-1, Ground Floor, Samriddhi, Room No. 10, 6Th Floor, Ashar Annapurna Estate, Indralok, Vs. It Park, Wagle Industrial Godhbunder Link Road, Thane, Estate, Thane (W)-400604. Bhayander, 401105. Pan No. Aahfg 0051 C Appellant Respondent Assessee By : Mr. Anuj Kisnadwala Revenue By : Mr. Manoj Kumar Singh, Sr. Dr Date Of Hearing : 16/04/2024 : Date Of Pronouncement 30/05/2024

For Appellant: Mr. Anuj KisnadwalaFor Respondent: Mr. Manoj Kumar Singh, Sr. DR
Section 143(3)Section 147Section 148Section 153CSection 234BSection 36Section 68

Investigation Wing that assessee had obtained accommodation en that assessee had obtained accommodation entries and accordingly tries and accordingly he recorded the reason to believe he recorded the reason to believe that income escaped assessment income escaped assessment and he issued notice u/s 148 of the Act and he issued ... Finance Act, 2021 envisaged that if the assessing offcer has 01.04.2021 by Finance Act, 2021 envisaged that if the assessing offcer has reason to believe in any assessment year, he may subjec reason to believe in any assessment year, he may subject to provisions of t to provisions of Section

M/S Gujarat Realtores, Mumbai Suburban vs. Deputy Commissioner of Income Tax -Central Circle 1, Thane

In the result, the appeal for assessment year 2009

ITA 3524/MUM/2023[2012-13]Status: DisposedITAT Mumbai30 May 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3523 To 3525/Mum/2023 Assessment Years: 2009-10, 2012-13, 2013-14 M/S Gujarat Realtors, Dy. Cit Central Circle-1, Ground Floor, Samriddhi, Room No. 10, 6Th Floor, Ashar Annapurna Estate, Indralok, Vs. It Park, Wagle Industrial Godhbunder Link Road, Thane, Estate, Thane (W)-400604. Bhayander, 401105. Pan No. Aahfg 0051 C Appellant Respondent Assessee By : Mr. Anuj Kisnadwala Revenue By : Mr. Manoj Kumar Singh, Sr. Dr Date Of Hearing : 16/04/2024 : Date Of Pronouncement 30/05/2024

For Appellant: Mr. Anuj KisnadwalaFor Respondent: Mr. Manoj Kumar Singh, Sr. DR
Section 143(3)Section 147Section 148Section 153CSection 234BSection 36Section 68

Investigation Wing that assessee had obtained accommodation en that assessee had obtained accommodation entries and accordingly tries and accordingly he recorded the reason to believe he recorded the reason to believe that income escaped assessment income escaped assessment and he issued notice u/s 148 of the Act and he issued ... Finance Act, 2021 envisaged that if the assessing offcer has 01.04.2021 by Finance Act, 2021 envisaged that if the assessing offcer has reason to believe in any assessment year, he may subjec reason to believe in any assessment year, he may subject to provisions of t to provisions of Section

M/S. Gujarat Realtors (Firm), Bhayander vs. DCIT, CC-1, Thane

In the result, the appeal for assessment year 2009

ITA 3523/MUM/2023[2009-10]Status: DisposedITAT Mumbai30 May 2024AY 2009-10

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3523 To 3525/Mum/2023 Assessment Years: 2009-10, 2012-13, 2013-14 M/S Gujarat Realtors, Dy. Cit Central Circle-1, Ground Floor, Samriddhi, Room No. 10, 6Th Floor, Ashar Annapurna Estate, Indralok, Vs. It Park, Wagle Industrial Godhbunder Link Road, Thane, Estate, Thane (W)-400604. Bhayander, 401105. Pan No. Aahfg 0051 C Appellant Respondent Assessee By : Mr. Anuj Kisnadwala Revenue By : Mr. Manoj Kumar Singh, Sr. Dr Date Of Hearing : 16/04/2024 : Date Of Pronouncement 30/05/2024

For Appellant: Mr. Anuj KisnadwalaFor Respondent: Mr. Manoj Kumar Singh, Sr. DR
Section 143(3)Section 147Section 148Section 153CSection 234BSection 36Section 68

Investigation Wing that assessee had obtained accommodation en that assessee had obtained accommodation entries and accordingly tries and accordingly he recorded the reason to believe he recorded the reason to believe that income escaped assessment income escaped assessment and he issued notice u/s 148 of the Act and he issued ... Finance Act, 2021 envisaged that if the assessing offcer has 01.04.2021 by Finance Act, 2021 envisaged that if the assessing offcer has reason to believe in any assessment year, he may subjec reason to believe in any assessment year, he may subject to provisions of t to provisions of Section

ACIT-19(3), Mumbai vs. Vinod Hirachand Sanghvi, Mumbai

In the result, the appeals filed by the assessee for the A

ITA 4870/MUM/2023[2010-11]Status: DisposedITAT Mumbai29 May 2024AY 2010-11

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos 4473, 4472 & 4470/Mum/2023 (A.Y.2009-10, 2010-11 & 2011-12)

Section 271(1)(c)

bills/bogus purchase bills from various parties as per website of sales tax department Maharashtra and the assesse is a beneficiary. The AO has reason to believe that the income has escaped the assessment and has issued notice u/sec 148 of the Act. Subsequently notice u/sec 143(2) and U/sec

Speedking Courier Services Pvt Ltd, Mumbai vs. Income Tax Officer-4(3)(3), Mumbai

In the result, the appeal is allowed

ITA 4677/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 May 2024AY 2012-13

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahayassessment Year: 2012-13 Speedking Courier Income Tax Officer- Services Pvt. Ltd. 4(3)(3), 25/27, Old Hanuman Galli, Room No. 648, Vs. 1St Cross Lane, 6Th Floor, Kalbadevi, Aayakar Bhavan, Mumbai- 400 002. Maharshi Karve Marg, Mumbai- 400 020 Pan: Aaics3715M (Appellant) (Respondent) Present For: Assessee By : Shri K. Gopal, A.R. Revenue By : Shri P. D. Chougule (Addl. Cit) Sr., D.R. Date Of Hearing : 16 . 05 . 2024 Date Of Pronouncement : 29 . 05 . 2024 O R D E R Per : Ratnesh Nandan Sahay: 1. The Appellant Has Filed This Appeal Against The Order Of The Ld. Income Tax Officer- 4(3)(3) Mumbai By Raising Following Grounds Of Appeal: “The Addition Of Rs.1,53,00,000/- Made Under Section 68 Of The Act Is Not Justified. 1. The Ld Cit(A) Is Erred In Confirming The Addition Of Rs. 1,53,00,000/- Made By The Ld. A.O. Under Section 68 Of The Act Without Appreciating That The Basic Condition To Invoke The Provisions Of Section 68 Are Not Satisfied In The Present Case. Hence, The Addition Made Under Section 68 Of The Act Is Not In Accordance With The Law & The Same May Be Deleted.

For Appellant: Shri K. Gopal, A.RFor Respondent: Shri P. D. Chougule (Addl. CIT) Sr., D.R
Section 142(1)Section 143Section 143(2)Section 147Section 148Section 151(1)Section 234BSection 68

relevant assessment year as per the first proviso to section 147 of the Act. The reopening has been done without having any reason to believe based on any tangible material that the income chargeable to tax has escaped assessment. Thus, the notice issued under section

Vinod Hirachand Sanghvi, Mumbai vs. DCIT 15(2), Piramal Chambers, Lalbaug, Mumbai

In the result, the appeals filed by the assessee for the A

ITA 4473/MUM/2023[2009-10]Status: DisposedITAT Mumbai29 May 2024AY 2009-10

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos 4473, 4472 & 4470/Mum/2023 (A.Y.2009-10, 2010-11 & 2011-12)

Section 271(1)(c)

bills/bogus purchase bills from various parties as per website of sales tax department Maharashtra and the assesse is a beneficiary. The AO has reason to believe that the income has escaped the assessment and has issued notice u/sec 148 of the Act. Subsequently notice u/sec 143(2) and U/sec

Vinod Hirachand Sanghvi, Mumbai vs. ACIT-15(2), Piramal Chambers, Lalbaug, Parel, Mumbai

In the result, the appeals filed by the assessee for the A

ITA 4472/MUM/2023[2010-11]Status: DisposedITAT Mumbai29 May 2024AY 2010-11

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos 4473, 4472 & 4470/Mum/2023 (A.Y.2009-10, 2010-11 & 2011-12)

Section 271(1)(c)

bills/bogus purchase bills from various parties as per website of sales tax department Maharashtra and the assesse is a beneficiary. The AO has reason to believe that the income has escaped the assessment and has issued notice u/sec 148 of the Act. Subsequently notice u/sec 143(2) and U/sec

Vinod Hirachand Sanghvi, Mumbai vs. ACIT-19(3), Piramal Chambers, Lalbaug, Parel, Mumbai

In the result, the appeals filed by the assessee for the A

ITA 4470/MUM/2023[2011-12]Status: DisposedITAT Mumbai29 May 2024AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos 4473, 4472 & 4470/Mum/2023 (A.Y.2009-10, 2010-11 & 2011-12)

Section 271(1)(c)

bills/bogus purchase bills from various parties as per website of sales tax department Maharashtra and the assesse is a beneficiary. The AO has reason to believe that the income has escaped the assessment and has issued notice u/sec 148 of the Act. Subsequently notice u/sec 143(2) and U/sec

Andhara Pradesh State Council of Higher Education, Guntur vs. Assistant Commissioner of Income Tax, Circle-1(1), Guntur

In the result, appeals of the assessee are allowed for the A

ITA 134/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam28 May 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.130/Viz/2024To 134/Viz/2024 (ननधधारण वर्ा/ Assessment Year : 2013-14 To 2016-17) Andhra Pradesh State Council Of Vs. Asst.Commissioner Of Higher Education Income Tax Neeladri Towers Circle-1(1) Atmakur Village, Mangalagiri Guntur Guntur [Pan :Aamfa3316R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Satyasai Rath, CIT(DR)
Section 144Section 147Section 148

held an amount of Rs.56,99,79,042/- in savings bank account during the relevant A.Y.2013-14 and thereafter concluded that there is reason to believe that the income from cash deposits to the tune of Rs.56,99,79,042/- has escaped assessment within the meaning of provisions

Andhra Pradesh State Council of Higher Education, Guntur vs. Assistant Commissioner of Income Tax, Circle-1(1), Guntur

In the result, appeals of the assessee are allowed for the A

ITA 133/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam28 May 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.130/Viz/2024To 134/Viz/2024 (ननधधारण वर्ा/ Assessment Year : 2013-14 To 2016-17) Andhra Pradesh State Council Of Vs. Asst.Commissioner Of Higher Education Income Tax Neeladri Towers Circle-1(1) Atmakur Village, Mangalagiri Guntur Guntur [Pan :Aamfa3316R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Satyasai Rath, CIT(DR)
Section 144Section 147Section 148

held an amount of Rs.56,99,79,042/- in savings bank account during the relevant A.Y.2013-14 and thereafter concluded that there is reason to believe that the income from cash deposits to the tune of Rs.56,99,79,042/- has escaped assessment within the meaning of provisions

Andhra Pradesh State Council of Higher Education, Guntur vs. Assistant Commissioner of Income Tax, Circle-1(1), Guntur

In the result, appeals of the assessee are allowed for the A

ITA 132/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam28 May 2024AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.130/Viz/2024To 134/Viz/2024 (ननधधारण वर्ा/ Assessment Year : 2013-14 To 2016-17) Andhra Pradesh State Council Of Vs. Asst.Commissioner Of Higher Education Income Tax Neeladri Towers Circle-1(1) Atmakur Village, Mangalagiri Guntur Guntur [Pan :Aamfa3316R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Satyasai Rath, CIT(DR)
Section 144Section 147Section 148

held an amount of Rs.56,99,79,042/- in savings bank account during the relevant A.Y.2013-14 and thereafter concluded that there is reason to believe that the income from cash deposits to the tune of Rs.56,99,79,042/- has escaped assessment within the meaning of provisions

Andhra Pradesh State Council of Higher Education, Guntur vs. Assistant Commissioner of Income Tax, Circle-1(1), Guntur

In the result, appeals of the assessee are allowed for the A

ITA 131/VIZ/2024[2014-15]Status: DisposedITAT Visakhapatnam28 May 2024AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.130/Viz/2024To 134/Viz/2024 (ननधधारण वर्ा/ Assessment Year : 2013-14 To 2016-17) Andhra Pradesh State Council Of Vs. Asst.Commissioner Of Higher Education Income Tax Neeladri Towers Circle-1(1) Atmakur Village, Mangalagiri Guntur Guntur [Pan :Aamfa3316R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Satyasai Rath, CIT(DR)
Section 144Section 147Section 148

held an amount of Rs.56,99,79,042/- in savings bank account during the relevant A.Y.2013-14 and thereafter concluded that there is reason to believe that the income from cash deposits to the tune of Rs.56,99,79,042/- has escaped assessment within the meaning of provisions

Andhra Pradesh State Council of Higher Education, Guntur vs. Assistant Commissioner of Income Tax, Circle-1(1), Guntur

In the result, appeals of the assessee are allowed for the A

ITA 130/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam28 May 2024AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.130/Viz/2024To 134/Viz/2024 (ननधधारण वर्ा/ Assessment Year : 2013-14 To 2016-17) Andhra Pradesh State Council Of Vs. Asst.Commissioner Of Higher Education Income Tax Neeladri Towers Circle-1(1) Atmakur Village, Mangalagiri Guntur Guntur [Pan :Aamfa3316R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Satyasai Rath, CIT(DR)
Section 144Section 147Section 148

held an amount of Rs.56,99,79,042/- in savings bank account during the relevant A.Y.2013-14 and thereafter concluded that there is reason to believe that the income from cash deposits to the tune of Rs.56,99,79,042/- has escaped assessment within the meaning of provisions