“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

Bharat Vanmalibhai Modiya, Mumbai vs. Income Tax Officer 25(2) (2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 125/MUM/2022[2010-11]Status: DisposedITAT Mumbai13 Mar 2024AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2010-11 Bharat Vanmalibhai Modiya, Income Tax Officer 25(2)(2), 503, Shree Krishna Bhuvan, Kautilya Bhavan, Dgit Vs. Dixit Road, Vile Parle (E), (Vigilance) (West) Avenue 3, Mumbai-400057. Near Videsh Bhavan, G Block Bkc, Bandra Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aawpm 1067 D Appellant Respondent Assessee By : Mr. Bharat Kumar : Mr. Ashok Kumar Ambastha, Dr Revenue By Date Of Hearing : 12/03/2024 Date Of Pronouncement : 13/03/2024

For Appellant: Mr. Bharat Kumar

Section 143(1)Section 148

from the office of the DGIT Investigation Wing, information received from the office of the DGIT Investigation Wing, Mumbai, the Assessing Officer recorded reasons to believe that Mumbai, the Assessing Officer recorded reasons to believe that Mumbai, the Assessing Officer recorded reasons to believe that income escaped assessment and issued ... during March, 2010. On the basis of this segment on NSE during March, 2010. On the basis of this information the AO had reason to believe that income had escaped information the AO had reason to believe that income had escaped information the AO had reason to believe that income

Reliable Vinimay (P) Ltd., Kolkata vs. ITO, Ward-4(1), Kolkata.

In the result, the appeal of the assessee stands allowed

ITA 695/KOL/2023[2011-12]Status: DisposedITAT Kolkata12 Mar 2024AY 2011-12

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No. 695/Kol/2023 Assessment Year: 2011-2012 Reliable Vinimay Private Limited,………..….Appellant Kaveri House, 132/1, Mahatma Gandhi Road, 5Th Floor, Kolkata-700001 [Pan:Aadcr7841N] -Vs.- Income Tax Officer,……………………………....Respondent Ward-7(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Manoj Kataruka, A.R. & Shri Rajeev Kumar Choudhury, Advocate, Appeared On Behalf Of The Assessee Shri B.K. Singh, Jcit Sr. Dr, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 13, 2023 Date Of Pronouncing The Order: March 12, 2024 O R D E R

Section 147Section 148Section 68

brought our attention to the reasons recorded for reopening of the assessment, which for the sake of ready reference are reproduced as under:- REASON' TO BELIEVE FOR INITIATION OF THE PROCEEDINGS U/s.147 OF THE I.T. ACT “From the information available with the department, it was noticed that Shri Santosh Kumar ... Rs.17,154/-. No scrutiny assessment has been made in this case for AY 2011-12. In view of the above, I have reasons to believe that income of Rs.44,50,000/- chargeable to tax has escaped assessment for AY 2011-12 warranting issue of the notice

ITO Ward - 7(1), New Delhi vs. Devika Gold Homz Pvt Ltd, New Delhi

In the result, the appeal of the revenue is dismissed

ITA 563/DEL/2020[2014-15]Status: DisposedITAT Delhi12 Mar 2024AY 2014-15

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usito, Vs. Devika Gold Homz Pvt. Ltd, Ward-7(1), Stilt Floor, Devika Tower, New Delhi New Delhi (Appellant) (Respondent) Pan:Aalcs4525J Assessee By : Shri Somil Agarwal, Adv Shri Deepesh Garg, Adv Revenue By: Shri Vivek Kumar Upadhyay, Sr. Dr Date Of Hearing 18/12/2023 Date Of Pronouncement 12/03/2024

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR

Section 143Section 143(3)

above facts and the detailed arguments raised by the AR during the course of appellate proceedings, it is observed that there is sufficient reason to believe that the project was planned and approved for ten towers and it was subsequently restricted to six towers due to various reasons as explained

M/S. Indovision Securities Limited., Kolkata vs. ITO, Ward-6(2), Kolkata.

In the result, the appeal of the assessee stands allowed

ITA 1353/KOL/2023[2012-13]Status: DisposedITAT Kolkata11 Mar 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.1353/Kol/2023 Assessment Year : 2012-13 M/S Indovision Securities Ltd….…………............…...……………....Appellant Block B, Suit No.1A, 1St Floor Mangalam, 24 & 26 Hemanta Basu Sarani, Isi P.O S.O, Kolkata-1. [Pan: Aaaci5310G] Vs. Ito, Ward-6(2), Kolkata….….............................................…..…..... Respondent Appearances By: Shri Sunil Surana, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 27, 2024 Date Of Pronouncing The Order : March 11, 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 30.03.2023 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 Appeal Is Time-Barred By 196 Days. A Separate Application For Condonation Of Delay Has Been Filed. Considering The Averments Made In The Application, The Delay In Filing The Present Appeal Is Hereby Condoned. 3. The Assessee In This Appeal Has Taken The Following Grounds Of Appeal: “1. For That The Ld Cit(A) Erred In Deciding The Appeal Ex-Parte When No Proper & Reasonable Opportunity Of Being Heard Was Granted.

Section 143(1)Section 143(3)Section 147Section 148Section 250

made. I.T.A. No.1353/Kol/2023 Assessment Year : 2012-13 M/s Indovision Securities Ltd. Considering the facts as stated above and the observations made, I have reason to believe that income of the assessee has escaped assessment within the meaning of Section ... year, hence, the exception provided under 1st Proviso to section 147 is attracted. 11. It has been held time and again that the reasons to believe regarding the escapement of the income should be based on certain tangible material and it should not be mere pretence of the Assessing I.T.A

Bharath Hi-Tech Builders Pvt. Ltd., Bangalore vs. Dy. CIT, Circle-1(1)(2), Bangalore

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

ITA 1034/BANG/2023[2009-10]Status: DisposedITAT Bangalore11 Mar 2024AY 2009-10

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

For Appellant: Sri.Inder Paul Bansal & Sri.Vivek BansalFor Respondent: Sri.Nilanjan Dey, Addl.CIT-DR

Section 147Section 148Section 151Section 153ASection 250

Further, unsecured loans taken by the assessee also needs to be verified. In the light of the above information, I have reason to believe that income amounting to Rs.1,17,50,000/- has escaped assessment in the hands of M/s.Bharath Hi-Tech Builders Pvt. Ltd. for the A.Y.2009-10

Blue Bell Finance Limited, Delhi vs. ITO Ward-5(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1592/DEL/2023[2012-13]Status: DisposedITAT Delhi11 Mar 2024AY 2012-13

Bench: Shri M. Balaganesh & Shri Anubhav Sharmablue Bell Finance Ltd, Vs. Ito, 564, A-1, P. No. 2/59, Ward-5(1), Bhim Gali, Vishwas New Delhi Nagar, Shahdra, Delhi (Appellant) (Respondent) Pan: Aaacb1156H Assessee By : Shri Anmol Sinha, Adv Shri Nitin Gulati, Adv Revenue By: Mrs. Sunita Verma, Cit Dr Date Of Hearing 06/03/2024 Date Of Pronouncement 11/03/2024

For Appellant: Shri Anmol Sinha, AdvFor Respondent: Mrs. Sunita Verma, CIT DR

Section 147Section 148Section 151Section 250(6)Section 271(1)(c)Section 68

submissions of the Appellant. 2. That the Ld.AO has grossly erred in assuming jurisdiction to reopen the present case in absence of any reason to believe as on date of issuance of notice u/s 148 of the Act. Blue Bell Finance Ltd 3. That the order passed ... finding of the Ld. AO. 4. That the notice issued by the Ld. AO u/s 148 of the Act is without any reason to believe and without proper satisfaction of the appropriate authority as required u/s 151 of the Act. The Ld. AO has concluded the reassessment proceeding

Dr. Arvind Taneja, New Delhi vs. ACIT Circle-61(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 9171/DEL/2019[2011-12]Status: DisposedITAT Delhi11 Mar 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Anubhav Sharmadr. Arvind Taneja, Vs. Acit, 75, Golf Links, Delhi Circle-61(1), New Delhi (Appellant) (Respondent) Pan:Aacpt0269N

For Appellant: Shri Bhupinder Jit Kumar, AdvFor Respondent: Shri Kanv Bali, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148Section 151

additional grounds raised by the assessee is as under:- Ground No.1 (i) On the basis of material available on record, the AO has reason to believe that income has escaped assessment within the meaning of the section 147 of the Act. (ii) The reason for reopening was based

Ashwini Sahakari Rungnalaya & Research Center, Solapur vs. Commissioner of Income-Tax, (Exemptions), Pune

ITA 714/PUN/2018[N.A]Status: DisposedITAT Pune07 Mar 2024

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 714/Pun/2018 Ashwini Sahakari Rugnalaya & Research Centre 7107/1, Plot No. 180, North Sadar Bazar, Solapur-413003. Pan: Aaaja0041K . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Pramod Shingte [‘Ld. AR’]For Respondent: Mr Keyur Patel [‘Ld. DR’]

Section 10Section 10(23)Section 11Section 12ASection 22Section 253(1)(c)

medical service from the patients classified into economic, deluxe, super-deluxe etc., any prudent man will form an opinion that there is no reason to believe that the appellant is running its hospitals, medical dispensaries etc. dominantly for providing free medical relief to the poor, needy and deserving citizen/general public

ITO-27(1)(5), Income Tax Office Vashi vs. J.V.Chem India, B Neelkanth Chhaya, R.B. Mehta

In the result, the appeal of the revenue is dismissed

ITA 2634/MUM/2023[2010-11]Status: DisposedITAT Mumbai07 Mar 2024AY 2010-11

Bench: Shri Kuldip Singh & Shri Amarjit Singhito-27(1)(5) Vs. J.V. Chem India, Room No.410, 4Th Floor, B Neelkanth Chhahya, Tower No.6, Vashi Railway R.B. Mehta Road Station, Mumbai – 400703 Ghatkopar East Maharashtra – 400077 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aabfj4268L Appellant .. Respondent Appellant By : S. Arunkumar Respondent By : None Date Of Hearing 28.02.2024 Date Of Pronouncement 07.03.2024 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Revenue In Electronic Mode Is Directed Against The Order Passed By The Ld. Cit(A) For A.Y. 2010-11. The Revenue Has Raised The Following Grounds Before Us: “1. Whether On The Facts & Circumstances Of The Case, The Ld. Cit(A) Has Lied To Appreciate The Fact That The Re-Opening Of Assessment Was Done By The Ao After Taking Prior Approval & Also Recording The Reasons That Entire Purchase Of Rs. 21,15,881/- Representing Accommodation Entries (As Per Information & Investigation Report Received From Dgit (Inv.) Mumbai, Based On Information Provided By Sales Tax Department), Should Have Been Disallowed. 2. Whether On The Facts & Circumstances Of The Case, The Id. Cit(A) Erred In Quashing The Assessment Proceeding Witl.At Appreciating That In The Case Of Bogus Purchase Transactions, Hon'Ble Gujarat High Court Upheld The Disallowance Of 100% In The Case Of N.K. Proteins Which Was Subsequently Confirmed By The Hon'Ble Supreme Court.

For Appellant: S. ArunkumarFor Respondent: None

Section 133(6)Section 143(3)Section 147Section 148Section 69

Rs.14,69,766/- made by the assessing officer. In the copy of reason recorded the assessing officer has simply stated he has reason to believe that there is escapement of income to the balance amount of Rs.648,155/- as being difference in the total purchases amount of Rs.21

Kusum Mittal, Haryana vs. DCIT, CC-1, Gurgaon

ITA 808/DEL/2022[2017-18]Status: DisposedITAT Delhi07 Mar 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

Section 132Section 143(2)Section 153ASection 55ASection 56(2)(vii)

made, as the case may be, where the Director General or the Director in consequence of information in his possession has reason to believe that any person is in Page 10 of 21 Kusum Mittal possession of any money, bullion, Jewellery or other valuable article or thing (hereafter referred

Vijay Pal, Gurgaon vs. ITO, Gurgaon

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

ITA 3033/DEL/2017[2010-11]Status: DisposedITAT Delhi07 Mar 2024AY 2010-11

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.3033/Del/2017 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Vs. Ito, Vijay Pal, S/O Late Sh. Manohar Lal, Ward-4(4), Village & P.O. Nakhrola, Gurgaon. Tehsil Manesar, Gurgaon. Pan No.Anvpp7279G अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.3031/Del/2017 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Vs. Ito, Raj Singh, S/O Late Sh. Manohar Lal, Ward-3(3), Village & P.O. Nakhrola, Gurgaon. Tehsil Manesar, Gurgaon. Pan No.Bjdps1075G अपीलाथ" Appellant ""यथ"/Respondent अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.3032/Del/2017 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Vs. Ito Hariom, S/O Late Sh. Manohar Lal, Ward-2(1), Village & P.O. Nakhrola, Gurgaon. Tehsil Manesar, Gurgaon. Pan No.Afuph1298A अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 234ASection 54B

exercise powers under Section 147/148 to re-open the assessment. This is because he alone would be in a position to form reasons to believe that some income of that particular AY has escaped assessment. This again cannot be based on a mere change of opinion. Further, in terms ... held that mere participation by a party in proceedings without jurisdiction will not vest / confer jurisdiction on the authority. Reason to believe that income chargeable to tax has escaped assessment is a jurisdictional fact and only on its satisfaction does the Assessing Officer acquire jurisdiction to issue notice. Thus this

Hariom, Gurgaon vs. ITO, Gurgaon

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

ITA 3032/DEL/2017[2010-11]Status: DisposedITAT Delhi07 Mar 2024AY 2010-11

Section 143(3)Section 147Section 234ASection 54B

Raj Singh, Gurgaon vs. ITO, Gurgaon

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

ITA 3031/DEL/2017[2010-11]Status: DisposedITAT Delhi07 Mar 2024AY 2010-11

Section 143(3)Section 147Section 234ASection 54B

State Organisation of Gyn and Obs of Gujarat, Ahmedabad vs. The ITO (Exemp), Bhavnagar Now the ITO, Ward-1(1)(3), Ahmedabad

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

ITA 1126/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad06 Mar 2024AY 2012-13

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2012-13 State Organization Of Gyn Ito (Exemption) & Obs Of Gujarat Bhavnagar Ama Building, Now Ito-Ward(1)(1)(3) Nr.Natraj Cinema Ahmedabad. Ashram Road Ahmedabad 380 009. Pan : Aaats 9145 A (Applicant) (Responent)

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Ketan Gajjar, Sr.DR

Section 144Section 148Section 250(6)

confirming the action of the A.O. in issuing notice u/s.148 of the I.T.Act, 1961 and reopening the assessment without nay valid reason to believe. 3. The learned Commissioner of Income Tax (Appeals), NFAC, Delhi has erred in confirming the action of the Assessing officer, Bhavnagar in passing an Ex Parte

Silkina Commodeal Pvt. Ltd., Kolkata vs. ITO, Ward-3(3), Kolkata.

In the result, appeal of the assessee is allowed

ITA 1161/KOL/2023[2011-12]Status: DisposedITAT Kolkata06 Mar 2024AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalassessment Years: 2011-12 Silkina Commodeal Pvt. Ltd. Income Tax Officer, Ward- 6, Waterloo Street, Kolkata- Vs. 3(3), Kolkata. 700069. (Pan: Aaecs5627C) (Appellant) (Respondent)

For Appellant: Shri Siddarth Agarwal, AdvocateFor Respondent: Shri B. K. Singh, JCIT, Sr. DR

Section 147Section 148Section 68

Notice u/s. 148 of the Act dated 07.03.2018 was issued and served on the assessee after recording the reasons to believe for the same. Copy of reasons to believe are placed at pages 21 and 22 of the paper book filed by the assessee. From the perusal of the said ... reasons to believe it is noted that information was received from the DIT (Inv.), Kolkata that assessee had suspicious bank transactions with Jamakharchi companies. It is noted by the Ld. AO that assessee had received Rs.50,00,000/- from one fictitious shell company namely M/s. Suniyojit Agency

Silkina Commodeal Pvt. Ltd., Kolkata vs. ITO, Ward 3(3), Kolkata

In the result, appeal of the assessee is allowed

ITA 1439/KOL/2023[2012-13]Status: DisposedITAT Kolkata05 Mar 2024AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Siddarth Agarwal, AdvocateFor Respondent: Shri Arup Chatterjee, Addl. CIT

Section 147Section 148Section 271(1)(c)Section 68

total income at Rs.48,250/-. Notice u/s. 148 of the Act dated 21.03.2017 was issued and served on the assessee after recording the reasons to believe for the same. Copy of reasons to believe are placed at pages 21 and 22 of the paper book filed by the assessee. From ... perusal of the said reasons to believe, it is noted that information was received from the DIT (Inv.), Kolkata that assessee had suspicious bank transactions with Jamakharchi companies. It is noted by the Ld. AO that assessee had received Rs.35,00,000/- from one fictitious shell company namely M/s. Suniyojit

Silkina Commodeal Pvt. Ltd., Kolkata vs. ITO, Ward-3(3), Kolkata

In the result, appeal of the assessee is allowed

ITA 1438/KOL/2023[2010-11]Status: DisposedITAT Kolkata05 Mar 2024AY 2010-11

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Siddarth Agarwal, AdvocateFor Respondent: Shri Arup Chatterjee, Addl. CIT

Section 147Section 148Section 271(1)(c)Section 68

Silkina Commodeal Pvt. Ltd., Kolkata vs. ITO, Ward-3(3), Kolkata

In the result, appeal of the assessee is allowed

ITA 1437/KOL/2023[2010-11]Status: DisposedITAT Kolkata05 Mar 2024AY 2010-11

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Siddarth Agarwal, AdvocateFor Respondent: Shri Arup Chatterjee, Addl. CIT

Section 147Section 148Section 271(1)(c)Section 68

M/S Din Dayal Pursotam Lal, Sirsa vs. Pr.CIT, Rohtak

ITA 148/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh04 Mar 2024AY 2016-17

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Gautam Jain, Advocate &For Respondent: Shri Rohit Sharma, CIT-DR

Section 147Section 263Section 40A(3)

issued mechanically without application of mind much less independent application of mind and without having any tangible, relevant credible material to form a reason to believe that income of the appellant has escaped assessment therefore the order of assessment u/s 147/143(3) of the Act was without jurisdiction ... transactions, in support of which the Department is having tangible information which is not accounted in the books of the assessee. I have reasons to believe that an income of Rs.58,42,590/- chargeable to tax for the assessment year 2011-12, besides any other income which comes to notice

M/S Din Dayal Pursotam Lal, Sirsa vs. Pr.CIT, Rohtak

ITA 147/CHANDI/2021[2015-16]Status: DisposedITAT Chandigarh04 Mar 2024AY 2015-16

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Gautam Jain, Advocate &For Respondent: Shri Rohit Sharma, CIT-DR

Section 147Section 263Section 40A(3)