“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. Sagun Sales Pvt. Ltd., Kolkata vs. I.T.O., Ward - 4(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 1194/KOL/2024[2011-2012]Status: DisposedITAT Kolkata13 Jan 2026AY 2011-2012

Bench: Shri George Mathan

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Abhijit Adhikary, Sr. DR

Section 147Section 148

held in para 5.2 to 6 as follows:- 5.2. It is settled that before an AO can be said to have had reasons to believe that some income has escaped assessment, he should have relevant material before him from which he could have drawn such conclusion. His vague imagination that ... CHALIHA (1971) 79 ITR 603 (SC)]. It is emphatically settled in this regard that there can be no doubt that the words "reason to believe suggest that the belief must be that of an honest and reasonable person based upon reasonable grounds and that the Assessing Officer

M/S. Aryan Share and Stock Brockers Limited, Chennai vs. ITO, Corp Ward-1, Chennai

In the result, Appeal filed by the assessee is allowed

ITA 2115/CHNY/2025[2014-15]Status: DisposedITAT Chennai13 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No. 2115/Chny/2025 "नधा"रण वष"/Assessment Year: 2014-15 M/S Aryan Share & Stock Brokers V. Ito Corp Ward-1, Limited., Itd, M G Road, No. 07, 07Th Cross Street, Nungambakkam, 2Nd Floor, Shreeji Metropolis, Chennai-600034 Aminjikarai, Chennai-600030 Tamil Nadu Tamil Nadu [Pan:Aadca 1233 H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Assessee By : Mr. Y Sridhar, Ca ""यथ" क" ओर से /Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 10.11.2025 घोषणा क" तार"ख /Date Of Pronouncement : 13.01.2026

For Appellant: Mr. Y Sridhar, CAFor Respondent: Ms. Anitha, Addl.CIT

Section 147Section 69A

Authorised Representative (AR) has prayed for quashing the consequent order passed u/s 147 r.w.s 144B on the following grounds as mentioned below: - (a) Reason to believe absence: From a mere perusal of the reasons recorded for reopening (Page 42 of Paper Book Index), it is clear that the Assessing Officer ... assessee company has incurred fictitious losses in equity/derivatives to the tune of Rs.40,48,000/-. He has not :: 5 :: stated what is the reason to believe that the said Rs.40,48,000/- is fictitious losses. (b) No tangible material: Ld.AR submitted that assessment cannot be reopened in the absence

DCIT(CC)-8(3), Mumbai vs. Shapoorji Pallonji and Company Private Limited, Mumbai

In the result, the cross-objection of the assessee is partly

ITA 2831/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Jan 2026AY 2014-15

Bench: Shri Om Prakash Kant ()

Section 115JSection 143(3)Section 147Section 148Section 14A

Rs.21,73,79,550/- and book profit u/s 115JB of the Act at Rs.92,66,70,763/-. 2.1 Subsequently, the Assessing Officer recorded reasons to believe that income escaped assessment and issued notice u/s 148 of the Act on 31.03.2019. In response to the notice, the assessee Shapoorji Pallaonji ... issued by another officer, therefore, reopening has not been done by the Assessing Officer who recorded the reasons to believe, which has rendered the entire reassessment proceedings as invalid. 5.2 On the contrary, the Ld. Departmental Representative (DR) submitted that notice u/s 148 has been validly issued by the same

Mahatma Phule Gramin Bigarsheti Sahakar Pat Sanstha Ltd, Kolhapur vs. PCIT-1, Pune

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

ITA 1049/PUN/2025[2018-19]Status: DisposedITAT Pune09 Jan 2026AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Mahatma Phule Gramin Bigarsheti Pcit-1, Pune Sahakar Pat Sanstha Vs. A/P Hattiwade, Ajara, Kolhapur – 416505 Pan: Aaaam2608K (Appellant) (Respondent) Assessee By : None (Written Submission Filed) Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 09-01-2026 O R D E R

For Appellant: None (written submission filed)For Respondent: Shri Amol Khairnar, CIT-DR

Section 139(1)Section 139(4)Section 147Section 148Section 263Section 80ASection 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

return. 7 10. Relying on various other decisions, it has been mentioned that the Assessing Officer has no power to make additions beyond reason to believe if there was no addition on account of reasons to believe for which notice u/s 148 of the Act was issued. 11. Referring

Doriswamy Gopi, Bengaluru vs. Income Tax Officer, Ward 3(1)(1), Bengaluru

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

ITA 2020/BANG/2025[A.Y. 2017-18]Status: DisposedITAT Bangalore09 Jan 2026

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Nagaraja K.H, CAFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department

Section 139Section 147Section 148Section 151Section 292B

AEIPR6515H) on 08.11.2016 for purchase of jewellery. The assessee has not filed return of income for AY 2017-18 4. Basis of forming reason to believe:- In view of the detailed analysis made in para 2&3 abvoe, I have reason to believe that income of more than 1 lakh ... invoked to cure a jurisdictional defect, particularly where the assumption of jurisdiction itself is invalid due to absence of a legally sustainable “reason to believe”. A reopening initiated on the basis of wrong and non-existent facts is not a mere procedural irregularity but a substantive illegality, which strikes

Kalpana Nitin Shah, Mumbai vs. Income Tax Officer 19(2)(2), Mumbai

ITA 7012/MUM/2025[2011-12]Status: DisposedITAT Mumbai09 Jan 2026AY 2011-12

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Harshad M. Karnik, Sr. DR

Section 143(3)Section 148Section 151Section 194Section 271(1)(c)

notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped assessment, has as a matter of fact not escaped assessment. it is not open to him independently to assess some other income

Devi Manubhai Shah, Mumbai vs. ITO - Circle 32(1), Mumbai

ITA 7005/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Jan 2026AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Piyush ChhajedFor Respondent: Shri Annavaran Kosuri

Section 143(1)Section 143(3)Section 147Section 54F

above transaction to tax for the assessment year under consideration. Therefore, on the basis of the above information and findings, I have reason to believe that income of more than Rs. 1,00,000/-has escaped assessment for A.Y 2012-13 within the meaning of Explanation ... accepted the contention of the assessee and holds that the income which he has initially 7 Assessment Year 2012-2013 formed a reason to believe had escaped assessment, has as a matter of fact not escaped assessment, it is not open to him independently to assess some other income

Rakesh Divedi, Delhi vs. Income Tax Officer, Ward 43(6), Delhi

In the result, appeal of the Assessee is allowed

ITA 3290/DEL/2025[2009-10]Status: DisposedITAT Delhi09 Jan 2026AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwalrakesh Divedi, Income Tax Officer, 87, Triveni Apartments, Ward-43(6), Delhi. Pitampura, New Delhi - Vs. 110034. Pan-Apcpd9179A (Appellant) (Respondent) Shri Pranshu Singhal, Ca Assessee By & Ms. Mansi Jain, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 30/10/2025 Date Of Pronouncement 09/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 07.03.2025 In Appeal No.40/10204/2018-19 Arising Out Of The Order Passed By The Income Tax Officer, Ward-40(3) U/S 143(3) Of The Act (‘The Act’ For Short) Dated 20.12.2016 For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Proprietor Of M/S Triambkay Gauri Impex. The Information Was Received By The Ao From Investigation Wing That There Were Cash Deposits In The Bank Account Of The Assesse With Icici Bank, However, Income Of The Assessee & Gross Receipt Has Not Rakesh Divedi Vs. Income Tax Officer Commensurate With The Cash So Deposited, Therefore, After Recording The Reason U/S 147, Notice U/S 148 Was Issued On 31.03.2016 After Obtaining Statutory Approval From The Pcit. Thereafter, Assessment Was Completed Vide Order Dated 20.12.2016 Wherein Total Addition Of Rs. 5,20,88,345/- Was Made U/S 68 Of The Act For Cash Deposited In The Bank Accounts By Holding The Same As Unexplained Cash Credits. 3. Against The Said Order, Assessee Has Filed An Appeal Before Ld. Cit(A) Who Vide Impugned Order Has Partly Allowed The Appeal Of The Assessee & Directed The Ao To Make Addition Of Peak Credit Of The Total Deposits In The Bank Accounts.

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68

other words, merely stating the reasons in a letter addressed by the AO to the Assessee is to be avoided; (ii) the reasons to believe ought to spell out all the reasons and grounds available with the AO for reopening the assessment - especially in those cases where the first proviso ... Section 147 is attracted. The reasons to believe ought to also paraphrase any investigation report which may form the basis of the reasons and any enquiry conducted by the AO on the same and if so, the conclusions thereof; (iii) where the reasons make a reference to another document, whether

Best Bull Stock Trading Pvt Ltd., New Delhi vs. ACIT, Central Circle-18, New Delhi

In the result, the appeals of the revenue in ITA No

ITA 2954/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

years but within a period of eight years from the end of the relevant year, viz., (1) the Income-tax Officer must have reason to believe that income chargeable to tax has escaped assessment, and (ii) he must have reason to believe that such income has escaped assessment by reason

Best Bull Stock Trading Pvt Ltd., New Delhi vs. ACIT Central Circle-18, Delhi

In the result, the appeals of the revenue in ITA No

ITA 2953/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

Alok Kumar Rungta, Lucknow vs. NFAC, Delhi

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

ITA 598/LKW/2025[2014-15]Status: DisposedITAT Lucknow08 Jan 2026AY 2014-15

Bench: Shri Kul Bharatassessment Year: 2014-15 Alok Kumar Rungta V. National Faceless Appeal B-40 Flat No.34 Manoram Centre Apartment Aliganj, Lucknow- Delhi. 226024. Pan:Ajqpr0755G (Appellant) (Respondent) Appellant By: Shri Vijay Prakash Agarwal, Advocate Shri Akshay Agarwal, Advocate Respondent By: Shri R. R. N. Shukla, Addl Cit(Dr) Date Of Hearing: 28 10 2025 Date Of Pronouncement: 08 01 2026 O R D E R

For Appellant: Shri Vijay Prakash Agarwal, AdvocateFor Respondent: Shri R. R. N. Shukla, Addl CIT(DR)

Section 1Section 143(3)Section 147Section 148Section 150(1)

basis of direction of Learned CIT (Appeal) is bad in law. 3. That the notice u/s 148 issued on the basis of reason to believe recorded by Learned CIT (Appeal) is bad in law. 4.That the notice u/s 148 has been issued by the Learned Assessing Officer for the same ... further contended that the order is bad in law, firstly, on the ground that the Ld. CIT(A) exceeded his jurisdiction by recording reasons to believe that the appellant had failed to disclose income and by directing the Assessing Officer to re-open the assessment. The Ld. Counsel

Pinnacle Consrto and Ecohomes Pvt.Ltd, Pune vs. DCIT Circle-4, Pune

In the result, appeal filed by the assessee is allowed

ITA 2818/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2818/Pun/2025 निर्धारण वषा / Assessment Year : 2017-18 Pinnacle Contro & V Dcit, Ecohomes Pvt. Ltd., S Circle-4, Pune. Madhav Heritage, Tilak Road, Sadashiv Peth, Pune – 411030. Pan: Aaecp0400E Appellant/ Assessee Respondent /Revenue Assessee By Shri Suhas P. Bora Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18Dated 01.10.2025 Emanating From The Assessment Order Passed Under Section 147 Of The Act, Dated 27.08.2021. The Assessee Has Raised The Following Grounds Of Appeal : “1. Reassessment Bad In Law.

Section 143(3)Section 147Section 148Section 151Section 250Section 250(6)

from the assessee on 19.02.2020. However, no compliance has been received from the assessee date. In view of the above, I have reason to believe that the income of Rs. 50,51,650 chargeable to tax has escaped assessment for the AY 2017-18 in the hands of the assessee ... found, then, the impugned notice cannot be sustained. As noted earlier, what we find is that there are no reasons to believe but only reasons to suspect. Hence, reopening of assessment is not satisfactory. 10. In the circumstances, the rule issued on 13th April 2016 is made absolute. The impugned

Income Tax Officer, Pune vs. Sagar Construction Company, Pune

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT

Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

notice under Section 148 of the I.T, Act was issued to the petitioner on 29 March, 2019. The petitioner received a copy of 'reasons to believe' furnished by respondent no. 3 on 11 September, 2019, which were objected by the petitioner. On such objection, an order was passed ... will be appropriate to extract the said provisions, which reads thus: "147. Income escaping assessment.--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 148 to 153, assess or reassess

Vilayil Satyan Pillai, New Delhi vs. Income Tax Officer, Delhi

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

ITA 2279/DEL/2025[2015-16]Status: DisposedITAT Delhi08 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Kishan Gupta, AdvocateFor Respondent: Shri Jitender Singh, CIT DR

Section 132ASection 144BSection 147Section 148Section 148ASection 153ASection 250

Unit, NFAC Delhi opening the assessment case and tangible materials discussed & presumed to be fit for reopening & escapement of income before by declaring reason to believe at the time of opening the re-assessment case given in the order u/s 148A(d) dated 30.06.2022 for A.Y.2015-16. 6. That

West Bengal Electronics Industry Development Corporation Limited, Kolkata vs. DCIT/ACIT, Circle - 2(1), Kolkata

The appeal of the assessee is allowed

ITA 1591/KOL/2024[2013-2014]Status: DisposedITAT Kolkata07 Jan 2026AY 2013-2014

Section 143(3)Section 147Section 148Section 24(1)Section 250

Direct Tax Laws (Amendment) Act, 1987, Section 147 read as under: "147. Income escaping assessment.-II- (a) the Income Tax Officer has reason to believe that, by reason of the omission or failure on the part of an assessee to make a return under Section 139 for any assessment year ... mentioned in clause (a) on the part of the assessee, the Income Tax Officer has in consequence of information in his possession reason to believe that income chargeable to tax has escaped assessment for any assessment year, 5 ITA No. 1590 & 1591/Kol/2024 West Bengal Electronics Industry Development Limited

West Bengal Electronics Industry Development Corporation Limited, Kolkata vs. D.C.I.T./A.C.I.T., Circle - 2(1), Kolkata

The appeal of the assessee is allowed

ITA 1590/KOL/2024[2012-2013]Status: DisposedITAT Kolkata07 Jan 2026AY 2012-2013

Section 143(3)Section 147Section 148Section 24(1)Section 250

Kaishar Interiors Private Limtied, Mumbai vs. Deputy Commissioner of Income Tax Circle 4(2)(2), Mumbai

Accordingly Ground No.16 raised by the Assessee is allowed

ITA 5665/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh Kukreja &For Respondent: Shri Hemanshu Joshi

Section 143(3)Section 147Section 148Section 14A

dated 18.03.2015 solely based on information from the Sales Tax Department without drawing a live link between material and reasons to believe. 6. On the facts and circumstances of the case and in law, the Ld AO erred in issuing notice u/s 148 of the Act dated 18.03.2015 based ... 27430671000V KARNI AADCK4458N 11,24,998 GRANIMARMO PRIVAE LIMITED Total 49,93,566 3. In view of the facts mentioned above, I have reasons to believe that the assessee has failed to disclose fully and truly all material facts necessary for assessment. Thus, I have reason to believe that

Ashish Girish Jain, Mumbai vs. ITO, Ward 42(1)(1), Mumbai

ITA 5328/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajesh ShahFor Respondent: Shri Pradipsinh Saktavat

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

Year 2010- 2011 from Mani Prabha Impex Pvt. Ltd., one of the group concerns of Dharmichand Jain Group. Accordingly, the Assessing Officer had reasons to believe that an amount of INR.15,00,000/- is simply an accommodation entry and income chargeable to tax amounting to INR.15,00,000/- had escaped ... carried out by these parties with their customers and they provide only accommodation entries of sales/loans after charging small commission. Hence, I have reasons to believe that income chargeable to tax to the extent of Rs. 15,00,000/-has escaped assessment by reason of the failure on the part

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, Appeal of the Assessee is allowed

ITA 5053/DEL/2025[2014-15]Status: DisposedITAT Delhi07 Jan 2026AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 144BSection 147Section 148Section 148ASection 250Section 68

erred in confirming the order dated 19-05-23, as proceeding initiated u/s 147 of the Act is without there being any reason to believe that income has escaped assessment. 6. Ld. CIT(A) has erred in confirming the order dated 19-05-23, as order passed u/s 147 r.w.s

M/S Jhs Svendgaard Laboratories Ltd., New Delhi vs. DCIT CC-31, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3454/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Jhs Svendgaard Vs. Dcit Laboratories Ltd. B1/E-23, Central Circle-31, New Mohan Cooperative Delhi Tuhglakabad, Badarpur, New Delhi New Delhi Pan: Aabcj5766G Appellant Respondent Assessee By Sh. Gaurav Jain, Adv & Sh. Tarun Chanana, Adv Revenue By Ms.Amisha S. Gupt, Cit (Dr) Date Of Hearing 09/10/2025 Date Of Pronouncement 07/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-30, New Delhi [‘Ld. Cit(A)’

Section 147Section 148Section 151ASection 37

escapement of income. Mere receipt of general or unverified information cannot, by itself, justify the reopening of assessment or sustain an addition. The "reason to believe" contemplated under Section 147 requires the AO to form an independent belief founded on relevant and verifiable material that bears a live link with