“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

DCIT, New Delhi vs. M/S Chotti Leasing & Finance Pvt. Ltd., New Delhi

In the result, the appeals filed by the Revenue in ITA No

ITA 6211/DEL/2015[2007-08]Status: DisposedITAT Delhi23 Jan 2023AY 2007-08

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR

Section 147Section 250Section 4

intermediary companies used by Shri Aseem Kumar Gupta for providing accommodation entries as admitted by Shri Aseem Gupta. I, therefore, have reasons to believe that this amount of Rs.8,60,27,610/- represents income of the assessee chargeable to tax which has escaped assessment for A.Y. 2008-09. The necessary ... eyes of law or in the facts of the present case. Language of provisions of section 147 which provides:- “If the AO has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to provisions of Section 148 to 153, assess

Income Tax Officer, Ward 2(3)(7), Surat vs. Shri Anil Pukhraj Jain, Surat

In the result the ground No

ITA 89/SRT/2017[2008-09]Status: DisposedITAT Surat23 Jan 2023AY 2008-09

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.89/Srt/2017 िनधा"रण वष"/Assessment Year: (2008-09) (Physical Court Hearing) Income Tax Officer, Ward-2(3)(7), Anil Pukhraj Jain, Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206-2Nd Floor, Tulsi Building, Bhavan, Adajan, Surat-395009 Vs. Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. (Appellant) (Respondent)/ "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q ""या"ेप सं Cross Objection No.10/Srt/2021 (A/O Ita No.89/Srt/2017) िनधा"रण वष"/Assessment Year: (2008-09) Anil Pukhraj Jain, Income Tax Officer, Ward-2(3)(7), Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206- 2Nd Floor, Tulsi Building, Vs. Bhavan, Adajan, Surat-395009 Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. Appellant/Co-Objector (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q िनधा"रती क" ओर से /Assessee By Shri Sapnesh R. Sheth, Ca राज"व क" ओर से /Respondent By Shri Ashok B. Koli, Cit-Dr सुनवाई क" तारीख/Date Of Hearing 23/12/2022 उ"ोषणा क" तारीख/Date Of Pronouncement 23/ 01/2023

Section 143(3)

89/SRT/2017 & CO. 10/SRT/2021/AY.2008-09 Anil Pukhraj Jain specific and important information received as above, has been subjected to the verification. After formation of reason to believe that the purchase bill of diamonds received by assessee firm are bogus in nature and escaped assessment due to failure on the part ... bare provisions of section 147 of the Income Tax Act, which are reproduced below: “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

Shri Dilipsinh Harubha Parmar, Limlipa, Muli, Dist. Surendranagar vs. The Income Tax Officer, Ward-4, Surendranagar

In the result, the appeal of the assessee is allowed

ITA 285/RJT/2019[2011-12]Status: HeardITAT Rajkot20 Jan 2023AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

For Appellant: NoneFor Respondent: Shri B. D. Gupta, Sr. D.R

Section 148Section 69

file return of income. During the course of verification the assessee failed to furnish any reply therefore the Assessing Officer had reason to believe that income amounting to Rs. 16,66,000/- deposited in cash in saving bank account is escaped the assessment. After recording the reasons dated

Gaurav Singhal, New Delhi vs. ITO, Ward-17(4), New Delhi

ITA 576/DEL/2019[2010-11]Status: DisposedITAT Delhi18 Jan 2023AY 2010-11

Bench: Sh. Pradip Kumar Kedia & Sh. Anubhav Sharmagaurav Singhal Vs. Ito, 149, Tarun Enclave, Ward-17(4), Pitampura, C.R.Building, New Delhi-110034 New Delhi-110002 Pan : Aohps3787D (Appellant) (Respondent)

Section 10(38)Section 143(2)Section 147Section 148Section 68

Rs.4,882/- which shows that the financial position is not very sound. Keeping in view of the facts mentioned above , I have reason to believe that the income of Rs. 3,50,280/- has escaped assessment on the reason of the failure on the part of the assessee to disclose ... disclose fully and truly all material facts necessary for assessment. Apparently the Ld. AO has merely expressed reason to suspect and not cited reason to believe that income chargeable to tax has escaped assessment. The Assessing Officer has no power to review; he has the power to re-assess

Smt. Sumariben R. Odedara, Porbandar vs. The Income Tax Officer, Ward-2(3), Porbandar

In the result, the appeal filed by the Assessee is hereby allowed

ITA 288/RJT/2019[2010-11]Status: DisposedITAT Rajkot18 Jan 2023AY 2010-11

Bench: Ms. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(3)Section 148Section 44A

State Bank of India saving account at Porbandar Branch during the Financial Year 2009-10. Therefore the Assessing Officer had reason to believe that income chargeable to tax has escaped assessment and issued a notice u/s. 148 of the Act on 31.03.2017. In response, the assessee filed her Return

Bikash Deb, Bhubaneswar vs. DCIT Circle- 2(1), Bhubaneswar

In the result, both the appeals of the assessee stand allowed

ITA 357/CTK/2019[2009-10]Status: DisposedITAT Cuttack17 Jan 2023AY 2009-10

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita Nos.357 & 388/Ctk/2019 /2019 Assessment Years : 2009-10 & 2010 10 & 2010-11 Bikash Dev Bikash Dev, Flat No.101, Vs. Dcit, Circle Dcit, Circle-2(1), Haraprity Haraprity Apar Apartment, Bhubaneswar. Bhubaneswar. Vivekananda Vivekananda Marg, Marg, Old Old Town, Bhubaneswar. Town, Bhubaneswar. Pan/Gir No. Pan/Gir No.Ahepd 0737 C (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri K.K.Bal, Adv K.K.Bal, Adv Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 17/01 01/2023 Date Of Pronouncement : 17/01 /01/2023 O R D E R

For Appellant: Shri K.K.Bal, AdvFor Respondent: Shri M.K.Gautam

Section 143(1)Section 147Section 148Section 149Section 21(5)

assessee has not shown the above alleged income in the return of income for the assessment year 2009-10. Hence, I have reason to believe that there is a considerable amount of taxable income, which escaped assessment. Therefore, the case of the assessee requires to be reopened u/s.147 ... High Court has held that as the notice itself does not indicate the approximate amount of income, which the Assessing Officer has reason to believe has escaped assessment nor does it quantify the extent to which the share premium received was in excess of intrinsic value, which has escaped assessment

The Deputy Commisioner of Income Tax, Circle- 3(1), Raipur vs. M/S Sankalp Realities, Raipur

In the result, appeal of the revenue is dismissed in terms of our aforesaid observations

ITA 47/RPR/2018[2009-10]Status: DisposedITAT Raipur13 Jan 2023AY 2009-10

Bench: Shri Ravish Sood & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.47/Rpr/2018 Co. No.01/Rpr/2018 "नधा"रण वष" / Assessment Year : 2009-10 The Deputy Commissioner Of Income Tax, Circle-3(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Sankalp Realities, 28/620 Anand Niwas, Shankar Nagar, Raipur (C.G.) Pan: Abcsf6391P ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri G.N Singh, Sr. DR

Section 143(3)Section 147Section 148

notice issued u/s.148 of the Act. Thereafter, the A.O at the request of the assessee made available to it a copy of the “reasons to believe” on the basis of which its case was reopened by him u/s.147 of the Act. Objections raised by the assessee as regards the validity ... w.e.f. 1st April, 1989), they are given a go by and only one condition has remained, viz., that where the AO has reason to believe that income has escaped assessment, confers jurisdiction to reopen the assessment. Therefore, post 1st April, 1989, power to reopen is much wider. However, one needs

ITO, Ward-2(3)(7), Surat vs. Anshuman Ramdayalji Kumawat, Surat

In the result the ground No

ITA 22/SRT/2020[2009-10]Status: DisposedITAT Surat13 Jan 2023AY 2009-10

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar

Section 132(4)Section 144

Wing that they had given bogus purchase bills to many persons including the appellant. Based on this report, the Id. assessing officer had 'reason to believe' that income was escaped the assessment. In the facts and circumstances, I am convinced that the re - opening in this case is justified. Further ... accommodation entry provider admitted before investigation wing that he has given such entry to various persons; based on such report the AO has reason to believe that the income of the assessee has escaped assessment and thus the action of AO in reopening is justified. 18. We find that

ITO, Ward-2(3)(7), Surat vs. Anshuman Ramdayalji Kumawat, Surat

In the result the ground No

ITA 21/SRT/2020[2008-09]Status: DisposedITAT Surat13 Jan 2023AY 2008-09

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar

Section 132(4)Section 144

ITO, Ward 2(3)(8), Surat vs. Mukesh Mahavirprasad Sen, Surat

In the result the ground No

ITA 16/SRT/2020[2009-10]Status: DisposedITAT Surat13 Jan 2023AY 2009-10

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar

Section 132(4)Section 144

ITO, Ward 2(3)(8), Surat vs. Mukesh Mahavirprasad Sen, Surat

In the result the ground No

ITA 15/SRT/2020[2008-09]Status: DisposedITAT Surat13 Jan 2023AY 2008-09

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar

Section 132(4)Section 144

Income Tax Officer, Ward 2(3)(8), Surat vs. Shri Rajesh Kumar Pamecha, Ajmer

In the result the ground No

ITA 87/SRT/2017[2007-08]Status: DisposedITAT Surat13 Jan 2023AY 2007-08

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar

Section 132(4)Section 144

Hetram Bokan, Gurgaon vs. ITO Ward - 2(1), Gurgaon

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

ITA 1688/DEL/2019[2013-14]Status: DisposedITAT Delhi12 Jan 2023AY 2013-14

Bench: Shri Kul Bharat[Assessment Year : 2013-14] Hetram Bokan, Vs Ito, 226, 2Nd Floor, Jmd Megapolis, Ward-2(1), Sohna Road, Sector-48, Gurgaon. Gurgaon, Haryana-122001. Pan-Amkpb3430B Appellant Respondent Appellant By None Respondent By Shri Ramdhan Meena, Sr.Dr Date Of Hearing 12.01.2023 Date Of Pronouncement 12.01.2023

Section 139(4)Section 147Section 234A

cash deposits of huge amount of Rs. 41,50,000/- in the bank account by the appellant. There was therefore a prima- facie reason to believe that the appellant had income which had escaped assessment. It is a settled law now that at the time of issue of notice ... only on prime-facie reason to believe that the income had escaped assessment is required. At the stage of issue of notice, the only question is whether there was belief. Whether the materials would conclusively prove the escapement is not the concern at that stage. This is so because

Pradeep Kumar, Jhujhunu vs. ITO Ward -2, Jhujhunu

In the result, appeal of the assessee is allowed

ITA 370/JPR/2022[2011-12]Status: DisposedITAT Jaipur11 Jan 2023AY 2011-12

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sharwan Kumar Gupta, AdvocateFor Respondent: Ms Monisha Choudhary (JCIT)

Section 142(1)Section 143(3)Section 147Section 148Section 234A

that “Since, the assessee neither filed his return of income nor furnished any evidence/documents/explanation in regard to such commodity transaction therefore I have reasons to believe that the transaction were made out of his undisclosed income and profit/loss on such transaction remained explained by the assessee hence I have reason ... that “Since, the assessee neither filed his return of income nor furnished any evidence/documents/explanation in regard to such commodity transaction therefore I have reasons to believe that the transaction were made out of his undisclosed income and profit/loss on such transaction remained explained by the assessee hence I have reason

Income Tax Officer, Ward - 2(3)(6), Surat vs. Shri Abhishek Navnitkumar Doshi, Surat

In the result the ground No

ITA 38/SRT/2022[2012-13]Status: DisposedITAT Surat09 Jan 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 21/Srt/2022 Assessment Year: (2012-13) (Physical Court Hearing) Abhishek Navnitkumar Doshi, Vs. The Ito, Ward-2(3)(7), 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) आयकर अपील सं./Ita No.38/Srt/2022 Assessment Year: (2012-13) The Ito, Ward-2(3)(6), Vs. Abhishek Navnitkumar Doshi, 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 28/12/2022 09/01/2023 Date Of Pronouncement

Section 132Section 143(3)Section 148

Mimixa Diam, Mother Exports, Naman Exports, Rahul Exports and Dax Diamonds to the tune of Rs.2,50,25,283/-. 6. Thus, there was reason to believe that income to the tune of Rs.2,50,25,203/- has escaped the assessment for A.Y.2012-13. With prior permission from Pr.CIT-2, Surat vides ... accommodation entry provider admitted before investigation wing that he has given such entry to various persons; based on such report the AO has reason to believe that the income of 21 & 38/SRT/2022/AY.2012-13 Abhishek Navnitkumar Doshi the assessee has escaped assessment and thus the action of AO in reopening is justified

Abhishek Navnitkumar Doshi, Surat vs. Income Tax Officer, WD. 2(3)(7), Surat

In the result the ground No

ITA 21/SRT/2022[2012-13]Status: DisposedITAT Surat09 Jan 2023AY 2012-13

Section 132Section 143(3)Section 148

M/S Direct Logistic India P. Ltd., Mumbai vs. CIT (Appeals)-16, Mumbai

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

ITA 805/MUM/2020[2009-10]Status: DisposedITAT Mumbai30 Dec 2022AY 2009-10

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Direct Logistics India Pvt. Ltd., V. Income Tax Officer – 9(3)(3) 2102 B-Wing, Oberoi Park View Room No. 471 Thakur Village, Kandivali (E) Aayakar Bhavan, M.K. Road Mumbai - 400101 Mumbai - 400020 Pan: Aaacd8774D (Appellant) (Respondent) Assessee By : Shri Ravi Sawana & Shri Dinesh Kukreja Department By : Smt Mahita Nair

For Appellant: Shri Ravi Sawana &For Respondent: Smt Mahita Nair

Section 131Section 133(6)Section 143(1)Section 143(2)Section 147Section 148Section 68

same company has provided accommodation entries to the assessee. 3. Based on the above information on record Assessing Officer had reason to believe that income has escaped the assessment within the meaning of Section 147 of the Act. Accordingly, notice u/s. 148 of the Act dated 30.03.2016 was issued

Maharashtra State Electricity Transmission Company Ltd., Mumbai vs. The Income Tax Officer, Ward-14(2)(3), Mumbai

In the result, the appeal of the assessee is al

ITA 990/MUM/2022[2011-12]Status: DisposedITAT Mumbai29 Dec 2022AY 2011-12

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-12 Maharashtra State Electricity Income-Tax Officer, Ward Transmission Company Ltd., 14(2)(3), Plot No. C-19 E Block, Vs. Aayakar Bhavan, Maharshi Prakashganga, Bandra-Kurla Karve Road, Complex, Bandra (East), Mumbai-400020. Mumbai-400051. Pan No. Aaecm 2936 N Appellant Respondent Assessee By : Mr. Ketan Ved, Ar Revenue By : Mr. Harishankar Lal, Dr : Date Of Hearing 15/11/2022 Date Of Pronouncement : 29/12/2022

For Appellant: Mr. Ketan Ved, ARFor Respondent: Mr. Harishankar Lal, DR

Section 148

inter alia provides that if the 5. Section 147 of the Act inter alia provides that if the Assessing Officer has reason to believe that any income Assessing Officer has reason to believe that any income Assessing Officer has reason to believe that any income chargeable to tax has escaped ... assessee, and form C& AG report and comments of the assessee, and form C& AG report and comments of the assessee, and form reason to believe that income escaped assessment. In absence of reason to believe that income escaped assessment. reason to believe that income escaped assessment. any such trigger

Neel Enterprises, Mumbai vs. I.T.O. Ward. 19(3)(4), Mumbai

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

ITA 2771/MUM/2022[2008-2009]Status: DisposedITAT Mumbai29 Dec 2022AY 2008-2009

Bench: Shri Pavan Kumar Gadaleneel Enterprises Vs. Ito, Ward – 19(3)(4) 209, 2Nd Floor, Konark 2Nd Floor, Matru Sharam, 156, Tardeo Mandir, Tardeo Road Mumbai – 400034 Mumbai. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagfn2816B Appellant .. Respondent Assessee By : Mr.Raj Kumar Singh.Ar Revenue By : Ms.Richa Gulati.Dr Date Of Hearing 22.12.2022 Date Of Pronouncement 22.12.2022 आदेश / O R D E R

For Appellant: Mr.Raj Kumar Singh.ARFor Respondent: Ms.Richa Gulati.DR

Section 143(2)Section 143(3)Section 148

Since the interest amount which was shown as be paid was not reflected in the profit and loss account, therefore the AO has reason to believe that the income has escaped the assessment and therefore the interest of Rs.6,23,304/- has to be treated as ineligible expenses and issued

Mamta Mehta, Mumbai vs. Income Tax Officer Ward 31(2)(3), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 1237/MUM/2022[2011-12]Status: DisposedITAT Mumbai29 Dec 2022AY 2011-12

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadale

For Appellant: Mr. Bhupendra Shah.ARFor Respondent: Mr. Tejinder Pal Singh Anand.DR

Section 10(38)Section 143(1)Section 143(3)Section 148Section 271BSection 274Section 44A

that the assessee has obtained accommodation entries of long term capital gains of shares in the F.Y 2010-11, therefore the AO has reason to believe that the income has escaped assessment and issued notice u/s 148 of the Act. In compliance to notice, the assessee has filed the details