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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

Shree Ginger Enterprises Ltd., Mumbai vs. DCIT - CC- 5(3), Mumbai

In the result, all the appeals by the assessee are partly allowed for statistical purpose

ITA 6377/MUM/2018[2015-16]Status: DisposedITAT Mumbai19 Oct 2022AY 2015-16

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Manoj Kumar
Section 133ASection 143(2)Section 147Section 148Section 250

paid to bank on the funds utilized on the purchases of fabrics and fixed assets. On the bases of above I have the reason of believe the income of Rs. 132 Cr. has escaped the assessment for AY 2009 10 within the meaning of section ... observed as under: “16. Section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word "reason" in the phrase "reason to believe" would mean cause or justification

Shree Ginger Enterprises Ltd, Mumbai vs. DCIT Cen Cr 5(3), Mumbai

In the result, all the appeals by the assessee are partly allowed for statistical purpose

ITA 1334/MUM/2018[2014-15]Status: DisposedITAT Mumbai19 Oct 2022AY 2014-15

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Manoj Kumar
Section 133ASection 143(2)Section 147Section 148Section 250

paid to bank on the funds utilized on the purchases of fabrics and fixed assets. On the bases of above I have the reason of believe the income of Rs. 132 Cr. has escaped the assessment for AY 2009 10 within the meaning of section ... observed as under: “16. Section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word "reason" in the phrase "reason to believe" would mean cause or justification

Shree Ginger Enterprises Ltd, Mumbai vs. DCIT Cen Cr 5(3), Mumbai

In the result, all the appeals by the assessee are partly allowed for statistical purpose

ITA 1333/MUM/2018[2013-14]Status: DisposedITAT Mumbai19 Oct 2022AY 2013-14

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Manoj Kumar
Section 133ASection 143(2)Section 147Section 148Section 250

paid to bank on the funds utilized on the purchases of fabrics and fixed assets. On the bases of above I have the reason of believe the income of Rs. 132 Cr. has escaped the assessment for AY 2009 10 within the meaning of section ... observed as under: “16. Section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word "reason" in the phrase "reason to believe" would mean cause or justification

Shree Ginger Enterprises Ltd, Mumbai vs. DCIT Cen Cr 5(3), Mumbai

In the result, all the appeals by the assessee are partly allowed for statistical purpose

ITA 1332/MUM/2018[2011-12]Status: DisposedITAT Mumbai19 Oct 2022AY 2011-12

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Manoj Kumar
Section 133ASection 143(2)Section 147Section 148Section 250

paid to bank on the funds utilized on the purchases of fabrics and fixed assets. On the bases of above I have the reason of believe the income of Rs. 132 Cr. has escaped the assessment for AY 2009 10 within the meaning of section ... observed as under: “16. Section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word "reason" in the phrase "reason to believe" would mean cause or justification

Shree Ginger Enterprises Ltd, Mumbai vs. DCIT Cen Cr 5(3), Mumbai

In the result, all the appeals by the assessee are partly allowed for statistical purpose

ITA 1331/MUM/2018[2010-11]Status: DisposedITAT Mumbai19 Oct 2022AY 2010-11

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Manoj Kumar
Section 133ASection 143(2)Section 147Section 148Section 250

paid to bank on the funds utilized on the purchases of fabrics and fixed assets. On the bases of above I have the reason of believe the income of Rs. 132 Cr. has escaped the assessment for AY 2009 10 within the meaning of section ... observed as under: “16. Section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word "reason" in the phrase "reason to believe" would mean cause or justification

Shree Ginger Enterprises Ltd, Mumbai vs. DCIT Cen Cr 5(3), Mumbai

In the result, all the appeals by the assessee are partly allowed for statistical purpose

ITA 1330/MUM/2018[2009-10]Status: DisposedITAT Mumbai19 Oct 2022AY 2009-10

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Manoj Kumar
Section 133ASection 143(2)Section 147Section 148Section 250

paid to bank on the funds utilized on the purchases of fabrics and fixed assets. On the bases of above I have the reason of believe the income of Rs. 132 Cr. has escaped the assessment for AY 2009 10 within the meaning of section ... observed as under: “16. Section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word "reason" in the phrase "reason to believe" would mean cause or justification

Shree Ginger Enterprises Ltd, Mumbai vs. DCIT Cen Cr 5(2), Mumbai

In the result, all the appeals by the assessee are partly allowed for statistical purpose

ITA 2641/MUM/2017[2012-13]Status: DisposedITAT Mumbai19 Oct 2022AY 2012-13

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Manoj Kumar
Section 133ASection 143(2)Section 147Section 148Section 250

paid to bank on the funds utilized on the purchases of fabrics and fixed assets. On the bases of above I have the reason of believe the income of Rs. 132 Cr. has escaped the assessment for AY 2009 10 within the meaning of section ... observed as under: “16. Section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word "reason" in the phrase "reason to believe" would mean cause or justification

Ganesh Chhganlal Jain, Mumbai vs. CIT (A), NFAC, Delhi

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

ITA 2101/MUM/2022[2012-13]Status: DisposedITAT Mumbai18 Oct 2022AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13 Ganesh Chhganlal Jain, Cit (A) Nfac, Plot No. 899 Jassawala Wadi, Delhi. Juhu Tara Road, Juju, Vs. Andheri West, Mumbai-400049. Pan No. Aanpj 1550 D Appellant Respondent Assessee By : Mr. Pramod Kumar Parida, Ar Revenue By : Mr. Sanyam Suresh Joshi, Dr Date Of Hearing : 12/10/2022 Date Of Pronouncement : 18/10/2022

For Appellant: Mr. Pramod Kumar Parida, ARFor Respondent: Mr. Sanyam Suresh Joshi, DR
Section 143(1)Section 148

during F.Y. 2011-12 in the aforesaid penny 12 in the aforesaid penny scrip: VMS Industries Ltd. Since there was a reason to believe scrip: VMS Industries Ltd. Since there was a reason to believe scrip: VMS Industries Ltd. Since there was a reason to believe that substantial income

Sangeetkumar Sawarmal Hisaria, Mumbai vs. Dy CIT -CC-2(4), Mumbai

ITA 785/MUM/2021[2011-12]Status: DisposedITAT Mumbai17 Oct 2022AY 2011-12
Section 132Section 143(3)Section 147Section 148Section 153A

purchases from hawala dealers for a sum of Rs. 8,57,78,280/-. In the light of above facts and detailed findings, have reason to believe that Rs.8,57,75,280/- has escaped assessment within the meaning assigned in the provision of section 147 of the Income ... availed accommodation entries, in the form of bogus purchase, from hawala dealers, for a sum of 8,57,78,280/-. Basis of forming reason to believe and details of escapement of Income: In the light of above facts and detailed findings, I have Reason to believe that

Keystone Realtors Private Limited, Mumbai vs. Deputy Commissioner of Income Tax - Central Circle 2(4), Mumbai

In the result, appeal filed by the assessee is dismissed

ITA 951/MUM/2018[2007-08]Status: DisposedITAT Mumbai17 Oct 2022AY 2007-08

Bench: Shri Aby T Varkey & Shri Gagan Goyal

For Appellant: Sh. Naresh KumarFor Respondent: Sh. Anil. S. Sant, Sr.DR
Section 115JSection 132(1)Section 143Section 143(3)Section 148Section 153A

proceedings u/s.147 in nutshell are summarized herein below: (a) It is contended that Proceedings u/s.147 can be initiated only if the AO has reason to believe that income chargeable to tax has escaped assessment and AO must have reason to believe that such escapement has occurred by reason of either ... assessee company and shamness of the Agreement was too obvious from its various clauses. Based on these details Prima-facie reasons to believe was formed in the mind of AO that payment to Shri Jitendra Awhad/M/s. Jitnat Infrastructure Pvt. Ltd. is not allowable u/s. 37 as it is not wholly

M/S. Kwality Biscuits Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 11(5), Bangalore

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

ITA 675/BANG/2020[2006-07]Status: DisposedITAT Bangalore17 Oct 2022AY 2006-07

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2006-07

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Smt. Priyadarshini Baseganni, Addl.CIT(DR)(ITAT)
Section 115Section 115JSection 143(3)Section 147Section 148Section 250Section 55(2)

first look at the relevant provisions of section 147 which reads as follows:- Page 11 of 16 “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 ... from 1-4-1989], they are given a go-by and only one condition has remained, viz., that where the Assessing Officer has reason to believe that income has escaped assessment, confers jurisdiction to re-open the assessment. Therefore, post 1-4-1989 , power to reopen is much wider. However

Globalworth Securities Ltd., Mumbai vs. ACIT, Circle 4(1)(1), Mumbai

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

ITA 620/MUM/2022[2012-13]Status: DisposedITAT Mumbai14 Oct 2022AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2012-13 Globalworth Securities Limited, Acit, Circle-4(1)(1), 716, Neelkanth Corporate Park, Room No. 640, 6Th Floor, Kirol Road, Vidyavihar (West), Vs. Aayakar Bhavan, Maharshi Mumbai-400086. Karve Road, Mumbai-400020. Pan No. Aadcg 7624 G Appellant Respondent Assessee By : Mr. Aditya Ramachndran, Ar Revenue By : Mr. Ashok Kumar Kardam, Cit-Dr Date Of Hearing : 07/10/2022 Date Of Pronouncement : 14/10/2022

For Appellant: Mr. Aditya Ramachndran, ARFor Respondent: Mr. Ashok Kumar Kardam, CIT-DR
Section 148Section 148(2)

Scan Steels Ltd. (₹1,98,000/-)” was received and therefore, was received and therefore, the Assessing Officer the Assessing Officer recorded another reasons to believe that income escaped in relation another reasons to believe that income escaped in relation another reasons to believe that income escaped in relation M/s Globalworth ... namely M/s Nivyah Infrastructure & Telecom Services Ltd. Obviously, this reason Infrastructure & Telecom Services Ltd. Obviously, this reason Infrastructure & Telecom Services Ltd. Obviously, this reason to believe which was supplied to the assessee supplied to the assessee was not duly approved not duly approved by the appropriate authority. Further, the scrip

Sunita Chaudhry, Mumbai vs. ITO WD 18(3) (4), Mumbai

In the result, appeal by the assessee is allowed

ITA 143/MUM/2022[2013-14]Status: DisposedITAT Mumbai13 Oct 2022AY 2013-14

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Vimalchand PunmiyaFor Respondent: Shri Ajay Singh
Section 10(38)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 250

impugned assessment order passed by the learned assessing officer (Ld. A.O) without having any lawful jurisdiction as a. there were no cogent reasons to believe that the Income had escaped assessment and accordingly the provisions of section 147 & 148 were not applicable to the case, b. the objections raised ... examined these evidence vis-à-vis the return of income of the assessee. After appraisal of these material on record, there is enough reason to believe that not only the claim of exemption under section 10(38) by the assessee is prima facie bogus but also by making such bogus

ITO 1(2)(3), Mumbai vs. M Pallonji Enerprises P. Ltd, Mumbai

In the result, the appeal of the In the result, the appeal of the Revenue is dismissed whereas dismissed whereas cross objection of the assessee is allowed

ITA 1907/MUM/2017[2009-10]Status: DisposedITAT Mumbai13 Oct 2022AY 2009-10

Bench: Shri Amit Shukla () & Shri Om Prakash Kant () Assessment Year: 2009-10 Ito-1(2)(3), M/S M Pallonji Enterprises Pvt. Ltd., R. No. 527, 5Th Floor, Aayakar 46/A, Cawasji Patel Street, Fort, Bhavan, M.K. Road, Vs. Mumbai-400020. Mumbai-400020. Pan No. Aafcm 3357 A Appellant Respondent

For Appellant: Dr. K. Shivaram, Sr. Adv. &For Respondent: Mr. T. Shankar, CIT-DR
Section 68

Subsequently, the Assessing Officer reopened the assessment Nil. Subsequently, the Assessing Officer reopened the assessment after recording reasons to bel after recording reasons to believe that income escaped assessment ieve that income escaped assessment and issued notice under section 148 issued notice under section 148 of the Act on 28/03/2014 ... within a period of four years, then what is required is within a period of four years, then what is required is 'reason to believe' but not established fact of escapement of income. At this stage believe' but not established fact of escapement of income. At this stage believe

R.Rajagopal Tondaiman, Trichy vs. DCIT Central Circle-1, Trichy

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

ITA 525/CHNY/2020[2010-11]Status: DisposedITAT Chennai12 Oct 2022AY 2010-11

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.525/Chny/2020 िनधा"रण वष"/Assessment Year: 2010-11 Sri R. Rajagopal Tondaiman, Vs. The Deputy Commissioner Of Old No. 4-D, New No. 22, Collector Income Tax, Office Road, Trichy 620 001. Central Circle 1, Trichy. [Pan:Afbpr0712E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Viswanathan, Ca ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 15.09.2022 घोषणा की तारीख /Date Of Pronouncement : 12.10.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Trichy, Dated 30.12.2019 Relevant To The Assessment Year 2010-11. 2. Facts Are, In Brief, That The Assessee Is A Hereditary Of Raja Of Pudukottai & Stated That He Is Assessed To Tax In The Status Of Huf & Individual. The Property At Cenotaph Road, Chennai Was Given To M/S. Doshi Housing Ltd. On A Development Agreement Entered Into On 30.01.2006 Through A Power Of Attorney. The Assessing Officer Has 2

For Appellant: Shri R. Viswanathan, CAFor Respondent: Shri G. Johnson, Addl. CIT
Section 143(3)Section 147Section 148Section 54F

into a purchase agreement only after 2 years. Hence, the deduction claimed u/s 54F needs to be brought to tax. Therefore, I have reason to believe that this income has escaped assessment and the case needs to be reopened u/s 147 of the IT Act. Necessary approval may kindly ... quote)"Therefore, post 1-4-1989, power to reopen is much wider. However, one needs to give a schematic interpretation to the words "reason to believe" failing which, we are afraid, section 147 would give arbitrary powers to the Assessing Officer to re-open assessments on the basis of "mere

S.Victor Arockiam, Ariyalur vs. DCIT Central Circle-1, Trichy

The appeal stand allowed in terms of our above order

ITA 348/CHNY/2020[2012-13]Status: DisposedITAT Chennai12 Oct 2022AY 2012-13

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Viswanathan (CA) – Ld. ARFor Respondent: Shri Guru Bashyam (CIT) –Ld. DR
Section 143(3)Section 153ASection 40A(3)

context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court

Phoenix International Freight Services P. Ltd( Now Known As As C.H. Robinson International (India) P.Ltd, Mumbai vs. DCIT RG 2(1), Mumbai

In the result, the appeal is partly allowed

ITA 3206/MUM/2015[2007-08]Status: DisposedITAT Mumbai12 Oct 2022AY 2007-08

Bench: Shripavankumargadale,Judicialmember & Shri Amarjit Singhm/S. Phoenix Vs. Dy. Commissioner Of International Freight Income Tax, Range-2(1) Services Pvt. Ltd. (Now Mumbai-400050 Known As C.H. Robinson International (India) Pvt. Ltd.) Excom House 7, Saki Vihar Road, Andheri (East) Mumbai-400072 Pan No.Aabce0443R Appellant Respondent

Section 142(1)Section 143(3)Section 148Section 271Section 271(1)Section 271(1)(c)Section 274

beneficiary. The Assessing officer (AO) after recording the reasons that the fraudulent transactions of accommodation entries were reported by investigating wing and has reason to believe that the income has escaped the Assesseement and issued notice under Section 148 of the Act. In reply, the assessee has filed a letter

Ayyappa Seva Samgham Bombay, Mumbai vs. Commissioner of Income Tax (A)-53, Mumbai

In the result of the appeal filed by the assessee is allowed

ITA 699/MUM/2022[2010-11]Status: DisposedITAT Mumbai07 Oct 2022AY 2010-11
Section 11(1)(a)Section 12ASection 143(3)Section 147Section 148Section 250

that the impugned amount was not proportionate to the gross receipts filed by the assessee in its return of income. The A.O. upon reason to believe that income has escaped assessment reopened the assessee’s case and assessment order u/s 143(3) of the Act dated ... same as gross receipts. Further to this Ld. AR submitted that the AO has reopened the assessment on mere suspicion and not on reason to believe that income has escaped assessment. The Ld. AR relied on the decision of Hon’ble Apex Court in Lakhamani Niwaldas to substantiate this proposition

Wilfred D'Souza, Mangaluru vs. Assistant Commissioner of Income Tax, Central Circle-2, Mangaluru

In the result, ITA Nos.323 & 324/Bang/2022 are allowed and the appeals filed by the assessee in ITA Nos

ITA 328/BANG/2022[2013-14]Status: DisposedITAT Bangalore07 Oct 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Smt. S. Praveena, D.R
Section 132Section 143Section 153ASection 246A

pursuant to such illegal search action are bad in law and void ab- initio. 4.2 Ld. A.R. further submitted that reason to believe is sine qua non for conducting search and valid search only can lead to assessment under section 153 A of the Act. Reliance is placed ... cannot be asked to produce records to show information having been received. Sriram Jaiswal Vs Union of India & Ors.(All.) 176 ITR 261 • "Reason to believe" need not be disclosed when a mere allegation made by petitioner — Illegality of search does not vitiate evidence collected during search. Dr. Pratap Singh

Wilfred D'Souza, Mangaluru vs. Assistant Commissioner of Income Tax, Central Circle-2, Mangaluru

In the result, ITA Nos.323 & 324/Bang/2022 are allowed and the appeals filed by the assessee in ITA Nos

ITA 327/BANG/2022[2012-13]Status: DisposedITAT Bangalore07 Oct 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Smt. S. Praveena, D.R
Section 132Section 143Section 153ASection 246A

pursuant to such illegal search action are bad in law and void ab- initio. 4.2 Ld. A.R. further submitted that reason to believe is sine qua non for conducting search and valid search only can lead to assessment under section 153 A of the Act. Reliance is placed ... cannot be asked to produce records to show information having been received. Sriram Jaiswal Vs Union of India & Ors.(All.) 176 ITR 261 • "Reason to believe" need not be disclosed when a mere allegation made by petitioner — Illegality of search does not vitiate evidence collected during search. Dr. Pratap Singh