“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

Deputy Commissioner of Income Tax, Cental Circle, Sambalpur vs. Smt. Indrani Patnaik, Rourkela

Appeals of the Revenue are dismissed

ITA 180/CTK/2020[209-10]Status: DisposedITAT Cuttack11 Dec 2025

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri S.C. Bhadra, ARFor Respondent: Shri Ashim Kumar Chakraborty, DR

Section 143(2)Section 147Section 148Section 271(1)(c)Section 37

Iron ore had escaped assessment. The AD accepted information from an outside source without subjecting it to a critical scrutiny and her "reason to believe that income had escaped assessment was not based on an independant application of mind. Hence, the re-assessment proceedings ... null and void. The AO did not have tangible material to form a ‘reason to believe’ that income for AY.- 2009-10 had escaped assessment. The Assessing Officer accepted the allegation made in the Justice M. B. Shah Commission report against the assessee without any independent application of mind

Deputy Commissioner of Income Tax, Cental Circle, Sambalpur vs. Smt. Indrani Patnaik, Rourkela

Appeals of the Revenue are dismissed

ITA 179/CTK/2020[2009-10]Status: DisposedITAT Cuttack11 Dec 2025AY 2009-10

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri S.C. Bhadra, ARFor Respondent: Shri Ashim Kumar Chakraborty, DR

Section 143(2)Section 147Section 148Section 271(1)(c)Section 37

Madhushree Enterprises, Kampli, Hospet vs. DCIT, Bengaluru

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

ITA 697/BANG/2024[2011-12]Status: DisposedITAT Bangalore11 Dec 2025AY 2011-12

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2011-12

For Appellant: NoneFor Respondent: Shri Muthu Shankar, CIT-DR

Section 142(1)Section 143(2)Section 144Section 148Section 276CSection 37(1)Section 41(1)

Ld.CIT(A) had not accepted the legal grounds raised by the assessee that the 148 notice was issued based on a valid reason to believe. The Ld.CIT(A) had also not accepted the ground that the recording of reasons to believe was not communicated to the assessee before passing

Baldev Singh, Village Jandli, Ambala vs. Income Tax Officer Ward-3, Ambala, Ambala Cantt

The appeal stand allowed

ITA 891/CHANDI/2025[2007-2008]Status: DisposedITAT Chandigarh10 Dec 2025AY 2007-2008

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.889/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2007-08) Shri Teja Singh Income Tax Officer C/O Rajiv Goel & Associates Ward-4 बनाम/ Vs. 179, Bank Road, Ambala Cantt. Ambala Cantt. Ambala (Haryana)-133 001 Haryana – 133 001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No. Bqzps-3706-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.891/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2007-08) Shri Baldev Singh Income Tax Officer C/O Rajiv Goel & Associates Ward-3 बनाम/ Vs. 179, Bank Road, Ambala Cantt. Ambala Cantt. Ambala (Haryana)-133 001 Haryana – 133 001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No. Brzps-4850-H (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ" कीओरसे/ Appellant By : Shri Rohit Goel (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2025

For Appellant: Shri Rohit Goel (CA) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR

Section 142(1)Section 143(3)Section 148

case where assessment has been made u/s 143(3), certain conditions are required to be satisfied viz. (i) Assessing Officer must have reason to believe that income chargeable to tax has escaped assessment, and (ii) he must also have reason to believe that such escapement occurred by reason of failure

Teja Singh, Ambala vs. Income Tax Officer, Ward-4, Ambala Cantt, Ambala

The appeal stand allowed

ITA 889/CHANDI/2025[2007-2008]Status: DisposedITAT Chandigarh10 Dec 2025AY 2007-2008

For Appellant: Shri Rohit Goel (CA) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR

Section 142(1)Section 143(3)Section 148

Venkata Rama Krishnam Raju Chintalapati, Hyderabad vs. DCIT., Circle 8(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 143/HYD/2025[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Us:

For Appellant: Shri KA Sai Prasad, CAFor Respondent: Shri Waseem UR Rehman

Section 147Section 148Section 148ASection 151

reasons, the same gave rise to numerous litigations and the reopening were challenged inter alia, on the grounds such as (1) no valid “reason to believe” (2) no tangible/reliable material /information in possession of the assessing officer leading to formation of belief that income has escaped assessment, (3) no enquiry

Income Tax Officer, Ward-1, Warangal vs. Shiva Kumar Thota, Warangal

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

ITA 996/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Mrs. U. Mini Chandran

Section 147Section 148Section 148ASection 43BSection 68

Aakanksha Gupta, Delhi vs. ITO Ward 69(1), New Delhi, Delhi

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

ITA 2763/DEL/2025[2017-18]Status: DisposedITAT Delhi10 Dec 2025AY 2017-18

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2763/Del/2025 िनधा"रणवष"/Assessment Year: 2017-18 बनाम Aakanksha Gupta, Income Tax Officer, C/O Ca Vaibhav Goel, Vs. Ward 69(1), 78, Navyug Market, 1St Floor, New Delhi. Ghazaibad, Uttar Pradesh. Pan No.Amhpg9430D अपीलाथ" Appellant ""यथ"/Respondent

Section 143(2)Section 144BSection 147Section 148Section 149Section 250Section 54

Income Tax Act, 1961 which was not existing as on 23.03.2021; - the amount of aggregate sale consideration recorded in reasons to believe was Rs.77 lacs without specifying the particulars like address of the property sold, name of the buyer, dates of transaction etc or supplying the basis of such information ... s.148/149/153, assessment is void ab initio and subsequent proceedings are illegal. 7. Because, notice u/s 148 is illegal being admittedly without supplying reason to believe with notice or within the period of limitation or even till the completion of assessment (reasons were specifically asked after complying with the notice

Girish Lahori, Gandhidham vs. Income Tax Officer Ward-1 Gandhidham, Gandhidham

In the result this appeal was allowed, the order of the High Court was set aside and the

ITA 283/RJT/2025[2010-11]Status: DisposedITAT Rajkot09 Dec 2025AY 2010-11

Bench: Dr. Arjun Lal Saini, Accountnt Member & Shri Dinesh Mohan Sinha, Judicial Membr

Section 144Section 147Section 148Section 234ASection 271(1)(c)Section 69

information was received, however, that some information has not been verified by the Assessing Officer, therefore, it was a borrowed satisfaction. When the “reason to believe” is not there, the reasons recorded by the Assessing Officer is bad in law and therefore, reopening of assessment under Section 147/148 ... wate, | NA { initiating prooseding AIPP = i oc tm belief that income has escaped assessment | As per annexure : A “ 3 ve. therefore, reason to believe that incoese 10 the extent of R&3,24,64,754/- has excaped from assess hin the meaning of Section

K.G.N.Enterprise, Veraval vs. Income Tax Officer, Veraval

In the result, appeal filed by the assessee is allowed

ITA 181/RJT/2025[2019-20]Status: DisposedITAT Rajkot09 Dec 2025AY 2019-20

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.181/Rjt/2025 िनधा"रण वष"/Assessment Year : 2019-20 K.G.N. Enterprise बनाम/ Income Tax Officer Al Iraki Bageraza Lucky Colony, Vs Ward – 4, Range 201, Junagarh, Ner Somnathtokish, Behind Amit Veraval Akela Clinic, Veraval, Gir Somnath, Gujarat - 362264 "ायीलेखासं./जीआइआरसं./Pan/Gir No.:Aatfk8798E (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri R. B. Shah, Ld. Ar राज"की ओर से / Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख /Date Of Hearing : 15/09/2025 घोषणा की तारीख /Date Of Pronouncement : 09/12/2025 आदेश/Order

For Appellant: Shri R. B. Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 139(1)Section 147Section 250

assessing officer 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, for that I rely ... notice under s. 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

ACIT, Central Circle-3, Patna vs. Smt. Sipra Gupta, Patna

In the result, the appeal of the Revenue is dismissed

ITA 71/PAT/2023[2017-18]Status: HeardITAT Patna09 Dec 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: S/Shri A.K. Rastogi &For Respondent: Shri Md. AH Chowdhary, DR

Section 143(3)Section 147Section 148

proprietorship concern. It would now necessary to examine whether there was any relevant material available before the learned AO to form reason to believe that income had escaped assessment. In the reason recorded the AO has merely reproduce the fact of cash deposit and the details of explanation submitted ... quote any precedence to justify huge cash deposit from sale proceeds during the period. With these reasons, the AO has apparently formed his reasons to believe that the income has escaped assessment. Undisputedly in this case, the AO had the audit report, the ITR for last several AY's wherein

Dhiraj Giridhar Maske, Latur vs. Income Tax Officer Ward 1, Latur

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2473/PUN/2025[2018-19]Status: DisposedITAT Pune09 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Rajesh Gawali, Addl.CIT

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 148ASection 194CSection 206CSection 270ASection 271A

Since the assessee has not filed his original return of income u/s 139(1) of the Act, the Assessing Officer had reason to believe that the assessee has failed to disclose his true source of payment to contractors and sale of motor vehicle which remained unexplained. Accordingly a show cause

Dhiraj Giridhar Maske, Latur vs. Income Tax Officer Ward 1, Latur

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2472/PUN/2025[2018-19]Status: DisposedITAT Pune09 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Rajesh Gawali, Addl.CIT

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 148ASection 194CSection 206CSection 270ASection 271A

Dhiraj Giridhar Maske, Latur vs. Income Tax Officer Ward 1, Latur

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2471/PUN/2025[2018-19]Status: DisposedITAT Pune09 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Rajesh Gawali, Addl.CIT

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 148ASection 194CSection 206CSection 270ASection 271A

Dhiraj Giridhar Maske, Latur vs. Income Tax Officer, Ward 1, Latur

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2470/PUN/2025[2018-19]Status: DisposedITAT Pune09 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Rajesh Gawali, Addl.CIT

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 148ASection 194CSection 206CSection 270ASection 271A

Dhiraj Giridhar Mhaske, Latur vs. Income Tax Officer Ward 1, Pune

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2469/PUN/2025[2018-19]Status: DisposedITAT Pune09 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Rajesh Gawali, Addl.CIT

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 148ASection 194CSection 206CSection 270ASection 271A

Dindayal Magasvargiya Sahakari Soot Girni Ltd, Sangli vs. Assistant Commissioner of Income Tax Circle Sangli, Circle Sangli

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

ITA 205/PUN/2025[2014-15]Status: DisposedITAT Pune09 Dec 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.205/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 Dindayal Magasvargiya Vs. Acit, Circle Sangli, Sahakari Soot Girni Ltd., Sangli. At Waghwadi, Post Kameri, Tal. Walwa, Sangli- 415403. Pan : Aaaad0254E Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 22.09.2025 Date Of Pronouncement : 09.12.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.12.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case & In Law, Ld. Ao Erred In Initiating Reassessment Proceedings U/S 147 For Ay 2014-15, Being The Year Beyond 4 Years & For Which Assessment Order U/S 143(3) Has Already Been Passed, Thereby

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Ramnath P. Murkunde

Section 143(2)Section 143(3)Section 147Section 148Section 37Section 438

circumstances of the case and in law, Ld. AO erred in initiating reassessment proceedings u/s 147 for AY 2014-15, by recording the reason to believe which is based on incorrect presumptions and therefore an action based on such presumed reason to believe is incorrect and order passed in consequence ... circumstances of the case and in law, Ld. AO erred in initiating reassessment proceedings u/s 147 for AY 2014-15 by recording the reason to believe which is based on audit objection. We submit that the reason based on such borrowed satisfaction cannot be the basis of reopening the concluded

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 499/RJT/2025[2020-21]Status: DisposedITAT Rajkot08 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &

Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 498/RJT/2025[2015-16]Status: DisposedITAT Rajkot08 Dec 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita Nos. 498 & 499/Rjt/2025 निर्धारणवर्ष /Assessment Years: 2015-16 & 2020-21 Gopal Snacks Pvt. Ltd. बनाम Asst. Commissioner Of Income Tax Circle-1(1), Rajkot Plot No.2322-2324, Gidc Metoda, Lodhika, Rajkot, Gujarat-360021 (अपीलार्थी/Appellant) Pan : Aadcg6113A (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राजस्व की ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख/Date Of Pronouncement : 08/12/2025 Order Per, Dr. Arjun Lal Saini: Captioned Two Appeals Filed By The Same Assessee, Pertaining To

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &

Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

notice u/s.148 issued in mechanical manner, in absence of fresh tangible material and on the basis of borrowed satisfaction and without having reason to believe of escapement of income; (ii)On facts and circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition u/s.68 ... based on above information and collected material. The assessee has claimed unsecured loans of Rs.85,00,000/- hence, the Assessing Officer has reason to believe that income has escaped assessment for the year under consideration. you and hence, the Assessing Officer has reason to believe that income chargeable

Rameshbhai Ratnabhai Parsana, Rajkot vs. The Deputy Circle-2(1), Rajkot

In the result, the assessee’s appeal is partly allowed, in above terms

ITA 219/RJT/2025[2014-15]Status: DisposedITAT Rajkot08 Dec 2025AY 2014-15

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.219/Rjt/2025 "नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Rameshbhai Ratnabhai Parsana Vs. The Assistant Commissioner Of Prop. Of Aman Ornament, 11, Income-Tax, Circle-2(1), Ornament Arcade, Soni Bazar Main Aayakar Bhavan, Race Course Road, Near Darbar Gadh, Rajkot Road, Rajkot Gujarat 360001 Gujarat 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acypp1885C (Appellant) (Respondent) Appellant By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 07 / 10 /2025 Date Of Pronouncement : 08 / 12 /2025

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. SR. DR

Section 115BSection 142(1)Section 144BSection 147Section 148Section 250Section 69A

cash received amounting to Rs.88,39,350/- and also the nature & source of such cash received remained unexplained and hence the AO had reason to believe that there was escapement of income. After recording reasons in writing & obtaining prior approval of the competent authority, the AO initiated action