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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

Meenaxi Gems Pvt Ltd, Surat vs. Income Tax Officer, WD-1(1)(4), Surat

In the result, the appeal of the assessee in ITA No

ITA 612/SRT/2025[2007-08]Status: DisposedITAT Surat27 Nov 2025AY 2007-08

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.612 & 613/Srt/2025 Assessment Year: (2007-08) (Hybrid Hearing) Meenaxi Gems Pvt. Ltd., Vs. Ito, 5/1108-A, 1167/68-B, Santok Ward – 1(1)(4), Diamonds Office No.106, Gurjar Surat Faliya, Haripura, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcm4645B (Appellant) (Respondent) Appellant By Shri Prakash Jhunjhunwala, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 27/11/2025

Section 145(3)Section 147Section 148Section 151(1)Section 250Section 271(1)(c)Section 274

since had been issued in absence of fresh tangible material, without independent application of judicial mind and without having valid reason to believe of escapement of income; 3.0 On facts and circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition of entire alleged

Kusum Mittal, Sangrur vs. Income Tax Officer, Ward - Sangrur, Sangrur

In the result, the appeal of the assessee is allowed

ITA 941/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh27 Nov 2025AY 2015-16

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 147Section 148Section 151Section 69

That the Ld. Commissioner of Income Tax (Appeals) has failed to appreciate that there was no tangible material on record to form a "reason to believe"that income of the appellant had escaped assessment and in view thereof the proceedings initiated are illegal, untenable and therefore unsustainable. 5. That initiation

Akbar Ali, Mandi Gobindgarh vs. Jao the Income Tax Officer Ward 2 Mandi Gobindgarh, Mandi Gobindgarh

In the result, Assessee’s appeal is allowed

ITA 868/CHANDI/2025[2019-2020]Status: DisposedITAT Chandigarh27 Nov 2025AY 2019-2020

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 868/Chd/2025 "नधा"रण वष" / Assessment Year : 2019-20 Akbar Ali, The Jao, बनाम H. No. 140, Ram Nagar, The Ito, Sector 9, Ward 2, Vs. Block B Mandi Gobindgarh, Mandi Gobindgarh Punjab 147301 "थायी लेखा सं./ Pan No: Awupk6417B अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Sh. Vivek Vardhan, Addl. CIT
Section 132Section 147Section 148Section 148A

assessee has allegedly made bogus purchases from Sh. Deepak Sharma, and no such information have been provided as evident from copy of reasons to believe. The AO relied upon such information without providing and incriminating evidence in the shape of statement, document and some other receipt or documents ... notice u/s 148 of the Income Tax Act as duly mentioned in the order of 148A(d) The reason mentioned in the reason to believe are as under:- i) As per page 2 relevant para No. 2 of the 148A(d) order i.e. reason to believe for issuance of notice

Geetanjali Anil Kankrej, Kopargaon vs. ITO, Ward-1, Ahmednagar

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

ITA 1104/PUN/2024[2017-18]Status: DisposedITAT Pune27 Nov 2025AY 2017-18

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1104/Pun/2024 िनधा"रण वष" / Assessment Year : 2017-18 Geetanjali Anil Kankrej, Vs. Ito, Ward-1, M/S. Kishor Wines, Jadhav Ahmednagar. Building, Dharangaon Road, Tal. Kopargaon- 423109. Pan : Agxpk9352L Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri Uodol Raj Singh Date Of Hearing : 12.11.2025 Date Of Pronouncement : 27.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.04.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2017-18. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. Whether On Facts & Circumstances Of The Case, The Reassessment Proceedings U/S 147 Valid In Law In Absence Of Reason To Believe That Any Income Has Escaped Assessment When The Ld Ao Himself States That Notice U/S 148 Is Issued To Verify & Make Enquiry

For Appellant: Smt. Deepa KhareFor Respondent: Shri Uodol Raj Singh
Section 143(3)Section 147Section 148Section 69A

grounds of appeal :- “1. Whether on facts and circumstances of the case, the reassessment proceedings u/s 147 valid in law in absence of reason to believe that any income has escaped assessment when the ld AO himself states that notice u/s 148 is issued to verify and make enquiry

Ravinder Singh 402Sai Deep Apartment 26-Ram Bagh Colony Shinde Ki Chawni Lashkar Gwalior, Gawalir vs. Income Tax Officer Ward 2(2) Gwalior Aaykar Bhawan City Centre Gwalior, Gwalior

In the result, both the assessee’s appeals

ITA 419/AGR/2025[2017-2018]Status: DisposedITAT Agra26 Nov 2025AY 2017-2018

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 133ASection 143(2)Section 144Section 147Section 148Section 250Section 44ASection 69A

found that the assessee has deposited a cash of Rs.57,85,000/- during the financial year 2015- 16. The Assessing Officer had reason to believe that the income chargeable to tax has escaped assessment for the year under consideration. Case was reopened u/s. 147 and notice

Ravinder Singh 402 Sai Deep Apartment 29 Ram Bagh Colony Shinde Ki Chawni Lashkar Gwalior, Gwalior vs. Income Tax Officer Ward 2(2) Gwalior Aaykar Bhawan City Centre Gwalior, Gwalior

In the result, both the assessee’s appeals

ITA 418/AGR/2025[2016-2017]Status: DisposedITAT Agra26 Nov 2025AY 2016-2017

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 133ASection 143(2)Section 144Section 147Section 148Section 250Section 44ASection 69A

found that the assessee has deposited a cash of Rs.57,85,000/- during the financial year 2015- 16. The Assessing Officer had reason to believe that the income chargeable to tax has escaped assessment for the year under consideration. Case was reopened u/s. 147 and notice

Income Tax Officer-3(1), Raipur vs. Rahul Kathuria, Raipur

In the result, appeal of the Revenue in ITA No

ITA 152/RPR/2025[2019-20]Status: DisposedITAT Raipur26 Nov 2025AY 2019-20

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

For Appellant: Shri V.K. Jindal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 148

assailed the assessment order citing that various Courts have already held that the third information is only an information and does not constitute "reason to believe" unless such information is subjected to investigation and on the basis thereof independent reasons are recorded by the AO. The appellant has cited several

Income Tax Officer, Raipur vs. Rahul Kathuria, Raipur

In the result, appeal of the Revenue in ITA No

ITA 151/RPR/2025[2018-19]Status: DisposedITAT Raipur26 Nov 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

For Appellant: Shri V.K. Jindal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 148

assailed the assessment order citing that various Courts have already held that the third information is only an information and does not constitute "reason to believe" unless such information is subjected to investigation and on the basis thereof independent reasons are recorded by the AO. The appellant has cited several

Pothina Satyanarayana, Visakhapatnam vs. Income Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 568/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.568/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Pothina Satyanarayana, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Ahdpp1312N Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 19/11/2025 Hearing: घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 10/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 12/02/2024 For The Assessment Year 2018-19. The 2 Pothina Satyanarayana Vs. Ito

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 139(1)Section 147Section 148Section 148ASection 151Section 151ASection 54F

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

Mahalakshmi Sanagala, Vuyyuru vs. Inome Tax Officer, Ward-1, Gudiwada

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

ITA 427/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2016-17

Bench: Shri Ravish Sood, Hon’Ble

Section 133(6)Section 142(1)Section 147Section 148Section 250

that assessee has deposited cash of 51,00,000/- for the A.Y. 2016-17. As, Ld.Assessing Officer [hereinafter in short “Ld. AO"] has reason to believe that income chargeable to tax has escaped assessment therefore issued notice under section 148 of the Act on 29.03.2023. In response, assessee

Purnagiri Rice Mills, Shahjahanpur vs. Income Tax Officer, Shahjahanpur

In the result, the appeal of the assessee is allowed

ITA 251/LKW/2017[2007-08]Status: DisposedITAT Lucknow26 Nov 2025AY 2007-08

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.251/Lkw/2017 ननिाारण वर्ा/ Assessment Year: 2007-08 Purnagiri Rice Mills, V. Income Tax Officer Meeran Pur Katra, Range-1(5), Shahajhanpur-242301. Shahajhanpur-242301. Pan:Aahfp6663R अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri Saurabh Gupta, Ca प्रत्यर्थी कक और से /Respondent By: Shri R. R. N. Shukla, Addl. Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 28 10 2025 घोर्णा कक तारीख/ Date Of 26 11 2025 Pronouncement: आदेश / O R D E R

For Appellant: Shri Saurabh Gupta, CAFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)
Section 143(3)Section 147Section 148

Section 147 of the Act, as quoted hereinabove. Under the Direct Tax Laws (Amendment) Act, 1987, Parliament not only deleted the words "reason to believe" but also inserted the word "opinion" in Section 147 of the Act. However, on receipt of representations from the Companies against omission of the words ... reason to believe", Parliament re-introduced the said expression and deleted the word "opinion" on the ground that it would vest arbitrary powers in the Assessing Officer. We quote hereinbelow the relevant portion of Circular No.549 dated 31st October, 1989, which reads as follows: "7.2 Amendment made by the Amending

Arkay Energy (Rameswarm) Private Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

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

ITA 1562/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.1562/Hyd/2025 (निर्धारण वर्ष/Assessment Year:2017-18) M/S. Arkay Energy (Rameswarm) Pvt. Ltd., Hyderabad. Vs. Dy. Commissioner Of Income Tax, Circle 1(1), Hyderabad. Pan: Aafca0044C (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao, C.A. राजस्व द्वारा / Revenue By: Shri Ranjan Agrawala, Sr-Dr सुनवाई की तारीख /Date Of Hearing: 20/11/2025 घोषणा की तारीख / Pronouncement: 26/11/2025 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 23.07.2025 Of National Faceless Appeal Centre (Nfac), Delhi For The

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Shri Ranjan Agrawala, SR-DR
Section 143(3)Section 147Section 148Section 148ASection 151ASection 250

defective and without identifying income escaped assessment as non- furnishing of calculation for method following under IND AS 109 is not having reason to believe that income chargeable to tax has escaped assessment. 10. The Ld. CIT(A) ought to have fairly and judiciously appreciated the fact that the reopening

Madina Rice Mill Pvt. Ltd., Hooghly vs. A.C.I.T., CC - 4(4), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2471/KOL/2024[2017-2018]Status: DisposedITAT Kolkata26 Nov 2025AY 2017-2018

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

there are reasons to issue notice under section 148. Before issuing a notice under section 148, the Income-tax Officer must have either reasons to believe that by reason of the omission or failure on the part of the assessee to make a return under section 139 for any assessment ... failure as mentioned above 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. Unless the requirements of clause (a) or clause (b) of section

Madina Rice Mill Pvt. Ltd., Hooghly vs. A.C.I.T., CC - 4(4), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2470/KOL/2024[2016-2017]Status: DisposedITAT Kolkata26 Nov 2025AY 2016-2017

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

there are reasons to issue notice under section 148. Before issuing a notice under section 148, the Income-tax Officer must have either reasons to believe that by reason of the omission or failure on the part of the assessee to make a return under section 139 for any assessment ... failure as mentioned above 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. Unless the requirements of clause (a) or clause (b) of section

Madina Rice Mill Pvt. Ltd., Hooghly vs. A.C.I.T., Central Circle - 4(4), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2469/KOL/2024[2015-2016]Status: DisposedITAT Kolkata26 Nov 2025AY 2015-2016

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

there are reasons to issue notice under section 148. Before issuing a notice under section 148, the Income-tax Officer must have either reasons to believe that by reason of the omission or failure on the part of the assessee to make a return under section 139 for any assessment ... failure as mentioned above 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. Unless the requirements of clause (a) or clause (b) of section

Madina Rice Mill Pvt. Ltd., Hooghly vs. A.C.I.T., CC - 4(4), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2468/KOL/2024[2014-2015]Status: DisposedITAT Kolkata26 Nov 2025AY 2014-2015

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

there are reasons to issue notice under section 148. Before issuing a notice under section 148, the Income-tax Officer must have either reasons to believe that by reason of the omission or failure on the part of the assessee to make a return under section 139 for any assessment ... failure as mentioned above 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. Unless the requirements of clause (a) or clause (b) of section

Madina Rice Mill Pvt. Ltd., Hooghly vs. A.C.I.T., CC - 4(4), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2467/KOL/2024[2013-2014]Status: DisposedITAT Kolkata26 Nov 2025AY 2013-2014

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133ASection 139(1)Section 143(1)Section 147Section 148Section 151Section 151(1)

there are reasons to issue notice under section 148. Before issuing a notice under section 148, the Income-tax Officer must have either reasons to believe that by reason of the omission or failure on the part of the assessee to make a return under section 139 for any assessment ... failure as mentioned above 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. Unless the requirements of clause (a) or clause (b) of section

Lic Housing Finance Limited, Mumbai vs. ACIT 2(2)(1), Mumbai, Aaykar Bhavan

In the result, the appeal of the assessee is allowed

ITA 5037/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Nov 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

For Respondent: Mr. Sunil Bhandari &
Section 143(3)Section 147Section 148Section 148ASection 151ASection 80G

course of assessment proceedings and this change of opinion does not constitut change of opinion does not constitute justification and/or e justification and/or reason to believe that income chargeable to tax has escaped reason to believe that income chargeable to tax has escaped reason to believe that income chargeable ... opinion does not constitute justification and/or reasons to opinion does not constitute justification and/or reasons to opinion does not constitute justification and/or reasons to believe that income chargeable to tax has escaped believe that income chargeable to tax has escaped believe that income chargeable to tax has escaped assessment." ment

Assistant Commissioner of Income Tax, Circle-1(1)(1), Meerut, Meerut (U.P.) vs. Nita Rastogi, Meerut (U.P.)

In the result, appeal of the Revenue is dismissed

ITA 3382/DEL/2025[2013-14]Status: DisposedITAT Delhi26 Nov 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2013-14] Acit Vs Nita Rastogi Circle-1(1)(1) 32-C, Janta Nagar, Garh Road, Meerut-250001. Meerut-250002. Pan-Aanpr7715E Appellant Respondent Revenue By Shri Shyam Manohar Singh, Sr.Dr Assessee By Dr. Kapil Goel, Adv. Date Of Hearing 23.09.2025 Date Of Pronouncement 26.11.2025

Section 139(1)Section 147Section 148Section 250Section 68Section 690

Gain or investment which this assessee has used to suppress her income. By going through the complete information, I by independent reason have reason to believe that there has been escapement of income on this account." On going through the reasons recorded it was observed that there was information available ... flagged report from Investigation Wing Rohtak and Delhi. During the course of reassessment proceedings, before proceeding further, the AO recorded his reasons to believe that income has escaped assessment. The reasons recorded were provided to the appellant. The appellant raised her objections against the reasons recorded. The AO disposed

Ashok Kumar Jain, Delhi vs. Pr, CIT 20, New Delhi

ITA 2641/DEL/2025[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2018-19 Ashok Kumar Jain, Vs. Pr. Cit-20, C/O Kapil Goel, Advocate, New Delhi. F-26/124, Sector-7, Rohini, Delhi – 110 085. Pan: Aakpj1872B

For Appellant: Dr. Kapil Goel, AdvocateFor Respondent: Ms Pooja Swaroop, CIT-DR
Section 147Section 148ASection 151Section 263Section 69C

dated 17.03.2022 but has also challenged the reopening proceedings itself on the assertion that there was no valid reason to believe and there was invalid sanction u/s 151 of the Act. As with regard to this aspect, whether while challenging the impugned order u/s 263 of the Act, the assessee ... 12th Dec., 2018. In the said reassessment proceedings, the learned AO had not even made any addition despite the fact that he had reason to believe that income of Rs. 11,55,330 had escaped assessment in the hands of the assessee which was sought to be taxed under