“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

Tribhawan vs. ITO Ward-2, Rewari

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

ITA 872/DEL/2025[2011-12]Status: DisposedITAT Delhi19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh & Shri Sudhir Kumartribhawan, Vs. Ito, C/O Ipso Legal H-35, 1St Ward-2, Rewari Floor, Jangpura Extension, New Delhi- 110014 (Appellant) (Respondent) Pan: Arlpt6268P Assessee By : Ms. Sumangla Saxena, Adv (Vc) Shri Dishant Sethi, Adv Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Ms. Sumangla Saxena, Adv (VC)For Respondent: Shri Om Prakash, Sr. DR

Section 144Section 147Section 151Section 154

year under consider accordingly, in this case, no assessment was made and the only requirement to initiate proceeding u/s 147 is reason to believe which has been recorded in this case. It is pertinent to mention here that in this case the assessee has chosen not to file return ... that the assessee has not filed any ITR for the year under consideration, the source of cash deposit remained unexplained. Therefore, I have reason to believe that the income to the extent of Rs. 36,00,000/- chargeable to tax, has escaped assessment for the assessment year 2011-12 within

Kisan International Trading Fze, New Delhi vs. ACIT, Int. Tax 2(1)(2), Delhi

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

ITA 6152/DEL/2024[2012-13]Status: DisposedITAT Delhi19 Nov 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Kisan International Trading Fze, Vs. Acit, Circle C/O Shri Tarandeep Singh, Advocate Int. Tax 2(1)(2), C – 179, Mansarover Garden, Delhi. New Delhi – 110 015. (Pan :Aaeck0424D) (Appellant) (Respondent) Assessee By : Shri Tarandeep Singh, Advocate Shri Sandeep Yadav, Advocate Revenue By : Shri Vikram Singh Sharma, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 19.11.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Delhi – 43 [“Ld. Cit(A)”, For Short] Dated 06.12.2024 For The Assessment Year 2012-13 Raising Following Grounds Of Appeal :- “1. That On Facts & In Law The Order Dated 06Th December 2024 Passed By The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As The "Cit(A)'} & Order Dated 23Rd December 2019 Passed By The Assessing Officer (Hereinafter Referred To As The "Ao") Are Bad In Law & Void Ab Initio.

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Vikram Singh Sharma, Sr. DR

Section 115A(5)Section 147Section 148Section 195Section 251

subsidiary amounted to 'income' which had escaped assessment was flawed. The question of such a transaction forming a live link for reasons to believe that income had escaped assessment is entirely without basis and is rejected as such. 26. For the aforementioned reasons, this Court sets aside the impugned notice ... Income Tax Act in relation to the Assessment Year 2012-13 to the petitioner, stating that the issuing officer has reason to believe that income chargeable to tax for the said Assessment Year has escaped assessment within the meaning of Section 147 of the Act. 7. The case

Satbir Sagwal, Karnal vs. Income Tax Officer, Ward-4, Karnal

ITA 1617/DEL/2024[2011-12]Status: DisposedITAT Delhi19 Nov 2025AY 2011-12

Bench: Sh. Sudhir Kumar & Sh. Brajesh Kumar Singhassessment Year: 2011-12 Satbir, Sagwal C/O Tej Mohan Vs Income Tax, Officer Singh H.No.527, Sector 10D Ward-4 Karnal Haryana Chandigarh 160011 Pan No. Bdops3759N (Appellant) (Respondent)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 263Section 69

well as on facts in upholding the initiation of proceedings under section 148 in as much as there has been no reason to believe that there was an escapement of income and the reasons recorded are based only on borrowed information and as such upholding of the assessment passed ... assessee showed that the aforesaid information was not available during the assessment proceedings on both occasions and has escaped assessment. Therefore, I have reason to believe that unexplained investment of Rs.78 Lacs has escaped assessment within the meaning of Section

Rajendrasinh Ranjitsinh Jadeja, Khakhadabela, Paddhari vs. ITO WD 2(1)(4), RKT, Rajkot

In the result, appeal filed by the assessee, is allowed, to the extent indicated above

ITA 459/RJT/2025[2012-2013]Status: DisposedITAT Rajkot17 Nov 2025AY 2012-2013

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.459/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) Rajendrasinh Ranjitsinh Jadeja Vs. Ito Ward 2 (1) (4), Khakhadabela, Paddhari, Aayakar Bhawan, Race Course Rajkot - 360110 Ring Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agvpj2529E (Appellant) (Respondent) Appellant By : Shri Gaurang Khakhar, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 01/09/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am ; Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2012-13, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 26/07/2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Dated 25/11/2009 U/S 144 R.W.S 147 Of The Income Tax Act, 1961. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1. That The Reasons Recorded U/S 147 Of The I.T. Act, 1961 By The Ld. A.O. Were Merely Based On The Suspicion & Without Any Tangible Material So As To Suggest Any Escapement Of Income. Hence The Reassessment Proceedings Are Liable To Be Quashed Rajendrasinh Ranjitsinh Jadeja

For Appellant: Shri Gaurang Khakhar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 144Section 147Section 148Section 250

only material available before the Id.AO was the information of assessee having Cash deposited in his saving bank account which is not sufficient reasons to believe escapement of income. 3. The Ld. CIT(A) has erred in confirming the addition of Rs. 12,10,000/- on the ground ... income, the source of cash deposited in his bank account remains unexplained and required to be taxed.In view of the above, I have reason to believe that the income chargeable to tax has escaped to the extent of Rs.27,91,500/- for the A.Y.2011-12 within the meaning of section

Sheetal Bathla, Kota vs. Income Tax Officer Ward 1(2) Kota, Kota

In the result, appeal of the assessee is allowed

ITA 215/JPR/2025[2012-13]Status: DisposedITAT Jaipur17 Nov 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shsrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

Section 142(1)Section 147Section 148Section 234ASection 250

notice u/s 148 can be issued only when there is any escapement of income because S.147 provides that If the Assessing Officer has reason to believe that an income chargeable to tax has escaped assessment for any assessment year, here the assessee has not escaped any income because the assessee ... said that there is the escapement of income by the assessee nor proved then the notice issued u/s 148 is invalid. 3. Reason to believe and not reason to suspect: 3.1It is further submitted that even under the amended law by the finance act 1989 the condition precedent

Vijit Singh, Jaipur vs. ITO Ward 3(2) Jaipur, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1246/JPR/2025[2009-10]Status: DisposedITAT Jaipur17 Nov 2025AY 2009-10

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

Section 147Section 234ASection 250

Rs.60,00,000/- and it is found that the assessee has not filed return of income for A.Y. 2009-10, hence I have reason to believe that the income to the extent of Rs.60,00,000/- has escaped assessment(PB1). The ld. AO has issued notice ... evidence/material available with AO—Commissioner had simply affixed “approved” at bottom of note sheet prepared by ITO technical—ITO could not have had reason to believe that income had escaped assessment by reasons of assessee 's failure to disclose material facts and if Commissioner had read report carefully he could

Jamyang Khyentse Yeshi, Kangra, Himachal Pradesh vs. ACIT, DCIT, C.R. Building, Chandigarh

The appeal of the assessee is partly allowed

ITA 604/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh17 Nov 2025AY 2013-14

Bench: The Ld. Cit(A). The Ld. Cit(A), After Calling For A Remand Report Under Rule 46A, Recorded The Following Findings (Para 5.1 To 5.5 Of The Appellate Order):

For Appellant: Shri Nitin Kanwar, Advocate (Virtual)For Respondent: Shri Prem Singh, Addl. CIT, Sr. DR

Section 133(6)Section 147Section 148Section 69A

facts in issuing notice u/s 148 on the date mentioned le. 31.03.2021 in the notice, without having any reason to believe that the income has escaped assessment. The reason to believe has been specifically mentioned while framing the assessment order by the AO and hence appellant’s ground of appeal ... facts in issuing notice u/s 148 on the date mentioned i.e. 31.03,2021 in the notice, without having any reason to believe that the income has escaped assessment. The reason to believe has been specifically mentioned while framing lhe assessment order by the AO and hence appellant's ground

Navdeep Medical Store, Ahmedabad vs. ITO Ward 6(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1322/AHD/2025[2017-2018]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2017-2018

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Gaurang Khakhhar, ARFor Respondent: Shri Sudhakar Verma, Sr. DR

Section 147Section 148Section 250Section 69A

appeal: 1.1) The ITO, Ward 6(1)(1), Ahmedabad has erred in issuing the notice under section 148 without there being any reason to believe that the income of the assessee had escaped assessment just on the basis of alleged incorrect information available with the department. Asst. Year ... independent evaluation by the learned AO. 1.3) Ld. A.O. has wrongly mentioned following facts in reason for reopening and, thus, there was wrong reason to believe that the income of the assessee had escaped assessment and, thus, the reopening is bad in law. Particular As per Reason for Correct Facts

Pritesh Ratanshi Ved, Pune vs. Income Tax Officer, Ward 1(2), Jalgaon

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

ITA 1618/PUN/2025[2015-16]Status: DisposedITAT Pune17 Nov 2025AY 2015-16

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Shashank Ojha

Section 147Section 148Section 148A

received rental income of Rs.75,984/-, however the return of income for the period under consideration was not furnished therefore the JAO had reason to believe that the income to the extent of 3 Rs.3,02,74,649/- has escaped assessment within the meaning of section

Vedanta Ltd (Earlier Known As Madras Aluminium Co. Ltd.), Gurgaon vs. ACIT, Circle- 26(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 2406/DEL/2019[2011-12]Status: DisposedITAT Delhi17 Nov 2025AY 2011-12

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

For Appellant: S/Shri Ravi Sharma & Jaskaran SinghFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 143(3)Section 147Section 148Section 80I

resulted excess claim of 80IA deduction by the same amount. 3. In view of the above facts, I have reason to believe that income chargeable to tax amounting to Rs.1,02,62,176/- has escaped the assessment, within meaning of provision of section 147 of the Income ... facts necessary for assessment and that because of this failure there has been an escapement of income chargeable to tax. Merely having a reason to believe that income had escaped assessment, is not sufficient to reopen assessments beyond the four year period indicated above. The escapement of income from assessment

Income Tax Officer, Income Tax Department, Visakhapatnam vs. Quality Steel Shoppe Private Limited, Visakhapatnam

In the result, the Cross Objection No

ITA 454/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam14 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.454/Viz/2024 ("नधा"रण वष"/Assessment Year: 2018-19) Income Tax Officer, Vs. Quality Steel Shoppe Ward-2(1), Private Limited, Visakhapatnam. Visakhapatnam. Pan: Aaacq1115D (Appellant) (Respondent) C.O. No. 18/Viz/2024 (In आ.अपी.सं /454/Viz/2024) ("नधा"रण वष"/Assessment Year: 2018-19)

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Sri Badicala Yadagiri

Section 144Section 144BSection 147Section 148Section 148ASection 151A

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

Neetu Hurkat, Pali vs. Principal Commissioner of Income Tax Ahmedabad-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 957/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad14 Nov 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Javed Khan, ARFor Respondent: Shri Alpesh Parmar, CIT. DR

Section 10Section 143(1)Section 143(2)Section 147Section 148Section 263

penny stock Toyam Industries Ltd wherein sale trade quantity is greater than buy quantity for the year under consideration. 3. Basis of forming reasons to believe and details of escapement of income: On perusal of the details and information, it is very clear that the assessee has received claimed bogus ... wherein sale trade quantity is greater than buy quantity for the year under consideration. In view of the above facts, I have reason to believe that income of Rs. 25,98,752/- has escaped assessment within the meaning of section 147 of the Act. Therefore it is a fit case

Income Tax Officer, Ward-1, Nellore vs. Venkata Ramanamma Sakamuri, Nellore

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

ITA 482/HYD/2025[2018-19]Status: DisposedITAT Hyderabad14 Nov 2025AY 2018-19

Bench: Us:

Section 147Section 148Section 148ASection 151

Guljar, Saharanpur vs. Income Tax Officer, Ward-3(5), Saharanpur

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

ITA 3797/DEL/2024[2009-10]Status: DisposedITAT Delhi14 Nov 2025AY 2009-10

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Ankit Gupta, Adv [through VC]For Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

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

That no proper statutory approval has been taken by the Assessing officer U/s 151 of the Income Tax Act, 1961 on the alleged reason to believe, as the same has been taken prior reason to believe, hence the proceedings initiated U/s 147/148 is illegal, bad in law and without jurisdiction ... Pharma India Limited in ITA No. 545/2015 wherein it has been held that the reason to believe should be based on some tangible material and the same should have the live nexus that income has escaped assessment. 9. It is further submitted that in the instant case, the assessing officer

Kamdhenu Mahila Multipurpose Co-Op Society Ltd, Belgaum vs. Assessment Unit, Income Tax Department, Delhi

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

ITA 253/PAN/2025[2015-16]Status: DisposedITAT Panaji13 Nov 2025AY 2015-16

Bench: Shri Pavan Kumar Gadalei T A. Nos.253/Pan/2025 (A.Y. 2015-16) Kamdhenu Mahila Vs I T O, Multipurpose Co Op Society, National E Assessment . Vengurla Road, Centre, Sulaga, Delhi. Belgaum-591108, Karnataka. Pan/Gir No. Aabak8652N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P

assesse in the F.Y.2014-15 and the assesse has not filed the return of income for the A.Y.2015-16. The Assessing officer (A.O) has reason to believe that the income has escaped the assessment and issued notice u/sec148 of the Act and further notice u/sec143 (2) and u/sec

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. Konark Rajhans Estate Private Limited, Panchkula

In the result, the appeal of the revenue stands dismissed

ITA 805/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh13 Nov 2025AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 805/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2011-12 Acit M/S Konark Rajhans Estate Private Limited Panchkula Circle बनाम/ Vs. Nh 73, Village Kot Extension-Ii, Sector 14, Panchkula. Panchkula. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaeck-2405-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Manav Bansal (Cit) – Ld. Dr ""थ"कीओरसे/Respondent By : Sh. Parikshit Aggarwal (Ca)-Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 20-08-2025 घोषणाकीतारीख /Date Of Pronouncement : 13/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal By The Revenue For Assessment Year (Ay) 2011- 12 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 27-05-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S. 147 Of The Act On 29-12-2018. The Revenue Is Aggrieved By Deletion Of Twin Quantum Additions Of Rs.40.85 Lacs & Rs.707.75 Lacs As Made By Ld. Ao In The Assessment Order. The Grounds Of Appeal Read As Under: -

For Appellant: Sh. Manav Bansal (CIT) – Ld. DRFor Respondent: Sh. Parikshit Aggarwal (CA)-Ld. AR

Section 131oSection 143(3)Section 148Section 40A(3)Section 68Section 68o

r.w.s. 147 was void-ab-initio and more-so when the reasons recorded were legally unsustainable and di not establish any valid ‘reason to believe; of escapement of income and also when no addition was made on issue on which reasons were recorded. 1.3 The Ld. CIT-DR advanced arguments ... decision of Hon’ble Supreme Court in the case of Associated Stone Industries (Kotah) Ltd. (224 ITR 560) which mandate that reason to believe must have four elements viz. some material before Ld. AO; a nexus of such material and belief of escapement of income; an application of mind

Anil Finature Pvt Ltd, Mumbai vs. ITO Ward 14(1)(1), Mumbai

The appeals of the assessee are allowed for statistical purposes

ITA 5640/MUM/2025[2010-11]Status: DisposedITAT Mumbai13 Nov 2025AY 2010-11

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Satish Kumar, ARFor Respondent: Shri Surendra Mohan, Sr. DR

Section 143(3)Section 250

shift out the profits or shift in the losses of other companies with the objective to reduce taxable income. The AO had a reason to believe that the assessee is one of the beneficiaries of CCM and accordingly reopened the assessment. After considering the submissions of the assessee

Anil Finature Pvt Ltd, Mumbai vs. ITO Ward 14(1)(1), Mumbai

The appeals of the assessee are allowed for statistical purposes

ITA 5639/MUM/2025[2009-10]Status: DisposedITAT Mumbai13 Nov 2025AY 2009-10

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Satish Kumar, ARFor Respondent: Shri Surendra Mohan, Sr. DR

Section 143(3)Section 250

Om Shreem Ananda Foods Private Limited, Delhi vs. Income Tax Officer, Ward- 19(1), Delhi

In the result, assessee’s appeal is allowed for statistical purposes

ITA 4780/DEL/2025[2012-13]Status: DisposedITAT Delhi13 Nov 2025AY 2012-13

Bench: Shri M Balaganesh & Ms. Madhumita Royassessment Year: 2012-13

Section 147Section 271(1)(c)Section 68

That the Ld. CIT(A) and Ld. AO 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. 4. That the Ld. CIT(A) erred in sustaining the addition made

Arjun Oil Traders, Surat vs. ACIT, Navsari Circle, Navsari

ITA 147/SRT/2024[2011-12]Status: DisposedITAT Surat12 Nov 2025AY 2011-12

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.147/Srt/2024

Section 143(3)Section 145ASection 147Section 148Section 250

IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER