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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

Jayantilal Rajmal Seth, Mumbai vs. DCIT-CC-4(3), Mumbai

ITA 3260/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Jayantilal Rajmal Seth, Dcit-Cc-4(3), A-3, Saibaba Shopping Centre, Bkc, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. Pan No. Agepj 0499 E Appellant Respondent

For Appellant: Mr. Vivek Perampurna, CIT-DRFor Respondent: Mr. Jayant Bhat
Section 139(5)Section 148Section 263

facie reason submitted that reassessment is valid if there is prima facie reason submitted that reassessment is valid if there is prima facie reason to believe that income has escaped assessment. AO is not required to believe that income has escaped assessment. AO is not required to believe that income ... suppose that income had escaped assessment, it can be said to suppose that income had escaped assessment, it can be said to have reason to believe that an income ha have reason to believe that an income had escaped assessment. d escaped assessment. The expression cannot be read to mean

Mr. Jatin Harish Sotta, Mumbai vs. Income Tax Officer Ward 26(1)(7), Mumbai

In the result, the appeal of the assessee is partly allowed for result, the appeal of the assessee is partly allowed for result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1916/MUM/2025[2012-13]Status: DisposedITAT Mumbai22 Sept 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Mr. Jatin Harish Sotta, Ito Ward 26(1)(7), A-16, Ajanta Apartment, C-41 To C-43, G Block, Bkc, Murar Road, Mulund West, Vs. Bandra (East), Mumbai-400080. Mumbai-400051. Pan No. Aqfps 6009 N Appellant Respondent

For Appellant: Ms. Kavita Kaushik, Sr. DRFor Respondent: Mr. Nimesh Chothani, CA
Section 144Section 147Section 69A

said tangible information, the Assessin Based on the said tangible information, the Assessin Based on the said tangible information, the Assessing Officer recorded reasons to believe that income chargeable to tax had recorded reasons to believe that income chargeable to tax had recorded reasons to believe that income chargeable ... furnishes, as true, information on the subject which he knows o furnishes, as true, information on the subject which he knows or has reason to believe to be false, shall be punished with simple has reason to believe to be false, shall be punished with simple has reason to believe

Mr. Rohit Vallabhdas Shah, Mumbai vs. ITO Ward 32(3)(2), Mumbai

In the result, appeal of the assessee is dismissed

ITA 1910/MUM/2025[2010-11]Status: DisposedITAT Mumbai22 Sept 2025AY 2010-11

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2010-11 Rohit Vallabhdas Shah Income Tax Officer, B-303, Dwarka Apartment Ward 32(3)(2), Vs. Daulat Nagar, Borivali, Mumbai Mumbai – 400066 (Pan: Accps2392B) (Assessee) (Respondent) Present For: Assessee : Shri Gunjan Kakkad, Advocate Revenue : Shri Annavaram Kosuri, Sr. Dr Date Of Hearing : 22.07.2025 Date Of Pronouncement : 22.09.2025 O R D E R Per Girish Agrawal: This Appeal Filed By Assessee Is Against The Order Of Ld. Pcit-32, Mumbai, Vide Order Dated 25.03.2019 Passed Against The Assessment Order By Income Tax Officer, Ward-32(3)(2), Mumbai, U/S. 143(3) R.W.S. 147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 17.06.2016 For Assessment Year 2010-11. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. On The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income-Tax Has Erred In Setting Aside The Assessment Order By Exercising Powers Under Section 263 Of The Income-Tax Act, 1961 ("The Act"). 2. On The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income-Tax Failed To Appreciate That The View Of The Assessing Officer Could Have Been Substituted In Exercise Of Powers Under Section 263 Of The Act. 3. On The Facts & Circumstances Of The Case & In Law, The View Taken By The Assessing Officer Was A Plausible View & Thus, The Commissioner Has Erred In Invoking The Powers Under Section 263 Of The Act. 4. On The Facts & Circumstances Of The Case & In Law, The Commissioner Could Not Have Set Aside The Assessment Order.

For Appellant: Shri Gunjan Kakkad, AdvocateFor Respondent: Shri Annavaram Kosuri, Sr. DR
Section 133(6)Section 143(3)Section 147Section 148Section 263

Investigation), Mumbai, ld. Assessing Officer took up the matter by reopening the assessment by issuing notice u/s. 148 dated 14.08.2015. According to the reasons to believe recorded by the ld. Assessing Officer, Investigation Wing of the Department had carried out detailed investigation with respect to information received from Sales ... alleged that assessee is one of such beneficiaries of obtaining bogus purchases from the following parties:- 3.3. Thus, ld. Assessing Officer formed a reason to believe that income had escaped assessment within the meaning of section 147 of the Act. Assessee in the course of re-assessment, submitted copies

Goodluck Metal Corporation, Mumbai vs. Assessing Officer, Mumbai

In the result, the appeal of the assessee is dismissed

ITA 1771/MUM/2025[2009-10]Status: DisposedITAT Mumbai22 Sept 2025AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2009-10 Goodluck Metal Corporation, Assessing Officer Circle 19(1), 98, Khetwadi Main Road, Piramal Chamber, Mumbai-400 004. Vs. Mumbai-400012. Pan No. Aaafg 1441 R Appellant Respondent

For Respondent: Mr. Sanjiv Shah, Adv
Section 132Section 143(1)Section 147Section 153A

entries. In view of for providing accommodation entries. In view of for providing accommodation entries. In view of information, the Assessing Officer recorded reasons to believe that essing Officer recorded reasons to believe that essing Officer recorded reasons to believe that Goodluck Metal Corporation Goodluck Metal Corporation ... basis of the aforesaid information available .with the On the basis of the aforesaid information available .with the 5. undersigned, I have reason to believe that income chargeable to tax, as undersigned, I have reason to believe that income chargeable to tax, as undersigned, I have reason to believe that

Rajesh Singh, Rewa vs. ITO Ward-1 Rewa, Rewa

In the result, appeal in ITA No

ITA 129/JAB/2023[2010-11]Status: DisposedITAT Jabalpur19 Sept 2025AY 2010-11

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.128 & 129/Jab/2023 A.Y. 2010-11 Rajesh Singh, Vs. Income Tax Officer, M/S Pharma Deal Agency, Ward No.8, Ward-1, Rewa, M.P. Mauganj, Distt. Rewa, M.P. Pan:Atrps5702K (Appellant) (Respondent)

For Appellant: Sh. Devendra Singh, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR
Section 143(2)Section 144Section 147Section 148Section 271(1)(b)Section 69A

prayed that the failure to make compliance to the notices under section 142(1) was because the ld. AO had not furnished the reasons to believe to the assessee. Accordingly, it was prayed that the penalty may be dismissed. However, the ld. CIT(A) did not agree with this logic ... assessee files a return and A.Y.2010-11 Rajesh Singh thereafter makes a request to the Assessing Officer for a copy of the reasons to believe, the same have to be provided so as to enable the assessee to object to the initiation of re-assessment proceedings

Rajesh Singh, Rewa vs. ITO Ward -1, Rewa

In the result, appeal in ITA No

ITA 128/JAB/2023[2010-11]Status: DisposedITAT Jabalpur19 Sept 2025AY 2010-11

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.128 & 129/Jab/2023 A.Y. 2010-11 Rajesh Singh, Vs. Income Tax Officer, M/S Pharma Deal Agency, Ward No.8, Ward-1, Rewa, M.P. Mauganj, Distt. Rewa, M.P. Pan:Atrps5702K (Appellant) (Respondent)

For Appellant: Sh. Devendra Singh, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR
Section 143(2)Section 144Section 147Section 148Section 271(1)(b)Section 69A

prayed that the failure to make compliance to the notices under section 142(1) was because the ld. AO had not furnished the reasons to believe to the assessee. Accordingly, it was prayed that the penalty may be dismissed. However, the ld. CIT(A) did not agree with this logic ... assessee files a return and A.Y.2010-11 Rajesh Singh thereafter makes a request to the Assessing Officer for a copy of the reasons to believe, the same have to be provided so as to enable the assessee to object to the initiation of re-assessment proceedings

Megnanapuram Paccs, Tiruchendur vs. PCIT, Madurai

ITA 895/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Sept 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:895/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Megnanapuram Primary Agricultural Co-Operative Credit Society 4/40, Megnanapuram Tiruchendur Road, Tiruchendur Thoothukudi – 628 210. [Pan: Aabam-9847-M] (अपीलार्थी/Appellant) Pcit Vs. Madurai - I (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 24.06.2025 घोषणा की तारीख/Date Of Pronouncement : 19.09.2025 आदेश /Order Per S. R. Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), Pcit, Madurai - 1, For The Assessment Year 2018-19, Vide Order Dated 17.03.2025. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 147Section 148Section 263Section 80P

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Phoenix Commodities Private Limited, Mumbai vs. ITO 3(2)(3), Mumbai, Aayakar Bhavan

In the result, grounds of appeal of

ITA 4730/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Sept 2025AY 2014-15

Bench: Shri Pawan Singh

Section 143(1)Section 147Section 148Section 254(1)

assessee made transaction of sale and purchase for various clients. On the basis of such information, the assessing officer has a reason to believe that taxable income in case of assessee has escaped assessment. In response to notice under section 148 filed its return of income on 15.04.2019 declaring

Phoenix Commodities Private Limited, Mumbai vs. ITO Ward 3(2)(4), Mumbai

In the result, grounds of appeal of

ITA 4729/MUM/2025[2013-14]Status: DisposedITAT Mumbai19 Sept 2025AY 2013-14

Bench: Shri Pawan Singh

Section 143(1)Section 147Section 148Section 254(1)

assessee made transaction of sale and purchase for various clients. On the basis of such information, the assessing officer has a reason to believe that taxable income in case of assessee has escaped assessment. In response to notice under section 148 filed its return of income on 15.04.2019 declaring

DCIT(CC)-8(3), Mumbai vs. Shapoorji Pallonji and Company Private Limited, Mumbai

The appeal of the revenue is dismissed on merits the various legal contentions in the C

ITA 2242/MUM/2025[2012-13]Status: DisposedITAT Mumbai19 Sept 2025AY 2012-13

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Rajan Vora & Shri Nikhil
Section 115JSection 143(3)Section 147Section 151Section 250

which the AO has treated the payments made by the assessee as unexplained which fact is substantiated by what is stated as the reason to believe which a replica of investigation report. The ld AR also took the bench through the details of payments made through banking channel

Santosh Rani Legal Heir of Late Sh Parveen Kalyan, Kurukshetra vs. Income Tax Officer, Ward 1, Karnal

In the result, appeal of the assessee is allowed

ITA 4770/DEL/2024[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2011-12] Santosh Rani Vs Ito, Legal Heir Of Late Shri Parveen Ward-1, Karnal, Kalyan, Krishna Nagar, Gamri, Haryana-132001. Thanesar, Distt.-Kurukshetra, Haryana-136118. Pan-Awhpr4944D Appellant Respondent Appellant By Shri Suresh K.Gupta, Ca Respondent By Shri Dheeraj Kumar Jaiswal, Sr.Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 19.09.2025 Order

Section 144Section 147Section 148Section 151Section 250

that income of the Assessee has escaped assessment. There is non-application of mind by the AO could not be said to have reason to believe as to justify reopening of assessment." Without prejudice to above, the Ld AO missed out the fact that prior to cash deposit of Rs.95 ... other words, merely stating the reasons in a letter addressed by the AO to the Assessee is to be avoided; (ii) the reasons to believe ought to spell out all the reasons and grounds available with the AO for reopening the assessment - especially in those cases where the first proviso

Arun Duggal, Faridabad vs. DCIT, Central Circle- 1, Faridabad

In the result, appeal of the assessee is partly allowed

ITA 3075/DEL/2018[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2009-10] Arun Duggal, Vs Dcit, 3E-42, Nit, Faridabad, Central Circle-1, Haryana-121001. Faridabad. Pan-Agupd5708Q Appellant Respondent Appellant By Dr. Kapil Goel, Adv. Respondent By Shri Pravin Rawal, Cit Dr Date Of Hearing 26.06.2025 Date Of Pronouncement 19.09.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 26.02.2018 Passed By Ld. Commissioner Of Income Tax (A)-3, Gurgaon [“Ld.Cit(A)”] In Appeal No.617/Cit(A)-3/Ggn/2016-17 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 23.12.2016 Passed U/S 147 R.W.S. 143(3) Of The Act Pertaining To Assessment Year 2009-10. 2. Brief Facts Of The Case Are That The Appeal Of The Assessee Was Heard By The Co-Ordinate “E” Bench Of The Tribunal & Was Decided In Terms Of Order Dated 01.04.2022 Wherein Co-Ordinate Bench Has Dismissed The Appeal Of The Assessee. Thereafter, Assessee Filed Miscellaneous Application (M.A.) Bearing No.100/Del/2022 U/S 254(2) Of The Act. The Co-Ordinate Bench Vide Its Order Dated 09.04.2025 Has Decided The M.A. Filed By Assessee Wherein Order Of Co-Ordinate Bench Dated 04.01.2022 Is Recalled For The Limited Purposes Of Adjudication Of Three Grounds Of Appeal Taken In The Original Form 36. These Grounds Of Appeal Are Bearing Nos.1.2, 1.8 & 5. The Relevant Observations Of The Co-Ordinate Bench In Para 16 Of The Order Of Ma Are As Under:-

Section 147Section 151Section 250Section 254(2)Section 68

other words, merely stating the reasons in a letter addressed by the AO to the Assessee is to be avoided; (ii) the reasons to believe ought to spell out all the reasons and grounds available with the AO for reopening the assessment - especially in those cases where the first proviso ... Section 147 is attracted. The reasons to believe ought to also paraphrase any investigation report which may form the basis of the reasons and any enquiry conducted by the AO on the same and if so, the conclusions thereof; (iii) where the reasons make a reference to another document, whether

Rukmini Fabrics, Belgaum vs. National Faceless Assessment Centre, Delhi

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

ITA 247/PAN/2025[2018-19]Status: DisposedITAT Panaji18 Sept 2025AY 2018-19

Bench: Shri Pavan Kumar Gadalei T A. No.247/Pan/2025 (A.Y. 2018-19) Rukmini Fabrics, Vs National Faceless 311, Chavadi Galli, Assessment Centre, . M Vadgaon, New Delhi-110003 Belgaum-590005, Karnataka. Pan.No. Aaufr2351R (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

that these amounts offered in the survey operations were not included in the return of income filed for A.Y.2018-19. The Assessing officer has reason to believe that the income has escaped the assessment and issued notice u/sec148 of the Act. Subsequently the notice u/sec

Allavuddin Ummarasab Hurakadli, Mapusa vs. Income Tax Officer, Panaji

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

ITA 229/PAN/2025[2016-17]Status: DisposedITAT Panaji18 Sept 2025AY 2016-17

Bench: Shri Pavan Kumar Gadalei T A. No.229/Pan/2025 (A.Y. 2016-17 ) Allavuddin Unmarasab Vs National Faceless Hurakadli, Assessment Centre, H,No.354, New Delhi-110003 Shetty Wada, Mapusa-403507, Goa.

Section 69C

assessee has made substantial cash deposits 2 ITA. No.229/PAN/2025 Alladin Umarsab Hurakadli. in the bank accounts during the F.Y.2015-16. The A.O has reason to believe that the income has escaped the assessment and has issued notice U/sec148 of the Act. Further notice u/sec 142(1) of the Act along with

Mithilesh Jagdeo Singh Pawar, Amravati vs. ITO Ward-5, Amravati

ITA 70/NAG/2025[2017-18]Status: DisposedITAT Nagpur18 Sept 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18 Mr. Mithilesh Jagdeo Singh Ito Ward-5 Pawar, Besides Dps, Vs. Ghatladki, Chandur Bazar, Saturna Road, Maharashtra - 444720. Maharashtra - 444605. Pan: Bpfpp6167L (Appellant) (Respondent) Present For: Assessee By : Ms. Mrudul Bhusari, Ld. Adv {Ld. Amicus Curie} Revenue By : Shri Surjit Kumar Saha, Ld. Sr. Dr Date Of Hearing : 26.06.2025 Date Of Pronouncement : 09.2025 O R D E R Per : Narender Kumar Choudhry:

For Appellant: Ms. Mrudul Bhusari, Ld. AdvFor Respondent: Shri Surjit Kumar Saha, Ld. Sr. DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(40)Section 250Section 69A

made. Accordingly, in this case the only requirement to initiate the proceedings u/s 147 of the Act is reason to believe which has been recorded as under: “It is pertinent to mention here that in this case the Assessee has filed return of income for the year under consideration

Sh. Hari Prakash Gupta, Jaipur vs. ITO, Ward-1(2), Jaipur

The appeal stands allowed

ITA 772/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

reasons recorded for issue of notice under section 148 is dealt with as under: In the impugned reasons, your goodself has reached a reason to believe that an entry of Rs. 5,01,000 dated December 18, 2002 received by the assessee, was a bogus entry and therefore ... reason to believe that there was an escapement of income of Rs. 5,01,000. The reason is erroneous and invalid for the following reasons: 2.1. There are no details or material extracted in the impugned reasons showing further the nature or type of the information. 2.2. How your goodself

Sh. Hari Prakash Gupta, Jaipur vs. ITO, Ward-1(2), Jaipur

The appeal stands allowed

ITA 771/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11
For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

reasons recorded for issue of notice under section 148 is dealt with as under: In the impugned reasons, your goodself has reached a reason to believe that an entry of Rs.5,01,000 dated December 18, 2002 received by the assessee, was a bogus entry and therefore ... reason to believe that there was an escapement of income of Rs.5,01,000. The reason is erroneous and invalid for the following reasons: 2. 1. There are no details or material extracted in the impugned reasons showing further the nature or type of the information. 2. 2. How your

Mo. Shariph Kureshi, Sikar vs. ITO Ward-4 Sikar, Sikar

In the result, the appeal of the assessee is allowed

ITA 366/JPR/2025[2013-14]Status: DisposedITAT Jaipur18 Sept 2025AY 2013-14

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

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 234ASection 271(1)(c)

assesses or reassesses any income chargeable to tax, which has escaped assessment for any assessment year, with respect to which he had "reason to believe" to be so, then only, in addition, he can also put to tax, the other income, chargeable to tax, which has escaped assessment, and which ... Kureshi, Sikar. proceedings under s. 147, the AO were to come to conclusion, that any income chargeable to tax, which, according to his "reason to believe", had escaped assessment for any assessment year, did not escape assessment, then, the mere fact, that the AO entertained a reason to believe, albeit

Amee Govindbhai Patel, Mehsana vs. The Income Tax Officer, Ward-1, Mehsana

In the result, the appeal of the assessee is, therefore, allowed in above terms

ITA 120/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2016-17

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Respondent byFor Respondent: Shri Abhijit, Sr. DR
Section 147Section 250Section 68Section 69A

material and facts related to Income. As assessee did not disclosed the correct income in the return of income filed. 1 have a reason to believe that the income of Rs.42.50,000/- escaped assessment on account of failure on the pan of assesses to fully and truly disclosed ... assessment u/s. 143(3) of the IT Act was made. Accordingly, in this case, the only requirement to initiate proceedings u/s, 147 is reason to believe which has been recorded above. It is pertinent to mention here that in this ease the assessee has filed return of income

Shri Nityanand Pandey, Hooghly vs. I.T.O., Ward - 23(1), Hooghly

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

ITA 2067/KOL/2024[2013-2014]Status: DisposedITAT Kolkata18 Sept 2025AY 2013-2014

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 148Section 148(2)Section 250

based of reason to suspect unsustainable as A.O. failed to demonstrate live link between tangible material and formation of reason to believe that income had escaped assessment, hence the reassessment is bad-in-law. 7. For that on the facts and in the circumstances of the case