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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

Agni Steels Pvt. Ltd., Erode vs. DCIT, Circle-1, Erode

In the result, appeal filed by the assessee is allowed

ITA 1285/CHNY/2025[2014-15]Status: DisposedITAT Chennai18 Sept 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 801A

allowable business expenditure and needs to be disallowed u/s 37 of IT Act. In the view of the above, I have reason to believe that income chargeable to tax more than Rs.1 lakh has escaped assessment for assessment year 2014-15 within the meaning of section 147 of the Income ... from 1st April, 1989], they are given a go-by and only one condition has remained, viz., that where the Assessing Officer has reason to believe that income has escaped assessment, confers jurisdiction to reopen the assessment. Therefore, post 1st April, 1989, power to reopen is much wider. However

ACIT -7(1)(1), Mumbai vs. Mazagon Dock Shipbuilders Ltd., Mumbai

In the result, appeal of the Revenue is dismissed

ITA 6574/MUM/2024[2005-06]Status: DisposedITAT Mumbai18 Sept 2025AY 2005-06

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2005-06 Assistant Commissioner Of Mazagon Dock Shipbuilders Income Tax-7(1)(1), Ltd. Mumbai Mazdock House, Dockyard Vs. Road, Mazagon, Mumbai – 400010 (Pan: Aaacm8029) (Appellant) (Respondent)

For Appellant: Shri. Prateek Goyal, AdvocateFor Respondent: Shri. Umashankar Prasad, CIT DR
Section 143(3)Section 147Section 148Section 50C

assessment proceedings u/s. 143(3), the income chargeable to tax will definitely be in lakhs of rupees. He thus, arrived at a reason to believe that income chargeable to tax has escaped assessment by reason of failure on the part of the assessee to disclose fully and truly all material ... facts necessary for the assessment. 3.1. It is important to take note of one specific para from the reasons to believe so recorded by the ld. Assessing Officer which reflects the casual mind for reopening the case, based merely on his apprehensions. The said para is extracted below: “The valuation

Advantage India, New Delhi vs. Pr.CIT (Central)-II, New Delhi

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

ITA 634/DEL/2019[-]Status: DisposedITAT Delhi18 Sept 2025

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Sanjay Mehra, FCAFor Respondent: Shri Javed Akhtar, CIT [DR]
Section 127Section 127(2)Section 12ASection 13(1)(c)

necessarily prospective. What it provides that the Commissioner has statutory powers to cancel the registration u/s. 12A/12AA if he finds reason to believe that the activities of the assessee are not in line with its objects or the activities carried out by the assessee are not genuine in nature

Sh. Ashok Kumar, Haridwar vs. ITO, Haridwar

In the result, the appeal of the assessee is allowed

ITA 107/DDN/2025[2015-16]Status: DisposedITAT Dehradun17 Sept 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalashok Kumar, Assessment Unit, 19, Sitapur Mazara, Jwalapur, Income Tax Haridwar, Uttarakhand-249407 Vs. Department. Pan-Btupk9604E (Appellant) (Respondent) Assessee By Shri Pankaj Goel, Adv. Department By Shri A. S. Rana, Sr. Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 17/09/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Ld. Cit(A)’ For Short) In Appeal No. Nfac/2014-15/10271519 Dated 10.04.2025 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is An Agriculturist Having No Any Other Source Of Income Than Agricultural Income. Since, The Income From Agricultural Operations Is Exempt From Tax, He Was Not Obliged To File The Return Of Income. The Assessing Officer Based On The Information That Assessee Has Deposited A Sum Of Rs.76,00,000/- In Zila Sahkari Bank Ltd., Initiated Reassessment Proceedings In The Case Of Assessee By Recording Reasons That Income To The Extent Of Rs.76,00,000/- Has Escaped Assessment In The Order Passed U/S 148A(D) Of The Act. Accordingly, Notices U/S 148 Was Issued On 26.03.2022. In Response To Which Assessee Filed Return Of Income On 12.04.2022 Ashok Kumar Vs. Ito Declaring Total Income Of Rs.10,00,000/- From Agriculture Activity & Claimed The Same As Exempt From Tax. The Assessing Officer Passed The Reassessment Order Wherein He Has Made The Additions On Account Of Agriculture Income Of Rs.10,00,000/- By Treating The Same As Income From Other Sources & Further Made Additions Of Rs.76,00,000/- Being Cash Deposited During Demonetization As Unexplained Money U/S 69A Of The Act. The Ao Further Made Additions Of Rs.2,67,195/- As Against Nil Income Declared Towards Bank Interest.

Section 147Section 148Section 148ASection 69A

service of notice to the assessee before the Assessing Officer proceeds to assess, reassess or recompute escaped income. Section 147 mandates recording of reasons to believe by the Assessing Officer that the income chargeable to tax has escaped assessment. All these conditions are required to be fulfilled to assess ... proceedings the Assessing Officer comes to conclusion that some items have escaped assessment, then notwithstanding that those items were not included in the reasons to believe as recorded for initiation of the proceedings and the notice, he would be competent to make assessment of those items. However, the legislature could

Yadav Rice Mills, Muktsar vs. Deputy Commissioner of Income Tax, Circle-2, Bathinda

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

ITA 415/ASR/2024[2012-13]Status: DisposedITAT Amritsar17 Sept 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashwani Kumar, Ms. Deepali Aggarwal
Section 131Section 143(1)Section 143(3)Section 147Section 148Section 151Section 250Section 68Section 69C

fact that it is trite law that at the time of initiation of proceedings u/s 147 of the Act, the condition precedent is reason to believe that income had escaped assessment but not establishment of the fact of actual escapement of income. Accordingly, while issuing notice

The Daivadnya Co-Operative Credit Society Limited, Karwar vs. The Assistant Commissioner of Income Tax, NFAC, Delhi

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

ITA 226/PAN/2025[2014-15]Status: DisposedITAT Panaji17 Sept 2025AY 2014-15

Bench: Shri Pavan Kumar Gadalei T A. Nos. 226/Pan/2025 (A.Y. 2014-15 ) The Daivadnya Cooperative Vs I T O, Credit Society Limited, National E Assessment . 1,Near Busstand, Centre, Maruti Galli, Delhi. Karwar-581301, . Uttara Kannada, Karnataka. Pan .No.Aaaad2169G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P

Subsequently the Assessing officer (A.0) found that the assesse has advanced loans and accepted the deposits from non members and the A.O has reason to believe that the income has escaped assessment and issued notice u/sec148 of the Act and also notice u/sec 142(1) of the Act is issued

Bharat Hanchinale, Chikodi vs. Income Tax Officer, Ward - 1, Nippani

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

ITA 219/PAN/2025[2020-21]Status: DisposedITAT Panaji17 Sept 2025AY 2020-21

Bench: Shri Pavan Kumar Gadalei T A. Nos. 219/Pan/2025 (A.Y.2020-21) Bharat Hanchinale, Vs National Faceless 1081,Hanabar Galli, Assessment Centre, . Khadaklat, Chikodi, New Delhi-110003. Belgaum-591228. Karnataka. Pan/Gir No. Aojph8149C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 69A

Rs.20,61,566/- as against 2 ITA. No.219/PAN/2025 Bharat Hanchinale. the income offered in the return of income filed. The Assessing Officer has reason to believe that the income has escaped assessment and issued notice u/sec148 of the Act and there was no proper compliance to the notice. Further

J.K.V. Stonex, Kishangarh vs. Income Tax Officer, Kishangarh

In the result, the appeal of the assessee is allowed

ITA 542/JPR/2025[2012-13]Status: DisposedITAT Jaipur17 Sept 2025AY 2012-13

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

For Appellant: ShriSandeep Jhanwar, CAFor Respondent: Shri Gaurav Awasthi, JCIT-DR
Section 147Section 68

conclusion. Function of the Assessing Officer at this stage is to administer the statute. What is required at this stage is a reason to believe and not establish fact of escapement of income and therefore. lookingto the scope of section 147 as also sections 148 to 152, even if scrutiny ... Income Rajesh Jhaveri Stock Brokers Pvt. in Civil Appeal No 2830 of 2007 held thatif the Assessing Officer for whatever reason has reason to believe that income has escaped assessment it confers jurisdiction to reopen the assessment. The relevant portion of the above decision is reproduced as under:- 16. Section

Sh. Baljinder Kumar Aggarwal 171, Model Town Ludhiana, Punjab vs. Jatin Abbi the Assistant Commissioner of Income Tax Circle-1 Ludhiana, Punjab

In the result, appeal of the Assessee is partly allowed

ITA 689/CHANDI/2024[2012-2013]Status: DisposedITAT Chandigarh17 Sept 2025AY 2012-2013

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 689/Chd/2024 िनधा"रण वष" / Assessment Year : 2012-13 बनाम Shri Baljinder Kumar Aggarwal, The Acit, 171, Model Town, Circle-1, Vs Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Bmcpk7473A अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit, Dr तारीख/Date Of Hearing : 21.08.2025 उदघोषणा क" तारीख/Date Of Pronouncement : 17.09.2025

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 10(38)Section 143(1)Section 148

persons on sale of certain stocks are not genuine. A perusal of Section 147 would indicate that it contemplates that AO has a reason to believe that income has escaped assessment. This formation of belief is to be based on the information which prima-facie suggests escapement of income

ITO, Kolkata vs. Ajit Kumar Minda, Kolkata

ITA 2668/KOL/2024[2015-16]Status: DisposedITAT Kolkata17 Sept 2025AY 2015-16

Bench: Shri Manunatha G & Shri Sonjoy Sarmaι.Τ.Α. No.2668/Kol/2024

Section 10(38)Section 142(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69C

आयकर अपीलीय अधिकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH KOLKATA Before Shri Manunatha G, Accountant

DCIT-27(3), Mumbai, Navi Mumbai vs. Vimal Arvind Kapasi, Ghatkopar-West

In the result, the appeal of the Revenue is allowed

ITA 3569/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Sept 2025AY 2014-15

Bench: Shri Om Prakash Kantms Suchitra Kamblethe Deputy Commissioner Vimal Arvind Kapasi, Vs. Of Income Tax-27(3), 4, Swati Apt., Hansoli Lane, Mumbai. Cama Lane, Ghatkopar-West, Mumbai-400086. [Pan :Adqpk1014 P] (Appellant) .. (Respondent) Appellant By : Shri Rajesh Shah, Ar Respondent By: Ms Kavitha Kaushik, Sr. Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 17.09.2025 O R D E R

For Appellant: Shri Rajesh Shah, ARFor Respondent: Ms Kavitha Kaushik, Sr. DR
Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 68

from sale of penny shares of First Financial Services during the year ended on 31.03.2014. There was reason to believe that by claiming exemption u/s 10(38) of the Income Tax Act, 1961 on account of ‘Long Terim Capital Gain’ accrued from arranged and bogus transactions in aforesaid equity shares

DCIT, Circle-14(2), New Delhi vs. Kohinoor Foods Ltd., Faridabad

In the result, the Revenue’s appeal as well as Assessee’s Appeal stand dismissed in the aforesaid manner

ITA 587/DEL/2020[2011-12]Status: DisposedITAT Delhi17 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Dcit, Circle-14(2), New Delhi Vs. M/S Kohinoor Foods Ltd. 10Th Floor, Pinnacle Room No. 323, C.R. Building, New Delhi – 2 Business Tower, Suraj Kund Road, Faridabad Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) & M/S Kohinoor Foods Ltd. Vs. Acit, Circle 14(2), 10Th Floor, Pinnacle New Delhi Business Tower, Suraj Kund Road, Faridabad, Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) Assessee By : S/Sh. Salil Kapoor, Utkarsha Kumar Gupta, Ms. Soumya Singh, Advocates Department By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 28.08.2025 Date Of Pronouncement 17.09.2025

For Appellant: S/Sh. Salil Kapoor, Utkarsha KumarFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 147Section 68Section 92C

payments made by assessee has been withdrawn in 4 cash by the seller party. This is also the allegation as mentioned in the reason to believe. Regarding argument of appellant that books of accounts are duly audited and no qualification has been made by Auditor nor rejected ... proceedings u/s 147/148 of the Act is void and the order is required to be annulled. On going through the details and the reason to believe, it is found that AO has received information regarding purchases made by appellant during the year under consideration, where based on the STR report

Kohinoor Foods Ltd., Faridabad vs. ACIT, Circle-14(2), New Delhi

In the result, the Revenue’s appeal as well as Assessee’s Appeal stand dismissed in the aforesaid manner

ITA 149/DEL/2020[2011-12]Status: DisposedITAT Delhi17 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Dcit, Circle-14(2), New Delhi Vs. M/S Kohinoor Foods Ltd. 10Th Floor, Pinnacle Room No. 323, C.R. Building, New Delhi – 2 Business Tower, Suraj Kund Road, Faridabad Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) & M/S Kohinoor Foods Ltd. Vs. Acit, Circle 14(2), 10Th Floor, Pinnacle New Delhi Business Tower, Suraj Kund Road, Faridabad, Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) Assessee By : S/Sh. Salil Kapoor, Utkarsha Kumar Gupta, Ms. Soumya Singh, Advocates Department By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 28.08.2025 Date Of Pronouncement 17.09.2025

For Appellant: S/Sh. Salil Kapoor, Utkarsha KumarFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 147Section 68Section 92C

payments made by assessee has been withdrawn in 4 cash by the seller party. This is also the allegation as mentioned in the reason to believe. Regarding argument of appellant that books of accounts are duly audited and no qualification has been made by Auditor nor rejected ... proceedings u/s 147/148 of the Act is void and the order is required to be annulled. On going through the details and the reason to believe, it is found that AO has received information regarding purchases made by appellant during the year under consideration, where based on the STR report

Quality Enabled Remote Solutions (P) Ltd., New Delhi vs. ITO, Ward-20(3), New Delhi

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

ITA 4107/DEL/2018[2009-10]Status: DisposedITAT Delhi17 Sept 2025AY 2009-10

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareekquality Enabled Remote Solutions (P) Ltd., Vs. Ito, Ward 20 (3), Ugf – 61A, World Trade Centre, New Delhi. Babur Road, Connaught Place, New Delhi – 110 001. (Pan :Aaacq0881A) (Appellant) (Respondent) Assessee By : Shri S. Krishnan, Advocate Shri Harshit Chauhan, Advocate Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 09.07.2025 Date Of Order : 17.09.2025 O R D E R Per S.Rifaur Rahman,Am: 1. This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-25, New Delhi [“Ld. Cit(A)”, For Short] Dated 16.08.2017 For The Assessment Year 2009-10 Raising Following Grounds Of Appeal :- “1. The Order Passed By Id. Cit(A) Is Wrong Both On Facts & In Law.

For Appellant: Shri S. Krishnan, AdvocateFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 147Section 148Section 234A

have any underlying or actual business transactions. With the above reasons recorded in the reasons, the Assessing Officer recorded and found reasons for believe in para 5 of the reasons recorded as per which, on perusal of various seized documents clearly show that the name of the assessee company appears ... closing stock of nil. It was also submitted that the reasons were recorded u/s 147 of the Act alleging that Assessing Officer has reasons to believe that the amount of at least Rs.3.4 crores has escaped assessment within the meaning of section 147. Further assessee submitted that the reasons

Kkotilya Chits Limited, Belagavi vs. ITO Ward-1, Income Tax Offices Opposite Civil Hospital

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

ITA 214/PAN/2025[2012-13]Status: DisposedITAT Panaji16 Sept 2025AY 2012-13

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

made time deposits and cash deposits in the bank account in F.Y.2011-12 and also income disclosed as per the Form.no26As.The assessing officer has reason to believe that the income has escaped the assessment and issued notice u/sec148 of the Act. In compliance, the assessee has filed the return of income

Aretha Dsouza, Vagator vs. Assistant Commissioner of Income Tax, Central Circle, Panaji

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

ITA 153/PAN/2025[2018-19]Status: DisposedITAT Panaji16 Sept 2025AY 2018-19

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 144

search action in the case of Shri Jhon Stephen D souza found that the assessee was working with the business organisation and has reason to believe that the income has escaped the assessment and has issued notice u/sec148 of the Act and also the notice u/sec142

Income Tax Officer-1, Korba vs. M/S Budhia Auto, Main Road

Accordingly, ground no. 1 of the appeal of revenue stands dismissed and the disallowance made by Ld

ITA 158/RPR/2025[2012-13]Status: DisposedITAT Raipur16 Sept 2025AY 2012-13

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 158/Rpr/2025 (िनधा"रण वष" Assessment Year: 2012-13)

For Appellant: NoneFor Respondent: Shri Ram Tiwari, Sr. DR
Section 142(1)Section 143(3)Section 144Section 147Section 148Section 250Section 43B

settled law that such view is not permitted within the scope of Income Tax laws. The Assessing Officer prima facie has to form "reason to believe" that income has escaped assessment before passing re-assessment order u/s. 147 of the Act and satisfaction to that extent has to be recorded

Mrs. Pranita P. Thakur, Mumbai vs. Income Tax Officer Ward4(3), Mumbai

In the result, ITA No.4704/M/2023 is partly allowed and ITA

ITA 4705/MUM/2023[2009-10]Status: DisposedITAT Mumbai16 Sept 2025AY 2009-10

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Shreyash Shah, Ld. A.RFor Respondent: Shri Kiran K. Chhatrapati, Ld. Sr. DR
Section 132Section 147Section 148Section 151Section 250Section 68

income of Rs.35,00,000/- have escaped assessment. In view of the information/facts mentioned in paras 1,2,3 above, I have reason to believe that, an amount of Rs.35,00,000/- has escaped assessment due to failure on the part of the assessee to disclosed her income by filing ... under consideration in its capital account. According to the Ld.AO, sources of the said cash was not explained and therefore, he recorded reasons to believe that income was escaped assessment and issued notice u/s 148 of the Act on 28.01.2016. During the course of reassessment proceedings, the assessee explained that

Mrs. Pranita P Thakur, Mumbai vs. Income Tax Officer, Ward4(3), Thane

In the result, ITA No.4704/M/2023 is partly allowed and ITA

ITA 4704/MUM/2023[2010-11]Status: DisposedITAT Mumbai16 Sept 2025AY 2010-11

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Shreyash Shah, Ld. A.RFor Respondent: Shri Kiran K. Chhatrapati, Ld. Sr. DR
Section 132Section 147Section 148Section 151Section 250Section 68

income of Rs.35,00,000/- have escaped assessment. In view of the information/facts mentioned in paras 1,2,3 above, I have reason to believe that, an amount of Rs.35,00,000/- has escaped assessment due to failure on the part of the assessee to disclosed her income by filing ... under consideration in its capital account. According to the Ld.AO, sources of the said cash was not explained and therefore, he recorded reasons to believe that income was escaped assessment and issued notice u/s 148 of the Act on 28.01.2016. During the course of reassessment proceedings, the assessee explained that

Shantadurga Multi Purpose Souharda Sahakari Niyamit, Belagavi vs. Income Tax Officer, Ward - 2, Belagavi

In the result, the two appeals filed by the assessee are allowed

ITA 204/PAN/2025[2016-17]Status: DisposedITAT Panaji15 Sept 2025AY 2016-17

Bench: Shri Pavan Kumar Gadalei T A. Nos. 203 &204/Pan/2025 (A.Y.2015-16 & A.Y.2016-17) Shantadurga Multi Purpose Vs National E – Souharda Sahakari Niyamit, Assessment Centre . Shop.No.13/14,Mangal Deep, Delhi-110001 Apartments Opp:Herwadkar, Belagavi-590006, Karnataka. Pan .No.Aahas7562F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Ramesh Mudhol.Ar Revenue By Smt. Manjula Thakur.Sr.Dr सुनवाई की तारीख/Date Of Hearing 10.09.2025 घोषणा की तारीख/Date Of Pronouncement 15.09.2025 Order Per Pavan Kumar Gadale, Jm: These Two Appeals Are Filed By The Assesse Against The Separate Orders Of National Faceless Appeal Centre (Nfac) Delhi / Cit(A) Passed U/Sec 250 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Order Of The Nfac/ Cit(A) Sustaining The Denial Of Claim Of Deduction Under Section 80P Of The Act Applying The Provisions Of Section 80Ac Of The Act. 2. Since Issues Involved In These Appeals Are Common & Identical, Hence They Are Clubbed, Heard & A Consolidated Order Is Passed. For The Sake Of Convenience

Section 80Section 80ASection 80A(5)Section 80P

assesse has made cash deposits in the three bank accounts and the assesse has not filed the return of income. The A.O has reason to believe that the income has escaped assessment and issued notice u/sec148 and U/sec 142(1) of the Act . Further notice u/sec