“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

Tejashree Atul Patil, Pune vs. Pr.CIT - 2, Pune

In the result, appeal of the assessee is dismissed

ITA 927/PUN/2025[2015-16]Status: DisposedITAT Pune08 Sept 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri C.V.DeshpandeFor Respondent: Shri Amit Bobde

Section 147Section 148Section 263Section 54F

Since huge amount in cash given by the assessee to her husband and no return of income filed, ld. Assessing Officer had reason to believe that Rs.1,58,94,320/- had escaped the assessment and accordingly issued notice u/s.148 of the Act on 31.03.2021 and reopened the assessment u/s.147 after ... which was not offered for taxation due to non filing of ITR for A.Y 2015-16. I have therefore, reason to believe that the income chargeable to tax amounting to Rs. 1,58,94,320/-has escaped assessment within the meaning of provisions of section

Income Tax Officer, Ward-1(1), Kolkata vs. Avinash Commercial Private Limited, Kolkata

In the result, the appeal of the Revenue is allowed for statistical purposes

ITA 1603/KOL/2024[2012-13]Status: DisposedITAT Kolkata08 Sept 2025AY 2012-13

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(2)Section 143(3)Section 147Section 148Section 149Section 250Section 69

assessment u/s 147/143(3) without independent application of mind, without having any fresh material and without having due consideration of law towards “reason to believe”. Therefore, passing the order u/s 143(3)/147 is beyond Jurisdiction and liable to be set aside. 2. For that, on the facts and circumstance

Narayan Suppliers Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(3), Kolkata

In the result, appeal of the assessee is dismissed

ITA 1077/KOL/2024[2011-2012]Status: DisposedITAT Kolkata08 Sept 2025AY 2011-2012

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri Avijit Ghoshal, ARFor Respondent: Shri Raja Sengputa, CIT-DR

Section 10(38)

mind by the AO on the information received by him nor he has made any enquiry to show that whatever stated in the reasons was believable. The AO in the reasons has stated that the information was received from the Pr. Director of Income Tax (Inv.), Kolkata wherein ... held that "prior to the reopening of the assessment, the AO had to, applying his mind to the materials, conclude that he had reason to believe that income of the assessee had escaped assessment. Unless that basic jurisdictional requirement was satisfied, a post mortem exercise of analysing materials produced subsequent

Laurels Properties Private Limited, Delhi vs. DCIT CC-1(4), Mumbai

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

ITA 1179/MUM/2025[2015-16]Status: DisposedITAT Mumbai05 Sept 2025AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 250

independent enquiry was made by the Ld. Assessing Officer before the re-opening of assessment proceedings to translate the information into a 'reason to believe' or even before passing the assessment order. 4. On the facts and in the circumstances of the appellant's case ... aside and no independent enquiry was made by the AO before the re- opening of assessment proceedings to translate the information into a 'reason to believe' or even before passing the assessment order. Apart from the above, it was also argued Ld. CIT(A) erred in upholding the disallowance

M/S Real Time Consultants Pvt. Ltd., Mumbai vs. ITO 15(3)(1), Mumbai

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

ITA 3290/MUM/2019[2011-12]Status: DisposedITAT Mumbai05 Sept 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Prabhash Shankar

For Appellant: Shri Rushabh Mehta,ARFor Respondent: Shri Uma Shankar Prasad, (CIT DR)

Section 131Section 133(6)Section 143(3)Section 147Section 148

erred in sustaining the actions of the Assessing Officer of initiating reassessment proceedingsfor making a ‘fishing or roving inquiry' without proper reason to believe that income had escaped assessment. 6. In the facts and circumstances of the case and in law, the learned CIT(A) has erred in sustaining ... Thus, it is evident that the department was in possession of fresh information which led the AO to arrive at reasons to believe necessary to invoke the provisions of section 147 of the Act. The Hon'ble Delhi High Court in the case of AGR Investments Ltd. vs. Addl

Income Tax Officer Ward-3(3)(2), Ahmedabad vs. Kapil Arun Agrawal, Ahmedabad

In the result, appeal of the Revenue stands dismissed

ITA 672/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad04 Sept 2025AY 2015-16

Bench: Shri Sanjay Garg & Smt. Annapurna Guptaआयकर अपील सं /Ita No.672/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Income Tax Officer Kapil Arun Agrawal बनाम/ Ward-3(3)(2) B-130 Pushp Industrial Park V/S. Ahmedabad Near Shital Cinema, Gomtipur Rakhial Ahmeabad – 390 021 "थायी लेखा सं./Pan: Agupa 1914 H (अपीलाथ)/ Appellant) (*+ यथ)/ Respondent) Assessee By : Ms. Urvashi Sodhan, Ar Revenue By : Shri Ravindra, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 28/08/2025 घोषणा की तारीख /Date Of Pronouncement: 04/09/2025 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Ms. Urvashi Sodhan, ARFor Respondent: Shri Ravindra, Sr.DR

Section 147Section 250Section 68Section 69C

assuming jurisdiction to reopen an assessment by the Assessing Officer, there is a condition precedent that the Assessing Officer must have reasons to believe that the income of the assessee for that year has escaped assessment. It has been held time and again that such reasons to believe must have ... purely subjective satisfaction of the assessing authority, such reason should be held in good faith and cannot merely be a pretence. The reasons to believe must have a rational connection with or relevant bearing on the formation of the belief. Rational connection postulates that there must be a direct nexus

Zalavadiya Kalubhai Mohanbhai, HUF, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 806/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad04 Sept 2025AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha, Accountannt Member Assessment Year 2015-16

For Appellant: Shri Tushar Hemani, Sr. A.R. &For Respondent: Shri Abhijit, Sr. D.R

Section 10(38)Section 142(1)Section 143(2)Section 147Section 148

further submitted that assuming without admitting that the Assessing Officer has some information received from external authority, the same does not constitute reason to believe until and unless such information is subject to investigation by the Assessing Officer and on the basis thereof and on independent application of mind

Venkata Hanumantha Rao Yaka, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 1080/HYD/2025[2018-19]Status: DisposedITAT Hyderabad04 Sept 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: MS. S. Sandhya, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 249(3)

filer, the assessee has sold immovable property amounting to Rs.55,00,000/-. On the basis of the above information, the Assessing Officer has reason to believe that, the income chargeable to tax has escaped assessment and, therefore, a show cause notice u/sec.148A(b) of the Income

Deputy Commissioner of Income Tax, Salem vs. Govinda Rajulu Srinivasan, Salem

In the result, appeal of the Revenue stands dismissed

ITA 1245/CHNY/2025[2014-15]Status: DisposedITAT Chennai04 Sept 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Bhupendran, AdvocateFor Respondent: Mrs.C. Yamuna, CIT

Section 147Section 148Section 40Section 40A(3)

therefore, he re-opened the assessment. However, having reopened the assessment on the aforesaid information on the basis of which he formed his reasons to believe escapement of income viz., regarding sale of immovable property jointly with some party and receiving ₹7,55,55,190/- and (ii) some other transactions ... first line of authority, to which a reference has already been made earlier, adopted the principle that where the AO has formed a reason to believe that income has escaped assessment and has issued a notice under s.148 on certain specific issues, it was not open to him during

ACIT, Aaykar Bhawan, M.K. Road, Mumbai vs. Railroad Logistics India Private Limited, Mumbai

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

ITA 3873/MUM/2025[2012-13]Status: DisposedITAT Mumbai04 Sept 2025AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankaracit Vs. Railroad Logistics India Room No. 607, Aayakar Pvt Ltd Bhavan, Mk Road, Mumbai C/O, Metal Trim, Gala – 400020. No.1, Tankiwala Indl Estate, Steel Made Compound, Marol, Maroshi Road, Mumbai Pan/Gir No. Aaccr3484J (Applicant) (Respondent) Assessee By Shri Satish R. Mody, Adv. Revenue By Shri Annavaran Kasuri, Sr. Ar Date Of Hearing 12.08.2025 Date Of Pronouncement 09.09.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 07.03.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre / Cit(A), Mumbai For The Assessment Year 2012- 13. 2. Both The Grounds Raised By The Revenue Are Interrelated & Interconnected & Relates To Challenging The Order Of Ld. Cit(A) In Terming The Order Passed By Ao As Infructuous.

Section 139Section 142(1)Section 143(3)Section 144Section 144BSection 147Section 148Section 250Section 263

facts. The relevant extract of Section 147 is cited hereinunder for ease of reference: "147. Income escaping assessment-If the Assessing Officer has reason to believe" that any income chargeable to tax has escaped assessment" for any assessment year, he may", subject to the provisions of sections

Satya Enterprises, Bilaspur vs. Income Tax Officer, Ward-1(2), Bilaspur

In the result, appeal of the assessee is allowed

ITA 396/RPR/2025[2017-18]Status: DisposedITAT Raipur03 Sept 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.396/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Satya Enterprises Ward No.3, Shanti Nagar, Bilaspur (C.G.)-495 001 Pan: Adcfs1415L .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143Section 143(2)Section 143(3)Section 144Section 148Section 292B

contained in sub- section (2) of section 143 of the Act is mandatory and the Legislature in its wisdom by using the word "reason to believe" had cast a duty on the Assessing Officer to apply mind to the material on record and after being satisfied with regard to escaped ... contained in sub- section (2) of section 143 of the Act is mandatory and the Legislature in its wisdom by using the word "reason to believe" had cast a duty on the Assessing Officer to apply mind to the material on record and after being satisfied with regard to escaped

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, NFAC, Delhi

In the result, the appeal of the assessee is allowed

ITA 186/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR

Section 119Section 142(1)Section 147Section 148Section 69A

assessee has not filed its return of income for the year under consideration. In view of above facts of the case, having reasons to believe that an amount of exceeding Rs.1 Lakh has escaped assessment within meaning of Sec. 147 of the I.T. Act, 1961 to the tune of Rs.22 ... section 148 could not be sustained. iii. Bhavin Jayendrakumar Soni (2024) 165 taxmann.com 109 (Guj. HC) wherein it was held that forming of 'reason to believe' is merely based on the information so received by the Assessing Officer. Thus, it cannot be said that the Assessing Officer has recorded

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, Ward 3(1)(1), Rajkot-

In the result, the appeal of the assessee is allowed

ITA 185/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR

Section 119Section 142(1)Section 147Section 148Section 69A

Nandigam Veerabrahmam, Rajahmundry vs. Income Tax Officer, Ward-2(1), Rajahmundry

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

ITA 271/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam03 Sept 2025AY 2018-19

Bench: Us:

Section 147Section 148Section 148A

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

Baldeep Singh, Chandigarh vs. Asstt. Commissioner of Income Tax, Circle-5(1), Chandigarh

In the result, Assessee’s appeal is allowed

ITA 199/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh03 Sept 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 199/Chd/2025 "नधा"रण वष" / Assessment Year : 2012-13 Baldeep Singh, The Acit, C/O Tej Mohan Singh, बनाम Circle 5(1), Advocate Chandigarh Vs. #527, Sector 10-D. Chandigarh "थायी लेखा सं./Pan No: Adyps3636F अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Tej Mohan Singh, Advocate राज"व क" ओर से/ Revenue By : Sh. Vivek Varadhan, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 03.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 03.09.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 10.01.2025 Of Addl./Jcit(A)-1. Nagpur For The A.Y. 2012-13. 2. Grounds Of Appeal Are As Under: -

For Appellant: Sh. Tej Mohan Singh, AdvocateFor Respondent: Sh. Vivek Varadhan, Addl. CIT, Sr.DR

Section 143(3)Section 147Section 148Section 69A

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. 3. That

M/S Lorgan Lifestyle Ltd., Pune vs. ITO, Ward14(4), Pune

In the result, appeal of the assessee is allowed as per terms indicated above

ITA 215/PUN/2025[2015-16]Status: DisposedITAT Pune03 Sept 2025AY 2015-16

Bench: Dr.Manish Borad & Ms.Astha Chandra

For Appellant: Shri B S RajpurohitFor Respondent: Shri Amol Khairnar

Section 143(3)Section 250

sustaining the illegal reassessment order passed by Ld. AO u/s 143(3) r.w.s.147 of the Act, since no addition on account of reasons to believe for re-opening of assessment was made but disallowance of bad debts was made which was not a part of reasons to believe, thereby, violated ... Airways (I) Ltd. 5 M/s Lorgan Lifestyle Limited (supra) (2011) 331 ITR 236 and has submitted that since no addition on account of reasons to believe for reopening of assessment was made and the alleged disallowance of bad debts is not part of the reasons to believe, therefore, in light

Aviral Marketing Pvt. Ltd., Kolkata vs. DCIT, Circle 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1423/KOL/2025[2012-2013]Status: DisposedITAT Kolkata03 Sept 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Aviral Marketing Pvt. Ltd…….……………..............................……….……Appellant 7, Camac Street, Azimganj House, 1St Floor, Shakespeare Sarani, Kol- 700017. [Pan: Aacca3794N] Vs. Dcit, Circle-4(1), Kolkata……………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Appellant. Shri Ruchika Sharma, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 02, 2025 Date Of Pronouncing The Order : September 03, 2025 Order Per Rajesh Kumar: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

Section 143(3)Section 147Section 148Section 250Section 68

Vinimay Pvt. Ltd. 2 Aviral Marketing Pvt. Ltd from the assessee amounting to Rs.1,00,00,000/- and therefore, the Assessing Officer has reasons to believe based on the said material that Rs.1,00,00,000/- has escaped assessment within the meaning of section ... reopening the assessments were entirely vague and devoid of any material. As such, on the available material, no reasonable person could have any reason to believe that income had escaped assessment. Consequently, the Tribunal held that the proceedings under Section 147 of the said Act were invalid. 8. The Tribunal

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Ltd, Kolkata

Appeal of the Revenue is dismissed

ITA 2541/KOL/2024[2008-09]Status: DisposedITAT Kolkata02 Sept 2025AY 2008-09

Bench: 30th day of September 2007.

Section 143(3)Section 147Section 148Section 250Section 32

Therefore, I have the reason to believe that this amount of Rs. 78,70,194/-has escaped assessment and the case is a fit case for imitation of proceedings u/s 147 of the 1.T. Act, 1961" Thereafter, the Ld. AO proceeded to add an amount ... treated test to check abuse an inbuilt of power by the AO. One needs to give a schematic interpretation to the words 'reason to believe', failing which section 147 would give arbitrary powers to the AO to reopen assessments on the basis of mare 'change of opinion' which cannot

Deputy Commissioner of Income Tax Central Circle-2, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 360/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh01 Sept 2025AY 2020-21

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos.356, 357, 358 & 360/Chd/2024 निर्धारण वर्ष / A.Y. : 2016-17, 2017-18, 2019-20 & 2020-21 The Dcit, Central Circle-2, Ludhiana. Vs Ab Alcobev Pvt. Ltd., 154, 1St Floor, Aggarwal Plaza-1, Anandvas Shakurpur, North West, Delhi. अपीलार्थी/Appellant स्थायी लेखा सं./Pan No: Aalca0327J प्रत्यर्थी/Respondent & C.O. Nos.17 To 20/Chd/2025 In

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR

Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5

conjoint reading of the aforesaid provisions, it becomes clear that a search can take place only when a concerned officer has information and reason to believe that any person is in possession of any valuable assets, which has not been or would not be disclosed under the Act. In such ... Undisclosed income includes money, bullion or other valuable assets. It is only when the concerned officer has information about the same and has reason to believe that the said valuable assets has not been or would not be disclosed would give jurisdiction to the officer authorized to conduct a search

Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 358/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh01 Sept 2025AY 2019-20

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR

Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5