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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

ACIT-8(1)(1), Mumbai vs. Reliance Life Sciences Pvt. Ltd., Navi Mumbai

ITA 2978/MUM/2025[2016-17]Status: DisposedITAT Mumbai25 Aug 2025AY 2016-17

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Nimesh Vora & Ms. Moksha Mehta, CAsFor Respondent: Shri Asif Karmali, Sr. DR
Section 143(3)Section 35Section 92F

having assessed the financial budget of 2015-16 and business plan of trading Pharmaceuticals Oncology products for the next 3 years, have no reason to believe that a material uncertainty exists that may cast significant doubt about the ability of the company to continue its operations as envisaged

Falgun Mahesh Oza, Mumbai vs. ITO Ward 22(1)(1), Mumbai

In the result, grounds of appeal of assesse is allowed

ITA 2970/MUM/2025[2009-10]Status: DisposedITAT Mumbai25 Aug 2025AY 2009-10

Bench: Shri Pawan Singh(Physical Hearing) Falgun Mahesh Oza Ito, Ward – 22(1)(1), Mumbai 3Rdfloow, Nandan Villa Model Town Vs Society Chs, Gulmohar Cross Road No. 7, Jvpd Scheme, Juhu, Mumbai – 400049. [Pan: Aaapo 0474 A] Appellant / Assessee Respondent / Revenue

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

account of multiple transaction. On the basis of such information, the assessing officer was of the view that he has reason to believe that income of Rs. 26,76,143/- has escaped from assessment. In response to notice under section 148, the assessee filed her reply dated 2 Falgun Mahesh ... officer, on the basis of which he could have validly reopened the assessment. There was no information with the assessing officer for forming reason to believe that income chargeable to tax has escaped assessment. The alleged information received from ADIT (Inv.) could not be treated as tangible information for reason

Shree Arihant Gems, Mumbai vs. Income Tax Officer-19(3)(1), Mumbai

ITA 2626/MUM/2025[2012-13]Status: DisposedITAT Mumbai25 Aug 2025AY 2012-13

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Himanshu GandhiFor Respondent: Shri Surendra Mohan
Section 131Section 143(1)Section 143(3)Section 147Section 148Section 250

Assessment Year 2012-2013 In view of the above facts and circumstances of the case and after application of my mind, I have reason to believe that the income of the assessee M/S. SHREE ARIHANT GEMS amounting to Rs. 20,10,000/- has escaped assessment due to failure ... facts necessary for the assessment in this case in terms of provisions of Section 147 of the I.T. Act 6. Basis of forming reason to believe and details of escapement of income During the investigation, the statement of Shri Deepak Kailash Babel was recorded

Lioyd'S Register of Shipping (Now Known As Lioyd 'S Register Group Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-3(1)(2), Mumbai

In the result, the appeal is allowed as indicated above

ITA 1457/MUM/2024[2010-11]Status: DisposedITAT Mumbai25 Aug 2025AY 2010-11

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Lloyd’S Register Of Shipping Dy. Cit (It)-3(1)(2) 16Th Floor, Air India Building, (Now Known As Lloyd’S Register Group Ltd.) Nariman Point, Mumbai-400 021 17Th Floor, Unit No. 1702, 1703 & Vs. 1704, Building Q2, Aurum Q Parc, Gen 4/1, Ttc, Thane Belapur Road, Ghansoli, Navi Mumbai-400 710

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Krishna Kumar
Section 143(1)Section 143(3)Section 147Section 234BSection 234CSection 40

read with section 147, the Assessing Officer does not assess or, as the case may be reassess the income which he has reason to believe had escaped assessment and which formed the basis of a notice under section 148, is it open to the Assessing Officer to assess or reassess ... notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped assessment, has as a matter of fact not escaped assessment, it is not open to him independently to assess some other income

Kanta Mittal, Delhi vs. CIT(A)-26, Delhi

In the result, the appeal of the assessee is allowed for

ITA 1433/DEL/2025[2014-2015]Status: DisposedITAT Delhi25 Aug 2025AY 2014-2015

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwal

Section 147Section 54B

erred in law _and_facts in upholding the reassessment_proceedings initiated _under_section 147 of the Income Tax Act 1961, without any valid reason to believe that income had escaped assessment. 2. The CIT(A) has failed_to consider _that_the reassessment proceedings were _ mechanically initiated __ without ___ proper verification

Devendra Kumar, Noida vs. Additional / Joint / Deputy / Assistant Commissioner of Income Tax, Delhi

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

ITA 5784/DEL/2024[2016-17]Status: DisposedITAT Delhi25 Aug 2025AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2016-17 Davendra Kumar, Additional/Joint/Deputy/Assistant Vs. H. No. 52, Vill. Barola, Commissioner Of Income Tax, Sector 49, Noida, U.P. Delhi Pin: 201 301 Pan: Caipk0485M (Appellant) (Respondent)

Section 10(37)Section 142(1)Section 144BSection 147Section 148Section 151Section 250Section 271(1)(c)Section 57

proceedings under section 147 of the Act ("Reassessment Proceedings") having been initiated on the basis of incorrect facts and without there being reason to believe that income of the appellant had escaped assessment, the impugned order is without jurisdiction, illegal. bad in law and liable to be quashed. 1.2. That

Shri Gulzar Ahmad Dar, Anantnag vs. Income Tax Officer Ward-1, Srinagar

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

ITA 530/ASR/2024[2016-17]Status: DisposedITAT Amritsar22 Aug 2025AY 2016-17

Bench: Shri Udayan Das Gupta & Shri Brajesh Kumar Singh[Assessment Year: 2016-17]

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 250Section 253Section 44A

escaped assessment. It is a trite law that for reopening of assessment, there must be only a prima facie basis for formation of reason to believe that income has escaped assessment. The escapement of income need not be proved at this stage. The AO found that the appellant failed

Assistant Commissioner of Income Tax, Central Circle-3, Surat vs. Massimo Enterprise, Surat

In the result, appeal of Revenue is dismissed and additional ground raised by the assessee is also dismissed

ITA 1111/SRT/2024[2013-14]Status: DisposedITAT Surat22 Aug 2025AY 2013-14

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1107 & 1108/Srt/2024 Assessment Years: 2014-15 & 2015-16 (Hybrid Hearing) Assistant Commissioner Of Jignesh Mahesh Amin बनाम/ Income-Tax, Central Circle- 418, Royal Trading Tower, Nr. Vs. 3, Surat, 5Th Floor, Aayakar Ratan Cinema, Salabatpura, Surat- Bhawan, Majura Gate, 395 003 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajpa 2349 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1109/Srt/2024 Assessment Year: 2013-14 Assistant Commissioner Of Anupa Jignesh Amin बनाम/ Income-Tax, Central Circle- B-19, Ashirwad Residency Near Vs. 3, Surat, 5Th Floor, Aayakar China Gate, City Light, Surat-395 Bhawan, Majura Gate, 017 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acspa 6502 F (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1111/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Assistant Commissioner Of Massimo Enterprise बनाम/ Income-Tax, Central Circle- Fp No.139, Orleaans, Near Sosyo Vs. 3, Surat, 5Th Floor, Aayakar Circle, Udhna Magdalla Road, Bhawan, Majura Gate, Surat-395 007 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aavfm 0143 M (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 250Section 68

Supreme Court in case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd., 291 ITR 500 (SC) held that the expression “reason to believe” would mean cause or justification and cannot be read to mean that the AO should have finally ascertained the fact by legal evidence or conclusion. Whether

Assistant Commissioner of Income Tax, Central Circle-3, Surat vs. Anupa Jignesh Amin, Surat

In the result, appeal of Revenue is dismissed and additional ground raised by the assessee is also dismissed

ITA 1109/SRT/2024[2013-14]Status: DisposedITAT Surat22 Aug 2025AY 2013-14

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1107 & 1108/Srt/2024 Assessment Years: 2014-15 & 2015-16 (Hybrid Hearing) Assistant Commissioner Of Jignesh Mahesh Amin बनाम/ Income-Tax, Central Circle- 418, Royal Trading Tower, Nr. Vs. 3, Surat, 5Th Floor, Aayakar Ratan Cinema, Salabatpura, Surat- Bhawan, Majura Gate, 395 003 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajpa 2349 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1109/Srt/2024 Assessment Year: 2013-14 Assistant Commissioner Of Anupa Jignesh Amin बनाम/ Income-Tax, Central Circle- B-19, Ashirwad Residency Near Vs. 3, Surat, 5Th Floor, Aayakar China Gate, City Light, Surat-395 Bhawan, Majura Gate, 017 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acspa 6502 F (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1111/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Assistant Commissioner Of Massimo Enterprise बनाम/ Income-Tax, Central Circle- Fp No.139, Orleaans, Near Sosyo Vs. 3, Surat, 5Th Floor, Aayakar Circle, Udhna Magdalla Road, Bhawan, Majura Gate, Surat-395 007 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aavfm 0143 M (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 250Section 68

Supreme Court in case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd., 291 ITR 500 (SC) held that the expression “reason to believe” would mean cause or justification and cannot be read to mean that the AO should have finally ascertained the fact by legal evidence or conclusion. Whether

Assistant Commissioner of Income Tax, Central Circle-3, Surat vs. Jignesh Mahesh Amin, Surat

In the result, appeal of Revenue is dismissed and additional ground raised by the assessee is also dismissed

ITA 1108/SRT/2024[2015-16]Status: DisposedITAT Surat22 Aug 2025AY 2015-16

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1107 & 1108/Srt/2024 Assessment Years: 2014-15 & 2015-16 (Hybrid Hearing) Assistant Commissioner Of Jignesh Mahesh Amin बनाम/ Income-Tax, Central Circle- 418, Royal Trading Tower, Nr. Vs. 3, Surat, 5Th Floor, Aayakar Ratan Cinema, Salabatpura, Surat- Bhawan, Majura Gate, 395 003 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajpa 2349 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1109/Srt/2024 Assessment Year: 2013-14 Assistant Commissioner Of Anupa Jignesh Amin बनाम/ Income-Tax, Central Circle- B-19, Ashirwad Residency Near Vs. 3, Surat, 5Th Floor, Aayakar China Gate, City Light, Surat-395 Bhawan, Majura Gate, 017 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acspa 6502 F (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1111/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Assistant Commissioner Of Massimo Enterprise बनाम/ Income-Tax, Central Circle- Fp No.139, Orleaans, Near Sosyo Vs. 3, Surat, 5Th Floor, Aayakar Circle, Udhna Magdalla Road, Bhawan, Majura Gate, Surat-395 007 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aavfm 0143 M (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 250Section 68

Supreme Court in case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd., 291 ITR 500 (SC) held that the expression “reason to believe” would mean cause or justification and cannot be read to mean that the AO should have finally ascertained the fact by legal evidence or conclusion. Whether

Assistant Commissioner of Income Tax, Central Circle-3, Surat vs. Jignesh Mahesh Amin, Surat

In the result, appeal of Revenue is dismissed and additional ground raised by the assessee is also dismissed

ITA 1107/SRT/2024[2014-15]Status: DisposedITAT Surat22 Aug 2025AY 2014-15

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1107 & 1108/Srt/2024 Assessment Years: 2014-15 & 2015-16 (Hybrid Hearing) Assistant Commissioner Of Jignesh Mahesh Amin बनाम/ Income-Tax, Central Circle- 418, Royal Trading Tower, Nr. Vs. 3, Surat, 5Th Floor, Aayakar Ratan Cinema, Salabatpura, Surat- Bhawan, Majura Gate, 395 003 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajpa 2349 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1109/Srt/2024 Assessment Year: 2013-14 Assistant Commissioner Of Anupa Jignesh Amin बनाम/ Income-Tax, Central Circle- B-19, Ashirwad Residency Near Vs. 3, Surat, 5Th Floor, Aayakar China Gate, City Light, Surat-395 Bhawan, Majura Gate, 017 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acspa 6502 F (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1111/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Assistant Commissioner Of Massimo Enterprise बनाम/ Income-Tax, Central Circle- Fp No.139, Orleaans, Near Sosyo Vs. 3, Surat, 5Th Floor, Aayakar Circle, Udhna Magdalla Road, Bhawan, Majura Gate, Surat-395 007 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aavfm 0143 M (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 250Section 68

Supreme Court in case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd., 291 ITR 500 (SC) held that the expression “reason to believe” would mean cause or justification and cannot be read to mean that the AO should have finally ascertained the fact by legal evidence or conclusion. Whether

Erothi Purnima Rani, Visakhapatnam vs. Income Tax Officer, Ward-4(1), Visakhapatnam

In the result, appeal filed by the assessee is allowed

ITA 185/VIZ/2023[2009-10]Status: DisposedITAT Visakhapatnam22 Aug 2025AY 2009-10

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 184/Viz/2023 निर्धारण वर्ा/ Assessment Year:2009-10) Erothi Latha Rani V. Income Tax Officer – Ward – 4(1) D.No. 34-10-1/B Income Tax Office Daya’S Street, Gnanapuram Pratyakshakar Bhavan Visakhapatnam – 530004 M.V.P. Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan:Aavpe7676H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita No. 185/Viz/2023 निर्धारण वर्ा/ Assessment Year:2009-10) Erothi Purnima Rani V. Income Tax Officer – Ward – 4(1) D.No. 34-10-1/B Income Tax Office Daya’S Street, Gnanapuram Pratyakshakar Bhavan Visakhapatnam – 530004 M.V.P. Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan:Aavpe7311H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt A. Aruna, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparna Villuri, Sr.Ar

Section 143(2)Section 143(3)Section 147Section 148

cash deposits made in her Axis Bank Account during the F.Y. 2008-09. Therefore, Ld. Assessing Officer [hereinafter in short “Ld.AO"] had reason to believe that the income chargeable to tax has escaped assessment within the meaning of section 147 of Income Tax Act, 1961 (in short ‘Act’). Thereafter proceeded

Erothi Latha Rani, Visakhapatnam vs. Income Tax Officer, Ward-4(1), Visakhapatnam

In the result, appeal filed by the assessee is allowed

ITA 184/VIZ/2023[2009-10]Status: DisposedITAT Visakhapatnam22 Aug 2025AY 2009-10

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 184/Viz/2023 निर्धारण वर्ा/ Assessment Year:2009-10) Erothi Latha Rani V. Income Tax Officer – Ward – 4(1) D.No. 34-10-1/B Income Tax Office Daya’S Street, Gnanapuram Pratyakshakar Bhavan Visakhapatnam – 530004 M.V.P. Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan:Aavpe7676H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita No. 185/Viz/2023 निर्धारण वर्ा/ Assessment Year:2009-10) Erothi Purnima Rani V. Income Tax Officer – Ward – 4(1) D.No. 34-10-1/B Income Tax Office Daya’S Street, Gnanapuram Pratyakshakar Bhavan Visakhapatnam – 530004 M.V.P. Double Road Andhra Pradesh Visakhapatnam – 530017 Andhra Pradesh [Pan:Aavpe7311H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt A. Aruna, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparna Villuri, Sr.Ar

Section 143(2)Section 143(3)Section 147Section 148

cash deposits made in her Axis Bank Account during the F.Y. 2008-09. Therefore, Ld. Assessing Officer [hereinafter in short “Ld.AO"] had reason to believe that the income chargeable to tax has escaped assessment within the meaning of section 147 of Income Tax Act, 1961 (in short ‘Act’). Thereafter proceeded

Harpreet Kaur, Bhopal vs. Income-Tax Officer, 5(2), Bhopal

ITA 730/IND/2024[2009-10]Status: DisposedITAT Indore22 Aug 2025AY 2009-10

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 131Section 133(6)Section 142(1)Section 143(2)Section 147Section 148Section 54Section 69A

आयकरअपीलीयअधिकरण,इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND

Shivam Betelnut Private Limited, Delhi vs. ACIT, Circle-22(2), New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 1297/DEL/2024[2020-21]Status: DisposedITAT Delhi22 Aug 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 147Section 69

during the year under consideration. 6. On the basis of the information and on enquiry the assessing officer had reason to believe that total income of the assessee to the extent of Rs. 74,19,41,815/- is chargeable to tax on account of above transaction has escaped from assessment

Shivam Betelnut Private Limited, Delhi vs. ACIT, Circle-22(2), Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 1296/DEL/2024[2017-18]Status: DisposedITAT Delhi22 Aug 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 147Section 69

during the year under consideration. 6. On the basis of the information and on enquiry the assessing officer had reason to believe that total income of the assessee to the extent of Rs. 74,19,41,815/- is chargeable to tax on account of above transaction has escaped from assessment

ACIT, Circle-26(2), New Delhi vs. Vikram Electric Equipment P.Ltd, New Delhi

ITA 4651/DEL/2018[2009-10]Status: DisposedITAT Delhi22 Aug 2025AY 2009-10

Bench: Shir Mahavir Singh() Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 143(1)Section 143(3)Section 147Section 148Section 68

I.T.A. No. 4651/Del/2018 & CO No.74/Del/2023 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F” NEW DELHI BEFORE SHIR MAHAVIR SINGH

Bhikhalal Prahaladrai Agarwal HUF, Gandhidham vs. Assistant Commissioner of Income Tax, Gandhidham Circle, Gandhidham

ITA 780/RJT/2024[2016-17]Status: DisposedITAT Rajkot21 Aug 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

been an escapement of income chargeable to tax. We also find that the AO was not having any material information to form "a reason to believe" that there was an escapement of income, in the assessee`s case under consideration. It is a settled position of law that the factually

Bhikhalal Prahladrai Agarwal HUF, Gandhidham vs. Assistant Commissioner of Income Tax Gandhidham Circle, Gandhidham

ITA 779/RJT/2024[2011-12]Status: DisposedITAT Rajkot21 Aug 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

been an escapement of income chargeable to tax. We also find that the AO was not having any material information to form "a reason to believe" that there was an escapement of income, in the assessee`s case under consideration. It is a settled position of law that the factually

Laggisetty Manohar Karthik, Chennai vs. ITO Non Corporate Ward 15(2), Chennai

In the result the appeal of the assessee is allowed

ITA 746/CHNY/2025[2012-13]Status: DisposedITAT Chennai21 Aug 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 746/Chny/2025 िनधा$रण वष$ / Assessment Year: 2012-13

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 147Section 54Section 80C

offered to tax in the said return of income filed for the assessment year under consideration. 5. The AO accordingly recorded the reason to believe income chargeable to tax arising out of the said sale of immovable property had escaped assessment and the notice u/s.148 of the Act dated