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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

ITO-28(3)(1), Mumbai vs. Satya Prakash Singh, Mumbai

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

ITA 3844/MUM/2025[2012]Status: DisposedITAT Mumbai08 Aug 2025

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 143(3)Section 153Section 69C

taken bogus purchase bills to reduce and suppress the profits and reasons were recorded wherein the AO has held that he has 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

Mr. Satya Prakash Singh, Mumbai vs. ITO, Ward-28(3)(1), Vashi

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

ITA 3715/MUM/2023[2012-13]Status: DisposedITAT Mumbai08 Aug 2025AY 2012-13

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 143(3)Section 153Section 69C

taken bogus purchase bills to reduce and suppress the profits and reasons were recorded wherein the AO has held that he has 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

Children Welfare Trust (Regd), Faridabad vs. CIT Exemption, Chandigarh

In the result, Appeal of the Assessee is allowed

ITA 3637/DEL/2024[2016-17]Status: DisposedITAT Delhi08 Aug 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 3637/Del/2024 (A.Y 2016-17) Children Welfare Trust (Regd) Vs National Faceless C/O. Gita Balniketan Senior Assessment Centre, Secondary School, 3-E, Nit, Delhi (Nafac) Faridabad Delhi Pan: Aabtc6957B Appellant Respondent Assessee By Sh. Pavan Ved, Adv, Shri Mohit Gupta, Ca, Sh. Mirza, Ca & Shri Sarthakkh Aggarwal, Ca Revenue By Ms.Pooja Swaroop, Cit(Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 08/08/2025

Section 11(6)Section 139Section 143(3)Section 147Section 148Section 263

income & Expenditure/Receipt & Children Welfare Trust Vs. CIT(E) payment account nor in ITR under the schedule 'Voluntary Contributions'. 6. basis of forming reason to believe and details of escapement of income:- In view of the above facts, amount of Rs. 1,13,08,822/- is to be added back ... taxable income of the assessee trust. I have, therefore, reason to believe, that amount of Rs. 1,13,08,822/- chargeable to tax has escaped assessment. Further, the case will be assessed on any other issue which may come to notice during the assessment proceedings. 7. In this case

Dy. Commissioner of Income Tax Circle 10(1), Delhi, Cr Building vs. Indus Towers Limited, Gurgram

ITA 2805/DEL/2023[2011-12]Status: DisposedITAT Delhi08 Aug 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 142Section 143(3)

block of assets of the assessee at Nil consideration and without payment of due taxes. In view of this there is reason to believe that the colourable device created through a scheme of De- merger and Amalgamation is only for tax evasion and no taxes on these transactions have been ... which were transferred at book value at Rs.1622,77,60,000/-through a scheme of De-merger and subsequent Amalgamation. Therefore, I have reason to believe that the difference of Rs.5707,97,96,000/- (Rs.7330,75,56,000 -Rs.1622,77,60,000) is the value of benefit received by Idea

Indus Towers Ltd., Gurugram, Haryana vs. Deputy Commissioner of Income-Tax, Circle 12(1), New Delhi

ITA 2607/DEL/2023[2011-12]Status: DisposedITAT Delhi08 Aug 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 142Section 143(3)

block of assets of the assessee at Nil consideration and without payment of due taxes. In view of this there is reason to believe that the colourable device created through a scheme of De- merger and Amalgamation is only for tax evasion and no taxes on these transactions have been ... which were transferred at book value at Rs.1622,77,60,000/-through a scheme of De-merger and subsequent Amalgamation. Therefore, I have reason to believe that the difference of Rs.5707,97,96,000/- (Rs.7330,75,56,000 -Rs.1622,77,60,000) is the value of benefit received by Idea

DCIT, Central Circle-4, Surat vs. Ekkta Devlopers, Mumbai

In the result, both appeals are dismissed

ITA 577/SRT/2024[2015-16]Status: DisposedITAT Surat07 Aug 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.576 & 577/Srt/2024 (Ays:2014-15 & 2015-16) (Hybrid Hearing) Dcit, Vs. M/S Ekkta Developers, Central Circle – 4, B-702, Business Point, S. V. Road, Surat Andheri (W), Mumbai - 400058 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefe5374R (Appellant) (Respondent) Co Nos.38 & 37/Srt/2024 (Arising Out Of Ita Nos.576 & 577/Srt/2024) (Ays: 2014-15 & 2015-16) M/S Ekkta Developers, Vs. Dcit, B-702, Business Point, S. V. Road, Central Circle – 4, Andheri (W), Mumbai - 400058 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefj3969P (Appellant) (Respondent) Appellant By Shri Ravi Kant Gupta, Cit-Dr Respondent By Shri Ramesh Malpani, Ca Date Of Hearing 30/07/2025 Date Of Pronouncement 07/08/2025

Section 133ASection 143(1)Section 147Section 148Section 292CSection 69BSection 69C

Supreme Court in case of ACIT vs. Rajesh Javeri 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

Income Tax Officer, Jaipur vs. Pooja Kedia, Jaipuir

In the result, the appeal of the revenue is dismissed

ITA 1321/JPR/2024[2019-20]Status: DisposedITAT Jaipur07 Aug 2025AY 2019-20
For Appellant: Sh. Siddharth Ranka, Adv. &For Respondent: Sh. Gaurav Awasthi, JCIT, Sr. DR
Section 142(1)Section 147Section 148ASection 68

DGIT (Inv.) that assessee had made certain bogus purchases. Thus reopening of assessment itself is bad in law for having not recorded independent “reason to believe” that income has escaped assessment. Decided in favour of assessee. • Amar Partap Steels Pvt. Ltd. v. ITO ITA No. 108/JPR/2024 dated 03.10.2024 (ITAT Jaipur

Assistant Commissioner of Income Tax (Central Circle), Bareilly vs. Varunarjun Trust, Lucknow

In the result, both the appeals are dismissed

ITA 620/LKW/2024[2016-17]Status: DisposedITAT Lucknow07 Aug 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

wherein Hon’ble Supreme Court held: “We accordingly allow the appeal by holding that the notice issued to the assessee shows sufficient reasons to believe on Page 11 of 87 I.T.A. No.619 & 620/Lkw/2024 Assessment year:2015-16 & 16-17 the part of the Assessing Officer to reopen the assessment ... conditions must be satisfied before the Income Tax Officer can assume jurisdiction to issue notice under section 147 (a). First, he must have reason to believe that the income of the assessee has escaped Page 31 of 87 I.T.A. No.619 & 620/Lkw/2024 Assessment year:2015-16 & 16-17 assessment and secondly

Assistant Commissioner of Income Tax, Central Circle, Bareilly vs. Varunarjun Trust, Lucknow

In the result, both the appeals are dismissed

ITA 619/LKW/2024[2015-16]Status: DisposedITAT Lucknow07 Aug 2025AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

wherein Hon’ble Supreme Court held: “We accordingly allow the appeal by holding that the notice issued to the assessee shows sufficient reasons to believe on Page 11 of 87 I.T.A. No.619 & 620/Lkw/2024 Assessment year:2015-16 & 16-17 the part of the Assessing Officer to reopen the assessment ... conditions must be satisfied before the Income Tax Officer can assume jurisdiction to issue notice under section 147 (a). First, he must have reason to believe that the income of the assessee has escaped Page 31 of 87 I.T.A. No.619 & 620/Lkw/2024 Assessment year:2015-16 & 16-17 assessment and secondly

Income Tax Officer Ward Hingoli Camp at Parbhani, Parbhani vs. Sumangal Traders, Parbhani

ITA 1352/PUN/2024[2014-15]Status: DisposedITAT Pune07 Aug 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1352/Pun/2024 िनधा"रण वष" / Assessment Year : 2014-15 Ito, Ward Hingoli Camp At Vs. Sumangal Traders, Parbhani. House No.154, Ward No.16, Gangakhed Road, Parbhani- 431401. Pan : Aazfs5051Q Appellant Respondent Revenue By : Shri Akhilesh Srivastva Assessee By : None Date Of Hearing : 29.07.2025 Date Of Pronouncement : 07.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 19.03.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15. 2. The Revenue Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case, The Ld. Cit(A), Nfac Failed To Appreciate The Facts Of The Case & Without Considering The Same Decided The Case In Favour Of The Assessee Which Is Against The Law & The Order Of The Cit(A) Deserves To The Set-Aside. 2. The Ld. Cit(A) Erred In Law In Holding That The Property Was Not Transferred.

For Appellant: NoneFor Respondent: Shri Akhilesh Srivastva
Section 142(1)Section 147Section 148Section 43C

above land is Rs.3,49,54,000/-. Since no return of income was filed by the assessee partnership firm therefore there was reason to believe that income chargeable to tax in the hands of the assessee was escaped 3 assessment within the meaning of provisions of section

Income Tax Officer, Coimbatore vs. Damayanti Ramachandran, Gn Mills Post, Coimbatore

ITA 149/CHNY/2025[2016-17]Status: DisposedITAT Chennai07 Aug 2025AY 2016-17

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.103/Chny/2025, निर्धारण वर्ष/Assessment Year: 2015-16 Income Tax Officer, Non-Corporate Ward-4(3) Coimbatore Damayanti Ramachandran, Pb No.5303, Gn Mills Post, Coimbatore, Tamil Nadu-641029 [Pan: Aabhd8298Q] (अपीलार्थी/Appellant) V. (प्रत्यर्थी/Respondent) Co No.19/Chny/2025, निर्धारण वर्ष/Assessment Year: 2015-16 Damayanti Ramachandran, Pb No.5303, Gn Mills Post, Coimbatore, Tamil Nadu-641029 [Pan: Aabhd8298Q] Income Tax Officer, Non-Corporate Ward-4(3) Coimbatore V. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.149/Chny/2025, निर्धारण वर्ष/Assessment Year: 2016-17 Income Tax Officer, Non-Corporate Ward-4(3) Coimbatore Damayanti Ramachandran, Pb No.5303, Gn Mills Post, Coimbatore, Tamil Nadu-641029 [Pan: Aabhd8298Q] (अपीलार्थी/Appellant) V. (प्रत्यर्थी/Respondent) Co No.20/Chny/2025, निर्धारण वर्ष/Assessment Year: 2016-17 Damayanti Ramachandran, Pb No.5303, Gn Mills Post, Coimbatore, Tamil Nadu-641029 [Pan: Aabhd8298Q] Income Tax Officer, Non-Corporate Ward-4(3) Coimbatore (अपीलार्थी/Appellant) V. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By Mr.Ketan K. Ved, C.A

Section 45(4)

Driveshafts India Ltd v. ITO (2003) 259 ITR 19. The Ld. CIT(A) has erred in concluding that there was no arbitrariness in reasons to believe furnished by Ld. AD. The Ld. CIT(A) has erred in concluding that the AD is correct in establishing that the respondent had failed

Income Tax Officer, Coimbatore vs. Damayanti Ramachandran, Gn Mills Post, Coimbatore

In the result, both the appeals of revenue for the A

ITA 103/CHNY/2025[2015-16]Status: DisposedITAT Chennai07 Aug 2025AY 2015-16

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.103/Chny/2025, ननिाारण वर्ा/Assessment Year: 2015-16

For Appellant: Mr.Ketan K. Ved, C.AFor Respondent: Mr.Bipin C.N, CIT
Section 45(4)

Driveshafts India Ltd v. ITO (2003) 259 ITR 19.  The Ld. CIT(A) has erred in concluding that there was no arbitrariness in reasons to believe furnished by Ld. AD.  The Ld. CIT(A) has erred in concluding that the AD is correct in establishing that the respondent had failed

Hasmukhbhai Raghubhai Goriya, Old Dhuva vs. Income Tax Officer, Morbi

In the result, appeal filed by the assessee is allowed

ITA 195/RJT/2025[2011-12]Status: DisposedITAT Rajkot06 Aug 2025AY 2011-12

Bench: Dr. Arjun Lal Saini. आयकर अपील सं./Ita No.195/Rjt/2025 "नधा"रण वष"/Assessment Year: (2011-12) (Hybrid Hearing) Hasmukh Raghubhai Goriya, Vs. Income Tax Officer, Ward 2, Morbi Village: Old Dhuva, Taluka: J.K. Chamber, National High Way-8A, Wakaner, District: Morbi- Near Ravi Residency Hotel, Lalpar, 363622 Morbi-363642 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Awupg 3221 D (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Dheeraj Kumar Gupta, Ld. Sr. (DR)
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 69A

source of cash deposited in his bank account remains unexplained and required to be taxed. In view of the above, I have reason to believe that the income chargeable to tax has escaped to the extent of Rs.27,91,500/- for the A.Y.2011-12 within the meaning of section ... this case, no assessment was made and the only requirement to ITA No. 195/RJT/2025 A.Y.11-12 Hasmukhbhai R Goriya, initiate proceeding u/s. 147 is reason to believe which has been recorded above. It is pertinent to mention here that in this case the assessee has chosen not to file return

Venkateswara Rao Gopalam, Guntur vs. ITO, Ward - I, Tenali

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

ITA 283/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam06 Aug 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.

For Appellant: Sri DL Narasimha RaoFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 147Section 148Section 148ASection 44ASection 69A

cash withdrawals in current account maintained with Axis Bank to the tune of Rs.1,39,02,130/-. Therefore, the Assessing Officer has reason to believe that income chargeable to tax has escaped assessment. The Assessing Officer based on the information, reopened the case of the assessee u/sec.147 of the Income

Mukesh Jain HUF, Jaipur vs. DCIT, Jaipur

In the result, the appeal of the assessee is allowed

ITA 620/JPR/2025[2010-11]Status: DisposedITAT Jaipur06 Aug 2025AY 2010-11

Bench: Reopening The Assessment & Without Independent Application Of Mind. Thus, The Action Of The Ld. Ao In Reopening The Assessment U/S 148 & The Consequent Reassessment Order So Passed Deserves To Be Held Bad In Law.

For Appellant: Sh. Tarun Mittal, CAFor Respondent: MS. Alka Gautam, CIT-DR
Section 143(3)Section 147Section 148Section 68

Jain HUF vs. DCIT available on record a notice u/s 148 was issued on 30.03.2017 by ITO, Ward 6(1), Jaipur after recording reasons to believe that income has escaped assessment. Notice was issued after taking necessary approval from Pr CIT u/s 151 of the Act. In response thereof, assessee ... Thus, the assessee did not disclose fully & truly all material facts necessary for its assessment. Therefore, I have reasons to believe that income of Rs.14,21,622/- and commission paid thereon @2% has escaped assessment within the meaning of Section 147 of the Income-tax act 1961. From perusal

Deputy Commissioner of Income Tax, Jaipur vs. Bharat Spun Pipe and Construction Company, Jaipur

In the result the appeal of the revenue in ITA no

ITA 360/JPR/2025[2017-18]Status: DisposedITAT Jaipur06 Aug 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Ms. Alka Gautam, (CIT) (V.C.)
Section 144BSection 147Section 148Section 148ASection 153C

issuing a notice under Section 148 of the Act. Read in this light, what has been recorded by the Assessing Officer as his "reasons to believe" is nothing more than a report given by him to the Commissioner of Income Tax. As held by the Supreme Court in Chhugamal Rajpal ... submission of a report is not the same as recording of reasons to believe for issuing a notice. The Assessing Officer has clearly substituted form for substance and, therefore, the action of the Respondent falls foul of the law laid down by the Supreme Court in ChhugamalRajpal which is clearly

Prime Rose City School Samiti, Jaipur vs. ITO WD 1(1), Jaipur

ITA 280/JPR/2025[2020-21]Status: DisposedITAT Jaipur06 Aug 2025AY 2020-21

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

For Appellant: Shri Anoop Bhatia, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 10Section 12ASection 270ASection 68

course of assessment proceedings and/ or any application under Rule 46A now seeking to introduce the additional evidence, this appellate authority has reason to believe that the additions made by the Assessing Officer (a) of Rs.36.79,012/- i.e. disallowance u/s 10(3C)(iiiad) of the Income

Jajoo Rashmi Refractories Limited, Jaipur, Rajasthan vs. DCIT, Circle 4-Jaipur, Jaipur, Rajasthan

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

ITA 209/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 Aug 2025AY 2018-19
For Appellant: Ms. Prabha Rana, AdvocateFor Respondent: Shri Gaurav Awasthi, JCIT-DR
Section 131Section 145Section 147Section 69C

sources of income of the assessee have been shown in the ITR from business and profession. During the assessment proceedings, the AO had reason to believe that the assessee is engaged in bogus purchase of Rs.1,82,05,040/-. Subsequently a notice u/s 148of the Act dated

Shivam Readymix Private Limited, Jaipur vs. ACIT, Jaipur

In the result, the appeal of the assessee is allowed

ITA 166/JPR/2025[2012-13]Status: DisposedITAT Jaipur06 Aug 2025AY 2012-13
For Appellant: Shri Tarun Mittal, CA &For Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 40A(3)Section 69C

notice under section 148, the Assessing Officer accepts contention of assessee and holds that income, for which he had initially formed a reason to believe that it had escaped assessment, has, as a matter of fact, not escaped assessment, it is not open to him to independently assess some other ... income. 63 DTR 212 – CIT vs. Adhunik Niryat Ispat Ltd. (Delhi) [DOD: 28.07.2011] Reassessment Scope Issue not subject-matter of reasons to believe Assessment reopened on the ground that the assessee had accepted accommodation entries from some parties in the garb of share capital – However during the reassessment proceedings

Rsd Containers Private Limited, Jaipur vs. ITO, Ward 7(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1320/JPR/2024[2017-18]Status: DisposedITAT Jaipur06 Aug 2025AY 2017-18
For Appellant: Shri Mukesh Khandelwal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr.-DR
Section 115BSection 147Section 148Section 149Section 151Section 151ASection 153CSection 68

represent "in the form of asset. It is undisputed fact that the instant case was reopened as the assessing officer had a reason to believe that the income otherwise chargeable to tax has escaped assessment, because of alleged accommodation entries on account of unsecured loans 7.3. The appellant claimed that ... having only a piece of information flagged on insight portal and only on the basis of such information he framed reasons to believe the concealment and issued notice u/s 148 without application of mind. It has been held by various judicial authorities that no notice u/s 148 can be issued