“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

Shri Vinod Sharma, New Delhi vs. ACIT, Circle, Shimla

In the result, Assessee’s appeal is partly allowed

ITA 1340/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh06 Aug 2025AY 2015-16

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1340/Chd/2019 "नधा"रण वष" / Assessment Year : 2015-16 Vinod Sharma, Acit, बनाम B-1/3, Safdarjang Enclave, Circle, New Delhi-110029. Shimla. Vs. "थायी लेखा सं./Pan No: Abkps1560N अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing) "नधा"रती क" ओर से/Assessee By : Shri. Vishal Mohan, Sr. Advocate With Shri Abhinav, Advocate (Virtual Mode) राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 14-05-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 06- 08-2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 16-08-2019 Of Ld. Commissioner Of Income Tax (Appeals), Shimla H.P. [ Herein Referred To As ‘Cit(A)’]

For Appellant: Shri. Vishal Mohan, Sr. Advocate with Shri Abhinav, Advocate (Virtual mode)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr.DR

Section 10Section 10(13)Section 54F

before the Assessing Officer nor before the Ld. CIT(A) and not even during the proceedings before the Tribunal. Therefore, there is no reason to believe the claim of the Assessee. Accordingly, under such circumstances, we find that the findings given by the Ld. CIT(A) on this issue

M/S. Innovative Micrfinance for Poverty Alleviation & Community Transformation, Chennai vs. CIT, Exemptions, Chennai

ITA 1161/CHNY/2025[-]Status: DisposedITAT Chennai06 Aug 2025

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1161/Chny/2025

Section 11Section 80G

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक

ITO 41(3)(1), Mumbai vs. Deepika Anil Agarwal, Mumbai

In the result the appeal filed by the revenue stands

ITA 1885/MUM/2025[2011-12]Status: DisposedITAT Mumbai06 Aug 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawal

Section 10(38)Section 132Section 132(4)Section 143Section 147Section 148Section 263Section 68

bogus LTCG amounting to Rs.2116776 /- had been facilitated to the assessee during the financial year 2010-11. Hence, I have reason to believe that the above income of Rs.2116776/- chargeable to tax has escaped assessment for the asst, year 2011-12, within the meaning of sec.147 of the Income ... considered as real. As laid down by this Court, apparent must be considered real until it is shown that there are reasons to believe that the apparent is not the real and that the taxing authorities are entitled to look into the surrounding circumstances to find out the reality

Mahesh Kumar, Delhi vs. ITO, Ward-68(6), Delhi

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2650/DEL/2024[2012-13]Status: DisposedITAT Delhi06 Aug 2025AY 2012-13

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 10(38)Section 143(3)Section 147Section 148Section 68

only additions made in the course of reassessment proceedings subject to the additions of amounts adverted to in the reassessment notice in the "reasons to believe" under Sections 147/148 of the Act and notice pursuant thereof?" However, the aforesaid reference ultimately came to be closed on 07 February ... 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

Ultra Modern Exports Pvt. Ltd., New Delhi vs. ITO Ward - 27(1), New Delhi

ITA 527/DEL/2020[2011-12]Status: DisposedITAT Delhi06 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Om Prakash, Sr. DR

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

also booked loss of Rs.11,74,00,000/- on sale of other investment by making sham transaction. Thus, I have reason to believe that the income of Rs.14,14,00,000/- has escaped assessment as defined under section 147 of the Act for assessment year 2011-12. / The escapernent ... assessee company whereby it is clear that the notice in question is merely based on 'reason to suspect' as opposed to `reason to believe'. The manner in which affairs are conducted by independent third parties, acting in their own self-interest and the results of any proceedings carried

Seema Devi Agrawal, Raigarh, Chhattisgarh vs. Income Tax Officer, Bilaspur

In the result, appeal of the assessee is allowed

ITA 250/RPR/2025[2015-16]Status: DisposedITAT Raipur04 Aug 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.250/Rpr/2025 "नधा"रण वष" /Assessment Year : 2015-16 Smt. Seema Devi Agrawal C/O. Sunil Kumar Agrawal Sewa Kund Road, Raigarh-496 001 (C.G.) Pan: Affpa4990K .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri Yogesh Sethia, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

legal ground is concerned, the Ld. Counsel for the assessee submitted that there was non-application of mind by the A.O while recording reasons to believe for reassessment proceedings. The Ld. Counsel in support of his aforesaid contention refers to the copy of the “reasons to believe”. For the sake ... been disclosed, thus confirming that the income chargeable to tax has escaped assessment for the AY 2015-16. Thus, I have reason to believe that the income of the assessee to the tune of Rs.1,22,80,100/- for the A.Y.2015-16 has escaped assessment within the meaning of explanation

Shri Shri Sandeep Meghani, Raipur (Cg) vs. The Dy. Commissioner of Income Tax, Raipur (Cg)

ITA 226/BIL/2016[2012-13]Status: DisposedITAT Raipur04 Aug 2025AY 2012-13

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No. 225 & 226/Bil/2016 ("नधा"रण वष" / Assessment Year: 2011-12 & 2012-13) Sandeep Meghani, V Dy. Commissioner Of Income Tax, Prop. M/S. Ramchandra Meghani & S Central Circle, Raipur (C. G) Sons, D-30, Shiv Shakti Villa, Sector-2, Bajaj Colony, New Rajendra Nagar, Raipur (Cg) Pan: Ajqpm2005E (अपीलाथ"/Appellant) . (""थ" / Respondent) . िनधा"रती की ओर से / Assessee By : Shri Sunil Kumar Agrawal, Ca राज" की ओर से / Revenue By : Shri Ram Tiwari, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 26.06.2025 घोषणा की तारीख / Date Of Pronouncement : 04.08.2025

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri Ram Tiwari, Sr. DR

Section 132(4)Section 144Section 153ASection 153DSection 250Section 69Section 69D

hundies name of the lender have not been mentioned. Issue date and due date as well as amount are reflected. There is no reason to believe that transactions have not been affected. In ground no-6 it has been contented that the addition made at para- 15 are erroneous

Shri Shri Sandeep Meghani, Raipur (Cg) vs. The Dy. Commissioner of Income Tax, Raipur (Cg)

ITA 225/BIL/2016[2011-12]Status: DisposedITAT Raipur04 Aug 2025AY 2011-12

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri Ram Tiwari, Sr. DR

Section 132(4)Section 144Section 153ASection 153DSection 250Section 69Section 69D

Shri Dinesh Sethi, Ludhiana vs. ITO, Ludhiana

The appeals are dismissed

ITA 338/CHANDI/2017[2006-07]Status: DisposedITAT Chandigarh04 Aug 2025AY 2006-07

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q 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 तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

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

Section 131Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 69A

required to have in his possession certain material or information on the basis of which he could prima-facie have reason to believe that income escaped assessment. The Hon'ble Delhi High Court in the case of Rattan Gupta Vs. CIT 234 ITR 2 20, observed as under:- "At this ... valid basis on the basis of information available at the time of initiating action u/s 147/148 of the Act to have prima-facie reason to believe that such income escaped assessment. The information received by the A.O., as mentioned above, could very well make him prima-facie have such reason

Sh. Dinesh Sethi, Ludhiana vs. ITO, Ludhiana

The appeals are dismissed

ITA 376/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh04 Aug 2025AY 2006-07

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

Section 131Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 69A

Truly Creative Developers Private Limited, Mumbai vs. ITO 13(3)(1), Mumbai

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

ITA 2771/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Aug 2025AY 2018-19

Bench: Shri Pavan Kumar Gadaleneel Enterprises Vs. Ito, Ward – 19(3)(4) 209, 2Nd Floor, Konark 2Nd Floor, Matru Sharam, 156, Tardeo Mandir, Tardeo Road Mumbai – 400034 Mumbai. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagfn2816B Appellant .. Respondent Assessee By : Mr.Raj Kumar Singh.Ar Revenue By : Ms.Richa Gulati.Dr Date Of Hearing 22.12.2022 Date Of Pronouncement 22.12.2022 आदेश / O R D E R

For Appellant: Mr.Raj Kumar Singh.ARFor Respondent: Ms.Richa Gulati.DR

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

Since the interest amount which was shown as be paid was not reflected in the profit and loss account, therefore the AO has reason to believe that the income has escaped the assessment and therefore the interest of Rs.6,23,304/- has to be treated as ineligible expenses and issued

Amit Prabhunath Jaiswal, Nerul West vs. ITO Ward 28(1)(1), Navi Mumbai

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

ITA 2284/MUM/2025[2013-2014]Status: HeardITAT Mumbai04 Aug 2025AY 2013-2014

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailamit Prabhunath Jaiswal, Jaiswal Niwas, Plot No.253 Sector-6, Darshan Darbar Marg, Nerul (W), Navi Mumbai - 400706 ............... Appellant Pan : Aibpj1635K V/S Income Tax Officer, Ward – 28(1)(1) ……………… Respondent Aaykar Bhavan Income Tax Office, Tower No.6, Vashi Railway Station, Commercial Complex, Vashi, Navi Mumbai-400703 Assessee By : Shri Harshit Kabra, Ca (Virtually Present) Revenue By : Shri Aditya Rai, Sr.Dr

For Appellant: Shri Harshit Kabra, CA (virtually present)For Respondent: Shri Aditya Rai, Sr.DR

Section 147Section 148Section 151Section 153CSection 234ASection 250Section 69A

recorded under Explanation 2(ca) of sec 147 of the Act. iii) The approval of higher authorities under sec 151 on wrong forming reason to believe and details of escapement of income in respect of Cash deposit & invoking Sec 69A Explanation 2(a) of sec 147 instead Explanation

Calyx Chemicals and Pharmaceuticals Limited, Mumbai vs. Income Tax Officer CC 4, Thane

In the result, the appeal of the assessee is allowed

ITA 2500/MUM/2024[2013-14]Status: DisposedITAT Mumbai04 Aug 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarcalyx Chemicals & V/S. Income Tax Officer, Pharmaceuticals Limited, बनाम Centre Circle – 4, Thane, 1408, 14Th Floor, Real Tech Maharashtra Park, Sector – 30A, Vashi, Navi Mumbai - 400 703, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcc1457B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Narayan Atal, ARFor Respondent: Mr. Virabhadra S. Mahajan (Sr. DR)

Section 133ASection 147Section 148Section 37

date of approval of Resolution Plan under Insolvency and Bankruptcy Code, on the ground that Respondent No. 1 - Assessing Officer had a reason to believe that the income chargeable to tax of the Corporate Debtor has escaped assessment within the meaning of Section 147 of the Income

Deputy Commissioner of Income Tax-1(1), Raipur vs. Usha Devi Singhania, Raipur

In the result, appeal of the revenue in ITA No

ITA 270/RPR/2025[2015-16]Status: DisposedITAT Raipur31 Jul 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.269 & 270/Rpr/2025 "नधा"रण वष" / Assessment Years : 2013-14 & 2015-16 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

For Appellant: Shri Praveen Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 139Section 142Section 143Section 147Section 148

proviso” to Section 147 of the Act which reads as follows: “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 148 to 153, assess or reassess ... Section 147 of the Act which deals with the contended issue before us: “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 148 to 153, assess

Deputy Commissioner of Income Tax-1(1), Raipur vs. Usha Devi Singhania, Raipur

In the result, appeal of the revenue in ITA No

ITA 269/RPR/2025[2013-14]Status: DisposedITAT Raipur31 Jul 2025AY 2013-14

For Appellant: Shri Praveen Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 139Section 142Section 143Section 147Section 148

Shri Shamjibhai Sadhabhai Kangad, Gandhidham-Kutch vs. The DCIT Central Circle-1, Rajkot

In the result, appeal filed by the Revenue, in IT(SS) No

ITA 320/RJT/2022[2021-22]Status: DisposedITAT Rajkot31 Jul 2025AY 2021-22

Bench: Dr. Arjun Lal Saini

Section 153A

arent ardteirer arftrezr, werare Farris, wWernlel IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI

Devendra Pratap Singh, Kumarganj Faizabad vs. ITO-1, Faizabad-New, Faizabad

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

ITA 176/LKW/2025[2017-2018]Status: DisposedITAT Lucknow31 Jul 2025AY 2017-2018

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Purnodaya Kumar Singh, AdvFor Respondent: Sh. Amit Kumar, DR

Section 142(1)Section 147Section 148Section 250Section 69A

along with the Income Tax Return. 4. The reasons recorded for reopening the assessment lack specific details and do not establish a valid "reason to believe" as mandated under Section 147 r.w.s. 148 of the Income Tax Act, 1961. 5. The additional documentary evidence submitted by the appellant was forwarded ... assessee challenged the satisfaction drawn by the ld. AO before the issuance of notice under section 148. He pointed out that the reasons to believe that were recorded, were only to verify the source of cash deposits of Rs. Rs.1,07,60,000/- made in the bank account, which

Omkar Ramchandra Velhal, Kolhapur vs. Income Tax Officer, Ward 1(1), Kolhapur

In the result, appeal of the assessee is Partly Allowed

ITA 672/PUN/2025[2015-16]Status: DisposedITAT Pune31 Jul 2025AY 2015-16

Bench: Shri Vinay Bhamore & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.672/Pun/2025 निर्धारण वर्ष / Assessment Year: 2015-16 Omkar Ramchandra Velhal, V The Income Tax Officer, Plot No.183/3, Omkar Near S Ward-1(1), Kolhapur. Ganga Hospital, A Ward Dudhali, Kolhapur – 416012. Maharashtra. Pan: Asipv6553D Appellant/ Assessee Respondent / Revenue Assessee By Revenue By Date Of Hearing None Shri Aknath Abhang – Addl.Cit(Dr) 23/07/2025 Date Of Pronouncement 31/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Dated 21.01.2025, Emanating From Order U/S.147 Read With Section 144B Of The Income Tax Act, 1961, Dated 31.01.2023. The Assessee Has Raised Following Grounds Of Appeal :

Section 144BSection 147Section 148Section 148ASection 149Section 149(1)(b)Section 250Section 68

assessment for A.Y.2015-16. The relevant paragraph 6 and 7 of the order us/.148A(d) are reproduced here as under : “6. I have therefore reason to believe that income to the extent of Rs.1,30,00,000/- has escaped assessment for A.Y.2015-16, within the meaning of sec. 147 read with provision ... Based on the above referred chart which was available on Insight Portal, the ITO-Ward-1(1), Kolhapur concluded that he has reason to believe that income to the extent of Rs.1,30,00,000/- has escaped assessment. 11.1 The said order u/s.148A(d) has been approved by Pr.Chief Commissioner

Dhondiram Pundalik Dhule, Raigad vs. Income Tax Officer, Panvel Maharashtra

In the result, appeal of the Assessee is allowed

ITA 895/PUN/2024[2013-2014]Status: DisposedITAT Pune31 Jul 2025AY 2013-2014

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.895/Pun/2024 िनधा"रण वष" / Assessment Year: 2013-14 Dhondiram Pundalik Dhule, V The Income Tax Officer, 114B, Gayali Aali, Ram Kadu S Panvel, Maharashtra. Road, Mahad – 402301. Maharashtra. Pan: Bcqpd6127A Appellant/ Assessee Respondent / Revenue Assessee By Shri Bharat Raichandani – Ar(Virtual) Revenue By Shri Eknath Abhang –Addl.Cit(Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 31/07/2025

Section 139Section 147oSection 148Section 250Section 69A

transaction in the form of undisclsoed receipts, which had not been disclosed for taxation. 5. In view of the above, I have reason to believe that income of the assessee for A.Y 2013-14 has escaped assessment within the meaning of provisions of Section 147 of the Income ... amount of income remained to be brought to tax is exceeding Rs.1,00,000/- for A.Y. 2013-14, I have reason to believe that the income of assessee for the year under consideration has escaped assessment within the meaning of provisions of Section 147 of the Income

ACIT, Circle-2(1), Hyderabad vs. Emaar Hills Township Private Limited, Hyderabad

In the result, appeal of the Revenue is dismissed

ITA 425/HYD/2023[2008-09]Status: DisposedITAT Hyderabad31 Jul 2025AY 2008-09

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, K C DevdasFor Respondent: Sri Gurpreet Singh, Sr. AR

Section 143(2)Section 147Section 148

speaking order and not dealing with the factual aspects lead to the conclusion that reopening of the assessment is without there being any reason to believe that the income has escaped assessment. 14 ITA.No.425/Hyd./2023 Learned Counsel for the Assessee referred to the decision of Hon’ble Supreme Court