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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

Shailesh Goyal, Tonk vs. ACIT, Centre Circle Jaipur, Jaipur

In the result, appeal of the assessee is allowed in above terms

ITA 496/JPR/2024[2016-17]Status: DisposedITAT Jaipur29 Jul 2025AY 2016-17

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Respondent byFor Respondent: Date of hearing
Section 132(1)Section 133ASection 143(3)Section 250Section 271(1)(c)Section 69C

Principal Commissioner or Commissioneror Additional Director or Additional Commissioneror Joint Director or Joint Commissioner in consequence of information in his possession, has reason to believe that- (α) any person to whom a summons under sub-section (1) of section 37 of the Indian Income ... section 120, it shall be competent for him to exercise the powers under this sub-section in all cases where he has reason to believe that any delay in getting the authorisation from the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner having jurisdiction over such person

Shivratan Motilal Rathi HUF, Pune vs. ITO, Jalna

In the result, the appeal filed by the assessee in ITA

ITA 606/PUN/2025[2011-12]Status: DisposedITAT Pune29 Jul 2025AY 2011-12

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.605 & 606/Pun/2025 िनधा"रण वष" / Assessment Years : 2008-09 & 2011-12 Shivratan Motilalji Rathi Vs. Ito, Ward-1, Jalna. Huf, Rathi Rathi & Co., 501-504, Akshay Landmarks, Opp. Pu La Garden, Sinhagad Road, Jalna- 411030. Pan : Aaehr5318G Appellant Respondent Assessee By : Miss Smruti Sabnis Revenue By Shri Akhilesh Srivastva : Date Of Hearing 24.07.2025 : Date Of Pronouncement : 29.07.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 21.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2011-12 Respectively. 2. There Is Delay Of 64 Days In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeals Within The Prescribed Time Limit. Ld. Dr Has Not Raised Any Serious Objection To Condone The Delay, Therefore We Condone The Delay Of 64 Days & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.605/Pun/2025 For Assessment Year 2008-09 As The Lead Case For Adjudication.

For Appellant: Miss Smruti Sabnis
Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 271(1)(c)Section 69

Rs.82,38,876 / 2 = Rs.41,19,438) by assessee for assessment year 2008-09. Therefore, as per the AO, there was reason to believe that within the meaning of section 147 assessee’s income chargeable to tax at Rs.41,19,438/- being his 50% share into the above property

Shivratan Motilalji Rathi HUF, Pune vs. ITO, Jalna

In the result, the appeal filed by the assessee in ITA

ITA 605/PUN/2025[2008-2009]Status: DisposedITAT Pune29 Jul 2025AY 2008-2009

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.605 & 606/Pun/2025 िनधा"रण वष" / Assessment Years : 2008-09 & 2011-12 Shivratan Motilalji Rathi Vs. Ito, Ward-1, Jalna. Huf, Rathi Rathi & Co., 501-504, Akshay Landmarks, Opp. Pu La Garden, Sinhagad Road, Jalna- 411030. Pan : Aaehr5318G Appellant Respondent Assessee By : Miss Smruti Sabnis Revenue By Shri Akhilesh Srivastva : Date Of Hearing 24.07.2025 : Date Of Pronouncement : 29.07.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 21.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2011-12 Respectively. 2. There Is Delay Of 64 Days In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeals Within The Prescribed Time Limit. Ld. Dr Has Not Raised Any Serious Objection To Condone The Delay, Therefore We Condone The Delay Of 64 Days & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.605/Pun/2025 For Assessment Year 2008-09 As The Lead Case For Adjudication.

For Appellant: Miss Smruti Sabnis
Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 271(1)(c)Section 69

Rs.82,38,876 / 2 = Rs.41,19,438) by assessee for assessment year 2008-09. Therefore, as per the AO, there was reason to believe that within the meaning of section 147 assessee’s income chargeable to tax at Rs.41,19,438/- being his 50% share into the above property

Shivratan Motilalji Rathi HUF, Pune vs. ITO, Jalna

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

ITA 604/PUN/2025[2007-08]Status: DisposedITAT Pune29 Jul 2025AY 2007-08

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.604/Pun/2025 िनधा"रण वष" / Assessment Year : 2007-08 Shivratan Motilalji Rathi Vs. Ito, Ward-1, Jalna. Huf, Rathi Rathi & Co., 501-504, Akshay Landmarks, Opp. Pu La Garden, Sinhagad Road, Jalna- 411030. Pan : Aaehr5318G Appellant Respondent Assessee By : Miss Smruti Sabnis Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 24.07.2025 Date Of Pronouncement 29.07.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2007-08. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “Ground 1. The Appellant Requests Your Honor To Condone The Delay Of 64 Days In Filing The Appeal As The Delay Was Due To Unforeseen Circumstances Beyond The Control Of The Appellant.

For Appellant: Miss Smruti SabnisFor Respondent: Shri Akhilesh Srivastva
Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 249(4)(b)Section 271(1)(c)Section 69

Rs.11,67,738 / 2 = Rs.5,83,869) by assessee for assessment year 2007-08. Therefore, as per the AO, there was reason to believe that within the meaning of section 147 assessee’s income chargeable to tax at Rs.5,83,869/- being his 50% share into the above property

M/S. Ashok Leyland Ltd., Chennai vs. DCIT, Ncc-8(1), Ltu-II, Chennai

In the result, appeal filed by the assessee is allowed

ITA 601/CHNY/2025[2010-11]Status: DisposedITAT Chennai29 Jul 2025AY 2010-11

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 143(2)Section 143(3)Section 147Section 148Section 32(1)(iia)

sine qua non for assumption/usurpation of jurisdiction. In the case of reopening of assessment, section 147 provides that where the Assessing Officer has reason to believe escapement of income [is the jurisdictional fact & law] he shall record his reasons for doing so and assess or reassess the income which ... respect to the reopening u/s. 147 of the Act, the Parliament by Direct Tax Laws (Amendment) Act 1987 w.e.f. 01.04.1989 had substituted “for reason to believe escapement of income” to “for reasons to be recorded by him in writing, is of the opinion’’ which gave unbridled subjective satisfaction

Jawaharlal Gulabrai Tulsiani, Delhi vs. ACIT, Int. Tax Circle 4(2)(1), Mumbai

In the result, all appeals filed by the respective assesses are allowed

ITA 538/MUM/2025[2007-08]Status: DisposedITAT Mumbai29 Jul 2025AY 2007-08

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal &For Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3.The action of the A.O. in rejecting the genuineness of bank statements provided by HSBC ... base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3. The action of the A.O. in rejecting the genuineness of bank statements provided

Jawaharlal Gulabrai Tulsiani, Delhi vs. ACIT, Int. Tax Circle 4(2)(1), Mumbai

ITA 537/MUM/2025[2006-07]Status: DisposedITAT Mumbai29 Jul 2025AY 2006-07

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

Section 147Section 149(1)(c)Section 234ASection 254

base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3. The action of the A.O. in rejecting the genuineness of bank statements provided ... base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3. The action of the A.O. in rejecting the genuineness of bank statements provided

Sham Gulabrai Tulsyani, Delhi vs. ACIT, Int. Tax Circle 4(2)(1), Mumbai

ITA 483/MUM/2025[2007-08]Status: DisposedITAT Mumbai29 Jul 2025AY 2007-08

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal & Akash KhandelwalFor Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3.The action of the A.O. in rejecting the genuineness of bank statements provided by HSBC ... base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3. The action of the A.O. in rejecting the genuineness of bank statements provided

Sham Gulabrai Tulsyani, Delhi vs. ACIT, Int. Tax Circle 4(2)(1), Mumbai

ITA 482/MUM/2025[2006-07]Status: DisposedITAT Mumbai29 Jul 2025AY 2006-07

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal &For Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3.The action of the A.O. in rejecting the genuineness of bank statements provided by HSBC ... base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3. The action of the A.O. in rejecting the genuineness of bank statements provided

Naraindas Gulabrai Tulsiani, Delhi vs. ACIT, Int. Tax Circle 4(2)(1), Mumbai

In the result, all appeals filed by the respective assesses are allowed

ITA 464/MUM/2025[2006-07]Status: DisposedITAT Mumbai29 Jul 2025AY 2006-07

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal &For Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3.The action of the A.O. in rejecting the genuineness of bank statements provided by HSBC ... base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3. The action of the A.O. in rejecting the genuineness of bank statements provided

Naraindas Gulabrai Tulsiani, Delhi vs. ACIT, Int. Tax Circle 4(2)(1), Mumbai

In the result, all appeals filed by the respective assesses are allowed

ITA 463/MUM/2025[2007-08]Status: DisposedITAT Mumbai29 Jul 2025AY 2007-08

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal &For Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3.The action of the A.O. in rejecting the genuineness of bank statements provided by HSBC ... base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3. The action of the A.O. in rejecting the genuineness of bank statements provided

Partab Gulabrai Tulsiani, Delhi vs. ACIT, Int. Tax Circle 4(2)(1), Mumbai

In the result, all appeals filed by the respective assesses are allowed

ITA 449/MUM/2025[2007-08]Status: DisposedITAT Mumbai29 Jul 2025AY 2007-08

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal &For Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3.The action of the A.O. in rejecting the genuineness of bank statements provided by HSBC ... base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3. The action of the A.O. in rejecting the genuineness of bank statements provided

Partab Gulabrai Tulsiani, Delhi vs. ACIT, Int. Tax Circle 4(2)(1), Mumbai

ITA 448/MUM/2025[2006-07]Status: DisposedITAT Mumbai29 Jul 2025AY 2006-07

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal & Akash KhandelwalFor Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3.The action of the A.O. in rejecting the genuineness of bank statements provided by HSBC ... base note having mentioned that the appellant was a British National and the HSBC account was opened on 16.02.1994, there could be no reason to believe that the income of the appellant had escaped assessment. 3. The action of the A.O. in rejecting the genuineness of bank statements provided

Indu Mahendra Shah (L/H of Late Shri Mahendra G. Shah), Mumbai vs. ITO, Ward-20(2)(2), Mumbai

In the result, the appeal filed by the assessee is allowed and the reassessment order passed under section 143(3) read with section 147 is quashed

ITA 855/MUM/2024[2012-13]Status: DisposedITAT Mumbai29 Jul 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 69A

already available on record and were easily verifiable. 8. In light of the above, we find that the very foundation upon which the ―reason to believe‖ was constructed, namely, the escapement of income, is severely flawed, being based on incorrect and unverified assumptions. The Assessing Officer, in his haste, failed ... Court in the case of Ankita A. Choksey v. ITO (Writ Petition No. 3344 of 2018), wherein Their Lordships held as under: “…the reasons to believe that income chargeable to tax has escaped assessment must be based on correct facts. If the facts as recorded are incorrect and the assessee

DCIT, New Delhi vs. M/S. Saamag Construction Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed as above

ITA 3738/DEL/2017[2006-07]Status: DisposedITAT Delhi29 Jul 2025AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishra

Section 132(1)Section 148Section 153ASection 69C

expiry of six years; therefore, the said notice was barred by limitation. 5.5 The Ld. Counsel further contended that the perusal of the reason to believe clearly showed that the case was reopened by the AO on 19.03.2024 based on the observations made

Bhagwandas Jagdish Prasad, Bagbahara vs. Income Tax Officer, Mahasamund

In the result, appeal of the assessee is allowed

ITA 413/RPR/2025[2014-15]Status: HeardITAT Raipur28 Jul 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.412 & 413/Rpr/2025 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15 Bhagwandas Jagdish Prasad Petrol Pump, Main Road, Bagbahara-493 449 (C.G.) Pan: Aamfb0173H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Mahasamund (C.G.) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 147Section 148

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

Bhagwandas Jagdish Prasad, Bagbahara vs. Income Tax Officer, Mahasamund

In the result, appeal of the assessee is allowed

ITA 412/RPR/2025[2013-14]Status: HeardITAT Raipur28 Jul 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.412 & 413/Rpr/2025 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15 Bhagwandas Jagdish Prasad Petrol Pump, Main Road, Bagbahara-493 449 (C.G.) Pan: Aamfb0173H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Mahasamund (C.G.) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 147Section 148

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

Anil Kumar Parekh, Dhamtari vs. Income Tax Officer, Ward Dhamtari, Dhamtari

In the result, appeal of the assessee is allowed

ITA 194/RPR/2025[2013-14]Status: DisposedITAT Raipur28 Jul 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.194/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Anil Kumar Parekh C/O. Madhu Traders, Station Road, Dhamtari (C.G.)-493 773 Pan: Akepp0240E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-Dhamtari (C.G.) ……""यथ" / Respondent

For Appellant: None (Adjournment Application)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(2)Section 147Section 148Section 68Section 69C

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

Bhagwan Prasadsinghania HUF, Neemuch vs. AO NFAC, Delhi

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

ITA 850/IND/2024[2013-14]Status: DisposedITAT Indore28 Jul 2025AY 2013-14

Bench: B.M. Biyani & Shri Paresh M Joshibhagwan Prasad Nfac, बनाम/ Singhania Huf, Delhi Vs. 8 Shastri Nagar, Neemuch

Section 115BSection 147Section 246ASection 250Section 253

confirming the action of the AO in assuming the jurisdiction for framing the assessment under s.147 of the Act without having any objective reason to believe as regard to escapement of any income in the hands of the appellant. 4. That, without prejudice to the above, the learned

Shri Amit Mangilal Jain, Mumbai vs. ACIT, - 33(1), Mumbai

In the result, both the above appeals are allowed

ITA 3332/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Jul 2025AY 2010-11

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Naresh Jain & Shri Mahaveer Jain, ARsFor Respondent: Shri Ram Krishn Kedia, (Sr. DR)
Section 131Section 143(3)Section 147Section 148Section 153C

true disclosure of these material facts in the relevant assessment year, as far as the above issue is concerned. Therefore, I have a reason to believe that the income of Rs. 6,80,00,000/- has escaped assessment within the meaning of Section 147 of the Income