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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

Vithal Leasefin(P) Ltd, Mumbai vs. DCIT, Circle Ward 1(3)(2), Mumbai

ITA 7745/MUM/2025[2012-13]Status: DisposedITAT Mumbai19 Feb 2026AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Bijayananda Pruseth

Section 142Section 143(1)Section 147Section 148Section 250Section 68

ACIT vs Rajesh Jhaveri Stock Brokers Pvt. Ltd 291 ITR 500wherein it was held that, ......if the AO for whatever reason has reason to believe that, income has escaped assessment it confers jurisdiction to reopen the assessment assessment..... Reliance can also be placed on the decision in the cases ... assumes jurisdiction to issue notice u/s 148". Hence, on the basis of such information, the Assessing Officer was justified in having a reason to believe that the income of assessee would have escaped assessment. The Hon'ble High Court of Bombay in the case of Export Credit Guarantee Corporation

Ramesh Purshottam Modi, Mumbai vs. Income Tax Officer Circle 22(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6577/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Purshottam Ito Circle 22(1) Modi Income Tax 303, Modi House, Linking Vs. Department, Road, Khar West, Piramal Chamber, Mumbai-400 052 Dr. Ss Rao Marg, Parel, Mumbai 0 400 012 Pan/Gir No. Aahpm2793F (Applicant) (Respondent) Assessee By Shri Ashwani Kumar A/W Ms. Deepali Aggarwal, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 12.02.2026 Date Of Pronouncement 19.02.2026

Section 143(3)Section 144BSection 147Section 148Section 250Section 94(7)Section 94(8)

Ranbaxy Laboratories Ltd. v. Commissioner of Income-tax (336 ITR 136)where it was held that the Assessing Officer, upon forming a reason to believe and issuing notice under section 148, must assess or reassess “such income” which formed the basis of reopening, and only thereafter the course of proceedings

Income-Tax Officer, Ward-1(3)(1), Ahmedabad vs. Parthiv Jawaharbhai Shah, Ahmedabad

The appeal of the asessee is partly allowed for statistical purposes while Revenue’s appeal is dismissed

ITA 1038/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2013-14
For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri Rignesh Das, CIT. DR
Section 147Section 148Section 250Section 68

erred in not holding that the reassessment notice issued by AO is bad in law as the assessing officer has no reasons to believe that income chargeable to tax has escaped assessment. 5. In the facts and in the circumstances of the case, the Ld. CIT(A) has erred ... also been stated in the information uploaded that the concern viz. Orange Tradex Pvt Lid is merely paper concerns. 3. Basis of forming reasons to believe and details of escapement of income: On perusal of the details furnished and the information uploaded by the DDIT (Inv.), Unit-1(3), Ahmedabad

Parthiv Jawaharbhai Shah, Ahmedabad vs. The ITO, Ward-1(3)(1), Ahmedabad

The appeal of the asessee is partly allowed for statistical purposes while Revenue’s appeal is dismissed

ITA 1030/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2013-14

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri Rignesh Das, CIT. DR
Section 147Section 148Section 250Section 68

erred in not holding that the reassessment notice issued by AO is bad in law as the assessing officer has no reasons to believe that income chargeable to tax has escaped assessment. 5. In the facts and in the circumstances of the case, the Ld. CIT(A) has erred ... also been stated in the information uploaded that the concern viz. Orange Tradex Pvt Lid is merely paper concerns. 3. Basis of forming reasons to believe and details of escapement of income: On perusal of the details furnished and the information uploaded by the DDIT (Inv.), Unit-1(3), Ahmedabad

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1884/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

Income Tax (Supra), wherein the Hon'ble Delhi High Court held that “whether it is information to suggest” under amended law or ‘reason to believe’ under erstwhile law, the benchmark of ‘escapement of income chargeable to tax’ still remains the primary condition to be satisfied before invoking powers under section

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1876/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

Income Tax (Supra), wherein the Hon'ble Delhi High Court held that “whether it is information to suggest” under amended law or ‘reason to believe’ under erstwhile law, the benchmark of ‘escapement of income chargeable to tax’ still remains the primary condition to be satisfied before invoking powers under section

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1571/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(3)Section 148

ITA Nos 1566 and 1571 Exel Rubber Private Ltd आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1566/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ. अपी.सं / Ita Nos.1566 & 1571/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2020-21 & 2021-22) M/S. Exel Rubber Private Ltd Vs. Hyderabad Dy.Cit Central Circle 1 (2) Hyderabad Pan:Aaace4495J (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V. Prasad, Ca राजस्व द्वारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 20/01/2026 घोषणा की तारीख / Pronouncement: 18/02/2026 Per Manjunatha, G. A.M. आदेश/Order These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 14/07/2025 For The A.Ys 2020-21, 2021-22 & 2022-23 Respectively. Since Common Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(3)Section 148

ITA Nos 1566 and 1571 Exel Rubber Private Ltd आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2542/KOL/2025[2015-16]Status: DisposedITAT Kolkata18 Feb 2026AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2541 & 2542/Kol/2025 Assessment Years: 2013-14 & 2015-16 Dcit, Cc-1(2), Kolkata…………..…....…………….……….……….……Appellant Vs. M/S Amluckie Investment Company Ltd.……………….....……...…..…..Respondent 2Nd Floor, 10 Princep Street, Kolkata-700072. [Pan: Aacca6749H] Appearances By: Shri Manoj Kr. Pati, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 12, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Filed By The Revenue Are Directed Against Separate Orders Both Dated 21.07.2025 Of The Cit(A)-20, Kolkata Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Years 2013–14 2015-16 Respectively. Since Both The Appeals Relate To The Same Assessee & Arisen From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Both The Appeal Filed By The Revenue With A Delay Of 35 Days & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

Section 131Section 143(2)Section 147Section 148Section 250

notice under s. 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 ... mandates service of notice to the assessee before the AO proceeds to assess, reassess or recompute escaped income. Sec. 147 mandates recording of reasons to believe by the AO that the income chargeable to tax has escaped assessment. All these conditions are required to be fulfilled to assess or reassess

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2541/KOL/2025[2013-14]Status: DisposedITAT Kolkata18 Feb 2026AY 2013-14

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2541 & 2542/Kol/2025 Assessment Years: 2013-14 & 2015-16 Dcit, Cc-1(2), Kolkata…………..…....…………….……….……….……Appellant Vs. M/S Amluckie Investment Company Ltd.……………….....……...…..…..Respondent 2Nd Floor, 10 Princep Street, Kolkata-700072. [Pan: Aacca6749H] Appearances By: Shri Manoj Kr. Pati, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 12, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Filed By The Revenue Are Directed Against Separate Orders Both Dated 21.07.2025 Of The Cit(A)-20, Kolkata Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Years 2013–14 2015-16 Respectively. Since Both The Appeals Relate To The Same Assessee & Arisen From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Both The Appeal Filed By The Revenue With A Delay Of 35 Days & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

Section 131Section 143(2)Section 147Section 148Section 250

notice under s. 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 ... mandates service of notice to the assessee before the AO proceeds to assess, reassess or recompute escaped income. Sec. 147 mandates recording of reasons to believe by the AO that the income chargeable to tax has escaped assessment. All these conditions are required to be fulfilled to assess or reassess

Pragnaben Jayeshbhai Patel, Surat Gujarat vs. Income Tax Officer, Surat

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

ITA 885/SRT/2024[2011-12]Status: DisposedITAT Surat17 Feb 2026AY 2011-12

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita No.885/Srt/2024 िनधा"रण वष" /Assessment Year : 2011-12 बनाम/ Pragnaben Jayeshbhai Patel The Ito V/S. 71, Satyanarayan Society Ward-2(3)(3) Dindoli Surat Surat – 394 210 "थायी लेखा सं./Pan: Bcvpp 2891 Q (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Shri Krutarth Desai, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख /Date Of Pronouncement: 17/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 20/06/2023 For The Assessment Year (Ay) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. In The Facts & Circumstances Of The Case, The Learned Assessing Officer Has Erred In Make An Addition Of Rs. 15,00,000/- Without Having Any Foundational Facts Which Leads To Reason To Believe That Income Has Escaped Assessment. It Is The Settled Position Of Law That Only Cash Deposit Is Not The Ground Of Initiating Assessment As The Same Is Nothing But The Inquiry By The Learned Assessing Officer & Therefore, Notice Issued Under Section 148 Deserves To Be Quashed & Set Aside. Pragnaben Jayeshbhai Patel Vs. Ito Asst. Year : 2011-12

For Appellant: Shri Krutarth Desai, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 143(3)Section 144Section 147Section 148Section 69A

learned assessing officer has erred in make an addition of Rs. 15,00,000/- without having any foundational facts which leads to reason to believe that income has escaped assessment. It is the settled position of law that only cash deposit is not the ground of initiating assessment

Goal Oriented Trade Link Pvt. Ltd., Kolkata vs. ITO, Ward 2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2576/KOL/2025[2013-2014]Status: DisposedITAT Kolkata17 Feb 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(2)Section 147Section 148Section 14ASection 158Section 250

observed: "the provisions contained in sub-Section (2) of Section 143 is mandatory and the legislature in their 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

Labh Combines Pvt. Ltd., Kolkata vs. DCIT, Circle 7(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2382/KOL/2025[2017-2018]Status: DisposedITAT Kolkata17 Feb 2026AY 2017-2018

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 132Section 132(4)Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)Section 250Section 68

perusing the material available on record, we find that the AO has reopened the assessment u/s 147 of the Act after recording the reasons to believe u/s 148(2) of the Labh Combines Pvt. Ltd. Act. The copy of the reason recorded is available at page ... assessment year under consideration is deemed to be a case where income of chargeable to tax has escaped assessment. Hence, I have reason to believe that 55.00.160- chargeable to tax has escaped assessment for the AY 2017-18.” 6. A perusal of above reasons, reveals that the AO in para

Poonam Gupta, Bengaluru vs. DCIT, Circle-5(1)(1), Bangalore

In the result appeal filed by the assessee is allowed

ITA 793/BANG/2025[2017-18]Status: DisposedITAT Bangalore17 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2017-18

For Appellant: Shri Manish Tiwari, CAFor Respondent: Shri Subramanian, Jt.CIT (DR)(ITAT), Bengaluru
Section 10Section 147Section 68

accommodation entry. He submits that when the assessee has offered the above sum as a short-term capital gain, there is no reason to believe for the assessing officer that assessee has obtained any benefit. He further referred to the reasons recorded to show that the above scrip was alleged ... short-term capital gain and paid tax thereon. Therefore the reasons recorded by the ld.AO does not withstand the test of reason to believe. He specifically referred to paragraph No. 7 of the notice of reopening wherein it is stated that the assessee has traded in a penny scrip

Spice of Life Hotels and Estates Private Limited, Mumbai vs. DCIT-2(3)(1), Mumbai

ITA 7704/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

Subsequently, the case of assessee was reopened by issuing a notice under section 148 of the Act on 30.03.2021. Towards the reason to believe recorded by the ld. AO, the assessee filed a preliminary objection which was disposed of by the ld. AO on 08.03.2022. Thereafter the issue regarding disallowance ... illegal. Hence, the objections raised by the assessee is not tenable in law. In view of the above, the AO has sufficient reasons to believe that certain income has escaped assessment. On overall appreciation of all the facts and circumstances of the case in its entirety as well

Spice of Life Hotels and Estates Private Limited, Mumbai vs. DCIT- 2(3)(1), Mumbai

ITA 7703/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

Subsequently, the case of assessee was reopened by issuing a notice under section 148 of the Act on 30.03.2021. Towards the reason to believe recorded by the ld. AO, the assessee filed a preliminary objection which was disposed of by the ld. AO on 08.03.2022. Thereafter the issue regarding disallowance ... illegal. Hence, the objections raised by the assessee is not tenable in law. In view of the above, the AO has sufficient reasons to believe that certain income has escaped assessment. On overall appreciation of all the facts and circumstances of the case in its entirety as well

Quetzal Buildtech Private Limited, Haryana vs. Income Tax Officer, Haryana

ITA 6409/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Feb 2026AY 2016-17

Bench: Shri C.N. Prasad

Section 115BSection 139(1)Section 143(2)Section 147Section 234BSection 68Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘SMC”: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER ITA No.6409/Del/2025 Assessment

Ashok Kumar, Merrut vs. ITO, Meeut

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

ITA 5090/DEL/2025[2011-12]Status: DisposedITAT Delhi17 Feb 2026AY 2011-12

Bench: Shri C.N. Prasadassessment Year 2011-12 Asok Kumar S/O Sher Singh Vs. Ito 24, Nagli, Azamabad Ward -1 (1) Meerut -250001 Meerut Pan No.Blapk3060J Appellant Respondent Appellant Sh. Manish Kumar, Advocate Respondent Sh. Manoj Kumar, Sr. Dr

Section 142Section 148

even without PAN) was issued without obtaining the approval of the prescribed authority as required under law and as a result thereof, the reason to believe is totally based on AIR information only without making any Inquiry or application of mind and consequently the reason recorded is in fact ... reason to suspect and not reason to believe. Grounds Concerning Opportunity: 11. The authority below in the facts and circumstances of the case and on the basis of material on record erred in not appreciating that the assessee was denied opportunity both at the assessment level as well as before

Sagar Dwellings P Ltd, Near Sun Temple Gwalior vs. ACIT, Faceless

In the result, assessee’s appeal is dismissed

ITA 373/AGR/2025[2014-15]Status: DisposedITAT Agra16 Feb 2026AY 2014-15

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

Baba Gurudev Traders during FY 2013-14 are apparently bogus and required to be disallowed. In view of all these facts, I have reason to believe that amount of Rs.1,03,89,106/- has escaped assessment in this case for AY 2014-15. Therefore, action u/s 147 is being taken

Shri Premroop V. Sahu, Nagpur vs. A.C.I.T. Central Cir., - 1(2), Nagpur

In the result, ground no. 2 to 5 are allowed for statistical purpose

ITA 131/NAG/2017[2011-12]Status: DisposedITAT Nagpur16 Feb 2026AY 2011-12

Bench: Shri Pawan Singh & Shri Khettra Mohan Roy(Physical Hearing) Shri Premroop V. Sahu Acit, Central Circle – 1(2), Nagpur C/O. M.S. Gupta, Advocate, 333, Vs Aayakar Bhawan, 2Nd Floor, Darodkar Square, Central Avenue, Telengkhedi Road, Nagpur – 440001. Gandhibag, Nagpur – 440032. [Pan: Aoeps4542R] Appellant / Assessee Respondent / Revenue Assessee By Shri K.M. Gupta, Ca Revenue By Shri Pankaj Kumar, Cit–Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 16.02.2026 Order Under Section 254(1) Of Income Tax Act

Section 132Section 254(1)

assessee has raised following grounds of appeal: “1. That, the search conducted in the premises of the assessee is without having any reason to believe which is mandatory condition for proceeding u/s. 132 and hence, the entire proceeding is void-ab-initio. And, hence the order passed needs