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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

Vrindavan Builders Pvt Ltd, Nagaland vs. ACIT Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 697/COCH/2024[2014-15]Status: DisposedITAT Cochin09 Jun 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

Ground Nos. 1 to 1d challenges the very validity of reopening of assessment on the ground that there were no reasons to believe that income escaped assessment to tax. It is submitted that assessment proceedings were sought to be reopened primarily on the ground that there were certain fund transfers ... Singh v. AACIT, 972 SCR (1) 175 (SC). 13.2 Reassessment proceedings were initiated merely on the basis of 'reason to suspect' and not 'reason to believe' for the purpose of 11 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. making fishing and roving enquiries in connection with

Vrindavan Builders Pvt Ktd, Nagaland vs. ACIT Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 696/COCH/2024[2013-14]Status: DisposedITAT Cochin09 Jun 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

Ground Nos. 1 to 1d challenges the very validity of reopening of assessment on the ground that there were no reasons to believe that income escaped assessment to tax. It is submitted that assessment proceedings were sought to be reopened primarily on the ground that there were certain fund transfers ... Singh v. AACIT, 972 SCR (1) 175 (SC). 13.2 Reassessment proceedings were initiated merely on the basis of 'reason to suspect' and not 'reason to believe' for the purpose of 11 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. making fishing and roving enquiries in connection with

Vrindavan Builders Pvt Ltd, Nagaland vs. ACIT, Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 695/COCH/2024[2012-13]Status: DisposedITAT Cochin09 Jun 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

Ground Nos. 1 to 1d challenges the very validity of reopening of assessment on the ground that there were no reasons to believe that income escaped assessment to tax. It is submitted that assessment proceedings were sought to be reopened primarily on the ground that there were certain fund transfers ... Singh v. AACIT, 972 SCR (1) 175 (SC). 13.2 Reassessment proceedings were initiated merely on the basis of 'reason to suspect' and not 'reason to believe' for the purpose of 11 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. making fishing and roving enquiries in connection with

Deputy Commissioner of Income Tax, Central Circle, Kollam vs. Allebasi Builders and Developers (P) Ltd, Attingal

In the result, appeal filed by the assessee stands allowed and Revenue’s appeal and assessee’s cross objection stand dismissed

ITA 317/COCH/2024[2015-16]Status: DisposedITAT Cochin09 Jun 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

time of hearing.” 11. Ground Nos. 1 & 2 challenges the very validity of reopening of assessment on the ground that there were no reason to believe that income escaped assessment to tax. It is submitted that assessment proceedings were sought to be reopened primarily on the ground that there were ... Singh v. AACIT, 972 SCR (1) 175 (SC). 11.2 Reassessment proceedings were initiated merely on the basis of 'reason to suspect' and not 'reason to believe' for the purpose of making fishing and roving enquiries in connection with the various items depicted in the regular books of account

Deputy Commissioner of Income Tax, Central Circle, Kollam vs. Moneymuttam Finance, Pathanamthitta

In the result, assessee’s cross objection stands allowed and appeal filed by the Revenue stands dismissed

ITA 315/COCH/2024[2017-18]Status: DisposedITAT Cochin09 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm Assessment Years: 2017-18

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

cross objections raised by the assessee challenges the very validity of reopening of assessment on the ground that there were no reason to believe that income escaped assessment to tax. It is the bank accounts of the Assessee from Nagaland based parties-fund transfers were in the nature of loans ... Singh v. AACIT, 972 SCR (1) 175 (SC). 11.2 Reassessment proceedings were initiated merely on the basis of 'reason to suspect' and not 'reason to believe' for the purpose of making fishing and roving enquiries in connection with the various items depicted in the regular books of account

Deputy Commissioner of Income Tax, Central Circle, Kollam vs. Arun Raj Pillai, Pathanamthitta

In the result, the cross objection filed by the assessee company stands allowed

ITA 314/COCH/2024[2018-19]Status: DisposedITAT Cochin09 Jun 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)

Assessee.” 11. Cross Objection No. 1, challenges the very validity of reopening of assessment on the ground that there were no reasons to believe that income escaped assessment to tax. It is submitted that assessment proceedings were sought to be reopened primarily on the ground that there were certain fund ... Singh v. AACIT, 972 SCR (1) 175 (SC). 11.2 Reassessment proceedings were initiated merely on the basis of 'reason to suspect' and not 'reason to believe' for the purpose of making fishing and roving enquiries in connection with the various items depicted in the regular books of account

Sreevalsam Hotels and Resorts Private Ltd, Rajavalsam vs. ACIT, Central Circle, Kollam

In the result, assessee’s appeal in ITA No

ITA 115/COCH/2024[2017-2018]Status: DisposedITAT Cochin09 Jun 2025AY 2017-2018

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

above grounds. 11. Ground Nos. 1 & 2 challenges the very validity of reopening of assessment on the ground that there were no reason to believe that income escaped assessment to tax. It is submitted that assessment proceedings were sought to be reopened primarily on the ground that there were certain ... Singh v. AACIT, 972 SCR (1) 175 (SC). 11.2 qReassessment proceedings were initiated merely on the basis of 'reason to suspect' and not 'reason to believe' for the purpose of making fishing and roving enquiries in connection with the various items depicted in the regular books of account

Hmg Engineering Private Limited, Mumbai vs. Income-Tax Officer, Ward 1(1)(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3012/MUM/2024[2012-13]Status: DisposedITAT Mumbai09 Jun 2025AY 2012-13

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सुं./Ita No. 3012/Mum/2024 (नििाारण वर्ा / Assessment Year :2012-13) Hmg Engineering Pvt. Ltd. V/S. Ito, Ward (1)(1)(4) 1St Floor, Bandukwala बिाम Income Tax Department, Building, 14 British Hotel 531A 5Th Floor, Aayakar Lane, Off B S Marg, Fort, Bhawan, Maharishi Karve Maharashtra-400023 Road, Maharashtra- 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach3226L Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Krutarth K. Desai राजस्व की ओर से /Revenue By: Shri Hemanshu Joshi

For Appellant: Shri Krutarth K. DesaiFor Respondent: Shri Hemanshu Joshi
Section 143(3)Section 147Section 148Section 41(1)

failure on the part of the assessee to disclose fully and truly all the material facts necessary for its assessment, the undersigned has reason to believe that the income chargeable to tax, amounting to Rs. 16,76,236/- has escaped assessment for A.Y. 2012-13, within the meaning of section ... escapement of income arising on account of non-filing of return or non-disclosure of material facts or the Assessing Officer should have reason to believe escapement in consequence of information in his possession. After the amendment, there is only one condition, that there is "reason to believe" escapement

Vanaraj Wood Industries Private Ltd, Chennai vs. Income Tax Officer, Delhi

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

ITA 115/CHNY/2025[2013-14]Status: DisposedITAT Chennai06 Jun 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:115/Chny/2025 िनधा"रण वष" / Assessment Year: 2013-14

For Appellant: Shri. A.Srinivasan, C.AFor Respondent: Shri. R.Clement Ramesh Kumar, C.I.T
Section 144Section 148

filed its return of income for the assessment year 2013-14. Based on information available with the department the AO had reason to believe that the assessee had not disclosed certain income and hence the AO issued notice u/s.148 on 31.03.2021 and asking assessee to file the return of income

Genpact Services Llc, Gurgaon vs. ACIT, Circle Int. Taxation 1(3)(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 788/DEL/2023[2019-20]Status: DisposedITAT Delhi06 Jun 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh[Assessment Year: 2019-20]

Section 142(1)Section 143(2)Section 143(3)Section 92C

cost sharing entities combined is significantly lower than the headcount ratio. In the light of the above, I have reason to believe that the assessee used an inappropriate and wholly unscientific method for charging of costs to GSL, which resulted in a higher ratio of common costs allocated

Kundarnad Janata Shikshan Sangh Ankalgi, Ankalgi Gokak vs. Income Tax Officer, Gokak

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

ITA 57/PAN/2025[2018-19]Status: DisposedITAT Panaji05 Jun 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.57/Pan/2025 (A.Y.2018-19 ) Kundarnad Janta Shikshan Vs National E – Sangh Ankalgi, Assessment Centre, . Ankalgi, Gokak, Delhi-110001 Belgaum-591101, Karnataka. Pan .No.Aadtk0333K (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 69A

Central Co Op Bank Ltd during the F.Y.2017- 18 and the assesse has not filed the return of income. The Assessing Officer has reason to believe that the income has escaped the assessment and notice u/sec148 of the Act was issued and the assessee has filed the return of income

My Healthskape Medicals Private Limited, Mumbai vs. Principal Commissioner of Income Tax Officer, Mumbai - 4, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2120/MUM/2024[2015-16]Status: DisposedITAT Mumbai05 Jun 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सुं./Ita No. 2120/Mum/2024 (नििाारण वर्ा / Assessment Year :2015-16) M/S. My Healthskape V/S. Pcit, Mumbai-4 Medicals Pvt. Ltd. बिाम Room No. 629, 6Th Floor, 4-425A, Sharma Industrial Aayakar Bhavan, Maharishi Estate, Walbhat Road, Karve Road, Mumbai- Goregaon (E), Mumbai- 400020 400063 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcm4683K Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Rakesh Joshi राजस्व की ओर से /Revenue By: Shri Ritesh Misra

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra
Section 12ASection 135Section 143(3)Section 147Section 148Section 263Section 35Section 35(1)(ii)Section 37Section 80G

years from the end of the relevant year has expired in this case, the requirement to initiate proceedings u/s.147 of the Act are reason to believe that income for the year under consideration has escaped assessment because of failure on the part of the assessee to disclose fully and truly ... diligence, accordingly attracting provisions of Explanation 1 of section 147 of the Act. 7. It is pertinent to mention here that reason to believe that income has escaped assessment for the year under consideration have been recorded in the above referred paragraph. I have carefully considered the assessment record containing

Cofre Do Fundo Da Cruz Alo De Bambolim, Bambolim vs. Income Tax Officer, NFAC, Delhi

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

ITA 305/PAN/2024[2015-16]Status: DisposedITAT Panaji04 Jun 2025AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.305/Pan/2024 (A.Y. 2015-16 ) Cofre Do Fundo Da Cruz Alo Vs National E – De Bombolim, Assessment Centre, . 101/1,Holy Cross Shrine, Delhi-110001 Bambolim, Gmc Complex, . Bambolim-403202, Goa. Pan .No. Aabtc0675N (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Smt.Pratibha.R. Ar Revenue By Shri.Deshmukh S Prakashsr.Dr

Section 11Section 249(4)(b)

cash deposits in two bank accounts during the F.Y.2014-15 and the assesse has not filed the return of income. The Assessing Officer has reason to believe that the income has escaped the assessment and notice u/sec148 of the Act was issued. Further notice u/sec 143(2) and u/sec

Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Sportking India Limited, Village Kanech Gt Road

Appeal stands dismissed

ITA 16/CHANDI/2024[2011]Status: DisposedITAT Chandigarh04 Jun 2025

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 16/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2011-12) Dcit-Central Circle-2 M/S Sportking India Limited बनाम/ Sco 1-6, 3Rd Floor Village Kanech, Gt Road, Sahnewal Vs. Kichlu Nagar, Ludhiana-141001 Khurd, Punjab 141120 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacs-3037-Q (अपीलाथ"/Appellant) (""थ" / Respondent) : & आयकरअपीलसं./ Co No.30/Chandi/2024 (In Ita No.16/Chandi/2024) (िनधा"रणवष" / Assessment Year: 2011-12) M/S Sportking India Limited Dcit-Central Circle-2 बनाम/ Village Kanech, Gt Road, Sco 1-6, 3Rd Floor Vs. Sahnewal Khurd, Punjab 141120 Kichlu Nagar, Ludhiana-141001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacs-3037-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ashwani Kumar (Ca) & Ms. Deepali Aggarwal (Ca) – Ld. Ars Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 09-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-06-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Revenue Is In Further Appeal Before Us For Assessment Year (Ay) 2011-12 Against The Order Of Ld. Commissioner Of Income Tax

For Appellant: Shri Ashwani Kumar (CA) & Ms. DeepaliFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 132Section 133(6)Section 143(3)Section 148Section 153ASection 68

necessary for AO to establish beyond doubt that income had escaped assessment. At this stage, there should be prima facie reason to believe that certain income had escaped assessment. This condition was fulfilled. Accordingly, the legal ground was dismissed. 3.3 For merits, the assessee drew attention to the purchase documents

Rekha Shah, Mumbai vs. AO, Kautilya Bhavan, Mumbai

In the result, the appeal filed by the assessee bearing ITA No

ITA 2311/MUM/2025[2011-12]Status: DisposedITAT Mumbai04 Jun 2025AY 2011-12

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeerekha Shah Vs National Faceless Appeal Centre D-614, Veena Santoor, Sector- (Nfac) / Ito-Ward-34(3)(2), 8, Opp. Kvsc, Sai Baba Nagar Mumbai Extension Road, Borivali (W), Kautilya Bhavan, Bkc, Banda, Mumbai-400 092 Mumbai-400 051 Pan: Abgps4732G Appellant Respondent

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Annavaram Kosuri (SR DR)
Section 144Section 147Section 250

filed for the year under consideration and no assessment was made and that the only requirement for initiating proceedings u/s 147 is reason to believe which has been recorded. The Ld.AR submitted that the above observation made by the Ld.AO is completely wrong as the return was filed

Jagdish Prasad, Delhi vs. ACIT-Circle 57(1), Delhi

In the result, the appeal filed by the assessee is partly allowed

ITA 2387/DEL/2023[2008-09]Status: DisposedITAT Delhi04 Jun 2025AY 2008-09

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Santanu Jain, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 132Section 132(4)Section 147Section 148Section 69C

That the Ld. Assessing Officer has not recorded any reason by using his independent application of mind to show that he has a "reason to believe" that the income has escaped assessment and as such the same are not valid in the eyes of law. 2.3 That reasons recorded

Dr. Sarvesh Kumar, Delhi vs. ACIT Circle 57(1), New Delhi

In the result, the appeal filed by the assessee is partly allowed

ITA 2339/DEL/2023[2008-09]Status: DisposedITAT Delhi04 Jun 2025AY 2008-09

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Santanu Jain, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 132Section 132(4)Section 147Section 148Section 69C

That the Ld. Assessing Officer has not recorded any reason by using his independent application of mind to show that he has a "reason to believe" that the income has escaped assessment and as such the same are not valid in the eyes of law. 2.3 That reasons recorded

Darshit Patel, Sanganer, Jaipur vs. Income Tax Officer Ward 7(2), Jaipur

In the result appeal filed by the assessee stands allowed and that of

ITA 957/JPR/2024[2013-2014]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-2014

Bench: Him.

For Appellant: Sh. Mukesh Goyal, CAFor Respondent: Sh. Anup Singh, Addl. CIT-DR
Section 147Section 44ASection 69A

Patel vs. ITO because the assessee also not made compliance to the letter issued by the JAO. Based on that Assessing Officer had reason to believe that income chargeable to tax has escaped assessment within the meaning of the provisions of clause (a) of Explanation 2 to section

Income Tax Officer, Ward-7(2), Jaipur vs. Darshit Patel, Jaipur

In the result appeal filed by the assessee stands allowed and that of

ITA 929/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-14

Bench: Him. 2. Since These Cross Appeals Relate One Assessee Involving The Same

For Appellant: Sh. Mukesh Goyal, CAFor Respondent: Sh. Anup Singh, Addl. CIT-DR
Section 147Section 44ASection 69A

Patel vs. ITO because the assessee also not made compliance to the letter issued by the JAO. Based on that Assessing Officer had reason to believe that income chargeable to tax has escaped assessment within the meaning of the provisions of clause (a) of Explanation 2 to section

Gaurav Vinodkumar Dugar Legal Heir of Late Vinodkumar Babulal Dugar, Ahmedabad vs. The ITO, Ward-1(1)(3)(Previously Ward- 1(2)(4)), Ahmedabad

In the result the ITA No

ITA 753/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad03 Jun 2025AY 2012-13

Bench: Dr. Brr Kumar & Ms Suchitra Kambleआयकर अपील सं./Ita Nos. 131 & 132/Ahd/2024 "नधा"रण वष"/Asstt. Years: 2010-2011 & 2011-12

For Appellant: Shri M S Chhajed, ARFor Respondent: Shri Santosh Kumar, Sr. DR
Section 139Section 148Section 151Section 44A

Assistant Commercial Tax Officer(Investigation) Unit-2, Ahmedabad (Charge), it was found that Rs.46,02,85,319/-. Therefore, the AO had a reason to believe that the assessee has suppressed sales in his books of accounts during the ITA Nos.131, 132 & 753/Ahd/2024 Asst. Year 2010-11 to 2012-13 Financial