“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

Gopal Extrusions Pvt Ltd, Jalgaon vs. Income-Tax Officer, Ward - 1(2), Jalgaon

ITA 1633/PUN/2017[2008-09]Status: DisposedITAT Pune29 Apr 2025AY 2008-09

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita. No.1633/Pun/2017 Assessment Year : 2008-09

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ramnath Murkunde

Section 143(3)

company stated that it had not contributed to share capital as claimed by the assessee. Based on such factual observation, ld. AO had reason to believe that 7 Gopal Extrusions Pvt. Ltd. income has escaped assessment and he accordingly issued notice u/s.148 of the Act and gave reasons recorded ... provisions of section 147 and first proviso to the said section are relevant and hence reproduced below: "147- 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 section

Assistant Commissioner of Income Tax, Coimbatore vs. Kamatchipuram Vellingiri Jayaraman, Coimbatore

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

ITA 2777/CHNY/2024[2017-18]Status: DisposedITAT Chennai29 Apr 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Ms. D.Komali Krishna, CITFor Respondent: Mr.Venkatswami, ITP &

Section 147Section 148

read with Section 148 of the Act, unless it assesses to tax that income with reference to which the Assessing Officer had formed reason to believe (within the meaning of Section 147), that it had escaped assessment. C.O.No.27/Chny/2025 21. To my mind, a careful reading of Section ... would show that it empowers an Assessing Officer to reopen the assessment, if, he has reason to believe, that any income chargeable to tax has escaped assessment for the relevant year, ''and also bring to tax", any other income, which may attract assessment, though, it is brought to his notice

Leela Enterprises, Mumbai vs. ITO Ward 41(2)(3), Mumbai

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

ITA 776/MUM/2025[2014-15]Status: DisposedITAT Mumbai29 Apr 2025AY 2014-15

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SMT. RENU JAUHRI (Accountant Member)

For Appellant: Shri. Hasmukh RavariaFor Respondent: 23.04.2025

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 40

neither any information nor any cogent evidence to show escapement of income due to the fact that A.O has shown basis of forming reason to believe stating that he has credible details in the form of computation sheet and assessment records submitted by assessee, which means reason for re-opening

ACIT, Mumbai vs. Reliance Industries Limited, Mumbai

In the result, the appeal of the Revenue is dismissed whereas the cross-objection of the assessee is allowed

ITA 3705/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Apr 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Acit, Reliance Industries Ltd., Room No. 559, 5Th Floor, 3Rd Floor Maker Chamber Iv, Aayakar Bhavan, New Marine Vs. Nariman Point, S.O. Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

For Appellant: Mr. Madhur Agarwal/Ms. MokshaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR

Section 10ASection 115JSection 144BSection 144CSection 147Section 801B(9)

assessment under section 147 of Act, after the expiry of four years from the end of the relevant assessment year. The AO recorded reasons to believe that income had escaped assessment and accordingly issued a notice under section 148 of the Act on 31.03.2021. Following the prescribed procedure under ... lease rent as income. 5.2 The Assessing Officer vide his letter dated 29.10.2018 and 24.06.2019 disagreed to above audit objections, still he recorded reasons to believe on all the above issues of the audit objection that income escaped assessment. 6. The reasons recorded has been reproduced

Assistant Commissioner of Income Tax, Corporate Circle 1(1), Chennai vs. M/S Cholamandalam Investment & Finance Company Ltd, Chennai

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

ITA 2836/CHNY/2024[2014-15]Status: DisposedITAT Chennai28 Apr 2025AY 2014-15

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

For Appellant: Mr. Ajith Kumar Jain CA & Mr. Kunal Shah, CAFor Respondent: Mr. R. Clement Ramesh Kumar, CIT &

Section 143(3)Section 250Section 43(5)

proposed reassessment for the following reasons: i. Reopening in absence of discovery of any new tangible material or fact is not valid ‘reason to believe’ that income has escaped assessment; ii. Initiation of reassessment proceedings for AY 2014-15 is based on mere change of opinion; iii. Lack of analysis ... 2836/Chny/2024 “Prior to the Direct Tax Laws (Amendment) Act, 1987, reopening could be done under two conditions, viz., if (a) the ITO had reason to believe that, by reason of the omission or failure on the part of an assessee to make a return under section 139 for any assessment

Assistant Commissioner of Income Tax, Corporate Circle 1(1), Chennai vs. M/S Cholamandalam Investment and Finance Company Limited, Chennai

ITA 2835/CHNY/2024[2014-15]Status: DisposedITAT Chennai28 Apr 2025AY 2014-15

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. R. Raghunatha, Hon'Bleआयकर अपीलसं./Ita Nos.: 2613 & 2732/Chny/2024 निर्धारणवर्ष / Assessment Years: 2013-14 & 2014-15 Cholamandalam Investment & Finance Company Limited, Chola Crest, C 54 & C 55, Super B-4, Thiru Vi Ka Industrial Estate, Guindy, Guindy Industrial Estate S.O., Chennai - 600 032. [Pan: Aaacc-1226-H] (अपीलार्थी/Appellant) & The Deputy Commissioner Of Income Tax, V. Corporate Circle -1(1), Chennai - 600 034. (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.: 2835, 2836 & 2820/Chny/2024 निर्धारणवर्ष / Assessment Years: 2014-15, 2014-15 & 2015-16 The Assistant Commissioner Of Income Tax, Corporate Circle -1(1), Chennai - 600 034 Cholamandalam Investment & Finance Company V. Limited, (अपीलार्थी/Appellant) Chola Crest, C 54 & C 55, Super B-4, Thiru Vi Ka Industrial Estate, Guindy, Guindy Industrial Estate S.O., Chennai - 600 032. [Pan: Aaacc-1226-H] (प्रत्यर्थी/Respondent) Assessee By Department By : Mr. Ajith Kumar Jain Ca & Mr. Kunal Shah, Ca & Ms. Aashna Dhila, Ca : Mr. R. Clement Ramesh Kumar, Cit & Ms. Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 12.02.2025 घोषणा की तारीख/Date Of Pronouncement : 28.04.2025 :-2-:

For Respondent: Mr. Ajith Kumar Jain CA & Mr. Kunal Shah, CA

Section 143(3)Section 250Section 43(5)

आयकर अपीलीय अधिकरण, 'सी'न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH, CHENNAI श्रीएबीटीवर्की, न्यायिकसदस्यएवंश्रीएस.आर. रघुनाथा, लेखासदस्यकेसमक्ष

Assistant Commissioner of Income Tax, Corporate Circle 1(1), Chennai vs. Cholamandalam Investment and Finance Company Limited, Chennai

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

ITA 2820/CHNY/2024[2015-16]Status: DisposedITAT Chennai28 Apr 2025AY 2015-16

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

For Appellant: Mr. Ajith Kumar Jain CA & Mr. Kunal Shah, CAFor Respondent: Mr. R. Clement Ramesh Kumar, CIT &

Section 143(3)Section 250Section 43(5)

Cholamandalam Investment and Fianance Co. Ltd., Chennai vs. DCIT, Corporate Circle-1(1), Chennai

ITA 2732/CHNY/2024[2014-15]Status: DisposedITAT Chennai28 Apr 2025AY 2014-15

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. R. Raghunatha, Hon'Bleआयकर अपीलसं./Ita Nos.: 2613 & 2732/Chny/2024 निर्धारणवर्ष / Assessment Years: 2013-14 & 2014-15 Cholamandalam Investment & Finance Company Limited, Chola Crest, C 54 & C 55, Super B-4, Thiru Vi Ka Industrial Estate, Guindy, Guindy Industrial Estate S.O., Chennai - 600 032. [Pan: Aaacc-1226-H] (अपीलार्थी/Appellant) & The Deputy Commissioner Of Income Tax, V. Corporate Circle -1(1), Chennai - 600 034. (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.: 2835, 2836 & 2820/Chny/2024 निर्धारणवर्ष / Assessment Years: 2014-15, 2014-15 & 2015-16 The Assistant Commissioner Of Income Tax, Corporate Circle -1(1), Chennai - 600 034 Cholamandalam Investment & Finance Company V. Limited, (अपीलार्थी/Appellant) Assessee By Department By Chola Crest, C 54 & C 55, Super B-4, Thiru Vi Ka Industrial Estate, Guindy, Guindy Industrial Estate S.O., Chennai - 600 032. [Pan: Aaacc-1226-H] (प्रत्यर्थी/Respondent) : Mr. Ajith Kumar Jain Ca & Mr. Kunal Shah, Ca & Ms. Aashna Dhila, Ca : Mr. R. Clement Ramesh Kumar, Cit & Ms. Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 12.02.2025 घोषणा की तारीख/Date Of Pronouncement : 28.04.2025 :-2-:

Section 143(3)Section 250Section 43(5)

Cholamandalam Investment and Finance Company Limited, Chennai, Tamil Nadu vs. Deputy Commissioner of Income-Tax (DCIT), Chennai-1, Chennai, Tamil Nadu

ITA 2613/CHNY/2024[2013-2014]Status: DisposedITAT Chennai28 Apr 2025AY 2013-2014

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. R. Raghunatha, Hon'Bleआयकर अपील सं./Ita Nos.: 2613 & 2732/Chny/2024 निर्धारण वर्ष / Assessment Years: 2013-14 & 2014-15 Cholamandalam Investment & Finance Company Limited, Chola Crest, C 54 & C 55, Super B-4, Thiru Vi Ka Industrial Estate, Guindy, Guindy Industrial Estate S.O., Chennai - 600 032. [Pan: Aaacc-1226-H] (अपीलार्थी/Appellant) & आयकर अपील सं./Ita Nos.: 2835, 2836 & 2820/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15, 2014-15 & 2015-16 The Assistant Commissioner Of Income Tax, Corporate Circle -1(1), Chennai - 600 034 (अपीलार्थी/Appellant) The Deputy Commissioner Of Income Tax, V. Corporate Circle -1(1), Chennai - 600 034. (प्रत्यर्थी/Respondent) Cholamandalam Investment & Finance Company V. Limited, Chola Crest, C 54 & C 55, Super B-4, Thiru Vi Ka Industrial Estate, Guindy, Guindy Industrial Estate S.O., Chennai - 600 032. [Pan: Aaacc-1226-H] (प्रत्यर्थी/Respondent) Assessee By : Mr. Ajith Kumar Jain Ca & Mr. Kunal Shah, Ca & Ms. Aashna Dhila, Ca Department By : Mr. R. Clement Ramesh Kumar, Cit & Ms. Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 12.02.2025 घोषणा की तारीख/Date Of Pronouncement : 28.04.2025 :-2-:

For Appellant: Mr. Ajith Kumar Jain CA & Mr. Kunal Shah, CAFor Respondent: Mr. R. Clement Ramesh Kumar, CIT &

Section 143(3)Section 250Section 43(5)

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH, CHENNAI श्रीएबीटीवर्की, न्यायिक सदस्य एवं श्री

Deputy Commissioner of Income Tax, Circle-1, Bareilly vs. Ms Shree Bhawani Mills, Shahjahanpur

In the result, the appeal of the Department is partly allowed while the Cross

ITA 332/LKW/2023[2017-18]Status: DisposedITAT Lucknow25 Apr 2025AY 2017-18

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Deputy Commissioner Of Income Vs. M/S Shree Bhawani Mills, Tax, Circle-1, Bareilly Gandhi Ganj, Shahjahanpur, U.P. Pan:Aadfs8573M (Appellant) (Respondent) & C.O. No.15/Lkw/2023 A.Y. 2017-18 M/S Shree Bhawani Mills, Gandhi Vs. Deputy Commissioner Of Ganj, Shahjahanpur, U.P. Income Tax, Circle-1, Bareilly Pan:Aadfs8573M (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. Manu Chaurasia, Cit Dr Date Of Hearing: 12.03.2025 Date Of Pronouncement: 25.04.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Revenue Against The Order Of The Ld. Cit(A) Passed Under Section 250 Of The Income Tax Act On 7.09.2023 Allowing The Appeal Of The Assessee Against The Order Passed By The Ld. Ao On 30.03.2022 Under Section 147 R.W.S. 144 Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:-

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. Manu Chaurasia, CIT DR

Section 144Section 147Section 151Section 250Section 46A

allowing the appeal of cross objector assessee, the Id. CIT(A) should also have held that the assessment proceedings commencing from recording of reason to believe and concluding with passing of order dated 30.03.2022 passed by NFAC u/s 147 r.w.s 144B of the Income Tax Act, 1961 were illegal ... held that the assessment proceedings u/s 147 of the Income Tax Act, 1961 were vide ab-initio owing to several infirmities in the reason to believe recorded by the Assessing Officer. 2 & CO No.15/LKW/2024 M/s Shree Bhawani Mills 3. BECAUSE the sanction u/s 151 of the Income

Manishkumar Ramlakhan Agrawal, Ahmedabad vs. Ward 6(1)(1) Ahmedabad, Ahmedabad

In the result, impugned notice is quashed

ITA 1738/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 10(38)Section 115BSection 132Section 143(1)Section 143(2)Section 144Section 147Section 148Section 69A

admits the above fact. However, in the reasons recorded for reopening of assessment the Ld AO observed as follows: “… 4. Basis of forming reason to believe and details of escapement of income: It is noticed that the assessee has done suspicious transaction aggregating Rs. 57,50,682/- during ... Unit-1(1), Ahmedabad which is suspicious transaction and required to be taxed u/s 68 of the Act. Therefore, I have the reason to believe that income chargeable to tax to the extent of Rs.57,50,682/- has escaped the assessment within the meaning of section

Mrs. Rachel Christina Joseph, Chennai vs. ACIT, Ncc-12(1), Chennai

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

ITA 497/CHNY/2025[2016-17]Status: DisposedITAT Chennai25 Apr 2025AY 2016-17

Bench: Shri Manu Kumar Giri, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 497/Chny/2025 िनधा"रण वष" / Assessment Year: 2016-17 Mrs.Rachel Christina Joseph, The Assistant Commissioner Of No.36, Balaji Nagar, Vs. Income Tax, Non-Corporate 1St Street, Royapettah, Circle -12 (1), Chennai – 600 014. Chennai.

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. Anitha, Addl.CIT

Section 139Section 143(3)Section 147

hereinafter referred to as “the Act”) on 31.03.2017 by declaring total income of Rs.73,53,920/-. The case was reopened as there was reason to believe that the income chargeable to tax has escaped assessment within the meaning of section 147 of the Act. The assessment was completed u/s.143

Karuppannan Kulandaivel, Karungaradu, Salem vs. Income Tax Officer - ITO Ward 1(8), Salem

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

ITA 371/CHNY/2025[2011-12]Status: DisposedITAT Chennai25 Apr 2025AY 2011-12

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.371/Chny/2025 ("नधा"रण वष" / Assessment Year: 2011-12) Vs Shri Karuppannan Kulandaivel, The Income Tax Officer, 2/4-898, Karungaradu, Ito Ward 1(8), Navapatty (Po), Mettur Taluk, Salem. Salem – 636 452. Pan : Anwpk 1060F (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Srivatsan Ranganathan, Ca ""यथ" क" ओर से/Respondent By : Shri Keerthi Narayanan, Jcit सुनवाई क" तार"ख/Date Of Hearing : 23.04.2025 घोषणा क" तार"ख/Date Of Pronouncement : 25.04.2025 आदेश / O R D E R Per S R Raghunatha, Am: This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 26.12.2024 For The Assessment Year 2011-12. 2. The Brief Facts Of The Case Are That The Assessee Is An Individual & Has Not Filed His Return Of Income For The Assessment Year 2011- 12. As Per Information, The Assessee Has Transactions In His Savings

For Appellant: Shri Srivatsan Ranganathan, CAFor Respondent: Shri Keerthi Narayanan, JCIT

Section 144Section 148Section 69A

information, the assessee has transactions in his savings - 2 - ITA No.371/Chny/2025 bank account for more than Rs.10 lakhs. Therefore, the AO had reason to believe income chargeable to tax had escaped assessment and hence notice u/s.148 of the Act was issued. Though AO had issued several notices, the assessee remained

Viswanathan Jayakumar, Coimbatore vs. ITO, Ncw4(5), Coimbatore

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

ITA 1844/CHNY/2024[2012-13]Status: DisposedITAT Chennai25 Apr 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr. Dharshan Bothra, C.AFor Respondent: Ms. Anitha, Addl.CIT

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

extent of 12.5 cents for total consideration of Rs.1,87,52,580/-. The assessee has not filed return of income. Therefore, AO has reason to believe that income chargeable to tax has escaped assessment within the meaning of section 147 of the Act and hence, issued notice u/s.148

Daryabad Co-Operative Cane Development Union Limited, Barabanki vs. The Addl./Joint/Deputy/ACIT, NFAC

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

ITA 196/LKW/2025[2014-15]Status: DisposedITAT Lucknow24 Apr 2025AY 2014-15

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2014-15 Daryabad Co-Operative Cane V. The Addl/Joint/Dy. Acit Development Union Limited Nfac Daryabad, Ram Sanehi Ghat Delhi Barabanki Tan/Pan:Aaaad4943N (Appellant) (Respondent) Appellant By: Shri Shubham Rastogi, C.A. Respondent By: Shri Sunil Kumar Rajwanshi, D.R. Date Of Hearing: 23 04 2025 Date Of Pronouncement: 24 04 2025 O R D E R

For Appellant: Shri Shubham Rastogi, C.AFor Respondent: Shri Sunil Kumar Rajwanshi, D.R

Section 144BSection 147Section 148Section 151Section 271(1)(c)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(c)

reasons recorded are reasons to suspect and without bringing and tangible material and live nexus of the information and reason to believe. (4) That the Authorities below erred on facts and in law in not allowing deduction u/s 80P(2)(a)(iii) of I. T. Act on Interest received

Kanwaldeep Kaur, Chandigarh vs. DCIT, Circle 1, Chandigarh

In the result, appeal filed by the Revenue in ITA No

ITA 89/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh24 Apr 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Yogesh Monga, C.AFor Respondent: Shri Rohit Sharma, CIT DR

Section 147Section 56(2)Section 56(2)(vii)

consideration and the value adopted by Stamp Valuation Authority. The share of the assessee in this transaction was 50%. Therefore, the AO had reason to believe that the income chargeable to tax had escaped assessment within the meaning of the provisions of section 147 of the Act. Accordingly, with

Income Tax Officer, Mohali vs. Gurtej Singh, Mohali

In the result, appeal filed by the Revenue in ITA No

ITA 806/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh24 Apr 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Yogesh Monga, C.AFor Respondent: Shri Rohit Sharma, CIT DR

Section 147Section 56(2)Section 56(2)(vii)

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Lalit Kumar Prop. Lalit Co., Mis Babu Ram Hem Raj, Faridkot

Appeal stands dismissed

ITA 684/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh24 Apr 2025AY 2016-17

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं./ Ita No.682/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2014-15) & 2. आयकरअपील सं./ Ita No.683/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2015-16) & 3. आयकर अपील सं./ Ita No.684/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2016-17) Dcit Central Circle-1 Shri Lalit Kumar Sco 1-6, 2Nd Floor, Opp. Bvm School बनाम/ (Prop. Lalit Co. & M/S Babu Ram Hem Raj) New Grain Market Kitchlu Nagar Vs. Faridkot - 151203 Ludhiana-141001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adapk-3617-L (अपीलाथ"/Appellant) (""थ" / Respondent) : & 4. Co. No.25/Chandi/2024 (In Ita No. 682/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2014-15) & 5. Co. No.26/Chandi/2024 (In Ita No. 683/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2015-16) & 6. Co. No.27/Chandi/2024 (In Ita No. 684/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2016-17)

For Appellant: Shri Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Shri Rohit Sharma (CIT) & Shri Vivek Vardhan

Section 147Section 68

lakhs is not justified. 3. That the Ld. CIT(A) has erred in resorting to notice u/s 148 as there was no reason to believe for re-opening of the assessment and also that there was mechanical approval accorded by the higher authorities

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Lalit Kumar, Prop. Lalit Co., Ms Babu Ram Hem Raj, Faridkot

Appeal stands dismissed

ITA 682/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh24 Apr 2025AY 2014-15

For Appellant: Shri Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Shri Rohit Sharma (CIT) & Shri Vivek Vardhan

Section 147Section 68

The Primary Agriculture Cooperative Credit Society, Nennal vs. ITO., Ward-I, Mancherial

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

ITA 139/HYD/2025[2018-2019]Status: DisposedITAT Hyderabad24 Apr 2025AY 2018-2019

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Upadhyay RaghavenderFor Respondent: Shri Srinath Sadanala, Sr. AR

Section 139Section 147Section 148Section 69ASection 80P

scrutiny by the Directorate of Income Tax (Systems) as per the information available in Insight Portal of the Department. The Assessing Officer has reason to believe that the income chargeable to tax has escaped assessment, he reopened the assessment of the assessee-society u/sec.147 of the Income