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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

Sns Constructions P.Ltd, Panipat vs. ITO, Ward-4, Panipat

In the result, the appeal of the revenue is dismissed and the CO of the 7

ITA 4013/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Apr 2025AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganeshincome Tax Officer, Vs. Anil Kumar, Ward-1(1), J-10, South City-1, Gurgaon Gurgaon, Haryana (Appellant) (Respondent) Pan: Aampk9521G Co No. 88/Del/2024 (Ita No. 4013/Del/2024) (Assessment Year: 2014-15) Anil Kumar, Vs. Income Tax Officer, J-10, South City-1, Ward-1(1), Gurgaon, Haryana Gurgaon (Appellant) (Respondent) Pan: Aampk9521G

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 10(38)Section 115BSection 133ASection 143(3)Section 144Section 147Section 148Section 44ASection 69

clear in this regard and the same is re-produced as under: CO No. 88/Del/2024 Anil Kumar “.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 sections

Income Tax Officer, Jamnagar vs. Nilesh Bipinchandra Mehta, Jamnagar

In the result, the appeal of the assessee is allowed

ITA 750/RJT/2024[2011-12]Status: DisposedITAT Rajkot02 Apr 2025AY 2011-12

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No. 750 /Rjt/ 2024 (निर्धारण वर्ष / Assessment Year: (2011-12) (Hybrid Hearing) The Ito, Jamnagar Vs. Nilesh Bipinchandra Mehta Prop. Of B. J. Industries Tej Prakash Society, P. N. Marg Jamnagar 361001, Gujarat India स्थायी लेखासं./जीआइआरसं./Pan/Gir No.: Aaqpm8295H (Appellant) (Respondent) Appellant By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2025 घोषणा की तारीख/Date Of Pronouncement : 02/04/2025 आदेश / Order Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld. Cit(A)”] Vide Order Dated 21.08.2024, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short “The Act"). 1

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 147Section 148

assessee which has escaped taxation, so it proposed to reopen the case u/s. 147 of the Income Tax Act. (ii) Thus, I have reason to believe that the above transactions were escaped the assessment for A Y 2009-10 of Rs. 2,50,91,260/- due to the reason

Satish Kumar Saini, Jaipur vs. Income Tax Officer, Alwar

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

ITA 1526/JPR/2024[2012-13]Status: DisposedITAT Jaipur02 Apr 2025AY 2012-13
For Appellant: Shri Vishal Kalra, C.A. (Thr. V.C.)For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 127Section 144Section 148Section 151Section 69A

issuing the notice and passing the order without providing assessee with the material in his possession which formed the basis of forming reason to believe that income has escaped assessment in hands of assessee. It is thus against the provisions of law and mandate given by various legal precedents ... provide any submissions or explanations, despite being given ample opportunity to do so. Further, the AO had tangible and sufficient reasons to believe that the income had escaped assessment based on information that was not previously disclosed or considered during the original assessment. The appellant's argument that the reassessment

Shri Salasar Balaji Developers Pvt. Ltd, Jaipur vs. Income Tax Officer, Ward 2(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1186/JPR/2024[2012-13]Status: DisposedITAT Jaipur02 Apr 2025AY 2012-13

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Saurav Harsh, Adv., Ld. ARFor Respondent: Mr. Manoj Kumar, JCIT, Ld. DR
Section 132Section 143(3)Section 148Section 250Section 68Section 69C

DATED: 28/03/2019 Notice No: ITBA/AST/S/148/2018-19/1015490154(1) Sir/ Madam/ M/s, Notice Under Section 148 Of The Income Tax Act, 1961 Whereas I have reasons to believe that your Income chargeable to Tax for the Assessment Year 2012-13 has escaped Assessment within the meaning of section 147 of the Income ... that 'Under section 147, as substituted w.e.f. 1st April 1989, if the AO, for whatever reason, has reason to believe that income has escaped assessment, it confers jurisdiction to reopen the assessment where the case is not covered by proviso to section 147. 4.2 The assessee has also raised objection

M/S S.R. Industries Limited, Chandigarh vs. ACIT, Chandigarh

In the result, appeal is allowed

ITA 1219/CHANDI/2018[2007-08]Status: DisposedITAT Chandigarh02 Apr 2025AY 2007-08

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri T.N. Singla, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr.DR
Section 143(2)Section 143(3)Section 147Section 148Section 36Section 36(1)(iii)

interest @ 12% computed at Rs. 73,44,534/- required to be disallowed under the provision of section 36(l)(iii). Therefore, I have reason to believe that there is under assessment to the tune of Rs. 73,44,534/-. 2. Perusal of the Schedule B to Balance-sheet shows that ... shows that personal nature expenses included therein are not ruled out. 4. Keeping in view above facts, I have reason to believe that there is under assessment. Therefore, notice u/s 148/- is being issued to the assessee for re- assessment its net taxable income/loss. Dated : 4.2.2011. (Princy Singla) Asstt. Commissioner

Alchemist Multitrade Pvt. Ltd., Malad West Mumbai vs. ITO 12 (1) (1), Mumbai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 3802/MUM/2023[2014-15]Status: DisposedITAT Mumbai02 Apr 2025AY 2014-15

Bench: Justice (Retd.) C.V. Bhadang & Shri B R Baskaran

For Appellant: Shri Ketan Vajani (virtual appearance)For Respondent: Dr. K.R. Subhash, CIT-DR
Section 148Section 69A

year under consideration. However, in this case no assessment was made and the only requirement to initiate proceedings u/s. 147 is to record reason to believe that income chargeable to tax has escaped assessment. 5. In view of the above, the provisions of clause (b) of Explanation 2 to Section ... deemed to be a case where income chargeable to tax has escaped assessment. 6. In view of the above, I have reason to believe that income amounting to Rs.66,83,00,000/- chargeable to tax has escaped assessment by reason of failure on the part of the assessee to disclose

Alchemist Multitrade Private Limited, Malad West Mumbai vs. ITO 12 (1) (1), Mumbai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 3801/MUM/2023[2015-16]Status: DisposedITAT Mumbai02 Apr 2025AY 2015-16

Bench: Justice (Retd.) C.V. Bhadang & Shri B R Baskaran

For Appellant: Shri Ketan Vajani (virtual appearance)For Respondent: Dr. K.R. Subhash, CIT-DR
Section 148Section 69A

year under consideration. However, in this case no assessment was made and the only requirement to initiate proceedings u/s. 147 is to record reason to believe that income chargeable to tax has escaped assessment. 5. In view of the above, the provisions of clause (b) of Explanation 2 to Section ... deemed to be a case where income chargeable to tax has escaped assessment. 6. In view of the above, I have reason to believe that income amounting to Rs.66,83,00,000/- chargeable to tax has escaped assessment by reason of failure on the part of the assessee to disclose

Alchemist Multitrade Private Limited, Malad West Mumbai vs. ITO 12 (1 ) (1), Mumbai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 3800/MUM/2023[2016-17]Status: DisposedITAT Mumbai02 Apr 2025AY 2016-17

Bench: Justice (Retd.) C.V. Bhadang & Shri B R Baskaran

For Appellant: Shri Ketan Vajani (virtual appearance)For Respondent: Dr. K.R. Subhash, CIT-DR
Section 148Section 69A

year under consideration. However, in this case no assessment was made and the only requirement to initiate proceedings u/s. 147 is to record reason to believe that income chargeable to tax has escaped assessment. 5. In view of the above, the provisions of clause (b) of Explanation 2 to Section ... deemed to be a case where income chargeable to tax has escaped assessment. 6. In view of the above, I have reason to believe that income amounting to Rs.66,83,00,000/- chargeable to tax has escaped assessment by reason of failure on the part of the assessee to disclose

Alchemist Multitrade Private Limited, Malad West Mumbai vs. ITO Ward 12 (1) (1), Mumbai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 3764/MUM/2023[2013-14]Status: DisposedITAT Mumbai02 Apr 2025AY 2013-14

Bench: Justice (Retd.) C.V. Bhadang & Shri B R Baskaran

For Appellant: Shri Ketan Vajani (virtual appearance)For Respondent: Dr. K.R. Subhash, CIT-DR
Section 148Section 69A

year under consideration. However, in this case no assessment was made and the only requirement to initiate proceedings u/s. 147 is to record reason to believe that income chargeable to tax has escaped assessment. 5. In view of the above, the provisions of clause (b) of Explanation 2 to Section ... deemed to be a case where income chargeable to tax has escaped assessment. 6. In view of the above, I have reason to believe that income amounting to Rs.66,83,00,000/- chargeable to tax has escaped assessment by reason of failure on the part of the assessee to disclose

ACIT, New Delhi vs. M/S. Bhushan Steel Ltd., New Delhi

In the result, appeal of the assessee is allowed

ITA 1470/DEL/2016[2009-10]Status: DisposedITAT Delhi02 Apr 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2006-07] S. C. Johnson Pvt. Ltd., Vs Dcit, 5Th Floor, Plot No.68, Circle-7(1), Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent [Assessment Year : 2007-08] S. C. Johnson Pvt. Ltd., Vs Acit, 5Th Floor, Plot No.68, Circle-22(2), Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent [Assessment Year : 2008-09] S. C. Johnson Pvt. Ltd., Vs Add.Cit, 5Th Floor, Plot No.68, Special Range-8, Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent Appellant By Shri K. M. Gupta, Adv. & Ms. Shruti Khimta, Ar Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 02.06.2025 Date Of Pronouncement 28.08.2025

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 250Section 80I

truly all material facts necessary for assessment. 1.3 That the Ld. CIT(A) erred in law in not appreciating that the alleged reasons to believe recorded are merely in the nature of pretence and vague as no fresh tangible material surfaced after completion of original assessment proceedings. 1.4 That ... mistake has resulted in underassessment of income of Rs. 34562000/-involving short levy of tax of Rs. 15472647/-including interest. I have therefore, reason to believe that an amount of Rs. 34562000/- have escaped assessment within the meaning of section 147(c) of the IT Act, 1961. The escapement

Rahul, Mathura vs. Income Tax Officer 1(3)(1), Mathura

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

ITA 2/AGR/2025[2017-18]Status: DisposedITAT Agra01 Apr 2025AY 2017-18

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2017-18]

Section 142(1)Section 144Section 271A

implies that assessee is deliberately not providing the desired information/details relating to source of cash deposit during demonetization period, hence, there is every reason to believe that cash deposits during demonetization period made by the assessee in above stated bank account are from undisclosed sources. The Assessing Officer completed

Malkiat Agro Industries 01, Cantt Road, Nabha 147201, Punjab vs. Lovish Shelley the DCIT Circle Mandigobind Garh Jao Income Tax Officer Nabha, Punjab

In the result, assessee’s appeal is allowed

ITA 485/CHANDI/2024[2012-2013]Status: DisposedITAT Chandigarh01 Apr 2025AY 2012-2013

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri K.K. Singla, C.AFor Respondent: Smt. Kusum Bansal, CIT DR
Section 133Section 133(6)Section 143(1)Section 148

That the ITO, Ward Nabha has erred in issuing the notice u/s 148 without there being any reason to believe that the income of the assessee had escaped assessment just on the basis of alleged information available with the department. b). That the Ld. ITO, Ward Nabha has not applied ... course of proceedings u/s 133 (6) prior to the issue of notice u/s 148 and, thus, the very basis of formation of reason to believe, the AO ignoring all such bank accounts, in which, there has been cash deposits, based on the audited set of books of accounts as declared

Anju Daruka, Burdwan vs. ITO, Ward - 3(1), Asansol

In the result, the appeal of the assessee is allowed

ITA 2143/KOL/2024[2013-14]Status: HeardITAT Kolkata01 Apr 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: S/Shri Somnath Ghosh &For Respondent: Shri Sailen Samadder, DR
Section 04Section 143(1)Section 147Section 148Section 148(2)Section 69A

undisputed facts are that the case of the assessee was reopened u/s 147 read with section 148 of the Act after recording reason to believe u/s 148(2) of the Act by the AO. The above reopening was done after the Id. AO received information from the DIT (Investigation) Kolkata ... LTCG In its ITR (Schedule El) filed for the A.Y.2013-14. (vi) On the basis of above discussion, I have every reason to believe that the income chargeable to tax has escaped assessment to the extent of Rs.11,87,522/-, coming within the meaning of section 147 read with proviso thereto

Assistant Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. Bellflower Finance Private Limited, Kolkata

In the result, the appeal of the revenue is dismissed and re-opening of assessment is quashed by allowing the issue raised under Rule 27 of ITAT Rules

ITA 2020/KOL/2024[2009-10]Status: DisposedITAT Kolkata01 Apr 2025AY 2009-10

Bench: Shri Rajesh Kumar, Am& Shri Sonjoy Sarma, Jm]

Section 147Section 148Section 250Section 68

stated that the reasons recorded were not vague rather very specific as details of transactions were duly mentioned in the reasons to believe. Further, the AO. has conducted enquiry on the basis of this reason to believe which resulted in addition to the total income. The AO. in the remand ... source either in individual current account or proprietorship account maintained with ICICI Bank Ltd. 2. Under the circumstances mentioned above I have reason to believe that the above income has escaped assessment and it is a fit case for reopening u/s 47 of the IT Act, 1961. This

N. N. Construction, Borsi, Durg vs. Deputy Commissioner of Income Tax Circle-1(1), Bhilai, Durg

The appeal of the assessee is partly allowed for statistical purposes

ITA 403/RPR/2024[2018-19]Status: DisposedITAT Raipur28 Mar 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 403/Rpr/2024 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 139(1)Section 144BSection 147Section 148Section 151ASection 250Section 44A

Section 147 of the Act lays down that the reopening the assessment can be done by the Assessing Officer (AO) if he has 'reason to believe' that the income has escaped assessment. Escapement of income chargeable to tax can be due to not filing of return of income

M/S. Keynesian Financial Services Ltd., Kolkata vs. D.C.I.T., Circle - 7(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2264/KOL/2024[2013-2014]Status: DisposedITAT Kolkata28 Mar 2025AY 2013-2014

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Dcit, Circle-7(1) M/S Keynesian Financial Aaykar Bhavan, P-7, Services Ltd. 205, Rabindra Sarani, 3 Rd Floor, Chowringhee Square, Vs. Room No.103, Kolkata-700007 Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabck3459M Assessee By : Shri Abhishek Bansal, Ar Revenue By : Shri Sanjay Paul, Dr Date Of Hearing: 23.01.2025 Date Of Pronouncement : 28.03.2025

For Appellant: Shri Abhishek Bansal, ARFor Respondent: Shri Sanjay Paul, DR
Section 143(2)Section 147Section 148Section 148(2)Section 68

securities. The case of the assessee was reopened u/s 147 of the Act, M/s Keynesian Financial Services Ltd; A.Y. 2013-14 after recording reasons to believe u/s 148(2) and after obtaining approval of the competent authority. Notice u/s 148 of the Act was issued on 19.03.2020. The assessee complied ... accounts from bogus shell company without any financial rationale behind such transactions in the financial year 2012-13. Owing the same, I have reason to believe that income chargeable to tax has escaped assessment for the A.Y. 2013-14. 3. In view of the above, you may submit your response

ACIT-19(1), Mumbai vs. M Nalin & Co, Mumbai

In the result, the assessee’s cross objection No

ITA 684/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Mar 2025AY 2012-13

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeeacit-19(1), Mumbai Vs M Nalin & Co 5Th 805,8Th Floor, Prasad Chambers, 506, Floor, Piramal Chambers, Parel, Mumbai-400 Tata Road No.02, Opera House 012 Mumbai-400 004 Pan: Aaafm3223H Appellant Respondent

For Appellant: Shri Dharan GandhiFor Respondent: Shri. R.R Makwana, Addl.CIT
Section 14Section 143(1)Section 143(3)Section 147Section 148Section 250

aforesaid paragraphs, it is opined that the assessee has obtained accommodation entries during the year. Thus, after applying my mind I have reason to believe that the income of the assessee chargeable to tax for the A.Y. 2012-13 amounting to Rs. 2,54,21,032/- or any other income ... scrutiny assessment u/s 143(3) of the Act was made. Accordingly, in this case, the only requirement to initiate proceedings u/s 147 is reason to believe as mentioned above. It is pertinent to mention here that in this case the assessee has chosen not to file return of income

Zenith Barter Pvt Ltd, Mumbai vs. DCIT, CC 4(1), Mumbai

In the result, the appeals are allowed as indicated above

ITA 6617/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Mar 2025AY 2016-17

Bench: Shri Saktijit Dey, Vp & Shri Narendra Kumar Billaiya, Am

For Appellant: Shri Vinod Kumar Bindal &For Respondent: Dr. Kishor Dhule
Section 132Section 139(1)Section 143(1)Section 147Section 68

funds to the tune of Rs.50 lakhs from during the F.Y. 2010-11 relating to the A.Y, 2011-12, Thus, there is Ihan reason to believe that the assessee has escaped assessment during the A.Y. 2011-12 to the tune of Rs.50 lakhs.” 14. A careful reading of the reasons ... their bank accounts have been utilized for providing accommodation entries to various parties, including, the assessee. Thus, he has recorded that he has reason to believe that income amounting to Rs.50 lacs, representing the accommodation entries received from the aforesaid entities has escape assessment during the A.Y. 2011-12. Whereas

Zenith Barter Pvt Ltd, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, the appeals are allowed as indicated above

ITA 6616/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Mar 2025AY 2015-16

Bench: Shri Saktijit Dey, Vp & Shri Narendra Kumar Billaiya, Am

For Appellant: Shri Vinod Kumar Bindal &For Respondent: Dr. Kishor Dhule
Section 132Section 139(1)Section 143(1)Section 147Section 68

funds to the tune of Rs.50 lakhs from during the F.Y. 2010-11 relating to the A.Y, 2011-12, Thus, there is Ihan reason to believe that the assessee has escaped assessment during the A.Y. 2011-12 to the tune of Rs.50 lakhs.” 14. A careful reading of the reasons ... their bank accounts have been utilized for providing accommodation entries to various parties, including, the assessee. Thus, he has recorded that he has reason to believe that income amounting to Rs.50 lacs, representing the accommodation entries received from the aforesaid entities has escape assessment during the A.Y. 2011-12. Whereas

Zenith Barter Pvt Ltd, Mumbai vs. DCIT, CC 4(1), Mumbai

In the result, the appeals are allowed as indicated above

ITA 6615/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Mar 2025AY 2014-15

Bench: Shri Saktijit Dey, Vp & Shri Narendra Kumar Billaiya, Am

For Appellant: Shri Vinod Kumar Bindal &For Respondent: Dr. Kishor Dhule
Section 132Section 139(1)Section 143(1)Section 147Section 68

funds to the tune of Rs.50 lakhs from during the F.Y. 2010-11 relating to the A.Y, 2011-12, Thus, there is Ihan reason to believe that the assessee has escaped assessment during the A.Y. 2011-12 to the tune of Rs.50 lakhs.” 14. A careful reading of the reasons ... their bank accounts have been utilized for providing accommodation entries to various parties, including, the assessee. Thus, he has recorded that he has reason to believe that income amounting to Rs.50 lacs, representing the accommodation entries received from the aforesaid entities has escape assessment during the A.Y. 2011-12. Whereas