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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

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6211/MUM/2025[1996-97]Status: DisposedITAT Mumbai10 Feb 2026AY 1996-97

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

assess the Income which CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji Havewala he has reason to believe had escaped the assessment as against the reasons which formed the basis of Notice U/s.148. 6. The Ld.CIT appeal erred in not adjudicating the ground raised by the appellant that ... invest and or borrow $ 3 million US $ or more. A snap shot of the website is placed on record. I, therefore, have reason to believe that the assessee would not have opened the bank account unless she had invested above US S 3 Million on year to year basis. However

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6209/MUM/2025[1998-99]Status: DisposedITAT Mumbai10 Feb 2026AY 1998-99

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

assess the Income which CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji Havewala he has reason to believe had escaped the assessment as against the reasons which formed the basis of Notice U/s.148. 6. The Ld.CIT appeal erred in not adjudicating the ground raised by the appellant that ... invest and or borrow $ 3 million US $ or more. A snap shot of the website is placed on record. I, therefore, have reason to believe that the assessee would not have opened the bank account unless she had invested above US S 3 Million on year to year basis. However

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6195/MUM/2025[1996-97]Status: DisposedITAT Mumbai10 Feb 2026AY 1996-97

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

assess the Income which CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji Havewala he has reason to believe had escaped the assessment as against the reasons which formed the basis of Notice U/s.148. 6. The Ld.CIT appeal erred in not adjudicating the ground raised by the appellant that ... invest and or borrow $ 3 million US $ or more. A snap shot of the website is placed on record. I, therefore, have reason to believe that the assessee would not have opened the bank account unless she had invested above US S 3 Million on year to year basis. However

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6194/MUM/2025[2000-01]Status: DisposedITAT Mumbai10 Feb 2026AY 2000-01

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

assess the Income which CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji Havewala he has reason to believe had escaped the assessment as against the reasons which formed the basis of Notice U/s.148. 6. The Ld.CIT appeal erred in not adjudicating the ground raised by the appellant that ... invest and or borrow $ 3 million US $ or more. A snap shot of the website is placed on record. I, therefore, have reason to believe that the assessee would not have opened the bank account unless she had invested above US S 3 Million on year to year basis. However

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

In the result, the appeal filed by the revenue stands dismissed, and the cross- objection filed by the assessee is disposed of in the above terms

ITA 6193/MUM/2025[1997-98]Status: DisposedITAT Mumbai10 Feb 2026AY 1997-98

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjeei.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01

For Appellant: Shri Akshay ShahFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 144Section 250Section 271(1)(c)

assess the Income which CO NOs.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji Havewala he has reason to believe had escaped the assessment as against the reasons which formed the basis of Notice U/s.148. 6. The Ld.CIT appeal erred in not adjudicating the ground raised by the appellant that ... invest and or borrow $ 3 million US $ or more. A snap shot of the website is placed on record. I, therefore, have reason to believe that the assessee would not have opened the bank account unless she had invested above US S 3 Million on year to year basis. However

ACIT-19(3), Mumbai vs. Hoshang Manekji Havewala, Mumbai

ITA 6192/MUM/2025[1999-00]Status: DisposedITAT Mumbai10 Feb 2026AY 1999-00

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

Section 143(3)Section 144Section 250Section 271(1)(c)

appellant that the Ld.AO concluded the assessment which is bad in law as the AO did not assess the Income which he has reason to believe had escaped the assessment as against the reasons which formed the basis of Notice U/s.148. 6. The Ld.CIT appeal erred in not adjudicating

DCIT, Central Circle 7(1), Mumbai vs. Dr D Y Patil Educational Academy, Mumbai

In the result, the appeal filed by the revenue stands

ITA 3922/MUM/2025[2015]Status: DisposedITAT Mumbai10 Feb 2026

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

Section 132Section 147Section 153CSection 250Section 68

been formed. 2.4. The appellants submit that the re-opening of assessment to be successful has to be tested on the touchstone of 'reason to believe' on the basis of tangible material that income has escaped assessment. There should be a live link between the tangible material and the formation

ACIT-2(1)(1), Mumbai vs. Bank of Baroda (E- Vijaya Bank), Mumbai

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

ITA 2942/MUM/2024[2019-20]Status: DisposedITAT Mumbai10 Feb 2026AY 2019-20

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 143(2)Section 143(3)Section 250Section 292Section 41

instead of M/s. Skylight Hospitality LLP, which according to the Hon’ble High Court was a mere mistake for the reason that the reason to believe recorded by the Ld. AO, approval obtained from the Ld. PCIT, order u/s 167 of the Act and the tax evasion report etc. mentions

Bank of Baroda (Erstwhile Vijaya Bank), Mumbai vs. Assessing Officer, NFAC, New Delhi

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

ITA 2533/MUM/2024[2019-20]Status: DisposedITAT Mumbai10 Feb 2026AY 2019-20

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 143(2)Section 143(3)Section 250Section 292Section 41

instead of M/s. Skylight Hospitality LLP, which according to the Hon’ble High Court was a mere mistake for the reason that the reason to believe recorded by the Ld. AO, approval obtained from the Ld. PCIT, order u/s 167 of the Act and the tax evasion report etc. mentions

Hasmukh Ugarchand Gadhecha, HUF, Ahmedabad vs. The ITO, Ward-5(2)(2), Ahmedabad

The appeal of the assessee stands allowed

ITA 591/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.591/Ahd/2025 िनधा"रण वष" /Assessment Year : 2013-14 Hasmukh Ugarchand The Ito बनाम/ Gadhecha, Huf Ward-5(2)(2) V/S. 3Rd Floor, Anjalee House Ahmedabad – 380 015 Cg Road Navrangpura Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aaahg 7194 K (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Hargovind Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/11/2025 घोषणा की तारीख /Date Of Pronouncement: 09/02/2026 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 26/12/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2013-2014. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Hasmukh Ugarchand Gadhecha, Huf Vs. Ito Asstt.Year : 2013-14 2 “1. That The Ld.Cit(A) Erred In Law & In The Facts Of The Case In Confirming The Order Of The Ao In Reopening Assessment U/S.147 Of The Act.

For Appellant: Shri Deepak R. Shah, ARFor Respondent: Shri Hargovind Singh, Sr.DR
Section 10(38)Section 143(3)Section 147Section 148Section 153CSection 250Section 68Section 69C

Therefore, no further enquiry is required in this case. On the basis of the same there are reasons to believe that the income chargeable to tax has escaped assessment. 5. Findings of the AO: On verification from the return of income of the assessee, it is found that the assessee ... Ahmedabad for the year under consideration has escaped assessment within the meaning sec. 147 of the IT. Act. 6. Basis of forming reasons to believe and details of escapement of income: From the detailed discussion made above, it is very clear that the assessee has purchased/sold 83500 shares of Sawaca

Income Tax Officer Ward 7.2.1 Ahmedabad, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1268/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR
Section 143(1)(a)Section 148Section 250

amount of Rs 1,73,94,080/- for taxation 6. In view, of the above facts narrated in above paras, I have reason to believe that income upto the extent of Rs. 1,73,94,080/- which is chargeable to tax, has escaped assessment for the A.Y. 2013-14. within ... amount of Rs 1,81,75,577/- for taxation 6. In view, of the above facts narrated in above paras, I have reason to believe that income upto the extent of Rs.1,61,75,577/- which is chargeable to tax, has escaped assessment for the A.Y. 2013-14. within

Income Tax Officer Ward 7.2.1 Ahmedabad, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1267/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR
Section 143(1)(a)Section 148Section 250

amount of Rs 1,73,94,080/- for taxation 6. In view, of the above facts narrated in above paras, I have reason to believe that income upto the extent of Rs. 1,73,94,080/- which is chargeable to tax, has escaped assessment for the A.Y. 2013-14. within ... amount of Rs 1,81,75,577/- for taxation 6. In view, of the above facts narrated in above paras, I have reason to believe that income upto the extent of Rs.1,61,75,577/- which is chargeable to tax, has escaped assessment for the A.Y. 2013-14. within

Income Tax Officer, Ward 7.2.1, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1266/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR
Section 143(1)(a)Section 148Section 250

amount of Rs 1,73,94,080/- for taxation 6. In view, of the above facts narrated in above paras, I have reason to believe that income upto the extent of Rs. 1,73,94,080/- which is chargeable to tax, has escaped assessment for the A.Y. 2013-14. within ... amount of Rs 1,81,75,577/- for taxation 6. In view, of the above facts narrated in above paras, I have reason to believe that income upto the extent of Rs.1,61,75,577/- which is chargeable to tax, has escaped assessment for the A.Y. 2013-14. within

Choksi Ranchhodlal Kishordas, Ahmedabad vs. The Pr. CIT, Ahmedabad-1, Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 558/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: us, A.Y. 2013-14, in the case of the assessee. According to the Ld. PCIT, the reasons for which the case of the assessee was reopened was not properly inquired into by the AO and, therefore, the assessment order, according to him, was erroneous causing prejudice to the Revenue for not having made any addition on account of income which was believed to have escaped assessment in the case of the assessee. The reopening, it transpires, was resorted to on finding that the assessee had received

For Appellant: Shri Rushin Patel, ARFor Respondent: Shri Rignesh Das, CIT.DR
Section 143(3)Section 147Section 263

substantiates that there is no escapement of income and the belief formed by your goodself based in general information is not a valid reason to believe as required u/s.147 of the Act but is merely a reason to suspect on the basis of presumptions and conjectures and reopening is done

Suhas Ramesh Rao Rangadhol, Shivamogga vs. Income Tax Officer, Ward-2, Shimoga

In the result, we direct the Ld

ITA 1912/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year :2017-18 Sri Suhas Ramesh Rao Rangadhol, Seetharama Sadana, Beside Adhichunchanagiri The Income Tax Officer, Samudaya Bhavana, Ward-4, Vs. Sharavathi Nagar,Shivamogga, Shimoga. Karnataka – 577 201. Pan: Agopr8445C Appellant Respondent

For Appellant: Shri Narendra Sharma, Advocate
Section 115BSection 143(3)Section 68

expenditure debited by the Assessee on the debit side of the profit and loss account is bogus, there is no reason to believe that the amount deposited by the Assessee which is duly disclosed in the books of the account of the Assessee as sales and as well as bank

Amiben Rajeshkumar Punatar, Rajkot vs. ITO, Ward-1(2)(1), Rajkot

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

ITA 24/RJT/2026[2015-16]Status: DisposedITAT Rajkot06 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.24/Rjt/2026 िनधा"रण वष"/Assessment Year : 2015-16 Amiben Rajeshkumar Punatar, बनाम/ Ito, Ashish, 41-New Jagnath Plot, Vs Ward – 1(2)(1), Rajkot – 360001(Gujarat) Rajkot "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahrpp4181F (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR
Section 10(38)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 250

assessee under section 147 of the Act.The ld.Counsel submitted that the assessing officer was not having any material information to form "a reason to believe" that there was an escapement of income. 10. I have also gone through the reasons recorded by the assessing officer and noticed that findings

Raghavan Nambath Menon, Bengaluru vs. ITO, Ward Intl. Taxation 1(2), Bmtc Building, Koramangala, Bengaluru

In the result, I pass the following:-

ITA 278/BANG/2025[2015-16]Status: DisposedITAT Bangalore06 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: CA Suresh Muthukrishnan, A.RFor Respondent: Dr. Divya K.J., CIT D.R
Section 143(2)Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 68

deposits in Saving Bank Account & also purchased a immovable property, the total value of which were Rs.3,02,84,795/- and accordingly had reason to believe that income relatable to the investments are not explained & same has escaped assessment for the Asst. year 2015-16. The AO invoked the extended ... from the “Taxpayer profile” on the insight portal. After the amendment made in the Finance Act, 2021, there is no such concept of “reason to believe” as stated by the AO in the SCN dated 26/03/2022 for reopening of the cases u/s 147of the Act but instead it is replaced

Rahul Meka, Bengaluru vs. Income Tax Officer, Ward International Taxation-1(2), Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 813/BANG/2024[2016-17]Status: DisposedITAT Bangalore06 Feb 2026AY 2016-17

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Dr. Divya K.J – CIT(DR)(ITAT), Bangalore
Section 147Section 45Section 54Section 54FSection 68

learned assessing officer at utmost may be considered as reason to support and stretch of imagination the same cannot constitute reason to believe which is a basic ingredient for a valid assumption of re- assessment, on the facts and circumstances of the case. 3. The notice issued under section ... assessment year 2016-17 u/s 139(1) of the Act on 01/08/2016 declaring total income of Rs.15,850/-. The AO had reasons to believe that the income of the assessee chargeable to tax for the assessment year 2016-17 had escaped assessment within the meaning of section

Kuldip Kumar Goel, Delhi vs. ACIT(1)(1), Delhi

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

ITA 3285/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri Raj Kumar Chauhanand

Section 143(3)Section 144Section 147Section 148Section 149(1)Section 250

without appreciating that the TA No. 3285/Del/2025 Kuldip Kumar Goel very assumption of jurisdiction by the Ld. AO was based on an incorrect reason to believe that the Appellant is a non-PAN case. 5. On the facts and in the circumstances of the case, the NaFAC has erred ... laid procedure for causing interference in action of Ld. JAO. TA No. 3285/Del/2025 Kuldip Kumar Goel It has been averred by Appellant that ‘reason to believe’ mandate has not been fulfilled while processing the case for issuance of notice under section 148. It has been contended by appellant that

DCIT, Vikash Bhawan Delhi vs. Rajan Kumar, Laxmi Nagar, Delhi

In the result, the appeal of the Revenue appeal is dismissed and the cross objection filed by the assessee is allowed in the aforesaid manner

ITA 130/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri Sudhir Kumar & Smt. Renu Jauhridcit Vs Rajan Kumar Room No. 218-D Block, 31,Vijay Block Laxmi Vikash Bhawan, Nagar Delhi-110092 Delhi- 110 002 Pan: Caapk8381E

Section 132Section 142(1)Section 143(1)Section 147Section 148Section 69A

proceedings u/s 148 and the consequent assessment u/s 147/148 is contrary to law in the absence of any incriminating material to form reason to believe, as per the report of Investigation Wing and AO relied on, which only directs that the AO has examine the details and after this examination ... Court held that there is no independent application of mind by the AO to the tangible material which forms the basis of the reasons to believe that income has escaped assessment. The conclusive of the AO are at best a reproduction of the conclusion in the investigation report. Indeed