“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

Sssp Consultant and Techno Services Private Limited, Mumbai vs. ACIT, Mumbai

In the result, both the appeals of the assessee are allowed

ITA 717/MUM/2024[2014-15]Status: DisposedITAT Mumbai12 Feb 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri B.R. Baskaran

For Appellant: Shri Naresh JainFor Respondent: Ms. Monika H. Pande

Section 133ASection 147Section 148

Thereafter the case is assigned to this charge and Survey report is forwarded to this office. Basis of forming reasons to believe and details of escapement of income. The undersigned have gone through the documents impounded during the survey proceedings, Survey report and Return of Income filed by assessee ... worthiness of the above mentioned assessee. Therefore, the case needs to be reopened u/s. 148 of the I.T. Act, 1961. Therefore, I have reasons to believe that income to the extent of Rs. 2,62,77,250/- chargeable to tax has escaped assessment within the meaning of Section

Navjyot International Private Limied, Mumbai vs. DCIT Circle 14(1)(1), Mumbai

In the result, the appeal filed by the Assessee stands allowed

ITA 3754/MUM/2024[2012-13]Status: DisposedITAT Mumbai12 Feb 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Suchek Anchaliya, Ld. C.A. &For Respondent: Shri Preetamkumar Turerao, Ld. D.R

Section 143(1)Section 143(3)Section 148Section 250

system. Thus, assessee has not disclosed the transactions in its books of account. Therefore, based on the above facts, the undersigned have reason to believe that the income chargeable to tax to the extent of Rs. 1,84,48,800/-has escaped assessment for A.Y. 2012-13.” 3. Consequently, notice ... system. Thus, assessee has not disclosed the transactions in its books of account. Therefore, based on the above facts, the undersigned have reason to believe that the income chargeable to tax to the extent of Rs. 1,84,48,800/-has escaped assessment for A.Y. 2012-13.” 5. The Assessee

Samtel India Ltd., New Delhi vs. ACIT, Circle- 22(1), New Delhi

In the result appeal of the assessee is allowed

ITA 7101/DEL/2018[2007-08]Status: DisposedITAT Delhi12 Feb 2025AY 2007-08

Bench: Shri Vikas Awasthy & Shri Manish Agarwalasst. Cit, Samtel India Limited, Circle-22(1), 501, Copia Corporate Vs. New Delhi. Suites, District Centre Jasola, New Delhi-110025 Pan-Aaacs0390N (Appellant) (Respondent) Assessee By Shri D.C. Garg, Ca Department By Shri Sahil Kumar Bansal, Sr. Dr Date Of Hearing 04/02/2025 Date Of Pronouncement 12/02/2025 Order Per Manish Agarwal, Am: This Is Appeal Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals)-8, New Delhi (“The Cit(A)” For Short) In Appeal No.32/13-14 Dated 27/01/2015 For Assessment Year 2007-08. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. That The Learned Commissioner Of Income Tax (Appeals)-Viii, New Delhi, Has Erred In Law As Well As On Facts & In Circumstances Of The Case In Upholding Action Of The Assessing Officer In Reopening The Assessment Under Samtel India Ltd. Vs. Acit

Section 143(3)Section 147Section 148Section 154Section 250Section 37

income of the assessee. Thus this as resulted in underassessment of income by Rs. 3,69,37,000/-. I have therefore, reason to believe that an amount of Rs. 3,69,37,000/- represents income of the assessee for AY 2007-08 which has escaped assessment within the meaning

Asst. Commissioner of Income Tax, Central Circle-3(1), Hyderabad vs. B.Ramalinga Raju, Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 57/HYD/2020[2002-03]Status: DisposedITAT Hyderabad11 Feb 2025AY 2002-03

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR

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

notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped assessment, has as a matter of fact not escaped assessment, it is not open to him independently to assess some other income ... which has been urged on behalf of the assessee that section 147(1) as it stands postulates that upon the formation of a reason to believe that income chargeable to tax has escaped assessment for any assessment year, the Assessing Officer may assess or reassess such income "and also

Asst. Commissioner of Income Tax, Central Circle-3(1), Hyderabad vs. B.Ramalinga Raju, Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 55/HYD/2020[2002-03]Status: DisposedITAT Hyderabad11 Feb 2025AY 2002-03

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR

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

Raghuvir Retailers Pvt. Ltd., Kolkata vs. PCIT-2, Kolkata

In the result, the appeal of the assessee is allowed

ITA 919/KOL/2024[2013-14]Status: DisposedITAT Kolkata11 Feb 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Pcit-2 Raghuvir Retailers Pvt. Ltd. Aaykar Bhavan P-7, Mandawa Shikhar, 151, Sarat Chowringhee Square, Kolkata- Bose Road, Kolkata-700026, Vs. 700069, West Bengal West Bengal (Respondent) (Appellant) Pan No. Aaecr8231M Assessee By : Shri S.M. Surana, Ar Revenue By : Shri Subhendu Datta, Dr Date Of Hearing: 19.12.2024 Date Of Pronouncement : 11.02.2024

For Appellant: Shri S.M. Surana, ARFor Respondent: Shri Subhendu Datta, DR

Section 147Section 148Section 263Section 69A

reopen the assessment only after fulfilling the conditions laid down in the said section (section 147 of the Act) namely reason to believe that income chargeable to Raghuvir Retailers Pvt. Ltd.; A.Y. 2013-14 tax for that assessment year has escaped assessment. If this essential condition is not satisfied ... that there is in fact an escapement of income. And thereafter if he believes the existence of escapement of income then record his reason to believe escapement of income and then issue notice u/s. 148 of the Act and not before that. Let us look at the settled position

Sunita Jajoo, Surat vs. ITO Ward 2(2)(4), Surat

In the result, assessee’s appeal is allowed

ITA 882/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

code number. (d) The AO noted that assessee has claimed exemption wrongly. (e) The AO finally recorded the reasons stating that he has reason to believe that an amount of Rs.3,85,006/- has escaped assessment within the meaning of section 147 of the Act. (f) This information ... verified the information with the record available in his office and duly noted the same. (h) He has thus recorded his prima facie reason to believe that amount of Rs.3,85,006/- has escaped assessment. 19. Having gone through the entire gamut of facts and circumstances

Rambilash Rajaram Jajoo, Surat vs. Income Tax Officer Ward-2(2)(4), Surat

ITA 552/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) Rambilash Rajaram Jajoo (Physical Court Hearing) 429-432, Golden Point, Falsawadi, Ring Road, Surat City, Surat-395 002 [Pan : Aampj 0040 K] अपीलार्थी/Appellant Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 प्रत्यर्थी / Respondent आयकर अपील सं./Ita No. 882/Srt/2024 (Ay 2011-12) Sunita Jajoo 429-432, Golden Point, Near Bsnl Office, Falsawadi, Ring Road, Surat-395 002 [Pan: Aampj 0040 K] बनाम Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 अपीलार्थी/Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से /Assessee By Ms. Richa Toshniwal. Ca राजस्व की ओर से /Revenue By Shri Minal Kamble, Sr. Dr सुनवाई की तारीख/Date Of Hearing 23.01.2025 उद्घोषणा की तारीख/Date Of Pronouncement 10.02.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. These Two Appeals By Separate Assessee Are Directed Against The Separate Orders Of Addl/Jcit(A)-7, Kolkata/National Faceless Appeal Centre, Delhi [For Short To As "Nfac/Ld.Cit(A)] Dated 21.03.2024 & 21.04.2023 For Same

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

wing has a live link for formation of belief in respect of income escaped assessment. 4. In view of the above, I have reason to believe that an amount of Rs.3,85,006/- had escaped of the assessment within the meaning ... also have reason to believe that such escapement had occurred by reason of failure on the part of the assessee to disclose fully or truly material facts. In view of the above facts, I am satisfied that this is a fit case for reopening of assessment u/s.147

Asstt. Commissioner of Incomet Ax Central Circle-1(1), Nagpur vs. Shri Sanjay Gaurishankar Agrawal, Nagpur

In the result, appeal by the Revenue stands dismissed

ITA 148/NAG/2018[2015-2016]Status: DisposedITAT Nagpur10 Feb 2025AY 2015-2016

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke

Section 132(4)Section 143(3)

with the assessee. In case the Assessing Officer was of the view that this is an afterthought or for any reason he had reason to believe that such statement recorded during cross examination cannot be admissible then he had every right to re-examine Shri Bajoria, and prove that

Saraswati Mukund Education Society, Mumbai vs. Income Tax Officer Exemption, Thane, Mumbai

ITA 3316/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Feb 2025AY 2014-15

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Kiran Unavekar

Section 11Section 13Section 13(1)(c)Section 13(3)Section 144BSection 147Section 250

held that the re- assessment proceeding completed are invalid, since Ld. AO failed to provide copy of 'reasons to believe' during the 2 Assessment Year 2014-2015 course of re- assessment proceedings. Accordingly, the re- assessment proceeding so completed be kindly quashed and appropriate relief be granted in this regard ... expiry of four years from the end of the assessment year 1992-93 on 31-3-1997 unless the respondent No. 1 has reason to believe that the assessee’s income has escaped assessment by reason of the failure on the part of the assessee to disclose fully and truly

The DCIT (Int.Taxa.), Vadodara vs. Shri Ajoy Kanaiyalal Khandheria, Vadodara

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

ITA 451/AHD/2019[2014-15]Status: HeardITAT Ahmedabad10 Feb 2025AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.451/Ahd/2024 िनधा"रण वष" /Assessment Year : 2012-13 Ranjitsinh Narsinh Vaghela The Income Tax Officer बनाम/ 3337, Nr. Palaiya Mahakali Ward-3 V/S. Mandir Gandhinagar Pethapur, Gandhinagar Gandhinagar – 382 610 "थायी लेखा सं./Pan: Afepv 3269 D (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Hardik Vora, Advocate Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/01/2025 घोषणा की तारीख /Date Of Pronouncement: 15/01/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Dated 19/01/2024, For The Assessment Year (Ay) 2012-13, Which Upheld The Order Of The Assessing Officer [Hereinafter Referred To As “Ao”] Dated 30/12/2019, Passed Under Section 144 R.W.S. 147 Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act"]. Ranjitsinh Narsinh Vaghela Vs. Ito Asst. Year : 2012-13

For Appellant: Shri Hardik Vora, AdvocateFor Respondent: Shri R.N. Dsouza, CIT-DR

Section 10(37)Section 144Section 147Section 148

Section 148 was valid as the Assessing Officer (AO) obtained the necessary approval from the Principal Commissioner of Income Tax (PCIT) and had reason to believe that an income of Rs. 4,32,36,000/- had escaped assessment. Hence, the CIT(A) dismissed the objection as the reopening ... case, applicable legal provisions, and judicial precedents. As per the legal framework the Reassessment can be initiated if the AO has "reason to believe" that income chargeable to tax has escaped assessment. When reassessment is initiated after four years from the end of the relevant assessment year, it must

M/S Suncity Niketan Pvt.Ltd., Kolkata vs. Income Tax Officer, 5(1), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 2101/KOL/2024[2013-14]Status: DisposedITAT Kolkata07 Feb 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.2101/Kol/2024 Assessment Year: 2013-14 M/S Suncity Niketan Pvt. Ltd………………....….......…....………....Appellant 5, Clive Row, Kolkata -1. [Pan: Aapcs4157E] Vs. Ito, Ward-5(1), Kolkata......................................................…..…..... Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Appellant. Shri Subhendu Datta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 12, 2024 Date Of Pronouncing The Order : February 07, 2025 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 06.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Is Aggrieved By The Action Of The Ld. Cit(A) In Confirming The Addition Of Rs.17,99,28,555/- Made By The Assessing Officer By Treating Credits In The Account Of The Assessee As Income Of The Assessee From Unexplained Sources. The Assessee Apart From Challenging The Validity Of The Additions Made/Confirmed By The Lower Authorities On Merits, Has Also Contested The Very Validity Of The Reopening Of The Assessment Order As Well As The Validity Of The Assessment Order For Want Of Issue Of Notice U/S 143(2) Of The Act.

Section 143(2)Section 147Section 250

comprehensive investigation/enquiries and verification of data possessed by the department and after applying mind, the undersigned has reasons to believe that the assessee M/S. SUNCITY NIKETAN PVT. LTD. PAN: AAPCS4157E is a beneficiary to the tune of Rs.17.99.28.555/- I.T.A. No.2101/Kol/2024 Assessment Year: 2013-14 M/s Suncity Niketan ... true and full income. In view of the same, in terms of the Proviso to Section 147 of the Act, I have reason to believe that income chargeable to tax has escaped assessment by reason of the failure on the part of the assessee to disclose fully and truly

Gautam Surendra Jaggi, Mumbai vs. ACIT, 27(1)-Vashi, Mumbai

In the result, appeal of the assessee is allowed

ITA 5545/MUM/2024[2013-14]Status: DisposedITAT Mumbai07 Feb 2025AY 2013-14

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Shailesh Shah, A/RFor Respondent: Shri Pushkaraj Bhangepatil, Sr. D/R

Section 142(1)Section 147Section 148Section 68

part of the assessee to disclose fully and truly all material facts necessary for his assessment, for A.Y. 2013-14. I have reason to believe that an amount of Rs. 35,11,590/- has escaped assessment for A.Y. 2013-14, within the meaning of provisions of section ... years from end of relevant assessment year has expired in this case, the requirements to initiate proceeding u/s 147 of the Act are reason to believe that income for the F.Y. 2012-13 relevant to A.Y. 2013-14has escaped assessment because of failure on the part of the assessee

Adonis Marketing (P) Ltd., Kolkata vs. I.T.O., Ward - 9(1), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 1769/KOL/2024[2009-2010]Status: DisposedITAT Kolkata06 Feb 2025AY 2009-2010

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

were applicable prior to the amendment of section 147 of the Act w.e.f. 01.04.1989, that is firstly the Assessing Officer must have reason to believe that income, profits or gains chargeable to income tax have escaped assessment, and secondly, he must also have reason to believe that such escapement ... will be applicable post amendment of the provisions of section 147 of the Act, whereby only the first condition of Assessing Officer having reasons to believe that the income has escaped assessment confers jurisdiction upon the Assessing Officer to reopen the assessment

Mangla International Pvt Ltd, Mumbai vs. Income Tax Officer-3(2)(2), Mumbai

In the result, the appeal by the assessee for the

ITA 1913/MUM/2024[2003-04]Status: DisposedITAT Mumbai06 Feb 2025AY 2003-04

For Appellant: Revenue byFor Respondent: Date of Hearing – 12/11/2024

Section 115Section 143(2)Section 143(3)Section 144Section 147Section 148Section 250

Mangla International Pvt Ltd, Mumbai vs. Income Tax Officer-3(2)(2), Mumbai

ITA 1912/MUM/2024[2002-03]Status: DisposedITAT Mumbai06 Feb 2025AY 2002-03

For Appellant: Revenue byFor Respondent: Date of Hearing – 12/11/2024

Section 115Section 143Section 143(2)Section 144Section 147Section 148Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “J (SMC)” BENCH, MUMBAI BEFOREMs. PADMAVATHY S., ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL, JUDICIAL

Mangla International Pvt Ltd, Mumbai vs. Income Tax Officer-3(2)(2), Mumbai

ITA 1911/MUM/2024[2000-01]Status: DisposedITAT Mumbai06 Feb 2025AY 2000-01

Bench: Ms. Padmavathy S.Shri Sandeep Singh Karhail

For Appellant: Revenue byFor Respondent: Date of Hearing – 12/11/2024

Section 115Section 143(2)Section 144Section 147Section 148Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “J (SMC)” BENCH, MUMBAI BEFORE Ms. PADMAVATHY S., ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL

Mangla International Pvt Ltd, Mumbai vs. Income Tax Officer -3(2)(2), Mumbai

In the result, the appeal by the assessee for the

ITA 1910/MUM/2024[1999-2000]Status: DisposedITAT Mumbai06 Feb 2025AY 1999-2000

Bench: Ms. Padmavathy S.Shri Sandeep Singh Karhail

For Appellant: Revenue byFor Respondent: Date of Hearing – 12/11/2024

Section 115Section 143(2)Section 144Section 147Section 148Section 250

Manoj Singh Gurjar, Gwalior vs. Income Tax Officer, Ward2(2) Gwalior, Gwalior

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

ITA 322/AGR/2024[2018-19]Status: DisposedITAT Agra05 Feb 2025AY 2018-19

Bench: Shri M. Balaganesh**

For Appellant: Shri S. C. Jain, CAFor Respondent: Shri Sukesh Kumar Jain, CIT DR

Section 139Section 144Section 147Section 148Section 249(4)(b)

assessee; interest received on deposit together with cash deposits made by the assessee. Based on this information, the ld AO formed reason to believe that income had escaped assessment and reopened the assessment of the assessee. Notice u/s 148 of the Act stood issued to the assessee. In response

Kashtakar Cold Storage Private Limited, Farrukhabad vs. Income Tax Officer 4(2)(1), Farrukhabad

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

ITA 162/AGR/2024[2017-18]Status: HeardITAT Agra05 Feb 2025AY 2017-18

Bench: Shri M. Balaganesh(Through Virtual Hearing) Manoj Singh Gurjar, Vs. Income Tax Officer, H. No. 214, Gokul Vihar, Near Ward-2(2), Aastha Nagar Gate Behind In Front Gwalior Of Deen Dayal Nagar Gate, Bahadurpur, Bo Gwalior (Appellant) (Respondent) Pan: Bdfpg6465G Assessee By : Shri S. C. Jain, Ca Revenue By: Shri Sukesh Kumar Jain, Cit Dr Date Of Hearing 05/02/2025 Date Of Pronouncement 05/02/2025

For Appellant: Shri S. C. Jain, CAFor Respondent: Shri Sukesh Kumar Jain, CIT DR

Section 139Section 144Section 147Section 148Section 249(4)(b)