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“tangible material”

ReassessmentSection 147Section 1472,812 judgments

The decision most relied on for tangible material is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on tangible material

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.

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.

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.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

PCIT v. RMG Polyvinyl (I) Ltd.
396 ITR 5 · 2017 · High Court
272
citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

CIT v. Foramer France
264 ITR 566 · 2003 · Supreme Court
253
citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Judgments citing tangible material

Truevalue Projects Private Limited, Mumbai vs. Deputy Commissioner of Income Tax-Circle 1(3)(2), Mumbai

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

ITA 3756/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Feb 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Dy. Cit Truevalue Projects Private Circle 1(3)(2) Limited Aaykar Bhavan Office No.Ii-B, Mezzanine Floor, Vs. 289 Emca House, S.B.S Road, Maharshi Karve Road, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aacct5333Q Assessee By : Ms. Rekha Pandey, Ar Revenue By : Shri P.D. Chougule, Dr Date Of Hearing: 29.02.2024 Date Of Pronouncement : 29.02.2024

For Appellant: Ms. Rekha Pandey, ARFor Respondent: Shri P.D. Chougule, DR
Section 132Section 133(6)Section 143(3)Section 147Section 148Section 68

issued notices to the assessee. Such notices were not complied with. Therefore, reasons were recorded and the assessment is reopened. Thus, there is a tangible material and prima facie reason formed by the learned Assessing Officer does not suffer any infirmity. Further, the learned CIT (A) provided opportunity of hearing

Addl.CIT, Special Range-18, New Delhi vs. Jagananth Hemchand Jain, New Delhi

In the result, the appeal of the Revenue as well as Cross Objection of the assessee is dismissed

ITA 7755/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Feb 2024AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

Section 143(3)Section 145(3)Section 147Section 148Section 148(2)Section 69C

diamonds. The assessee had thereby claimed higher expenditure and reduced the profit it cannot be stated that the Assessing Officer did not have tangible materials to form a belief that the income chargeable to tax had escaped assessment. Such information was not available during the original assessment. Obviously the assessee ... with Kriya are sham transactions in the nature of accommodation entries. In the circumstances, it cannot be said that Assessing Officer did not have tangible material to form belief that income chargeable to tax has escaped assessment. The assessment in the instant case was earlier concluded under Section

Addl.CIT, Special Range-18, New Delhi vs. Jagananth Hemchand Jain, New Delhi

In the result, the appeal of the Revenue as well as Cross Objection of the assessee is dismissed

ITA 7754/DEL/2018[2010-11]Status: DisposedITAT Delhi29 Feb 2024AY 2010-11

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

Section 143(3)Section 145(3)Section 147Section 148Section 148(2)Section 69C

diamonds. The assessee had thereby claimed higher expenditure and reduced the profit it cannot be stated that the Assessing Officer did not have tangible materials to form a belief that the income chargeable to tax had escaped assessment. Such information was not available during the original assessment. Obviously the assessee ... with Kriya are sham transactions in the nature of accommodation entries. In the circumstances, it cannot be said that Assessing Officer did not have tangible material to form belief that income chargeable to tax has escaped assessment. The assessment in the instant case was earlier concluded under Section

Roop Kumar Chopra, Jaipur vs. PCIT Jaipur 1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 264/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Feb 2024AY 2018-19

Bench: Him By The Assessee In Compliance To The Notice Notices Issued To Him U/S 142(1) As Well As U/S 143(2) Of The Act By The Ao As Erroneous In So Far As It Is Prejudicial To The Interest Of The Revenue For The Purpose Of Section 263 Of The Act & Consequently Setting Aside The Assessment Order Passed Dated 01-01-2021 To Be Made Afresh Made Is Most Arbitrarily, Unjust, Untenable & Liable To Be Vacated.’’

For Appellant: Shri Dheeraj Borad, CAFor Respondent: Shri Ajay Malik, CIT
Section 142(1)Section 142(2)Section 143Section 143(2)Section 143(3)Section 263Section 57

order of the Assessing Officer is erroneous and that it is prejudicial to the interest of the revenue and that too, based on tangible materials on record, is impermissible rendering the resultant order void. 3. CIT Vs. Green World Corporation 314 ITR 81 (SC) The Income-tax Officer, while passing

Pnk Space Development Private Limited, Mumbai vs. Income Tax Officer, Ward 13(1)(4), Mumbai

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

ITA 3286/MUM/2023[2012-13]Status: FixedITAT Mumbai28 Feb 2024AY 2012-13

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Pnk Space Development Private Income Tax Officer, Ward 13(1)(4) Limited Mumbai 601, Purva Plaza, Shimpoli Road, Vs. Borivali West, Mumbai-400 092

For Appellant: NoneFor Respondent: Ms. Kakoli Ghosh
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148Section 245D(4)Section 250Section 32(1)(ii)Section 69C

Apex Court in the case of ITO vs. Purshottam Das Bangur 90 taxmann.com 541 (1997) held that the ld. A.O. had tangible material to believe that income chargeable to tax has escaped assessment and further relied on the 5 PNK Space Development Private Limited vs. ITO decision

Dy, Commissioner of Income Tax, Central Circle-3(4), Mumbai vs. Glint Infraporjects Private .Ltd, Mumbai

In the result, the appeal of the learned Assessing Officer and CO of the assessee, are dismissed

ITA 2166/MUM/2023[2012-13]Status: DisposedITAT Mumbai28 Feb 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Dy. Commissioner Of Income Glint Infraprojects Private Tax, Limited Central Circle 3(4), 5Th Floor, Sunteck Centre, Room No.1915, 19T Floor, Vs. 37-40 Subash Rd, Vile Parle Air India Building, (E), Mumbai-400 057 Nariman Point-400 021 (Appellant) (Respondent) Pan No. Aadcg5620L Co No. 131/Mum/2023 (Arising In Ita No.2166/Mum/2023 For A.Y. 12-13) Dy. Commissioner Of Income Glint Infraprojects Private Tax, Limited Central Circle 3(4), 5Th Floor, Sunteck Centre, Room No.1915, 19T Floor, Vs. 37-40 Subash Rd, Vile Parle Air India Building, (E), Mumbai-400 057 Nariman Point-400 021 (Appellant/ Cross Objector) (Respondent) Assessee By : Shri Gaurav Kabra, Ar Revenue By : Shri Mirza Azhar, Dr Date Of Hearing: 25.01.2024 Date Of Pronouncement : 28.02..2024

For Appellant: Shri Gaurav Kabra, ARFor Respondent: Shri Mirza Azhar, DR
Section 143(1)Section 143(3)Section 147Section 148Section 68

reopening is invalid. 014. The learned Departmental Representative submitted that there is no assessment made by the learned Assessing Officer on original return, subsequently tangible material as per the report of the DDIT was received, the learned Assessing Officer has formed prima facie reason of escapement of income and therefore ... rationale. Based on the same reasons were recorded and the notice for reopening of the assessment was issued. We find that there is a tangible material in the form of report of the investigation wing which also raised issue of the unusual transaction in the bank account of the assessee

Snr Electronics Ltd, New Delhi vs. ITO Ward - 24(1), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 937/DEL/2020[2009-10]Status: DisposedITAT Delhi28 Feb 2024AY 2009-10

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: NoneFor Respondent: Ms. Deepti Chandola, Sr. DR
Section 143Section 147Section 148Section 151Section 292CSection 68Section 69C

PCIT Vs. Paramount Communication Pvt. Ltd. 392 UR 444, Hon'ble Court has opined that the information received from Directorate constitutes the tangible material and reopening of assessment on the basis of such tangible material is valid. This is supported by Hon'ble Gujarat High Court also in the case ... which was not framed after scrutiny, the AO would have considerable latitude in issuing notice for reopening if it was found that he had tangible material to form a belief that income chargeable tax have escaped assessment. However, in the recent cases, Meenakshi Overseas P. Ltd. Vs. PCIT

ITO, Ward-35(7), New Delhi vs. Sumitra Devi, Delhi

In the result, the appeal of the Revenue stands dismissed and the Cross Objection of the assessee is partly allowed

ITA 906/DEL/2020[2010-11]Status: DisposedITAT Delhi28 Feb 2024AY 2010-11

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2010-11 & Co. No. 173/Del/2022 Asstt. Year 2010-11 Ito, Ward-35(7), Vs. Smt. Sumitra Devi, New Delhi. Plot No. 132/133, First Floor, Pocket-12, Sector-24, Rohini, Delhi-110 085. Pan Craps6145R (Appellant) (Respondent)

For Appellant: Shri Sachin Kumar, AdvocateFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 147Section 148Section 151Section 45(1)Section 45(5)(b)

processing thereof under section 143(1) of the Act is not considered; the deposit of cheque in bank is not income; there was no tangible material for ‘reason to believe’ that income has escaped assessment; notice under section 148 was not issued within the limitation period and that satisfaction recorded ... definite opinion by conducting any detailed investigation regarding escapement of income from assessment, it certainly did require to form prima facie opinion based on tangible material which provide nexus or link to having reason to believe that income escaped assessment. The Ld. AR placed reliance on the decisions of Jaipur

Hansika Jain, Jaipur vs. ITO, Ward 5(4), Jaipur

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

ITA 766/JPR/2023[2014-15]Status: DisposedITAT Jaipur27 Feb 2024AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri H.M. Singhvi (C.A.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 10(38)Section 139(1)Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 68Section 69C

erred on facts and in law in issuing notice u/s 148 on reasons which are vague and are not based on any tangible material. The AO has issued the notice mechanically on the basis of information received from Investigation Wing without proper application of mind and independent analysis. As neither

DCIT-3(1)(1), Mumbai vs. Ecgc Limited, Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 3813/MUM/2023[2016-17]Status: DisposedITAT Mumbai27 Feb 2024AY 2016-17

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Shri Vijay Mehta, A.R. a/wFor Respondent: Shri Biswanath Das, D.R
Section 10(38)Section 14ASection 234B

reopening the assessment would have to be regarded as a mere change of opinion which has also not been based on any tangible material. Consequently, we hold that the reopening of the assessment is contrary to -law. The petition would have, therefore, to be allowed.” Since the issue on hand

DCIT-3(1)(1), Mumbai vs. Ecgc Limited, Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 3812/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Feb 2024AY 2017-18

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Shri Vijay Mehta, A.R. a/wFor Respondent: Shri Biswanath Das, D.R
Section 10(38)Section 14ASection 234Section 234B

reopening the assessment would have to be regarded as a mere change of opinion which has also not been based on any tangible material. Consequently, we hold that the reopening of the assessment is contrary to -law. The petition would have, therefore, to be allowed." 26. Since the issue

Varsha Ratan Bhalwankar, Mumbai vs. ITO Ward 13(3)(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3645/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Feb 2024AY 2017-18
Section 142(1)Section 250Section 68

said contention based on mere suspicion does not hold merit. We also noticed that the revenue has not brought on record any tangible material in support of the allegation that the cash deposited during demonetization period is from any unexplained source warranting addition under section 68 of the Act. Considering

Ecgc Limited, Ecgc Bhawan vs. ACIT, New Marine Lines Mumbai

ITA 3551/MUM/2023[2016-17]Status: DisposedITAT Mumbai27 Feb 2024AY 2016-17

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Shri Vijay Mehta, A.R. a/wFor Respondent: Shri Biswanath Das, D.R
Section 10(38)Section 14ASection 234Section 234B

IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “E”, MUMBAI BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER AND MS. KAVITHA RAJAGOPAL

Ecgc Limited, Ecgc Bhawan vs. ACIT, New Marine Lines Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 3544/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Feb 2024AY 2017-18

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Shri Vijay Mehta, A.R. a/wFor Respondent: Shri Biswanath Das, D.R
Section 10(38)Section 14ASection 234B

reopening the assessment would have to be regarded as a mere change of opinion which has also not been based on any tangible material. Consequently, we hold that the reopening of the assessment is contrary to -law. The petition would have, therefore, to be allowed.” Since the issue on hand

Ecgc Limited, Ecgc Bhawan vs. National E-Assessment Centre, Delhi

In the result, all the appeals of the assessee are partly allowed

ITA 3543/MUM/2023[2018-19]Status: DisposedITAT Mumbai27 Feb 2024AY 2018-19

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Shri Vijay Mehta, A.R. a/wFor Respondent: Shri Biswanath Das, D.R
Section 10(38)Section 14ASection 234B

reopening the assessment would have to be regarded as a mere change of opinion which has also not been based on any tangible material. Consequently, we hold that the reopening of the assessment is contrary to -law. The petition would have, therefore, to be allowed.” Since the issue on hand

Ecgc Limited, Ecgc Bhawan vs. AO, New Marine Lines, Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 3542/MUM/2023[2020-21]Status: DisposedITAT Mumbai27 Feb 2024AY 2020-21

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Shri Vijay Mehta, A.R. a/wFor Respondent: Shri Biswanath Das, D.R
Section 10(38)Section 14ASection 234B

reopening the assessment would have to be regarded as a mere change of opinion which has also not been based on any tangible material. Consequently, we hold that the reopening of the assessment is contrary to -law. The petition would have, therefore, to be allowed.” Since the issue on hand

Jitesh Jitendra Sakhidas, Mumbai vs. ITO Ward 30 (1) (5), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3112/MUM/2023[2012-13]Status: DisposedITAT Mumbai27 Feb 2024AY 2012-13

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nitesh Joshi, CAFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 131Section 133ASection 143(1)Section 69B

into full and true disclosure of facts of the assessee, within the meaning of section 147. The reasons have been recorded based on the tangible material available on record and on specific information. Thus the reasons recorded for issue of notice are on reasonable foundation and constitute reasonable belief that ... established fact of the escapement of income. Attention may be drawn to the decision of the Hon, Bombay High Court on the issue of tangible material for reopening of assessment in the case of Export Credit Guarantee Corporation of India Ltd. (WP No. 502 of 2012 dated 10/11th January

Assistant Commissioner of Income Tax, Thane West vs. Konark Infrastructure Limited, Ulhasnagar

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 3088/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Feb 2024AY 2017-18

Bench: Shri Br Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No. 3025/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2017-18) Konark Infrastructure Ltd बिधम/ Dcit, Central Circle – 4 Ground Floor, Sapna 6Th Floor, Ashar It Park, Vs. Talkies, Konark Plaza, Near 16Z, Waghle Estate, Sapna Garden, Ulhasnagar Thane (W) 42100. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aabck6745L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) आयकर अपील सं/ I.T.A. No. 3088/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2017-18) Dcit, Central Circle – 4 बिधम/ Konark Infrastructure Ltd 6Th Floor, Ashar It Park, Ground Floor, Sapna Vs. 16Z, Waghle Estate, Thane Talkies, Konark Plaza, (W) Near Sapna Garden, Ulhasnagar 42100. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aabck6745L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Vijay Mehta Revenue By: Shri Biswanant Das, Cit Dr सुनवाई की तारीख / Date Of Hearing: 14/02/2024 घोषणा की तारीख /Date Of Pronouncement: 27/02/2024 आदेश / O R D E R Per Aby T. Varkey, Jm:

For Appellant: Shri Vijay MehtaFor Respondent: Shri Biswanant Das, CIT DR
Section 132Section 153A

lower authorities that these two noting’s ought to suggest payment of cash on-monies need not be correct, unless there is any tangible material available to infer these noting’s as cash payments, which in this case was not available. A.Y. 2017-18 Konark Infrastructure Ltd 9. To buttress

Konark Infrastructure Ltd, Ulhasnagar vs. DCIT Central Circle - 4, Thane

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 3025/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Feb 2024AY 2017-18

Bench: Shri Br Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No. 3025/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2017-18) Konark Infrastructure Ltd बिधम/ Dcit, Central Circle – 4 Ground Floor, Sapna 6Th Floor, Ashar It Park, Vs. Talkies, Konark Plaza, Near 16Z, Waghle Estate, Sapna Garden, Ulhasnagar Thane (W) 42100. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aabck6745L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) आयकर अपील सं/ I.T.A. No. 3088/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2017-18) Dcit, Central Circle – 4 बिधम/ Konark Infrastructure Ltd 6Th Floor, Ashar It Park, Ground Floor, Sapna Vs. 16Z, Waghle Estate, Thane Talkies, Konark Plaza, (W) Near Sapna Garden, Ulhasnagar 42100. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aabck6745L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Vijay Mehta Revenue By: Shri Biswanant Das, Cit Dr सुनवाई की तारीख / Date Of Hearing: 14/02/2024 घोषणा की तारीख /Date Of Pronouncement: 27/02/2024 आदेश / O R D E R Per Aby T. Varkey, Jm:

For Appellant: Shri Vijay MehtaFor Respondent: Shri Biswanant Das, CIT DR
Section 132Section 153A

lower authorities that these two noting’s ought to suggest payment of cash on-monies need not be correct, unless there is any tangible material available to infer these noting’s as cash payments, which in this case was not available. A.Y. 2017-18 Konark Infrastructure Ltd 9. To buttress

Ranicherra Tea Co. Ltd., Kolkata vs. ITO, Ward-4(4), Kolkata

In the result, the appeal of the assessee is allowed

ITA 609/KOL/2023[2017-18]Status: DisposedITAT Kolkata26 Feb 2024AY 2017-18

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaassessment Year: 2017-18 Ranicherra Tea Co. Ltd. Ito, Ward-4(4), Kolkata. C/O, P. K. Himatsinghka & Co. 41, B. B. Ganguly Vs. Street, Central Plaza, 2Nd Floor, Kolkata-700012. (Pan: (Appellant) (Respondent)

For Appellant: Shri P. K. Himatsinghka, ARFor Respondent: Shri Ankur Goyal, JCIT, Sr. DR
Section 143(2)Section 147Section 148Section 148ASection 151Section 153CSection 250Section 68

basis of vague, arbitrary and suspicious reasoning without attaching the report of investigation wing and without bringing any tangible material on record and without linking the assessee that Income chargeable to tax has escaped assessment. 5. For that the approval for initiation of reopening proceedings u/s.148 has not been taken