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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

R K Infralink LLP, Rajkot vs. ACIT, CC-1, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 528/RJT/2024[2019-20]Status: DisposedITAT Rajkot24 Feb 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Learned Counsel for the assessee, argued that reasons recorded by the assessing officer are bad in law, as there is no tangible material to reopen the assessment, therefore, reassessment proceedings may quashed. 10. On the other hand, learned DR for the revenue submitted that there were lot of unaccounted transactions ... noticed by the assessing officer from the seized material. The seized material clearly state that the income has escaped assessment, hence there were enough tangible material to reopen the assessment. Apart from this, the approval under section 151 of the Act has been taken from the competent authority, hence, reopening

DCIT, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 521/RJT/2024[2022-23]Status: DisposedITAT Rajkot24 Feb 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Learned Counsel for the assessee, argued that reasons recorded by the assessing officer are bad in law, as there is no tangible material to reopen the assessment, therefore, reassessment proceedings may quashed. 10. On the other hand, learned DR for the revenue submitted that there were lot of unaccounted transactions ... noticed by the assessing officer from the seized material. The seized material clearly state that the income has escaped assessment, hence there were enough tangible material to reopen the assessment. Apart from this, the approval under section 151 of the Act has been taken from the competent authority, hence, reopening

DCIT, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 520/RJT/2024[2021-22]Status: DisposedITAT Rajkot24 Feb 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Learned Counsel for the assessee, argued that reasons recorded by the assessing officer are bad in law, as there is no tangible material to reopen the assessment, therefore, reassessment proceedings may quashed. 10. On the other hand, learned DR for the revenue submitted that there were lot of unaccounted transactions ... noticed by the assessing officer from the seized material. The seized material clearly state that the income has escaped assessment, hence there were enough tangible material to reopen the assessment. Apart from this, the approval under section 151 of the Act has been taken from the competent authority, hence, reopening

DCIT, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 519/RJT/2024[2020-21]Status: DisposedITAT Rajkot24 Feb 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Learned Counsel for the assessee, argued that reasons recorded by the assessing officer are bad in law, as there is no tangible material to reopen the assessment, therefore, reassessment proceedings may quashed. 10. On the other hand, learned DR for the revenue submitted that there were lot of unaccounted transactions ... noticed by the assessing officer from the seized material. The seized material clearly state that the income has escaped assessment, hence there were enough tangible material to reopen the assessment. Apart from this, the approval under section 151 of the Act has been taken from the competent authority, hence, reopening

DCIT, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 518/RJT/2024[2019-20]Status: DisposedITAT Rajkot24 Feb 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Learned Counsel for the assessee, argued that reasons recorded by the assessing officer are bad in law, as there is no tangible material to reopen the assessment, therefore, reassessment proceedings may quashed. 10. On the other hand, learned DR for the revenue submitted that there were lot of unaccounted transactions ... noticed by the assessing officer from the seized material. The seized material clearly state that the income has escaped assessment, hence there were enough tangible material to reopen the assessment. Apart from this, the approval under section 151 of the Act has been taken from the competent authority, hence, reopening

Palak Designer Diamond Jewellery, Mahidharpura, Surat vs. Ld. AO, NFAC, Delhi

In the result, the appeal of the assessee for AY 2016-17 is dismissed

ITA 955/SRT/2024[2018-19]Status: DisposedITAT Surat23 Feb 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 147Section 148Section 250

ACIT Vs. Devesh Kumar vide ITA No: 2068/Del/2010 dated 31/10/2014 (Delhi High Court) 8.2 The Ld. CIT(A), however, held that there was tangible material in the form of seized printouts and statement recorded during GST proceedings. The Ld. CIT(A) therefore upheld the validity of reassessment. 8.3 Heard

Palak Designer Diamond Jewellery, Mahidharpura, Surat vs. Ld. AO, NFAC, Delhi

In the result, the appeal of the assessee for AY 2016-17 is dismissed

ITA 954/SRT/2024[2017-18]Status: DisposedITAT Surat23 Feb 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 147Section 148Section 250

ACIT Vs. Devesh Kumar vide ITA No: 2068/Del/2010 dated 31/10/2014 (Delhi High Court) 8.2 The Ld. CIT(A), however, held that there was tangible material in the form of seized printouts and statement recorded during GST proceedings. The Ld. CIT(A) therefore upheld the validity of reassessment. 8.3 Heard

Palak Designer Diamond Jewellery, Mahidharpura Surat vs. Ld. AO, NFAC, Delhi

In the result, the appeal of the assessee for AY 2016-17 is dismissed

ITA 953/SRT/2024[2016-17]Status: DisposedITAT Surat23 Feb 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 147Section 148Section 250

ACIT Vs. Devesh Kumar vide ITA No: 2068/Del/2010 dated 31/10/2014 (Delhi High Court) 8.2 The Ld. CIT(A), however, held that there was tangible material in the form of seized printouts and statement recorded during GST proceedings. The Ld. CIT(A) therefore upheld the validity of reassessment. 8.3 Heard

Kamalkumar Ramkumar Agrawal, Ahmedabad vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1975/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad23 Feb 2026AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 132Section 147Section 148Section 153CSection 69

assessee, upheld the reopening of the assessment. The CIT(Appeals) held that the information emanating from the search in the case of NODPL constituted tangible material justifying reopening under section 147 and that section 153C was not applicable as the seized documents did not belong to the assessee but were

DCIT, Central Circle 7(1), Mumbai vs. Balaji Bullions and Commodities India Private Limited, Mumbai

ITA 3915/MUM/2025[2017]Status: DisposedITAT Mumbai23 Feb 2026

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

Section 131Section 133ASection 143(1)Section 147Section 148

formed a prima facie belief that income chargeable to tax had escaped assessment. 7.2 The expression “reason to believe” postulates the existence of tangible material having a rational connection with the formation of belief regarding escapement of income. The belief must be that of a reasonable person based on relevant ... cannot be characterised as vague or non-specific or roving or fishing enquiry. The information emanating from the Investigation Wing constitutes fresh, external, and tangible material. The link between such material and the formation of belief is clearly discernible from the reasons recorded. The law does not mandate that

Balaji Bullions and Commodities India Private Limited, Mumbai vs. DCIT Central Circle 7(1), Mumbai

The appeal of the Revenue is allowed for statistical purposes

ITA 3755/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Shri Sharwan Kumar Jha, Adv
Section 133ASection 143(1)

believe” postulates the existence of The expression “reason to believe” postulates the existence of The expression “reason to believe” postulates the existence of tangible material having a rational connection with the formation of tangible material having a rational connection with the formation of tangible material having a rational connection with ... from the Investigation Wing constitutes The information emanating from the Investigation Wing constitutes The information emanating from the Investigation Wing constitutes fresh, external, and tangible material. The link between such material fresh, external, and tangible material. The link between such material fresh, external, and tangible material. The link between such

Rohitkumar Chinubhai Modi, Ahmedabad vs. The ACIT, Cir. 5(2) Now DCIT, Circle-2(1)(1), Ahmedabad

The appeal of the assessee is hereby dismissed

ITA 1961/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

cash. 10. The Commissioner of Income-tax (Appeals), after considering the submissions, upheld the reopening of the assessment. He held that there was tangible material in the form of impounded documents and admission of the purchaser which constituted sufficient reason to believe that income had escaped assessment. Relying on judicial ... only the registered consideration and not the cash component of sale consideration which, as established, formed part of the same transaction. The existence of tangible material in the form of impounded documents and the admission of the purchaser constituted sufficient reason to believe that income chargeable to tax had escaped

Saurabhbhai Rohitbhai Modi, Ahmedabad vs. The ACIT, Cir. 5(2) Now DCIT, Circle-2(1)(1), Ahmedabad

The appeal of the assessee is hereby dismissed

ITA 1960/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

cash. 10. The Commissioner of Income-tax (Appeals), after considering the submissions, upheld the reopening of the assessment. He held that there was tangible material in the form of impounded documents and admission of the purchaser which constituted sufficient reason to believe that income had escaped assessment. Relying on judicial ... only the registered consideration and not the cash component of sale consideration which, as established, formed part of the same transaction. The existence of tangible material in the form of impounded documents and the admission of the purchaser constituted sufficient reason to believe that income chargeable to tax had escaped

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1335/HYD/2025[2014-15]Status: DisposedITAT Hyderabad20 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

evidence. 3. The Learned CIT(A) ought to have fairly and judiciously appreciated the fact that the reopening was based on mere suspicion without tangible material, violating the conditions u/s 147 of the Act. 4. The Learned CIT(A) failed to appreciate the fact that the AO had failed

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1334/HYD/2025[2013-14]Status: DisposedITAT Hyderabad20 Feb 2026AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

evidence. 3. The Learned CIT(A) ought to have fairly and judiciously appreciated the fact that the reopening was based on mere suspicion without tangible material, violating the conditions u/s 147 of the Act. 4. The Learned CIT(A) failed to appreciate the fact that the AO had failed

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1333/HYD/2025[2012-13]Status: DisposedITAT Hyderabad20 Feb 2026AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

evidence. 3. The Learned CIT(A) ought to have fairly and judiciously appreciated the fact that the reopening was based on mere suspicion without tangible material, violating the conditions u/s 147 of the Act. 4. The Learned CIT(A) failed to appreciate the fact that the AO had failed

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1332/HYD/2025[2011-12]Status: DisposedITAT Hyderabad20 Feb 2026AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

evidence. 3. The Learned CIT(A) ought to have fairly and judiciously appreciated the fact that the reopening was based on mere suspicion without tangible material, violating the conditions u/s 147 of the Act. 4. The Learned CIT(A) failed to appreciate the fact that the AO had failed

ACIT-4(3)(1), Mumbai vs. Qmax Synthetics Private Limited, Mumbai

ITA 7561/MUM/2025[2012-13]Status: DisposedITAT Mumbai20 Feb 2026AY 2012-13
For Appellant: Shri Ashok BansalFor Respondent: Shri Annavaran Kosuri
Section 143(3)Section 147Section 148Section 37(1)Section 68Section 69C

independent post-search evidence received from the Directorate of Investigation after the search in the Pravin Kumar Jain group on 01.10.2013, constituting fresh tangible material for this assessment year. 3. The Ld. CITIA) erred in deleting the disallowance of interest expenditure of Rs.2,63,243/- (comprising

ACIT, CC 6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 4321/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

built test to check abuse of power by the Assessing Officer. Hence, after1.4.1989, the Assessing Officer has power to re-open, provided there is “tangible material” to come to the conclusion that there is escapement of income from assessment. Reasons must have a live link with the formation

ACIT, CC 6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 4320/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

built test to check abuse of power by the Assessing Officer. Hence, after1.4.1989, the Assessing Officer has power to re-open, provided there is “tangible material” to come to the conclusion that there is escapement of income from assessment. Reasons must have a live link with the formation