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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

DCIT, Circle-I, Ludhiana vs. Hemant Sood (HUF), Ludhiana

In the result, Revenue’s appeal is partly allowed

ITA 890/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Aug 2025AY 2015-16

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 890/Chd/2024 "नधा"रण वष" / Assessment Year : 2015-16 Deputy Commissioner Of M/S Hemant Sood Income Tax, Circle-1, बनाम (Huf), Ludhiana. H.No 417-2, Sohi Vs. Street, College Road, Ludhiana. "थायी लेखा सं./Pan No: Aadhh2051P अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By: Sh. Ashwani Kumar, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 24.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 11.08.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 24-06-2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR
Section 10(38)Section 143(3)Section 147Section 148

accordance with the procedure in law ? 890-Chd-2024 Hemant Sood (HUF), Ludhiana 5 2. When there is a tangible material and reasons to believe are recorded in detail then how can the Ld. CIT(A) state that the initiation of proceeding u/s 147 is not in accordance with ... Assessing Officer and taking approval of the specified authority within stipulated time. It is also argued by the Ld. DR that there was tangible material on record for recording reasons that the income had escaped assessment, therefore, the findings given by the Ld. CIT(A) against the reopening

Geeta, New Delhi vs. ITO Ward-2, Rohtak

In the result, the Assessee’s appeal is allowed in the aforesaid manner

ITA 3716/DEL/2025[2016-17]Status: DisposedITAT Delhi11 Aug 2025AY 2016-17

Bench: Shri Mahavir Singha.Yr. : 2016-17 Geeta Ito, Ward-2, Rohtak B-50, Lgf, South Extension-Ii, Vs. New Delhi – 49 (Pan: Aaypg9406A) (Appellant) (Respondent)

For Appellant: Shri Shantanu Jain, Adv. &For Respondent: Shri Sangeet Bansal, Sr. DR
Section 147Section 148Section 151

mind by the AO. 1.5 That the impugned order passed u/s. 147/148 of the Act is bad in law as no new fresh / tangible material has come to the knowledge of the AO. 1.6 That the reopening of the assessment is bad in law for the reason that the sanction ... same may be confirmed. 6. I have heard rival contentions and perused the relevant records. 6.1 It transpires from records, that there is no tangible material, which is a pre-condition, available with the AO to allege the escapement of income, the reopening tantamount to only review of original assessment

Sumit Suneja, Delhi vs. Assistant Commissioner of Income Tax, Circle 34(1), Delhi

In the result, the Assessee’s appeal is allowed in the aforesaid manner

ITA 3688/DEL/2025[2011-12]Status: DisposedITAT Delhi11 Aug 2025AY 2011-12

Bench: Shri Mahavir Singha.Yr. : 2011-12 Sumit Suneja, Vs. Acit, Circle 34(1), H-34, Pocket-17, Sector-3, Rithala, New Delhi Rohini, Delhi – 85 (Pan: Aaypg9406A) (Appellant) (Respondent)

For Appellant: Shri Suregsh Gupta, CAFor Respondent: Shri Sangeet Bansal, Sr. DR
Section 144Section 147Section 148Section 151

power to reopen the assessment u/s. 147 provided that Assessing Officer has reason to believe that income has escaped assessment and there is tangible material to come to the conclusion that there is escapement of income; mere change of opinion may not per se to be a reason for reopening

Udhavrao Raghunath Kharate, Aurangabad vs. ITO Ward-1(1), Aurangabad

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

ITA 1470/PUN/2025[2011-12]Status: DisposedITAT Pune08 Aug 2025AY 2011-12

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1470/Pun/2025 निर्धारण वषा / Assessment Year: 2011-12 Udhavrao Raghunath Kharate, V The Income Tax Officer, 220/1, Raghunandini Niwas, S Ward-1(1), Aurangabad. Near Bsnl Tower, At Post Maniknagar, Teh. Sillod District, Aurangabad – 431135. Pan: Apupk3432R Appellant/ Assessee Respondent / Revenue Assessee By Shri Ramesh N. Thete –Ar(Virtual) Revenue By Shri Ajay D. Kulkarni – Addl.Cit(Dr) Date Of Hearing 06/08/2025 Date Of Pronouncement 08/08/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(A)-1, Gurugram Passed Under Section 250 Of The Income Tax Act, 1961 Dated 24.04.2025 For The A.Y.2011-12 Emanating From The Assessment Order Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961, Dated 05.12.2018. Ita No.1470/Pun/2025 [A] Submission Of Ld.Ar :

Section 143(3)Section 147Section 250Section 44ASection 68

Bagasse, and this fact was within the knowledge of the AO even at the time of reopening. Mere deposit of cash, without any further tangible material indicating escapement of income, does not constitute "reason to believe" within the meaning of Section 147. Thus, the reopening

Daya Shanker Tiwari, Hyderabad vs. Income Tax Officer, Ward-6(1), I T Tower, Hyderabad

In the result, appeal of the assessee is allowed

ITA 827/HYD/2025[2017-18]Status: DisposedITAT Hyderabad08 Aug 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, K A Sai PrasadFor Respondent: Shri Vinod Kannan, Sr. AR
Section 143(3)Section 147Section 148Section 69A

lakhs in the assessment order section 143(3) of the Act. Further, the assessment has been reopened on very same issue without any fresh tangible material came to the possession of the Assessing Officer subsequent to the completion of original assessment, which amounts to ‘change of opinion’ and thus ... income, on the basis of very same information, which was available during the course of original assessment proceedings without there being any fresh tangible material. In absence of fresh tangible material, formation of belief of escapement of income, in our considered view, is a ‘change of opinion’ on the basis

Tushar Enterprises, Goregaon East, Mumbai vs. Jurisdictional Assessing Officer, Kautilya Bhavan, Bkc, Bandra East Mumbai

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

ITA 2542/MUM/2024[2011-12]Status: DisposedITAT Mumbai08 Aug 2025AY 2011-12

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailtushar Enterprises, 2-A/401-402 Dheeraj Valley, Mohan Gokhale Road, Saibaba Complex, Goregaon East, Mumbai ............... Appellant Maharahstra - 400063 Pan : Aaaft1242R V/S Income Tax Officer, ……………… Respondent Ward – 41(4)(4), Kautilya Bhavan, Bkc, Bandra East, Mumbai-400051 Assessee By : Shri Sanjay Shah, Ca Revenue By : Shri Asif Karmali, Sr.Dr

For Appellant: Shri Sanjay Shah, CAFor Respondent: Shri Asif Karmali, Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 50C

recording the reasons. Therefore, in the present case, we are of the considered view that the information received by the AO constitutes new and tangible material for initiating the reassessment proceedings. As a result, we find no infirmity in the reassessment proceeding initiated by the AO under section

Assistant Commissioner of Income Tax (Central Circle), Bareilly vs. Varunarjun Trust, Lucknow

In the result, both the appeals are dismissed

ITA 620/LKW/2024[2016-17]Status: DisposedITAT Lucknow07 Aug 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

there was any failure on the part of the assessee to disclose all the materials fully and truly for the purposes of assessment. No tangible material for the formation of belief that income have escaped assessment has been provided to the assessee that were requested vide submission filed

Assistant Commissioner of Income Tax, Central Circle, Bareilly vs. Varunarjun Trust, Lucknow

In the result, both the appeals are dismissed

ITA 619/LKW/2024[2015-16]Status: DisposedITAT Lucknow07 Aug 2025AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

there was any failure on the part of the assessee to disclose all the materials fully and truly for the purposes of assessment. No tangible material for the formation of belief that income have escaped assessment has been provided to the assessee that were requested vide submission filed

Mukesh Jain HUF, Jaipur vs. DCIT, Jaipur

In the result, the appeal of the assessee is allowed

ITA 620/JPR/2025[2010-11]Status: DisposedITAT Jaipur06 Aug 2025AY 2010-11

Bench: Reopening The Assessment & Without Independent Application Of Mind. Thus, The Action Of The Ld. Ao In Reopening The Assessment U/S 148 & The Consequent Reassessment Order So Passed Deserves To Be Held Bad In Law.

For Appellant: Sh. Tarun Mittal, CAFor Respondent: MS. Alka Gautam, CIT-DR
Section 143(3)Section 147Section 148Section 68

Supreme Court ruled that the sufficiency of reasons cannot be questioned as long as there is tangible material indicating escapement of income. Given that the AO had concrete information regarding CCM transactions and it has been shared after due and detailed examination of modus-operandi adopted in this case ... opinion that the assessment cannot be reopened validly on the basis of the above reasons recorded in absence of any tangible material to infer that income escaped in the case of the assessee. We, accordingly, quash the reassessment proceedings and set aside the order of the Learned

Deputy Commissioner of Income Tax, Jaipur vs. Bharat Spun Pipe and Construction Company, Jaipur

In the result the appeal of the revenue in ITA no

ITA 360/JPR/2025[2017-18]Status: DisposedITAT Jaipur06 Aug 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Ms. Alka Gautam, (CIT) (V.C.)
Section 144BSection 147Section 148Section 148ASection 153C

that assessee was beneficiary of accommodation entries but no further inquiry was undertaken by Assessing Officer, said information could not be said to be tangible material per se and, thus, reassessment on said basis was not justified. In case of PCIT vs. Meenakshi Overseas (P.) Ltd. [2017] 82 taxmann.com ... basis of information from DIT(Investigation) that assessee had received accommodation entry and there was no independent application of mind by Assessing Officer to tangible material and reasons failed to demonstrate link between tangible material and formation of reason to believe that income had escaped assessment, reassessment was not justified

Jajoo Rashmi Refractories Limited, Jaipur, Rajasthan vs. DCIT, Circle 4-Jaipur, Jaipur, Rajasthan

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

ITA 209/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 Aug 2025AY 2018-19
For Appellant: Ms. Prabha Rana, AdvocateFor Respondent: Shri Gaurav Awasthi, JCIT-DR
Section 131Section 145Section 147Section 69C

formation of the belief was missing. In support of the AR's contention that the information received from the Investigation Wing cannot constitute tangible material for re-opening the assessment without the Assessee being informed what in the report of the investigation wing constituted tangible material for forming a belief ... formation of the belief was missing. In support of the AR's contention that the information received from the Investigation Wing cannot constitute tangible material for re-opening the assessment without the Assessee being informed what in the report of the investigation wing constituted tangible material for forming a belief

Deputy Commissioner of Income -Tax, Central Circle-1(2), Ahmedabad vs. Goyal and Co. (Const.) Private Limited., Ahmedabad

ITA 1836/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad06 Aug 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1836/Ahd/2024 िनधा"रण वष" /Asst.Year 2016-17 The Dcit Goyal & Co. (Const.) Private बनाम/ Central Circle-1(2), Limited V/S. Ahmedabad – 380 009 10Th Floor Commerce House Iv Beside Reliance Petrol Pump 100Ft. Road, Satellite Ahmedabad – 380 015 अपीलाथ'/ (Appellant) !( यथ'/ (Respondent) .. & Cross Objection No.42/Ahd/2024 - िनधा"रण वष" /Ay 2016-17 (In Ita No.1836/Ahd/2024 – Ay 2016-17) V/S. Goyal & Co. (Const.) Private The Dcit Limited Central Circle-1(2), 10Th Floor,Commerce House Iv Ahmedabad – 380 009 Beside Reliance Petrol Pump 100Ft. Road, Satellite Ahmedabad – 380 015 Pan: Aabcg 5459 R (Cross Objector) .. (Respondent)

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Kavan Limbasiya, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148Section 69

books. The AO had recorded reasons based on seized material and obtained necessary sanction under section 151. It was held that there was tangible material and live link justifying reopening under section 147. Accordingly, this ground was dismissed by the Ld.CIT(A). 7.3. On merits, the assessee submitted that

Siva Mohan Reddy Parvathreddy, Hyderabad vs. DCIT, Central Circle-3(2), Hyderabad

ITA 199/HYD/2025[2015-16]Status: DisposedITAT Hyderabad06 Aug 2025AY 2015-16

Bench: Us:

Section 131Section 132Section 143(2)Section 153A

erroneous and is liable to be quashed. 4 The Ld. CIT(A) ought to have observed that there is no tangible material or documentary evidence to corroborate the addition made by the AO for Rs.57,50,000/- and the same is liable for deletion. 5. The learned CIT(A) ought

ITO 41(3)(1), Mumbai vs. Deepika Anil Agarwal, Mumbai

In the result the appeal filed by the revenue stands

ITA 1885/MUM/2025[2011-12]Status: DisposedITAT Mumbai06 Aug 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawal

Section 10(38)Section 132Section 132(4)Section 143Section 147Section 148Section 263Section 68

credit, from the material facts on record were quite evident that it was from the sale of shares. As there was no tangible material brought on record to controvert these transactions, therefore the same cannot be treated as unexplained cash credit to be added under deeming provisions of section ... credit, from the material facts on record were quite evident that it was from the sale of shares. As there was no tangible material brought on record to controvert these transactions, therefore the same cannot be treated as unexplained cash credit to be added under deeming provisions of section

Rajendra Kumar Mundra (HUF), Mumbai vs. National Faceless Assessment Centre (NFAC), Delhi

In the result the appeal filed by the assessee stands allowed

ITA 1000/MUM/2024[2016-17]Status: DisposedITAT Mumbai06 Aug 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawalrajendra Kumar Mundra Vs. Ito, Ward 24(3)(1) (Huf) Piramal Chamber C-28, Ameya Bldg, Behind Lalbaug, Mumbai – Ymca Dn Nagar Andheri (W) 400012. 400053. Pan/Gir No.Aadh6828J (Applicant) (Respondent)

Section 147Section 148Section 2Section 263Section 68Section 69A

Rajendra Kumar Mundra (HUF)., Mumbai. material facts on record were quite evident that it was from the sale of shares. As there was no tangible material brought on record to convert these transactions then it is very difficult to treat the sale proceeds of the shares as unexplained cash credit ... credit, from the material facts on record were quite evident that it was from the sale of shares. As there was no tangible material brought on record to convert these transactions then it is very difficult to treat the sale proceeds of the shares as unexplained cash credit

Ultra Modern Exports Pvt. Ltd., New Delhi vs. ITO Ward - 27(1), New Delhi

ITA 527/DEL/2020[2011-12]Status: DisposedITAT Delhi06 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 68

accommodation entries warranting addition as unexplained cash credit under section 68 of the Act. This goes to prove that there is absolutely no tangible material available with the Learned AO which would have a live link to form a belief that income of the assessee had escaped assessment warranting reopening ... assessment had been made merely on borrowed satisfaction of the investigation wing of Mumbai vide letter dated 16-3-2018 and without having any tangible material. It is trite law that the reasons for formation of belief for reopening an assessment must have a rational , intimate and direct connection

Goel Jewellery & Mart P. Ltd., New Delhi vs. ITO, Ward- 10(2), New Delhi

In the result, appeal of the assessee is partly allowed as indicated above

ITA 6686/DEL/2017[2007-08]Status: DisposedITAT Delhi06 Aug 2025AY 2007-08

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Shri Satyen Sethi, Adv. &For Respondent: Shri Om Parkash, Sr. DR
Section 147Section 68

That on the facts and circumstances of the case and in law, the CIT(A) did not appreciate that neither there was any tangible material to reopen the assessment nor there was application of mind to the information received. 2.2 That on the facts and circumstances of the case ... erroneously upheld the assumption of jurisdiction under section 147 of the Act by ignoring the fact that there was neither any tangible material to reopen the assessment nor there was any application of mind to the information received and approval in question is quite mechanical in nature, as raised ground

Jay Prabhudas Vithalani, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

In the result, both the appeals of the same assessee (ITA No

ITA 75/RJT/2025[2021-22]Status: DisposedITAT Rajkot05 Aug 2025AY 2021-22

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 75/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudas Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat-361001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent) आयकर अपीलसं./Ita No.74/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) Khushaboo Jaykumar Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Lal Wadi Main Road, Kaushal Nagar, Gujarat - 361110 स्थायी लेखासं . / जी आइआरसं . / Pan/Gir.: Aefpv6723A (Appellant) (Respondent) Appellant By Respondent By Date Of Hearing Date Of Pronouncement : Shri Sagar Shah, Ld. Ar : Shri Sanjay Kumar, Ld. Cit(Dr) : 19/06/2025 : 05/08/2025 आदेश / Order Per Dinesh Mohan Sinha, Jm: Captioned Two Appeals Filed By The Different Assessee, Pertaining To Assessment Year (Ay) – 2021-22, Are Directed Against The Separate Order Passed By The Principal Commissioner Of Income Tax [(In Short "Ld. Pr.Cit”] U/S. 263 Of The Act, Both Orders Dated 24.01.2025. 2. Since, These Two Appeals Filed By The Different Assessee For Same

Section 263

Insurance Co Ltd. (2010) 325 ITR 471 (Bom), it was held that, "Reopening of assessment on the same ground in the absence of any tangible material was based on mere change of opinion and therefore is not sustainable." Hence, based on the above-mentioned judicial pronouncements, in the absence

Khushboo Jaykumar Vithlani, Jamnagar vs. The Principal Commissioner of Income Tax, Jamnagar

In the result, both the appeals of the same assessee (ITA No

ITA 74/RJT/2025[2021-22]Status: DisposedITAT Rajkot05 Aug 2025AY 2021-22

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 75/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudasvithlani Vs. The Principal Commissioner Of 201, Varajresidency, 8 – Patel Colony, Income Tax, Gujarat – 361008 Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent)

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Sanjay Kumar, Ld. CIT(DR)
Section 263

Insurance Co Ltd. (2010) 325 ITR 471 (Bom), it was held that, "Reopening of assessment on the same ground in the absence of any tangible material was based on mere change of opinion and therefore is not sustainable." Hence, based on the above-mentioned judicial pronouncements, in the absence

Dhanji Murji Hirani, Kutch vs. ITO.(Int.Txn)Gandhidham, Gandhidham

In the result, the appeal of the assessee is allowed

ITA 131/RJT/2025[2019-20]Status: DisposedITAT Rajkot05 Aug 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.131/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2019-20 Dhanji Murji Hirani, Baladia Ito (Int.Txn), बनाम Bhuj, Kutch, Gandhidham Gujarat 370427 Vs. Pan : Afaph0463B (अपीलाथ"/Appellant) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr

For Appellant: Shri Kalpesh Doshi, ld.ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 115BSection 127Section 139Section 147Section 148Section 148ASection 234ASection 271ASection 69

reasons and is convinced that the case is fit for Dhanji Murji HIrani ITA No.131 /RJT/2025 (AY : 2019-20) 8 the reopening without having tangible material on hand and merely by relying on third party information. The snap shot of para 22 from the approval is enclosed hereunder: 22. Reasons