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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

Ravinder Baweja, New Delhi vs. ITO Ward 36(2), New Delhi

In the result, these appeals are allowed as indicated above for

ITA 2254/DEL/2019[2015-16]Status: DisposedITAT Delhi21 Aug 2024AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Rikky Dua, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 143Section 143(2)Section 143(3)Section 144Section 148Section 151Section 250(6)

information received from investigation wing. It is submitted a power to reopen would vest in the Assessing Officer only if, there is tangible material in his possession for coming to a conclusion that there was an escapement of income chargeable to tax, from assessment and the reasons with the Assessing

Decent Industries P. Ltd., Bhopal vs. ITO-1(2), Bhopal

Appeal is partly allowed

ITA 356/IND/2023[2012-13]Status: DisposedITAT Indore20 Aug 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2012-13 M/S Decent Industries Ito-1(2), Private Ltd, Bhopal 5Th Floor, Corporate Park, बनाम/ Db City Area Hills, Vs. Opp. M.P. Nagar Zone I, Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aaeca6271G Assessee By Ms. Shilpa Gupta & Shri N.K. Gupta Revenue By Shri V.K. Singh, Cit-Dr Date Of Hearing 04.06.2024 Date Of Pronouncement 20.08.2024

Section 133ASection 143(2)Section 147Section 148Section 14ASection 68

relevant. He submitted that the AO has made addition on the basis of mere surmises and conjectures without having any iota of tangible material to establish that the transactions are not genuine. 16. We have considered rival contentions of both sides and perused the orders of lower-authorities as well ... submitted that the addition made by the AO is based on surmises and conjectures and without having any tangible material to show that the transaction is not genuine. Page 31 of 44 M/s Decent Industries Pvt. Ltd ITA No. 356/Ind/2023 – AY 2012-13 2.4 We have considered the rival submissions

Indra Kumar Narwani, Jaipur vs. ITO WD 5(3), Jpr, Jaipur

In the result, the appeal of the assessee is allowed with no orders as to costs

ITA 564/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 Aug 2024AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvocateFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 131Section 132(4)Section 133Section 133ASection 143(3)Section 69Section 69A

estimation or extrapolation of income is not permissible unless there are strong evidences to suggest otherwise. The additions are to be based solely on tangible material and not on the basis of estimations or extrapolation theory. This principle supports the case of the assessee." Hence, in view of the entirety

Manohar Lal Chugh, Jaipur vs. ITO, Ward 6(1), Jaipur

In the result, the appeal of the assessee is allowed with no order as to costs

ITA 505/JPR/2023[2011-12]Status: DisposedITAT Jaipur20 Aug 2024AY 2011-12

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sanjay Godha, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 10(38)Section 147Section 68Section 69C

capital gains to large number of beneficiaries in lieu of unaccounted cash. These observations of the AO in the assessment order cannot constitute any tangible material or evidence to show that the 5 MANOHAR LAL CHUGH VS ITO, WARD 6(1) , JAIPUR transaction of the assessee is bogus being ... made simply on the basis of statement alone. The same has to be substantiated and corroborated either by enquiries or by linking it with tangible material/ evidence. It is a settled law that statement, that too of 3rd person, alone cannot be treated as incriminating material for the purposes

Aarna Infrazone Pvt. Ltd., Noida vs. Pr, CIT, Noida

In the result, the impugned order is upheld and appeal of the assessee is dismissed

ITA 1208/DEL/2024[2013-14]Status: DisposedITAT Delhi20 Aug 2024AY 2013-14

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

For Appellant: S/Shri S Krishnan, and V. Rajkumar, AdvocatesFor Respondent: Ms. Neha Chaudhary, CIT-DR
Section 132Section 142(1)Section 147Section 263

assessee nor has it been made part of satisfaction note which lists the reasons for reopening. The said master sheet was crucial and tangible material for recording reasons to believe for reopening of assessment. Nevertheless, the assessee furnished all the relevant material to substantiate that the payments made to celebrations

Rajesh Khanna, Neelkanth Plywood, Yamunanagar vs. Income Tax Officer, Ward-3, Yamunanagar

In the result, the assessee's appeal in ITA

ITA 62/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh19 Aug 2024AY 2018-19

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Goel, CAFor Respondent: Shri Dharam Vir, JCIT Sr.DR
Section 148Section 69A

dated 05.09.2022, the assessee again requested the AO to provide the following documents to the assessee ; a. Please provide the copy of tangible material related to information of Rs. 2,74,58,591 /- being tally data and impounded material of Shiv Shankar Plywood group. b. Please inform

Income Tax Officer, Yamuna Nagar vs. Rajesh Khanna, Yamuna Nagar

In the result, the assessee's appeal in ITA

ITA 230/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh19 Aug 2024AY 2018-19

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Goel, CAFor Respondent: Shri Dharam Vir, JCIT Sr.DR
Section 148Section 69A

dated 05.09.2022, the assessee again requested the AO to provide the following documents to the assessee ; a. Please provide the copy of tangible material related to information of Rs. 2,74,58,591 /- being tally data and impounded material of Shiv Shankar Plywood group. b. Please inform

ACIT-2(1)(1), Mumbai vs. Amalfi Realty Pvt. Ltd., Mumbai

ITA 888/MUM/2024[2015-16]Status: DisposedITAT Mumbai19 Aug 2024AY 2015-16

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri Ajay Chandran (CIT-DR)For Respondent: Shri Mihir Naniwadekar
Section 143(3)Section 148Section 151Section 56(2)(viib)

thus there was no failure on the part of the assessee to disclose fully and truly any material facts nor there was any tangible material with the AO which would justify the re-opening. 7 Amalfi Realty Pvt. Ltd. 12. It is not necessary to multiply authorities on the point

Ranjay Developers Private Limited, Mumbai vs. ITO-14(3)(1), Mumbai

In the result, the appeal of the assessee is restored back to the file of the learned Assessing Officer with the direction to the assessee to furnish the necessary details before the Assessing

ITA 308/MUM/2024[2011-12]Status: DisposedITAT Mumbai19 Aug 2024AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shrisunil Kumar Singh, Jm A.Y.2011-12

Section 143Section 143(1)Section 143(2)Section 147Section 148Section 153Section 68

Officer, National Faceless Assessment Centre, Delhi, The AO erred reopening the assessment of the appellant under section 147 of the assessment without fresh tangible material . The A erred in reopening application of mind and without having valid reason to believe that income had escaped assessment simply on the basis ... from M/s. Empower Industries Ltd. The assessee filed its return of income, which was not picked up for scrutiny, therefore, the ld. AO had tangible material and reason to believe that the income has escaped assessment. The Assessing Officer applied his mind A Y : 2011–12 Ranajay Developers

Jain Machine Tools, Mumbai vs. Income Tax Officer, Ward 26(1)(7), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2110/MUM/2024[2012-13]Status: DisposedITAT Mumbai19 Aug 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2012-13 Jain Machine Tools, Ito, Ward 26(1)(7), 16, Meghal Industrial Estate, Room 625, 6Th Floor, Kautilya Vs. Devidayal Road, Mulund (West) Bhavan, C-41 To C-43, G Block, Mumbai-400080. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan No. Aacfj 6163 H Appellant Respondent

For Appellant: Ms. Rajeshwari Menon, Sr. DRFor Respondent: Mr. Devendra Jain
Section 143(3)Section 147Section 148

proceedings u/s 147 of the Act without being initiating the reassessment proceedings u/s 147 of the Act without being in possession of any fresh tangible material after completion of the first in possession of any fresh tangible material after completion of the first in possession of any fresh tangible material ... support of ground No. 4, He In support of ground No. 4, He submitted that there was no submitted that there was no afresh tangible material available with the Assessing Officer for afresh tangible material available with the Assessing Office afresh tangible material available with the Assessing Office reopening

DCIT-191, Mumbai vs. Bhavin P Mehta, Mumbai

In the result, the appeal of the revenue is partly allowed for statistical purposes

ITA 4689/MUM/2023[2012]Status: DisposedITAT Mumbai19 Aug 2024

Bench: Shri Om Prakash Kant, Am & Shri Sunil Kumar Singh, Jm

For Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 132Section 132(4)Section 143

that while framing the present re- assessment the Ld. AO failed to appreciate that the present re-assessment has been initiated without any new tangible material information coming into the possession of the AO, based on the very same facts already on record on the basis of which the original

Pareshkumar Punamchand Shah, Ahmedabad vs. The Income Tax Officer, Ward-2(2)(4), Ahmedabad

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

ITA 1096/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad16 Aug 2024AY 2011-12

Bench: Shri Ramit Kochar (Accountant Member)

For Appellant: CA Preyashi TatedFor Respondent: Shri Hrishikesh Hemant Patki, Sr. D.R
Section 144Section 250Section 253(3)

conclusive proof of income escaping assessment is not required rather a prima-facie formation of a belief of the AO is required based on tangible material having live link/nexus with the formation of belief that the income of the assessee has escaped assessment. The said reasons to believe that income ... considered view, the AO has rightly invoked provisions of Section 147/148 of the 1961 Act. Existence of reasons to belief by way of tangible material and its live link/nexus with formation of belief by the AO that income of the assessee has escaped assessment is relevant, and not the sufficiency

Krishna Murthy Ella, Hyderabad vs. DCIT-Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 585/HYD/2023[2014-15]Status: DisposedITAT Hyderabad14 Aug 2024AY 2014-15

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.585/Hyd/2023 & Sa No.10/Hyd/2024 (Arising Out Of Ita No.585/Hyd/2023) (िनधा"रण वष"/Assessment Year: 2014-15) Shri Krishna Murthy Ella Vs. Dy. C. I. T. Hyderabad Circle 1(2) Pan:Aacpe6389G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 18/07/2024 घोषणा की तारीख/Pronouncement: 14/08/2024 आदेश/Order

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Smt. Sheetal Sarin, DR
Section 147Section 148Section 56(2)(vii)

from reasons for reopening of the assessment where the Assessing Officer has formed reasonable belief of escapement of income on the basis of fresh tangible material which is information received from the Assessing Officer of M/s. Bharat Biotech International Ltd where it was noticed that the number of shares held ... Before initiating proceedings u/s 147 for re-assessment of any income, escapement of income should be proved and such escapement is based on fresh tangible material come to the possession of the Assessing Officer. In other Page

Sri Ukkandath Dileepan, Uroob Nagar, Palapram vs. ACIT(OSD)International Taxation, Kozhikode

ITA 99/COCH/2024[2011-12]Status: DisposedITAT Cochin14 Aug 2024AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.C.Venugopal, AdvocateFor Respondent: Smt.V.Swarnalatha, Sr.DR
Section 143(3)Section 147Section 148

para 2 supra, it is evident that the AO had sufficient reason to believe that the appellant's income had escaped assessment. The tangible material brought on record by the AO is the fact that information was available with the AO regarding the investment made by the appellant

Ukkandath Dileepan, Pallapuram vs. ITO International Taxation, Calicut

ITA 101/COCH/2024[2013-14]Status: DisposedITAT Cochin14 Aug 2024AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.C.Venugopal, AdvocateFor Respondent: Smt.V.Swarnalatha, Sr.DR
Section 143(3)Section 147Section 148

para 2 supra, it is evident that the AO had sufficient reason to believe that the appellant's income had escaped assessment. The tangible material brought on record by the AO is the fact that information was available with the AO regarding the investment made by the appellant

Hindustan Marble & Granite, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1091/BANG/2024[2020-21]Status: DisposedITAT Bangalore13 Aug 2024AY 2020-21

Bench: Shri Chandra Poojari & Shri Keshav Dubeyhindustan Marble & Granite Dcit, Central Circle-1(4) Regd. Office: No.5, Lalbagh- Cr Building, Queens Rod Hosur Road, Wilson Garden Vs. Bengaluru 560001 Bangalore 560027 Pan – Aaafh8437Q (Appellant) (Respondent) Assessee By: Shri Narendra Sharma, Advocate Revenue By: Shri V. Parithivel, Jcit-Dr Date Of Hearing: 08.08.2024 Date Of Pronouncement: 13.08.2024 O R D E R Per: Keshav Dubey, J.M.

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri V. Parithivel, JCIT-DR
Section 143(3)Section 250Section 282

underlying addition was made on adhoc basis in as much the stock value was increased at flat rate of 27% without there being any tangible materials. 15. The Ld. AO erred in the order by holding that the present method of stock valuation does not account the direct costs

Andimuthu Raja, Perambalur vs. ACIT, Circle 1(1), Tiruchirapalli

The appeals stand allowed

ITA 262/CHNY/2024[2010-11]Status: DisposedITAT Chennai12 Aug 2024AY 2010-11

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं./ Ita No.261/Chny/2024 (िनधा*रणवष* / Assessment Year: 2006-07) & 2. आयकरअपील सं./ Ita No.262/Chny/2024 (िनधा*रणवष* / Assessment Year: 2010-11) Shri Andimuthu Raja Acit बनाम/ 3/127, Ambedkar Street, Velur Post Circle-1(1) Vs. Perambalur-621 104. Tiruchirapalli. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adtpr-2755-B (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Y.Sridhar (Fca)-Ld.Ar " थ"कीओरसे/Respondent By : Ms.R.Anita (Addl.Cit) -Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 01-08-2024 घोषणाकीतारीख /Date Of Pronouncement : 12-08-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Y.Sridhar (FCA)-Ld.ARFor Respondent: Ms.R.Anita (Addl.CIT) -Ld. Sr. DR
Section 143Section 143(3)Section 147Section 148

that there was any failure on the part of the assessee to furnish true particulars of income. Further, there is no tangible material before Ld. AO to reopen the case of the assessee. Therefore, there is no valid ground to initiate reassessment proceedings. The issue of STCG has already been

Andimuthu Raja, Perambalur vs. ACIT, Circle 1(1), Tiruchirapalli

The appeals stand allowed

ITA 261/CHNY/2024[2006-07]Status: DisposedITAT Chennai12 Aug 2024AY 2006-07

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं./ Ita No.261/Chny/2024 (िनधा*रणवष* / Assessment Year: 2006-07) & 2. आयकरअपील सं./ Ita No.262/Chny/2024 (िनधा*रणवष* / Assessment Year: 2010-11) Shri Andimuthu Raja Acit बनाम/ 3/127, Ambedkar Street, Velur Post Circle-1(1) Vs. Perambalur-621 104. Tiruchirapalli. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adtpr-2755-B (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Y.Sridhar (Fca)-Ld.Ar " थ"कीओरसे/Respondent By : Ms.R.Anita (Addl.Cit) -Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 01-08-2024 घोषणाकीतारीख /Date Of Pronouncement : 12-08-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Y.Sridhar (FCA)-Ld.ARFor Respondent: Ms.R.Anita (Addl.CIT) -Ld. Sr. DR
Section 143Section 143(3)Section 147Section 148

that there was any failure on the part of the assessee to furnish true particulars of income. Further, there is no tangible material before Ld. AO to reopen the case of the assessee. Therefore, there is no valid ground to initiate reassessment proceedings. The issue of STCG has already been

Ram Kumar Gupta, Kolkata vs. ACIT, Cir. 43, Kolkata

In the result, the appeal of the assessee stands allowed

ITA 309/KOL/2024[2017-18]Status: DisposedITAT Kolkata09 Aug 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.309/Kol/2024 Assessment Year: 2017-18 Ram Kumar Gupta…...…………….....……………………....………....Appellant 67/46, Posta Chowrasta, Kolkata -700007. [Pan: Adrpg8556B] Vs. Acit, Circle-43, Kolkata…...................................................…..…..... Respondent Appearances By: Shri Rajiva Kumar, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit- Dr On Behalf Of P. P. Barman, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 30, 2024 Date Of Pronouncing The Order : August 09, 2024 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 07.12.2023 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 Has Agitated Against The Confirmation Of Addition Of Rs.1,10,46,000/- Made By The Assessing Officer On Account Of Cash Deposits In The Bank Account Of The Assessee During Demonetization Period. 3. The Brief Facts Of The Case Are That The Assessee Derives Income From Retail Trading In The Name Of M/S R. Kumar & Co. The Assessee Filed His Return Of Income On 28.07.2017 Declaring A Total Income Of Rs.8,19,420/-. The Return Was Selected For Scrutiny & Notices U/S

Section 250Section 44ASection 68

were based upon placing a wrong onus of proof and applying not the correct principles of law governing such cases. On the facts, no tangible material had been brought on the record to take the shape of any legal evidence for the purpose of recording a finding that the assessee

Chandra Bhavani Sankar, Chennai vs. ITO, Non Corp Ward 16(2), Chennai

In the result, appeal filed by the assessee is allowed

ITA 101/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Aug 2024AY 2012-13

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.101/Chny/2024 िनधा"रण वष"/Assessment Year: 2012-13 V. Shri Chandra Bhavani Sankar, The Ito, 1/3A, Vinayakar Koil Street, Ncw-16(2), Thalambur, Chennai. Chennai-600 130. [Pan: Aeypb 1764 J] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Sathyanarayanan, AdvFor Respondent: Shri P. Sajit Kumar, JCIT
Section 54(1)Section 54FSection 68

claim u/s.54F of the Act. In the case of Pradeep Kumar (supra), there was a definite finding of fact that there was no tangible material to form a belief that a residential house/dwelling unit was constructed; and it was found that it was only an extension of existing building