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“escapement of income”

ReassessmentSection 147Section 1473,765 judgments

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

Leading authorities on escapement of income

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.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

CIT v. Sun Engineering Works (P) Ltd.
198 ITR 297 · 1992 · Supreme Court
814
citing judgments

A court's pronouncement derives its scope and color from the specific questions involved in the case, thus, due regard must always be given to the questions framed before the court when interpreting its judgment.

ITO v. Lakhmani Mewal Das
103 ITR 437 · 1976 · Supreme Court
721
citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

CIT v. Jet Airways (I) Ltd.
331 ITR 236 · 2011 · High Court
694
citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

PCIT v. Meenakshi Overseas Pvt. Ltd.
395 ITR 677 · 2017 · High Court
471
citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Judgments citing escapement of income

Comfort Intech Limited, Mumbai vs. Assistant Commissioner of Income Tax 4(1)(1) Mumbai, Aaykar Bhawan Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2926/MUM/2024[2012-2013]Status: DisposedITAT Mumbai27 Sept 2024AY 2012-2013

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

mention the name of the assessee company in their respective statements. Based on the above facts, the AO entertained belief that there was escapement of income in the hands of the assessee. The AO noticed that 6 Comfort Intech Limited batch the sales turnover of assessee company was Rs.1 ... determined by the market forces and there is no connection between the market prices of shares of assessee company with the alleged escapement of income in the hands of the assessee company. According to the Ld.AR, the above inconsistencies have occurred mainly for the reason that

Comfort Intech Limited, Mumbai vs. Assistant Commissioner of Income Tax 4(1)(1) Mumbai, Aaykar Bhawan Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2573/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Sept 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

mention the name of the assessee company in their respective statements. Based on the above facts, the AO entertained belief that there was escapement of income in the hands of the assessee. The AO noticed that 6 Comfort Intech Limited batch the sales turnover of assessee company was Rs.1 ... determined by the market forces and there is no connection between the market prices of shares of assessee company with the alleged escapement of income in the hands of the assessee company. According to the Ld.AR, the above inconsistencies have occurred mainly for the reason that

Jayshree Ravi Sancheti, Mumbai vs. PCIT-20, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2269/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Sept 2024AY 2013-14

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Prakash Jhunjhunwala, ARFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 10(38)Section 147Section 148Section 263Section 68Section 69C

amounts will be taxed applying provisions of section 115BBE to tax both the amounts at a higher tax rate. This has resulted into escapement of income of Rs.44,19,280/- (Rs.35.31.934/- Rs.8.87.346/-), and is required to be disallowed. The escaped amount of accommodation entry is required to be taxed ... estimated further proposed addition of Rs.8,87,346/- (3% of total sale consideration of Rs.2,95,78,213/-). By this the total escapement of income has been pointed out of total of Rs.44,19,280/- with the tax effect of Rs.30,37,381/- 4. In the light of the above

Assistant Commissioner of Income Tax- 4(1)(1), Mumbai vs. Comfort Intech Limited, Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2218/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Sept 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

mention the name of the assessee company in their respective statements. Based on the above facts, the AO entertained belief that there was escapement of income in the hands of the assessee. The AO noticed that 6 Comfort Intech Limited batch the sales turnover of assessee company was Rs.1 ... determined by the market forces and there is no connection between the market prices of shares of assessee company with the alleged escapement of income in the hands of the assessee company. According to the Ld.AR, the above inconsistencies have occurred mainly for the reason that

Assistant Commissioner of Income Tax-4(1)(1), Mumbai vs. Comfort Intech Limited, Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2216/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Sept 2024AY 2012-13

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

mention the name of the assessee company in their respective statements. Based on the above facts, the AO entertained belief that there was escapement of income in the hands of the assessee. The AO noticed that 6 Comfort Intech Limited batch the sales turnover of assessee company was Rs.1 ... determined by the market forces and there is no connection between the market prices of shares of assessee company with the alleged escapement of income in the hands of the assessee company. According to the Ld.AR, the above inconsistencies have occurred mainly for the reason that

Assistant Commissioner of Income Tax- 4(1)(1), Mumbai vs. Comfort Intech Limited, Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2212/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Sept 2024AY 2014-15

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

mention the name of the assessee company in their respective statements. Based on the above facts, the AO entertained belief that there was escapement of income in the hands of the assessee. The AO noticed that 6 Comfort Intech Limited batch the sales turnover of assessee company was Rs.1 ... determined by the market forces and there is no connection between the market prices of shares of assessee company with the alleged escapement of income in the hands of the assessee company. According to the Ld.AR, the above inconsistencies have occurred mainly for the reason that

A.C.I.T, Wardha Circle, Wardha vs. M/S Kapil Solvex Pvt .Ltd, Yavatmal

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

ITA 221/NAG/2017[2009-20010]Status: Trans-OutITAT Pune26 Sept 2024

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(1)Section 147Section 148

fact by legal evidence or conclusion. Thus, at that stage, what is required is "reason to believe", but not the established fact of escapement of income. At the stage of issuance of notice, the only question is whether there was relevant material on which a reasonable person could have formed ... that any income has escaped assessment. All that the Assessing Officer desires is examination of certain details pertaining to the actual extent of escapement of income which can be established only after detailed investigation. Even in the reasons recorded, it says" In this case as per the CIB information

Ishoo Narang, Hyderabad vs. DCIT Circle -2(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 450/HYD/2022[2014-15]Status: DisposedITAT Hyderabad25 Sept 2024AY 2014-15

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.450/Hyd/2022 & S.A. No.1/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2014-15) Ishoo Narang Vs. Dy. Cit Hyderabad Circle 2(1) Pan:Aaupn9082B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Smt. Th Vijaya Lakshmi, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/08/2024 घोषणा की तारीख/Pronouncement: 25/09/2024 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 15/07/2022 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2014-15. 2. The Assessee Has Raised The Following Grounds: “1. The Ld. Cit(A) Erred In Dismissing The Appeal. 2. The Ld.Cit(A) Erred In Holding That Al The Mandatory Preconditions Before Reopening Of Assessment U/S 147 Of The Act Were Duly Complied & Met With By The A.O.

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Smt. TH Vijaya Lakshmi, CIT (DR)
Section 10(38)Section 133ASection 147Section 68

reopening of the assessment is merely on the basis of change of opinion without there being any fresh tangible material which suggests escapement of income. The appellant has also challenged the additions made by the Assessing Officer towards the consideration received from sale of shares in light of certain judicial ... ground that there is enough material which come to the possession of the Assessing Officer subsequent to completion of the assessment which suggests escapement of income on account of under assessment of Long-Term Capital Gain derived from sale of shares. Therefore, the reasons recorded by the Assessing Officer

Prasant Desai, Kolkata vs. DCIT, Cir. 61, Kolkata

In the result, the appeal of the assessee stands allowed

ITA 735/KOL/2024[2013-14]Status: DisposedITAT Kolkata25 Sept 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. No.735/Kol/2024 Assessment Year: 2013-14 Prasant Desai……..……………….………...........………………....Appellant C/O Subash Agarwal & Associates, Advocate, Siddha Gibson, 1, Gibson Lane, Suite – 213, 2Nd Floor, Kolkata – 700069. [Pan: Acypd1511B] Vs. Dcit, Circle-61, Kolkata.……………….…............................…..…..... Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Assessee. Shri Arup Chatterjee, Addl. Cit- Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : July 02, 2024 Date Of Pronouncing The Order : September 25, 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 26.02.2024 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.75,00,000/- Made By The Assessing Officer On Account Of Unsecured Loans Received From M/S Festive Deal Trade Pvt. Ltd. Treating The Same As Bogus.

Section 147Section 148Section 250

Wing was supposed to corelate the same with the records and other facts of the case and thereafter should have satisfied himself of escapement of income. Reopening is not permissible on the basis of borrowed satisfaction of the Assessing Officer. That such reasons to believe must have a material bearing ... question of escapement of income. It does not mean a purely subjective satisfaction of the assessing authority, such reason should be held in good faith and cannot merely be a pretence. The reasons to believe must have a rational connection with or relevant bearing on the formation of the I.T.A

M/S Flora Exports, Kolkata vs. ITO, Ward 31(1), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 502/KOL/2024[2014-15]Status: DisposedITAT Kolkata25 Sept 2024AY 2014-15

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. No.502/Kol/2024 Assessment Year: 2014-15 M/S Flora Exports……………….………...........………………....Appellant 17/2/H/13, Smith Lane, Taltala, Kolkata – 700013. [Pan: Aabff1684J] Vs. Ito, Ward-31(1), Kolkata.……………….…............................…..…..... Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Assessee. Shri Arup Chatterjee, Addl. Cit- Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : July 01, 2024 Date Of Pronouncing The Order : September 25, 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 14.12.2023 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 Taken The Following Revised Grounds Of Appeal:

Section 139Section 143(1)Section 147Section 151Section 250

Wing was supposed to corelate the same with the records and other facts of the case and thereafter should have satisfied himself of escapement of income. Reopening is not permissible on the basis of borrowed satisfaction of the Assessing Officer. It does not mean a purely subjective satisfaction ... satisfaction from the information of Investigation Wing, hence, such an action of Assessing Officer would fall short of the reasons to believe of escapement of income of the assessee. In view of the above discussion, in our view, the reasons pointed out by the Assessing Officer cannot be said

Friends Timber Pvt. Ltd, Nagpur vs. Assistant Commissioner of Income Tax, Nagpur

In the result, appeal filed by the assessee is dismissed

ITA 120/NAG/2021[2014-15]Status: DisposedITAT Nagpur24 Sept 2024AY 2014-15

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

For Appellant: Shri Kapil HiraniFor Respondent: Shri Abhay Y. Marathe

under: v. Instruction No 7/2014 (para 4) In case, during the course of assessment proceedings it is found that there is potential escapement of income exceeding Rs. 10 lakhs (for non metro charges, the monitoring limit shall be Rs. 5 lakhs) on any other issue(s) apart from AIR/CIB/26AS information ... concerned. vi. Instruction No 20/2015 (para 3d) In case, during the course of assessment proceedings it is found that there is potential escapement of income exceeding Rs.10 lakhs (for non–metro charges, the monitoring limit shall be Rs. 5 lakhs) on any other issue(s) requiring substantial verification, the case

Polly Saha, Kolkata vs. ITO Ward 45(3), Kolkata

ITA 1097/KOL/2024[2011-12]Status: DisposedITAT Kolkata24 Sept 2024AY 2011-12

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2011-12

For Appellant: Taraknath Jaiswal, AdvFor Respondent: Madhumita Das, Addl. CIT
Section 143(3)Section 147Section 148Section 250Section 50C

filed her Return of Income (ROI) on 29.03.2012, declaring total income of Rs. 1,86,188/-. Based on information suggesting escapement of income pertaining to A.Y. 2011-12, arising from the sale of immovable property, the Assessing Officer (the Ld. AO) initiated reassessment proceedings under section

Asian Earth Movers, Bellary vs. Income Tax Officer, Ward 1 & Tps, Bellary

In the result, the appeal is allowed for statistical purposes

ITA 136/BANG/2024[2018-19]Status: DisposedITAT Bangalore24 Sept 2024AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Shri B.S. Balachandran, AdvocateFor Respondent: Shri V. Parithivel, Jt. CIT(DR)(ITAT), Bengaluru
Section 139(1)Section 144BSection 147Section 148Section 234ASection 249(4)Section 270ASection 272A(1)(d)

condition precedent for issue of the Notice u/s 148 of the Act. (ii) Because and without prejudice to the above, the alleged escapement of income did not exceed the minimum limit of Rs. 50 lakhs justifying the issue of the Notice u/s 148, since the material facts placed on record

Dipikaben Kaniyalal Prajapati, Ahmedabad vs. The Pr. CIT, Ahmedabad -3, Ahmedabad

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

ITA 513/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad20 Sept 2024AY 2015-16

Bench: Ms. Suchitra R. Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year: 2015-16 Principal Commissioner Of Dipikaben Kaniyalal Prajapati, Income-Tax, Prop. Of Shivam Roadways, बनाम/ Ahmedabad-3, 17, Bhuyangdev Society, Sola Ahmedabad Road, Ghatlodia, Ahmedabad, Vs. Gujarat -380061 (Appellant) (Respondent) Assessee By Shri Shailesh Shah, Ca Revenue By Shri H. Phani Raju, Cit-Dr Date Of Hearing 13.08.2024 Date Of Pronouncement 20.09.2024 आदेश/ O R D E R Per Ms. Suchitra Kamble:

Section 147Section 151Section 153CSection 263

under section 147 is itself is bad in law as the reason recorded would not have led to the formation of belief of escapement of income. b) That no valid satisfaction/approval under section 151 was obtained. c) That impugned reassessment order was passed without complying with the mandatory conditions

Nilima Kothari, Indore vs. The Income Tax Officer, National Faceless Asstt. Centre, Indore

In the result appeal of the assessee is allowed as per terms indicated above

ITA 259/IND/2024[2016-17]Status: DisposedITAT Indore20 Sept 2024AY 2016-17

Bench: Shri Manish Boradsmt. Neelima Kothari, Income Tax Officer, 601, N.R.K. Villas, Delhi Vs. 22/2 Manoramaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Adnpk7832J Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 08.08.2024 Date Of Pronouncement 20.09.2024

Section 10(38)Section 147Section 148Section 151Section 68

secondly, that no valid approval u/s 148 of the Act has been taken and thirdly, there was no proper reason to believe about escapement of income for initiating proceedings u/s 148 of the Act. Submissions filed by the assesse on these three legal issues reads as under: 5 Smt. Nilima ... wherein it was held that notices issued u/s 148 of the Act pertaining to A.Y. 2016-17 & 2017-18 where the escapement of income was below Rs.50.00 lacs, the normal period of limitation i.e. three years was to apply. In comparison, the extended period of ten years would apply

Smt. Rekha Ganesh, Davangere vs. Assistant Commissioner of Income Tax, Circle-1(1), Davangere

ITA 1275/BANG/2024[2015-16]Status: DisposedITAT Bangalore20 Sept 2024AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Subramanian S, JCIT (DR)
Section 131Section 132Section 133ASection 143(3)Section 147

believe that the income of the assessee has escaped assessment, and he is not expected to dig out the absolute facts about the escapement of income. In this regard we also draw support and guidance from the judgment of the Hon'ble Gujarat High Court in the case of Amar

Sujeet Gupta, Bareilly vs. ITO Ward-2(2), Bareilly New

The appeal stands partly allowed for statistical purposes

ITA 208/LKW/2024[2018-19]Status: DisposedITAT Lucknow19 Sept 2024AY 2018-19

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Subhash Malguriaआयकर अपऩल सं. / Ita No.208/Lkw/2024 निर्धारण वषा / Assessment Year : 2018-19 Sujeet Gupta, Shop No. S-55, M/S Paris Fashions, Awas Vikas Market, Rajendra Nagar, Bareilly, Up-243122 Pan: Aifpg6341K . . . . . . . अपीलार्थी / Appellant

For Appellant: None for the AssesseeFor Respondent: Mr Sanjeev Krishna Sharma [‘Ld. DR’]
Section 139(1)Section 143(3)Section 148Section 250Section 253(1)Section 270ASection 270A(9)Section 3

result of which, the Ld. AO invoked his re-opening jurisdictional by issue of notice u/s 148 of the Act dt.27/03/2022 alleging escapement of income and thus called upon the assessee to file his ITR thereunder. In response to aforestated notice, the assessee filed his ITR declaring 3.2 taxable income

Paris Elysees India Pvt. Ltd., Jaipur vs. DCIT, Circle-7, Jaipur

ITA 681/JPR/2023[2012-13]Status: DisposedITAT Jaipur19 Sept 2024AY 2012-13

Bench: Him Against The Order Dated 05.12.2019 Passed Under Section 147/143(3) Of The Income Tax Act, [ For Short “Act” ] By Acit, Circle-07, Jaipur.

For Appellant: Sh. Rohan Sogani, CAFor Respondent: Sh. Anup Singh, Addl. CIT
Section 115JSection 147Section 148Section 151Section 250Section 253(5)

after 1-4-1989 , Assessing Officer has power to reopen, 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 of the belief. Our view gets support from the changes made to section

DCIT 27 (2), Mumbai, Navi Mumbai vs. Narayan Tatu Rane, Chembur

In the result, both the appeals filed by the Revenue are dismissed

ITA 4716/MUM/2023[2012-13]Status: DisposedITAT Mumbai19 Sept 2024AY 2012-13

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Rashmikant C. Modi &For Respondent: Shri Ashok Kumar Ambastha
Section 143(1)Section 148Section 68

transactions of purchase and sale of shares of above said company as bogus in nature. Accordingly, the AO entertained belief that there was escapement of income and accordingly, reopened the assessment of the AY. 2011-12 by issuing notice u/s. 148 of the Act. 4. In the year relevant

DCIT-27(2), Mumbai, Navi Mumbai vs. Narayan Tatu Rane, HUF, Mumbai

In the result, both the appeals filed by the Revenue are dismissed

ITA 4668/MUM/2023[2011-12]Status: DisposedITAT Mumbai19 Sept 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Rashmikant C. Modi &For Respondent: Shri Ashok Kumar Ambastha
Section 143(1)Section 148Section 68

transactions of purchase and sale of shares of above said company as bogus in nature. Accordingly, the AO entertained belief that there was escapement of income and accordingly, reopened the assessment of the AY. 2011-12 by issuing notice u/s. 148 of the Act. 4. In the year relevant