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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

M/S. Aryan Share and Stock Brockers Limited, Chennai vs. ITO, Corp Ward-1, Chennai

In the result, Appeal filed by the assessee is allowed

ITA 2115/CHNY/2025[2014-15]Status: DisposedITAT Chennai13 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No. 2115/Chny/2025 "नधा"रण वष"/Assessment Year: 2014-15 M/S Aryan Share & Stock Brokers V. Ito Corp Ward-1, Limited., Itd, M G Road, No. 07, 07Th Cross Street, Nungambakkam, 2Nd Floor, Shreeji Metropolis, Chennai-600034 Aminjikarai, Chennai-600030 Tamil Nadu Tamil Nadu [Pan:Aadca 1233 H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Assessee By : Mr. Y Sridhar, Ca ""यथ" क" ओर से /Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 10.11.2025 घोषणा क" तार"ख /Date Of Pronouncement : 13.01.2026

For Appellant: Mr. Y Sridhar, CAFor Respondent: Ms. Anitha, Addl.CIT
Section 147Section 69A

reasons recorded are vague, general and conclusory in nature and do not disclose any live link between the material and the belief of escapement of income. Therefore, the initiation of reassessment proceedings fails to satisfy the statutory conditions prescribed under sections 147 and :: 10 :: 148 of the Act. On this

Abhishek Jayketu Joshi, Mumbai vs. Ac Cir-42(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5775/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Jan 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarabhishek Jayketu Joshi Ac Cir-42(2)(1), C-73, Venus Society, R. G. Kautilya Bhavan, Thadani Marg, Worli Sea Vs. Mumbai-400 051 Face, Mumbai-400 018 Pan/Gir No. Ackpj8583H (Applicant) (Respondent) Assessee By Shri M. M. Golvala, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 13.01.2026

Section 132Section 132(4)Section 139(1)Section 139(5)Section 143(1)Section 144BSection 147Section 148Section 148ASection 250

vitiated, as the said notice was issued on the basis of vague, generalized and borrowed information, without there being any tangible material demonstrating escapement of income in the case of the assessee. According to the learned Authorized Representative, the notice merely reproduces allegations arising out of search proceedings conducted ... issued on an incorrect factual premise, the assumption of jurisdiction under section 147 stands vitiated, as the very basis for forming satisfaction regarding escapement of income was flawed. 14. The learned Authorised Representative submitted that such an error cannot be brushed aside as a mere clerical lapse, since the jurisdiction

DCIT(CC)-8(3), Mumbai vs. Shapoorji Pallonji and Company Private Limited, Mumbai

In the result, the cross-objection of the assessee is partly

ITA 2831/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Jan 2026AY 2014-15

Bench: Shri Om Prakash Kant ()

Section 115JSection 143(3)Section 147Section 148Section 14A

valid. 7.4 The Ld. counsel further submitted that the Assessing Officer in the present case has not arrived at the satisfaction about the escapement of income in the hands of the assessee in an independent manner as contemplated u/s 147 of the Act i.e. the Assessing Officer has simply accepted ... information given by the Investigation Wing and concluded that there was escapement of income without making any independent enquiry. Thus the reassessment made by the Ld. AO, on the basis of borrowed satisfaction and without independent application of the mind, is bad in law and liable to be quashed

Seema Rani Sarna, Haryana vs. ITO Ward-1, Fatehabad

In the result, both the appeals of the assessee are allowed in above terms

ITA 6236/DEL/2025[2015-16]Status: DisposedITAT Delhi12 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh & Smt. Renu Jauhrieash Kumar Sarna, Vs Ito, Ward -1, House No. 35, Ward 19, Fatehabad Friends Colony, Tohana Haryana Fatehabad-125120 Haryana (Appellant) (Respondent) & Seema Rani Sarna, Vs. Ito, Ward -1, Plot No. 10, Ratia Road, Fatehabad Jamalpur Sheikhan, Haryana Fatehabad-125120 Haryana (Appellant) (Respondent)

For Appellant: Ms. Vandana Kothari, AdvFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 144BSection 147Section 148Section 149Section 149(1)(b)Section 3Section 3(1)

Assessing Officer – i. Initiating proceedings u/s. 147/148 of the Act without there being any valid reason leading to the belief of escapement of income; ii. Disposing off the objections to the reopening of assessment mechanically by non speaking order.” 3. Ld. Counsel for the assessee stated that the notice

Eash Kumar Sarna, Fatehabad vs. ITO Ward-1, Fatehabad

In the result, both the appeals of the assessee are allowed in above terms

ITA 6235/DEL/2025[2015-16]Status: DisposedITAT Delhi12 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh & Smt. Renu Jauhrieash Kumar Sarna, Vs Ito, Ward -1, House No. 35, Ward 19, Fatehabad Friends Colony, Tohana Haryana Fatehabad-125120 Haryana (Appellant) (Respondent) & Seema Rani Sarna, Vs. Ito, Ward -1, Plot No. 10, Ratia Road, Fatehabad Jamalpur Sheikhan, Haryana Fatehabad-125120 Haryana (Appellant) (Respondent)

For Appellant: Ms. Vandana Kothari, AdvFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 144BSection 147Section 148Section 149Section 149(1)(b)Section 3Section 3(1)

Assessing Officer – i. Initiating proceedings u/s. 147/148 of the Act without there being any valid reason leading to the belief of escapement of income; ii. Disposing off the objections to the reopening of assessment mechanically by non speaking order.” 3. Ld. Counsel for the assessee stated that the notice

Rajkamal Agro Industries, Deesa vs. ITO, Ward 1, Palanpur

In the result, the appeal of the assessee stands allowed

ITA 1853/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Jan 2026AY 2015-16

Bench: Shri Sanjay Gargआयकर अपील सं /Ita No.1853/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Rajkamal Agro Industries The Ito बनाम/ Deesa Palanpur Highway Ward-I V/S. At Rasna, Deesa – 385 535 Palanpur 385 001 (Gujarat) "थायी लेखा सं./Pan: Aaifr 7263 C (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08/01/2026 घोषणा की तारीख /Date Of Pronouncement: 09/01/2026 आदेश/O R D E R The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 04/09/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2015-2016. 2. The Assessee, In This Appeal, Has Taken The Following Grounds Of Appeal:

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Smt. Mamta Singh, Sr.DR
Section 147Section 250

consideration has escaped assessment and reopened the assessment. Rajkamal Agro Industries vs. ITO Asst. Year : 2015-16 3 3.1. So far as the escapement of income on claim of excess depreciation is concerned, the Ld. Counsel for the assessee has invited my attention to Page No.49 of the paper-book ... made merely on the basis of audit objection, without application of mind, by the AO and without forming an independent belief regarding the escapement of income of the assessee for the assessment year under consideration. 4. The Ld. DR, on the other hand, has fairly admitted that no addition

Doriswamy Gopi, Bengaluru vs. Income Tax Officer, Ward 3(1)(1), Bengaluru

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

ITA 2020/BANG/2025[A.Y. 2017-18]Status: DisposedITAT Bangalore09 Jan 2026

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Nagaraja K.H, CAFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department
Section 139Section 147Section 148Section 151Section 292B

Assessing Officer. In this background, what has been sought to be pointed out is that the reasons recorded for formation of belief of escapement of income are based on an incorrect fact. The incorrect fact being the return not having been filed by the assessee. It has also been pointed ... situation it could not be said with certainty as to which factor weighed with the Assessing Officer to form a belief about escapement of income. Thus, in our view, as in the instant case, the recording of reasons is based on an incorrect assumption of fact, the same invalidates

Sanjeev Kumar Aggarwal, New Delhi vs. DCIT, Circle-52(1), Civic Centre, Delhi

The appeal of the assessee is allowed

ITA 6208/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh & Shri Amitabh Shuklasanjeev Kumar Aggarwal, Vs. Dcit, Circle 52(1), C/O M/S Raj Kumar & Civic Centre, Associates, New Delhi L-7A (Lgf), South Extension, Part-Ii, New Delhi – 110 049 (Appellant) (Respondent)

For Appellant: Sh. Raj Kumar Gupta, CAFor Respondent: Sh. Jitender Singh, CIT(DR)
Section 144BSection 147Section 148Section 148ASection 149Section 149(1)(b)Section 3

based on 2nd notice u/s. 148 dated 25.05.2023 26.7.2022. 3.1 Ld. Counsel for the assessee further argued that in this case the alleged escapement of income was more than Rs. 50 lacs and hence, notice u/s. 148 could have been issued within 6 years from the end of the relevant

White Orchid Hospitality (P) Ltd, Delhi vs. DCIT, Central Circle-29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5130/DEL/2025[2021-22]Status: DisposedITAT Delhi09 Jan 2026AY 2021-22

Bench: Shri Vimal Kumar & Smt. Renu Jauhriassessment Year : 2021-22 White Orchid Hospitality (P) Ltd., Vs. Dcit, 306, Suneja Tower Ii, Central Circle-29, Distt. Centre, Janakpuri, Delhi. Desu Colony So, West Delhi, New Delhi– 110 058. Pan: Aaccw1923F

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms Amisha S. Gupt, CIT- DR
Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153Section 153ASection 153CSection 250Section 69

though there was no incriminating material at all gathered for any of the assessment years much less for the AY 2021-22 suggesting escapement of income, demonstrating complete lack of application of mind by the AO to initiate proceedings u/s 153С of the Act and which must be quashed

Sarabjeet Singh Bedi, New Delhi vs. DCIT, Central Circle 20, Delhi

ITA 4475/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharmasarabjit Singh Bedi Vs. Dcit, Central Circle-20 C-706, New Friends Jhandewalan Extension Colony, New Delhi Delhi, New Delhi – 110065 New Delhi – 110055 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abjpb3799H Appellant .. Respondent

For Appellant: Sh. Salil Agarwal, Sr.AdvFor Respondent: Sh. Jitender Singh, CIT, DR
Section 147Section 148Section 149Section 149(1)Section 149(1)(b)

impact for all the years to be reopened has to be seen. Admittedly, the allegation in the said notice is only of an escapement of income to the extent of Rs.35,00,000/- which certainly falls below the threshold of Rs.50,00,000/- and the assumption of jurisdiction for reopening

Gyan Enterprises Private Limited, New Delhi vs. ACIT Circle 10(2), New Delhi

ITA 2401/DEL/2025[2012-2013]Status: DisposedITAT Delhi09 Jan 2026AY 2012-2013

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Sh. Chandan Agarwal, CAFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148

during FY .2011-12. On examining the information with assessment records and inquiry made in this regard, it was found that there was escapement of income within the meaning of section 147/148 of the Act. Hence, the case was reopened u/s 147/148 of the Income Tax Act and notice

Pinnacle Consrto and Ecohomes Pvt.Ltd, Pune vs. DCIT Circle-4, Pune

In the result, appeal filed by the assessee is allowed

ITA 2818/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2818/Pun/2025 निर्धारण वषा / Assessment Year : 2017-18 Pinnacle Contro & V Dcit, Ecohomes Pvt. Ltd., S Circle-4, Pune. Madhav Heritage, Tilak Road, Sadashiv Peth, Pune – 411030. Pan: Aaecp0400E Appellant/ Assessee Respondent /Revenue Assessee By Shri Suhas P. Bora Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18Dated 01.10.2025 Emanating From The Assessment Order Passed Under Section 147 Of The Act, Dated 27.08.2021. The Assessee Has Raised The Following Grounds Of Appeal : “1. Reassessment Bad In Law.

Section 143(3)Section 147Section 148Section 151Section 250Section 250(6)

u/s.148 to investigate the information. It means, the Assessing Officer was not having any material to prima facie arrive at a conclusion of escapement of income. It is noted that Assessing Officer has not carried out any independent verification of the so-called material available before issuing notice u/s.148 ... 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

Income Tax Officer, Pune vs. Sagar Construction Company, Pune

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

basis of presumption. The Assessing Officer has not carried out any inquiry or verified the facts before drawing the conclusion about the escapement of income. 19. Referring to the following decisions, he submitted that when the reasons recorded are vague, far-fetched and cannot by any stretch of imagination lead ... conclusion of escapement of income, such re-assessment proceedings are bad in law and are liable to be quashed: i) Milind Madhukar Edke vs. ITO vide ITA No.648/PUN/2020 order dated 18.01.2023 ii) ITO vs. Lakshmi Mewal Das reported in 103 ITR 437 (SC) 16 CO No.43/PUN/2025

Vilayil Satyan Pillai, New Delhi vs. Income Tax Officer, Delhi

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

ITA 2279/DEL/2025[2015-16]Status: DisposedITAT Delhi08 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Kishan Gupta, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 132ASection 144BSection 147Section 148Section 148ASection 153ASection 250

Vilayil Satyan Pillai vs Assessment Unit, NFAC Delhi opening the assessment case and tangible materials discussed & presumed to be fit for reopening & escapement of income before by declaring reason to believe at the time of opening the re-assessment case given in the order u/s 148A(d) dated

Assistant Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Ritu Dhingra, Shakti Vihar, Haibowal Kalan, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 862/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:- (a) That the assessment order dated 31.03.2023 passed u/s 143(3) r.w.s.153C is bad in law in as much no incriminating material was found suggesting any escapement of income at premises of Sh. Avtar Singh Kochhar. (b) That the assessment order passed is non-est and bad in law in as much the proceedings have not been conducted in the manner prescribed by the Department instructions from time to time which are mandatory for compliance by the Learned Authorities particularly with respect

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)

order dated 31.03.2023 passed u/s 143(3) r.w.s. 153C is bad in law in as much no incriminating material was found suggesting any escapement of income at premises of Sh. Avtar Singh Kochhar. (b) That the assessment order passed is non-est and bad in law in as much

Ritu Dhingra, Ludhiana vs. Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 645/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:-

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)

order dated 31.03.2023 passed u/s 143(3) r.w.s. 153C is bad in law in as much no incriminating material was found suggesting any escapement of income at premises of Sh. Avtar Singh Kochhar. (b) That the assessment order passed is non-est and bad in law in as much

Parvindar Indar Singh, Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

In the result, the appeal filed by the Assessee in ITA No

ITA 1002/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2013-14

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 147Section 14ASection 154

assessee. Furthermore, the assessee is taxed at the maximum rate of 30% slab for all these years, thus there is no escapement of income, even it is assessed in the other years. 7.3. Further it is for the same reason for the assessment year 2010-11, the assessment was reopened ... crores from SHIS which was utilized in purchase of fixed assets had not been added back and same had resulted in escapement of income - However, it was found that all aspects of matter sought to be relied upon for purpose of reopening were very much before Assessing Officer when scrutiny

Parvindar Indar Singh, Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

In the result, the appeal filed by the Assessee in ITA No

ITA 1001/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2013-14

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 147Section 14ASection 154

assessee. Furthermore, the assessee is taxed at the maximum rate of 30% slab for all these years, thus there is no escapement of income, even it is assessed in the other years. 7.3. Further it is for the same reason for the assessment year 2010-11, the assessment was reopened ... crores from SHIS which was utilized in purchase of fixed assets had not been added back and same had resulted in escapement of income - However, it was found that all aspects of matter sought to be relied upon for purpose of reopening were very much before Assessing Officer when scrutiny

Rajroop Doshi, Kolkata vs. I.T.O., Ward - 2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1838/KOL/2025[2017-2018]Status: DisposedITAT Kolkata07 Jan 2026AY 2017-2018

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Sandip Sarkar, DR
Section 124(3)Section 127Section 127(1)Section 142(1)Section 143(2)

income as per return has fixed the jurisdiction of the Assessing Officers. 7. Now, in this case, the reasons for forming belief of escapement of income by the assessee were recorded by the ITO, Ward-23(3), Hooghly and thereafter, notice u/s 148 of the Act was also issued

Subodh Adhikary, Kolkata vs. ITO, Ward 51(1), Kolkata

Appeal of the assessee is allowed

ITA 669/KOL/2024[2015-16]Status: DisposedITAT Kolkata07 Jan 2026AY 2015-16

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 142(1)Section 143(2)Section 250Section 56(2)(vii)

course of assessment proceedings in ' Limited Scrutiny ' cases,if it comes to the notice of the Assessing Officer that there is potential escapement of income exceeding Rs. five lakhs (for metro charges, the monetary limit shall be Rs. ten lakhs) requiring substantial verification on any other issue(s) , then