“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

Samandeep Kaur, Irs, Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Trimurti Homes Pvt. Ltd., Ludhiana

Appeals stand dismissed

ITA 1035/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh13 Nov 2025AY 2019-20

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 1034/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2018-19) & 2. आयकर अपील सं./ Ita No. 1035/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2019-20) Dcit-Central Circle-1 M/S Trimurti Homes Pvt. Ltd. बनाम/ Ludhiana – 141001 Hb-1199, Phase-1, Urban Estate Vs. Dugri, Ludhiana-141002 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aadct-6759-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. Co. No. 29/Chandi/2025 [In Ita No. 1034/Chandi/2024] (िनधा"रण वष" / Assessment Year: 2018-19) & 4. Co. No. 30/Chandi/2025 [In Ita No. 1035/Chandi/2024] (िनधा"रण वष" / Assessment Year: 2019-20) M/S Trimurti Homes Pvt. Ltd. Dcit-Central Circle-1 बनाम/ Hb-1199, Phase-1, Urban Estate Ludhiana-141001 Vs. Dugri, Ludhiana-141002 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aadct-6759-P (Cross-Objector) (Respondent) : Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr (Virtual) Assessee By : Shri Ashwani Kumar (Ca) A/W Shri Aditya Kumar (Ca) & Ms. Deepali Aggarwal (Ca) - Ld. Ars सुनवाईकीतारीख/Date Of Hearing : 15-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 13/11/2025

For Appellant: Shri Ashwani Kumar (CA) a/w Shri Aditya KumarFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR (Virtual)

Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148

that the assessee sold farmlands at higher rates in comparison to rates as shown in the registers. Upon formation of belief of escapement of income, a notice u/s 148 was issued by Ld. AO to the assessee on 24-03- 2022 which was followed by notice

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Trimurti Homes Pvt. Ltd., Ludhiana

Appeals stand dismissed

ITA 1034/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh13 Nov 2025AY 2018-19

For Appellant: Shri Ashwani Kumar (CA) a/w Shri Aditya KumarFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR (Virtual)

Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148

Wheatons Design Private Limited, Jaipur vs. ACIT / DCIT, Circle -6, Jaipur

In the result, appeal of the assessee is allowed

ITA 781/JPR/2025[2014-15]Status: DisposedITAT Jaipur12 Nov 2025AY 2014-15

Bench: The Due Date Of Hearing.”

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita rinesh, JCIT-DR a

Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

Therefore, it is a fit case for initiation of assessment proceedings under section 148 of the IT Act, 1961 for escapement of income arising out from not allowable business expenditure. On this basis it is apparent that the assessee had claimed expenses of Rs. 34,60,713/- which made

Bala Devi, Jaipur Rural vs. ITO, Jaipur

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

ITA 1306/JPR/2025[2013-2014]Status: DisposedITAT Jaipur12 Nov 2025AY 2013-2014

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No.1306/JPR/2025 निर्धारणवर्ष / AssessmentYear : 2013-14 Smt. Bala Devi Dhani :Kankaraiwali, Saravatpura Gram: Amer, Via: Kalwad, Tehsil: Amer Jaipur 303 706 (Raj) Vs. बनाम The ITO Ward 7(4) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: CPCPD 3195 L अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri Shyam Sunder Jangid, Advocate राजस्व की ओरसे/Revenue by: Mrs. Harshi

For Appellant: Shri Shyam Sunder Jangid, AdvocateFor Respondent: Mrs. Harshita Choudhary, Addl.CIT (DR)

Section 148

DEVI VS ITO, WARD 7(4), JAIPUR 2 Issuing notice u/s 148 to the assessee mentioning escaped income whereas there was no such escapement of income, as the appellant only sources of income is agriculture which was not liable to tax. The notice issued

Somnath Ramdas Jadhav, Ahmednagar vs. ITO Ward 2, Ahmednagar

In the result, the appeal filed by the assessee in ITA

ITA 441/PUN/2025[2016-17]Status: DisposedITAT Pune12 Nov 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

return of income, therefore the income to the above extent has escaped assessment. 6. Basis of forming reason to believe and details of escapement of income In light of the details available on records and the above facts and findings, I have reason to believe that income chargeable ... Rs.5051750/- has escaped the assessment. I have reasons to believe that this is a fit case for reopening and there is escapement of income within the meaning of Explanation 2(a) to Section 147 of the Income Tax Act, 1961. 6.5 There is no dispute that appellant had maintained

Somnath Ramdas Jadhav, Ahmednagar vs. ITO, Ward 2, Ahmednagar

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 440/PUN/2025[2015-16]Status: DisposedITAT Pune12 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

return of income, therefore the income to the above extent has escaped assessment. 6. Basis of forming reason to believe and details of escapement of income In light of the details available on records and the above facts and findings, I have reason to believe that income chargeable ... escaped the assessment. I have reasons to believe that this is a fit case for reopening and there is escapement of income within the meaning of Explanation 2(a) to Section 147 of the Income Tax Act, 1961. 6.5 There is no dispute that appellant had maintained an account with

Somnath Ramdas Jadhav, Ahmednagar vs. ITO, Ward 2, Ahmednagar

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 439/PUN/2025[2013-14]Status: DisposedITAT Pune12 Nov 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

return of income, therefore the income to the above extent has escaped assessment. 6. Basis of forming reason to believe and details of escapement of income In light of the details available on records and the above facts and findings, I have reason to believe that income chargeable ... escaped the assessment. I have reasons to believe that this is a fit case for reopening and there is escapement of income within the meaning of Explanation 2(a) to Section 147 of the Income Tax Act, 1961. 6.5 There is no dispute that appellant had maintained an account with

Somnath Ramdas Jadhav, Ahmednagar vs. ITO Ward 2, Ahmednagar

In the result, the appeal filed by the assessee in ITA

ITA 1093/PUN/2025[2015-16]Status: DisposedITAT Pune12 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamore

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

Somnath Ramdas Jadhav, Ahmednagar vs. ITO Ward2, Ahmednagar

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 1092/PUN/2025[2013-14]Status: DisposedITAT Pune12 Nov 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

return of income, therefore the income to the above extent has escaped assessment. 6. Basis of forming reason to believe and details of escapement of income In light of the details available on records and the above facts and findings, I have reason to believe that income chargeable ... escaped the assessment. I have reasons to believe that this is a fit case for reopening and there is escapement of income within the meaning of Explanation 2(a) to Section 147 of the Income Tax Act, 1961. 6.5 There is no dispute that appellant had maintained an account with

Somnath Ramdas Jadhav, Ahmednagar vs. ITO Ward 2, Ahmednagar

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 1089/PUN/2025[2016-17]Status: DisposedITAT Pune12 Nov 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha

Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

return of income, therefore the income to the above extent has escaped assessment. 6. Basis of forming reason to believe and details of escapement of income In light of the details available on records and the above facts and findings, I have reason to believe that income chargeable ... escaped the assessment. I have reasons to believe that this is a fit case for reopening and there is escapement of income within the meaning of Explanation 2(a) to Section 147 of the Income Tax Act, 1961. 6.5 There is no dispute that appellant had maintained an account with

Lekhraj Jasraj Jain, Mumbai vs. DCIT 19(1), Mumbai

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

ITA 4937/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Nov 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2014-15

For Respondent: Mr. Suchek Anchaliay &

Section 147Section 68Section 69C

come to reasonable belief that there has basis for the Assessing Officer to come to reasonable belief that there has been any escapement of income on the ground that the modifications done been any escapement of income on the ground that the modif been any escapement of income ... nexus between the application of mind and absence of any live nexus between the material relied upon material relied upon and the alleged escapement of income. The and the alleged escapement of income. The reopening of assessment, being based on mere suspicion and reopening of assessment, being based on mere

Shri Rushabhdev Swetambar Murtipujak Jain Sangh, Ahmedabad vs. The ITO, Ward-2 (Exemption), Ahmedabad

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

ITA 136/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad11 Nov 2025AY 2012-13

Bench: Shri T.R. Senthil Kumar&Shri Makarand V. Mahadeokar

For Appellant: Shri Jaimin Shah, A.RFor Respondent: Shri R P Rastogi, CITDR

Section 12ASection 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

basis of credible information generated through the departmental system. He held that such information constituted tangible material for forming a belief of escapement of income. 9. On the merits of the addition, however, the learned CIT(A) took cognizance of the fact that the assessment was completed ex parte

Mridul Shashikant Khandelwal, Mumbai vs. PCIT(Central)-1, Mumbai

In the result, the grounds of

ITA 3645/MUM/2025[2020-21]Status: DisposedITAT Mumbai11 Nov 2025AY 2020-21

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 143(3)Section 153CSection 153DSection 254(1)Section 263

unjustified and bad in law. 4. The Ld. PCIT in the impugned order as failed to point out any specific defect or escapement of income or any particular issue or document which had remained to be examine, therefore, merely invoking Explanation 2 to sec. 263 in fact of the case

Mridul Shashikant Khandelwal, Mumbai vs. PCIT Central -1, Mumbai

In the result, the grounds of

ITA 3644/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 143(3)Section 153CSection 153DSection 254(1)Section 263

Haseeb Mohammed Iqbal Shaikh, Mumbai vs. ITO, Int Tax 4(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 235/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Nov 2025AY 2016-17

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2016-17 Haseeb Mohammed Iqbal Shaikh Income Tax Officer, 9/301, Vijay Park Ghodbunder (International Taxation)- Road, Kasarvadavli, Thane, Vs 4(2)(1), Mumbai - 400601 Mumbai (Pan : Bscps9388A) (Appellant) (Respondent) Present For: Assessee : Shri Nishant Thakkar, Shri Rajesh Poojary & Ms. Jasmin Amalsadwala, Advocates Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 14.08.2025 Date Of Pronouncement : 11.11.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Assessment Passed Under The Directions Of Dispute Resolution Panel-1, Mumbai, Vide Order No. Itba/Drp/F/144C(5)/2024-25/1070521602(1), Dated 21.11.2024, Passed U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Assessment Year 2016-17. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. Reassessment Proceedigns: 1.1 The Income Tax Officer 1 (1), Thane ("The J.A.O.") Erred In Passing The Order U/S. 148A(D) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Dated 28Th March 2023 & Issuing Notice U/S. 148 Of The Act On 29Th March 2023 In Violation Of The Provisions Of Section 151A Of The Act Read With E-Assessment Of Income Escaping Assessment Scheme, 2022. 2 Haseeb Mohammed Iqbal Shaikh Ay 2016-17

For Appellant: Shri Nishant Thakkar, Shri Rajesh Poojary and Ms. Jasmin Amalsadwala, AdvocatesFor Respondent: Shri Krishna Kumar, Sr. DR

Section 144Section 144C(5)Section 147Section 148Section 148ASection 151ASection 56Section 56(2)(vii)Section 69Section 69A

proceedings. In the cause title of the impugned assessment order, the status of the assessee is mentioned as “non-resident”. Since there was escapement of income from assessment to the tune of Rs.64,18,104/- case of the assessee was reopened by applying the provisions of section 147 r.w.s.148

Prajesh Maneklal Rupareliya, Mumbai vs. 33(1)(1), Mumbai

In the result, the ground No

ITA 6608/MUM/2024[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Pawan Singh& Shri Arun Khodpia(Physical Hearing)

Section 115BSection 132(4)Section 139(1)Section 143(3)Section 147Section 148Section 151Section 254(1)Section 69A

thus, it is a case of extension of limitation period u/s.143(3) of the Act in the pretext of assessment of escapement of income s.147 of the Act which is bad in law being void ab initio. c. Ld. JAO has erred to invoke s.147 of the Act instead ... such show cause notice, the assessee filed his reply dated 24.04.2023. In reply, the assessee asked for material and the information about escapement of income along with approval of higher authorities under section 151 r.w.s. 148A(b). The assessing officer in para 4.3 of assessment order recorded that assessee

Pushkar Vishwas, Bulandshahr vs. Income Tax Officer Ward 3(3), Bulandshahr

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

ITA 5661/DEL/2025[2011-12]Status: DisposedITAT Delhi11 Nov 2025AY 2011-12

Bench: Shri Mahavir Singha.Yr. : 2011-12 Pushkar Vishwas, Vs. Income Tax Officer, C/O Ca Vaibhav Goel, Ward 3(3), Bulandshahr, 75, Navyug Market, Uttar Pradesh 1St Floor, Ghaziabad Uttar Pradesh (Pan: Aezpv4597E) (Appellant) (Respondent)

For Appellant: Shri Vaibhav Goel, CAFor Respondent: Shri Manoj Kumar, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 151

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. 9……………………. 10. Facts being identical. Respectfully following the said decision

Sajithkumar Subi, Ankleshwar vs. Income-Tax Officer Ward-2(4), Bharuch

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

ITA 670/SRT/2024[2012-13]Status: DisposedITAT Surat10 Nov 2025AY 2012-13

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.670/Srt/2024 Assessment Year: 2012-13 (Hybrid Hearing) Sajithkumar Subi, Ito Ward- 2(4), Bharuch बनाम/ 60, Raghuveer Society, Opp. Harikunj Building, Above Bank Of Vs. Surwadi, Bor Bhatha Road, Baroda, Station Road, Bharuch Ankleshwar, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Axcpk0947P (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Ms. Kinjal Shah, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr. Dr सुनवाई की तारीख/Date Of Hearing 12/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 10/11/2025

Section 144Section 147Section 148Section 151Section 250

source of cash deposits to the tune of Rs.15,48,200/- and contract income of Rs.3,99,428/- remained unexplained resulting in escapement of income. Therefore, case of the assessee was reopened u/s 147 of the Act and notice u/s.148 of the Act was issued on 27.03.2019. In response

Amit Kumar, Jaipur vs. ITO Ward 4(2), Jaipur

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

ITA 1087/JPR/2025[2018-19]Status: DisposedITAT Jaipur10 Nov 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. C. L. Yadav, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT

Section 144Section 144BSection 147Section 148ASection 2

assessee to the extent of the cash deposited in bank has escaped assessment. Consequently, he issued a notice u/s 148, alleging escapement of income to the extent of Rs1,10,21,220/-. During the course of assessment, the AO found the source of cash deposited in the bank account ... without issuing fresh notice under section 148 of the I.T. Act after recording reasons under section 147 of the I.T. Act, 1961 for escapement of income. Since the A.O. in the instant case has not done so, therefore, such addition being bad in Law has to be deleted

Income Tax Officer, Parwanoo vs. Saboo Tor Private Limited, Kala Amb. Distt Sirmour

In the result, the appeal stand dismissed

ITA 786/CHANDI/2025[2011-12]Status: DisposedITAT Chandigarh10 Nov 2025AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.786/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2011-12) Ito M/S Saboo Tor Private Limited बनाम/ Sector-2 Trilokpur Road, Kala Amb Parwanoo-173220 Dist: Sirmour-173030 Vs. Himachal Pradesh Himachal Pradesh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcs-8995-C (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Sudhir Sehgal (Advocate) – Ld. Ar Revenue By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 27-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 10/11/2025

For Appellant: Shri Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR

Section 143(3)Section 148

received payment of Rs.268 Lacs from that entity. The same was also marked as suspicious transaction. On these facts, having formed opinion of escapement of income, the case of the assessee was reopened by issuance of notice u/s 148 on 30-03-2018. The assessee furnished documentary evidences and established