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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

Nitu Khadariya, Jaipur vs. ITO Ward 1(3), Ncrb Building

In the result, the appeal of the assessee is allowed

ITA 1360/JPR/2024[2014-15]Status: DisposedITAT Jaipur09 Oct 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri C.L. Yadav, CAFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR
Section 143(3)Section 144BSection 147Section 69A

issued by Jurisdictional Assessing Officer (JAO) and not Faceless Assessing Officer (FAO)? (C) Whether the issues raised in impugned order show an alleged escapement of income represented in the form of an asset or expenditure in respect of transaction in relation to an event or an entry in the books ... petitioner by Assessing Officer and the Appellate Authority in the earlier years can the Assessing Officer carry a belief that there is escapement of income. 10. Identical issues have been considered by a Division Bench of High Court of Bombay, authored by one of us (the Chief Justice), in Hexaware

Nitaben Girishbhai Patel, Ahmedabad vs. The ITO, Ward-3(3)(2), Ahmedabad

In the result, while upholding the validity of reopening, we set aside the ex parte order of the CIT(A) on merits and restore the matter to his file for fresh adjudication in accordance with law

ITA 1560/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad09 Oct 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Nitaben Girishbhai Patel The Ito, Ward-3(3)(2) 33/B, Swi Park, Private Plot Vejalpur Madhuvrund Society Ahmedabad. Ghatlodiya, Ahmedabad. Pan : Aappp 5738 F (Applicant) (Responent) : Shri Parimalsinh B. Parmar, Ar Assessee By : Shri B.P. Srivastava, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 06/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 09/10/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri B.P. Srivastava, Sr.DR
Section 144BSection 147Section 148Section 271ASection 69A

oversight in forwarding the notices. 3.1 The learned AR of the assessee further contended that the reasons recorded for reopening specifically alleged escapement of income of Rs.83,05,785/- on account of accommodation entries in the form of bogus share transactions. However, in the reassessment order

Urmish M. Udani, Mumbai vs. Aci 10(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 6144/MUM/2017[2009-10]Status: DisposedITAT Mumbai09 Oct 2025AY 2009-10

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Shri Madhur Agrawal/Shri Fenil Bhatt, A/RsFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 139(4)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 68

with the AO, the said return of income can be selected for scrutiny assessment under regular assessment and, therefore, the question of any escapement of income does not arise. In our humble opinion, unless the return of income is scrutinized by the AO or the time limit to scrutinize ... return of income is over, he cannot come to a conclusion of any escapement of income. 8. On identical facts, the Hon'ble High Court of Madras in the case of Commissioner of Income Tax Vs K.M. Pachayappan (2008) 304 ITR 264, quashed the reassessment proceedings. In the facts before

Income Tax Officer, Ward-2(1), Guntur vs. Shivani Cotton Industries Private Limited, Guntur

In the result, appeals ITA

ITA 460/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

invalid to make the ‘protective assessment’ because, in the present case, although, the Assessing Officer has reopened the assessment on the belief of escapement of income, but, finally he has made addition on protective basis, even though, there is no substantive assessment in the case of M/s. Jaya Balajee Real ... reasons recorded for reopening of the assessment by the Assessing Officer is not on the basis of formation of reasonable believe of escapement of income, but, it is only on the basis of reasons to suspect that, the income chargeable to tax had been escaped assessment. In our 30 ITA.Nos

Income Tax Officer, Ward- 1(1), Guntur vs. Potti Kumara Naga Venkata Sai Chakravarthy, Guntur

In the result, appeals ITA

ITA 368/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

invalid to make the ‘protective assessment’ because, in the present case, although, the Assessing Officer has reopened the assessment on the belief of escapement of income, but, finally he has made addition on protective basis, even though, there is no substantive assessment in the case of M/s. Jaya Balajee Real ... reasons recorded for reopening of the assessment by the Assessing Officer is not on the basis of formation of reasonable believe of escapement of income, but, it is only on the basis of reasons to suspect that, the income chargeable to tax had been escaped assessment. In our 30 ITA.Nos

Income Tax Officer, Guntur vs. Madhusushana Venkata Subba Rao Potti, Guntur

In the result, appeals ITA

ITA 367/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

invalid to make the ‘protective assessment’ because, in the present case, although, the Assessing Officer has reopened the assessment on the belief of escapement of income, but, finally he has made addition on protective basis, even though, there is no substantive assessment in the case of M/s. Jaya Balajee Real ... reasons recorded for reopening of the assessment by the Assessing Officer is not on the basis of formation of reasonable believe of escapement of income, but, it is only on the basis of reasons to suspect that, the income chargeable to tax had been escaped assessment. In our 30 ITA.Nos

Assistant Commissioner of Income Tax, Guntur vs. Ms.Vijayasai Lakshmi Srinivasa Cotton Mills, Guntur

In the result, appeals ITA

ITA 359/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

invalid to make the ‘protective assessment’ because, in the present case, although, the Assessing Officer has reopened the assessment on the belief of escapement of income, but, finally he has made addition on protective basis, even though, there is no substantive assessment in the case of M/s. Jaya Balajee Real ... reasons recorded for reopening of the assessment by the Assessing Officer is not on the basis of formation of reasonable believe of escapement of income, but, it is only on the basis of reasons to suspect that, the income chargeable to tax had been escaped assessment. In our 30 ITA.Nos

Income Tax Officer, Ward-2(3), Vijayawada vs. Sreelakshmi Musunuru, Penamaluru

ITA 278/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2013-14

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.278/Viz/2024 (िनधा"रण वष"/Assessment Year: 2013-14) Income Tax Officer, Vs. Sreelakshmi Musunuru, Ward-2(3), Penamaluru. Vijayawada. Pan: Aojpm4884K (Appellant) (Respondent)

For Appellant: Sri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 147Section 148Section 149(1)(b)Section 69

exercises power of reassessment beyond the period of four years from the end of relevant assessment year, an essential requirement is that the escapement of income chargeable to tax is due to the failure on the part of the assessee to disclose truly and fully all material facts. This

Na Roto Machine & Moulds India, Ahmedabad vs. The ACIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1349/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 133ASection 147Section 148ASection 270A

notice u/s 148 of the Act (in other than search cases), the Assessing Officer shall conduct enquiries with reference to the information of escapement of income, if required, and provide an opportunity of being heard to the assessee. After considering the reply of the assessee, the Assessing Officer shall decide ... approval of specified authority. The provision of section 148A of the Act was thus applicable to the cases where the reason for escapement of income was recorded as per the new provisions effective from 01.04.2021. Therefore, the time limit of one month from the end of the month in which

Pitti Holdings Private Limited, Hyderabad vs. ACIT., Central Circle-1(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 450/HYD/2025[2018-19]Status: DisposedITAT Hyderabad08 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

For Appellant: Shri A. Srinivas, C.AFor Respondent: Dr. Sachin Kumar, DR
Section 148Section 148A

information available on record, which according to explanation 1 to sec 148 is the information available with the Assessing Officer suggesting an escapement of income to the extent Rs. 1,25,00,000/- in the case. This is a fit case for issue of notice ... Supreme Court dealt with the following question of law in the course of its judgment: Where an item unconnected with the escapement of income has been concluded finally against the assessee, how far in reassessment on an escaped item of income is it open to the assessee to seek

Shri Parin Seventilal Shah, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 1(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3690/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Oct 2025AY 2013-14
Section 10(38)Section 143(3)Section 147Section 234ASection 254(1)Section 271(1)(c)Section 68

considering the corresponding ground of appeal also rejected submission of the assessee. At the time of recording reasons, mere information, which leads to escapement of income, is sufficient and not full proof conclusion that income of the assessee has escaped assessment. On merits of additional

Huawei International Pte Ltd, Singapore vs. ACIT-Circle 2(1)(1), Intl. Tax, New Delhi

In the result, the appeal of the assessee is allowed and stay application of 7

ITA 2648/DEL/2025[2014-15]Status: DisposedITAT Delhi08 Oct 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganesh & Sa 298/Del/2025 (Assessment Year: 2014-15) Huawei International Pte. Ltd, Vs. Acit, 51, Change Business Park, Circle-2(1)(1), Central-2, #07-08, The International Signature, Singapore Taxation, New Delhi (Appellant) (Respondent) Pan: Aacch3694N Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Aggarwal, Adv Shri Yash Nagar, Adv Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 01/10/2025 Date Of Pronouncement 08/10/2025

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri M. s. Nethrapal, CIT DR
Section 144CSection 147Section 148Section 148ASection 149

deemed to have been complied with." Hence, the objection raised by the assessee stands disposed off. B. Without prejudice to above, no escapement of income as per merits and facts of the case The Assessee is a company incorporated in Singapore and is engaged in the business of providing information

Jagdish Solanki, Jhabua vs. Income Tax Officer Jhabua, Jhabua

ITA 169/IND/2025[2017-18]Status: DisposedITAT Indore07 Oct 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Ashwani Kumra, Chandigarh vs. Assistant Commissioner of Income Tax, Chandigarh

The appeal stand allowed for statistical purposes

ITA 718/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh07 Oct 2025AY 2013-14

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 718/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2013-14) Shri Ashwani Kumra Acit-Ward 2(1) बनाम/ Sco 338, Motor Market Aaykar Bhawan, Sector-17 Vs. Manimajra – 160101 Chandigarh – 160017 "ायीलेखासं /. जीआइआरसं /. Pan/Gir No. Adppk-2516-H (अपीलाथ"/Appellant) : (""थ" /Respondent) अपीलाथ"कीओरसे/Appellant By : Sh. Deepak Aggarwal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 22-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 07/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2013- 14 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 15-05-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 144 R.W.S. 147 Of The Act On 29-03-2022. The Sole Issue That Arises For Our Consideration Is Computation Of Capital Gains. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under. The Assessee Has Also Filed Written Submissions Which Have Duly Been Considered While Adjudicating The Appeal.

For Appellant: Sh. Deepak Aggarwal (Advocate) – Ld. ARFor Respondent: Shri Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 143(1)Section 144Section 148Section 263Section 54Section 54F

that the assessee sold certain immovable property for Rs.58.81 Lacs which was not declared in the regular return of income, the opinion of escapement of income was formed by Ld. AO and the case was reopened. The assessee furnished same return of income but failed to respond to various hearing

Income-Tax Officer, Ward-1, Raichur vs. Maralbid Padmavathi, Raichur

In the result, appeal filed by theRevenue is dismissed

ITA 1006/BANG/2025[2016-17]Status: DisposedITAT Bangalore07 Oct 2025AY 2016-17

Bench: Shri.Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2016-17 Ito, Vs. Maralbid Padmavathi, Ward – 1, 4-4-145, Zahirabad Raichur, Raichur. Raichur – 584 101, Karnataka. Pan :Anhpp 8615 N Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Shankar Ganesh D, Addl. Cit(Dr)(Itat), Bangalore. Date Of Hearing : 12.08.2025 Date Of Pronouncement : 07.10.2025

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Shankar Ganesh D, Addl. CIT(DR)(ITAT), Bangalore
Section 139Section 142(1)Section 143(2)Section 147Section 148Section 271(1)(b)

Assessing Officer and the Assessing Officer has power to reopen, provided there is 'tangible material' to come to conclusion that there is escapement of income from assessment; reasons must have a live link with formation of belief”. In the present case, the JAO was not having any tangible material ... Page 6 of 8 possession to come to conclusion that there is escapement of income from assessment. 5.1 In view of the above discussion, impugned reopening of the assessment is unsustainable in law, so also, the assessment order passed by the AO is also notsustainable on facts and accordingly, both

Narendra Kachrulal Abad, Jalna vs. Income-Tax Officer, Ward - 1, Jalna

In the result, appeal of the assessee partly allowed

ITA 866/PUN/2019[2009-10]Status: DisposedITAT Pune06 Oct 2025AY 2009-10

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.866/Pun/2019 निर्धारण वषा / Assessment Year: 2009-10 Shri Narendra Kachrulal Abad, V The Income Tax Officer, Abad House, Nal Galli, S Ward-1, Jalna. Kadrabad, Jalna – 431203. Maharashtra. Pan: Acspa9531C Appellant/ Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Arvind Renge –Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 06/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)-1, Aurangabadpassed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2009-10 Dated 30.03.2019, Emanating From Order U/S.143(3) R.W.S 147Of The Income Tax Act, 1961, Dated 03.11.2017. The Assessee Has Raised The Following Concise Grounds Of Appeal :

Section 143(3)Section 148Section 250

orders. The reasons do not indicate the 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 in the client code was not on account of a genuine error, originally occurred while punching thetrade

Garje Rudrappa Jayanna, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result, appeals filed by the assessee are partly allowed

ITA 1079/BANG/2025[2018-19]Status: DisposedITAT Bangalore03 Oct 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue
Section 147Section 148Section 148ASection 149Section 271F

under section 147 r.w.s. 144B of the Act is correct and the period of 6 years will apply in this case because escapement of income is more than prescribed limit of Rs.50lakhs at the time of issue of notice as per section 149(1b) of the Act. 5. Considering ... Assessment Year 2018-19 is beyond the period of 3 years as per section 1491(b) of the Act. In this case, escapement of income is less than 50 lakhs. Therefore, the period of more than three years will not apply in this case and learned Counsel strongly relied

Garje Rudrappa Jayanna, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result, appeals filed by the assessee are partly allowed

ITA 1078/BANG/2025[2015-16]Status: DisposedITAT Bangalore03 Oct 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue
Section 147Section 148Section 148ASection 149Section 271F

under section 147 r.w.s. 144B of the Act is correct and the period of 6 years will apply in this case because escapement of income is more than prescribed limit of Rs.50lakhs at the time of issue of notice as per section 149(1b) of the Act. 5. Considering ... Assessment Year 2018-19 is beyond the period of 3 years as per section 1491(b) of the Act. In this case, escapement of income is less than 50 lakhs. Therefore, the period of more than three years will not apply in this case and learned Counsel strongly relied

Jitendra Singh, Bijnor vs. Income Tax Officer, Bijnor

In the result, the Assessee’s appeal is allowed

ITA 3316/DEL/2025[2015-16]Status: DisposedITAT Delhi03 Oct 2025AY 2015-16

Bench: Shri Mahavir Singhasstt. Year : 2015-16 Jitendra Singh, Vs. Acit/Jcit(Appeals) C/O S R Agarwalla & Co., Ca Faridabad / Nfac Shop No. 7, Kisan Inter College Market, Meerut-Karnal Road, Shamli, Uttar Pradesh-246776 (Pan: Ezaps4872M) (Appellant) (Respondent) Appellant By : Sh. Manish Singh, Ca Respondent By : Ms. Harpreet Kaur Hansra, Sr. Dr. Date Of Hearing 09.09.2025 Date Of Pronouncement 03.10.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Ld. Addl/Jcit (A), Faridabad Dated 27.03.2025 Pertaining To Assessment Year 2015-16 On The Solitary Issue Of Addition Of Rs. 13,00,000/- On Account Of Cash Deposit. 2. Heard Both The Sides & Perused The Records. 3. Brief Facts Of The Case Are That The Information Reported In Aims Module Of Itba That The Assessee Had Deposited More Than Rs. 10 Lacs In Different Saving Bank Accounts Maintained By Him During The F.Y. 2014-15 Relevant To Ay 2015-16. A Query Letter As Well As A Notice U/S. 133(6) Of The Income Tax Act, 1961 Was Issued & Served Upon The Assessee Asking Him To Furnish The Source Of Income & Credit

For Appellant: Sh. Manish Singh, CAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 133(6)Section 147Section 69A

sale deed. No cash was deposited after the sale deed. The AO initiated reassessment proceedings under Section 147 of the Act, alleging escapement of income based on information regarding cash deposits in the Appellant's bank account. In the assessment order, the AO treated these cash deposits as unexplained money

Jitendrabhai Bhagvanbhai Dalvadi, Surendranagar vs. ITO Ward 2, Morbi

In the result, the appeal of the assessee is allowed

ITA 466/RJT/2024[2011-12]Status: DisposedITAT Rajkot30 Sept 2025AY 2011-12

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 124Section 127Section 143(3)Section 147Section 234ASection 250Section 254Section 271(1)(c)Section 68

case for assessment year (AY) 2011-12, which was duly served upon the assessee. As such, with a view to bring the escapement of income, if any, to the tax net, the case of the assessee was re-opened resorting the provisions of section 147 of the Act. Thereafter