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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

Manubhai Dahyabhai Bhoi, Godhra vs. ITO, Ward 1, Godhra

In the result, the appeal of the assessee is allowed

ITA 779/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Pratik Sharma, Sr. DR
Section 144Section 147Section 250Section 44ASection 69A

invoking provisions of Section 147 and 148 of the Act. On facts and circumstances of the case, there is not at all any escapement of income on part of Appellant. It is therefore submitted that the whole reopening of assessment is bad in law and void ab initio

Hiral Tapankumar Chudgar, Vadodara, Gujarat vs. Income Tax Officer, Ward 1(3)(1), Vadodara, Gujarat

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

ITA 44/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 10(38)Section 147Section 148Section 148ASection 69Section 69A

claimed by the assessee by filing the return within the Section 139(1) or u/s 147 of the Act. Thus there is no escapement of income, therefore the reassessment proceedings is liable to be deleted. Thus the ground no. 1 raised by the assessee is allowed and remaining grounds does

Hiral Tapankumar Chudgar, Vadodara, Gujarat vs. Income Tax Officer, Ward 1(3)(1), Vadodara, Gujarat

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

ITA 43/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar, Judicial Member And\nShri Makarand Vasant Mahadeokar, Accountant Member\nITA Nos 43 & 44/Ahd/2025\nAssessment Years: 2017-18 & 2018-19\nHiral Tapankumar\nChudgar\n201/A, Premdarshan,\nBehind Jay Ambe School,\nSamasavli Raod, Vemali,\nVadodara-390008,\nGujarat\nPAN: ANCPC4000H\n(Appellant)\nIncome Tax Officer\nWard-1(3)(1),\nVs Vadodara\n(Respondent)\nAssessee Represented:\nShri Deepak Shah, A.R.\nRevenue Represented:\nShri Abhijit, Sr.D.R.\nDate of hearing\n: 18-06-

Section 10(38)Section 115BSection 147Section 148Section 148ASection 69Section 69A

claimed by the assessee by filing the return within the Section 139(1) or u/s 147 of the Act. Thus there is no escapement of income, therefore the reassessment proceedings is liable to be deleted. Thus the ground no. 1 raised by the assessee is allowed and remaining grounds does

Urveen Shivprasad Vyas, Ahmedabad vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

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

ITA 1119/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2018-19

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokarasstt.Year : 2018-2019 Urveen Shivprasad Vyas The Dcit, Cir.2(1)(1) 2, Dev Vihar-H Vs. Ahmedabad. B/H. Vrundavan Bungalows Thaltej-Shilaj Road, Ahmedabad. Pan : Ablpv 7563 R (Applicant) (Responent) Assessee By : Shri Prithu Parimal, Advocate : Shri Amit Pratap Singh, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 12/08/2025

For Appellant: Shri Prithu Parimal, Advocate
Section 147Section 148Section 148ASection 250

under Section 148 suffer from procedural infirmities, notably the absence of any credible prima facie evidence or reasons suggesting escapement of income, thereby rendering such reopening invalid in the eyes of law. 13. The Ld. AO and Ld. CIT(A) have both failed to appreciate the binding judicial precedents laid

ITO Ward 5(3)(1), Ahmedabad vs. Harsha Asheshbhai Patel, Ahmedabad

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

ITA 1074/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 147Section 148Section 69ASection 69C

notice under Section 148 of the Act. The approving authority is not required to record his own reasons as to how there was escapement of income. This responsibly is cast on the Assessing Officer and not on the approving authority. In view of these facts, the finding

New Laxmi Enterprises, Jogeshwari East, Mumbai vs. The Income Tax Officer, Ward 41(4)(3), Mumbai

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

ITA 2789/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Aug 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18 New Laxmi Enterprises The Income Tax Officer, 702, Laxmi Narayan Apartments, Ward 41(4)(3), Mumbai Rane Compound, Natvar Nagar Vs. Road No. 1, Jogeshwari East, Mumbai - 400060 (Pan : Aadfn2479B) (Appellant) (Respondent) Present For: Assessee : Shri Amit Kothari, Ca Revenue : Shri Leyaqat Ali Aafaqui, Sr. Ar Date Of Hearing : 05.08.2025 Date Of Pronouncement : 12.08.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2024-25/1073736005(1), Dated 26.02.2025 Passed Against The Assessment Order By Assessment Officer, Mum-W- (404)(93), U/S. 147/148 Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 21.05.2023 For Assessment Year 2017-18. 2. Grounds Taken By The Assessee Are Reproduced As Under: " 1) The Learned Commissioner Of Income Tax (Appeals) Ered In Upholding The Addition Of Rs. 1,58,23,513 Without Appreciating The Fact That The Appellant Is A Builder & The Flats Sold Were Stock In Trade Which Is Chargeable To Tax Under The Head Business Income & Not Capital Gains. 2) The Learned Commissioner Of Income Tax (Appeals) Ought To Have Considered That Out Of The Addition Of Rs 1,58,23,513, Sale Value Of Flats Of Rs. 1,56,42,514

For Appellant: Shri Amit Kothari, CAFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR
Section 147Section 148Section 43CSection 44ASection 50C

sold number of properties during the year and no capital gain was offered in the return of income filed by it, leading to escapement of income. He thus completed the assessment by making an addition of Rs. 1,58,23,513/- on account of variation in respect of sale consideration

Assistant Commissioner of Income Tax, 4(1)(1), Mumbai vs. Haresh Shantichand Jhaveri, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 1971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Aug 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Prabhash Shankarassistant Commissioner Of V/S. Haresh Shantichand Income Tax, Ward – 4(1)(1), बनाम Jhaveri, Room No. 642, Aaykar Bhavan, Ps 6-7 Rotunda Bldg, M.K. Road, Churchgate, Samachar Marg, Mumbai – Mumbai–400 020, Maharashtra 400 023, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabpj8053B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Nitin Shantilal Doshi, ARFor Respondent: Shri Hemanshu Joshi (Sr. DR)
Section 147

that merely because assessee’s name figured in a list of constituents or beneficiaries as per investigation did not amount to evidence of escapement of income or bogus transactions. The AO has treated this ‘list’ as gospel of truth and made adverse inferences without independent corroboration. He did not make

M/S. India Exposition Mart Ltd., New Delhi vs. DCIT, New Delhi

Appeal of the Assessee stands allowed

ITA 1079/DEL/2016[2009-10]Status: DisposedITAT Delhi12 Aug 2025AY 2009-10

Bench: Shri Mahavir Singhshri Kuldip Singh & Shri Anadee Nath Misshra, Accountnat Member Shri Vikas Awasthy & Shri Brajesh Kumar Singh

For Appellant: Shri A. K. Khanna, C. A./NoneFor Respondent: Shri M.S. Nethrapal, CIT-DR
Section 139(1)Section 147Section 148

April, 1989, Assessing Officer has power to re-open, 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.” 16. Hon’ble jurisdictional High Court in the case cited

Kanaiyalal Labhubhai Narola, Surat vs. The Asstt. Commissioner of Income Tax, Circle-3, (2), Surat

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

ITA 816/SRT/2023[2014-15]Status: DisposedITAT Surat11 Aug 2025AY 2014-15

Bench: Ms Suchitra Raghunath Kamble & Shri Buayananda Pruseth

Section 131Section 132Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

relevant material on the basis of which a reasonable person could have formed the requisite belief. Whether the material would conclusively prove escapement of income is not the concern at that stage. The CIT(A) also relied on the decision of the Hon’ble Gujarat High court in case ... wherein he has argued against validity of re-opening u/s 147 of the Act and submitted that the AO should satisfy himself regarding escapement of income. He should not mechanically reopen the assessment based on the information supplied by any other person. The AO has not analyzed the transaction mentioned

Sh. Kapil Taneja, Jaipur vs. The Deputy Commissioner of Income Tax Circle-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 578/JPR/2025[2017-18]Status: DisposedITAT Jaipur11 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Gorav Avasthi, JCIT
Section 144BSection 147Section 148Section 148ASection 151ASection 69A

escaped assessment and thus, it is submitted that since there was no independent application of mind by ld.AO while recording the satisfaction of escapement of income before issue of notice u/s 148 and he simply proceeded on borrowed satisfaction reached by some other officials without verifying the same, therefore

Unique Mercantile India Limited, Ahmedabad vs. The Principal Commissioner of Income Tax Ahmedabad - 3, Ahmedabad

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

ITA 748/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad11 Aug 2025AY 2018-19

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Vartik Chokshi, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 143(3)Section 263Section 32

revenue on the ground that Id. Assessing Officer has not made inquiries with reference to claim of depreciation on goodwill and issue of escapement of income with respect to Unique Mercantile India Ltd. vs. PCIT Asst.Year –2018-19 - 2– transaction reflecting in the PAN of amalgamating company (Unique mercantile India ... Officer had accepted the returned income that inter- alia includes the allegation of Rs. 20,92,49,727/- accepted that there is no escapement of income vide Assessment Order dated 07-04-2021. Thus, not considering the same results into arbitrary passing of the order thus such order deserves

SHI vs. Hankar Agarwal Hufhuf, Andheri (East)Vs.Income Tax Officer 31(2)(1), Mumbai, Bandra (East)

Appeal of the assessee is allowed

ITA 2468/MUM/2024[2010-11]Status: DisposedITAT Mumbai11 Aug 2025AY 2010-11

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Ashok Bansal & Shri AjayFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 148Section 250Section 251

despite several opportunities given and after perusal of assessment records, no proof is available with respect to supply of the reasons recorded for escapement of income for our verification. Merely because in the assessment order at Para 4 ,it is stated that the reasons for reopening were provided

Geeta, New Delhi vs. ITO Ward-2, Rohtak

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

ITA 3716/DEL/2025[2016-17]Status: DisposedITAT Delhi11 Aug 2025AY 2016-17

Bench: Shri Mahavir Singha.Yr. : 2016-17 Geeta Ito, Ward-2, Rohtak B-50, Lgf, South Extension-Ii, Vs. New Delhi – 49 (Pan: Aaypg9406A) (Appellant) (Respondent)

For Appellant: Shri Shantanu Jain, Adv. &For Respondent: Shri Sangeet Bansal, Sr. DR
Section 147Section 148Section 151

transpires from records, that there is no tangible material, which is a pre-condition, available with the AO to allege the escapement of income, the reopening tantamount to only review of original assessment based on change of opinion which is not permissible u/s 147/148, as per settled ... 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. 6.3 In the background of the aforesaid discussions and respectfully

Sumit Suneja, Delhi vs. Assistant Commissioner of Income Tax, Circle 34(1), Delhi

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

ITA 3688/DEL/2025[2011-12]Status: DisposedITAT Delhi11 Aug 2025AY 2011-12

Bench: Shri Mahavir Singha.Yr. : 2011-12 Sumit Suneja, Vs. Acit, Circle 34(1), H-34, Pocket-17, Sector-3, Rithala, New Delhi Rohini, Delhi – 85 (Pan: Aaypg9406A) (Appellant) (Respondent)

For Appellant: Shri Suregsh Gupta, CAFor Respondent: Shri Sangeet Bansal, Sr. DR
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

Udhavrao Raghunath Kharate, Aurangabad vs. ITO Ward-1(1), Aurangabad

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

ITA 1470/PUN/2025[2011-12]Status: DisposedITAT Pune08 Aug 2025AY 2011-12

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1470/Pun/2025 निर्धारण वषा / Assessment Year: 2011-12 Udhavrao Raghunath Kharate, V The Income Tax Officer, 220/1, Raghunandini Niwas, S Ward-1(1), Aurangabad. Near Bsnl Tower, At Post Maniknagar, Teh. Sillod District, Aurangabad – 431135. Pan: Apupk3432R Appellant/ Assessee Respondent / Revenue Assessee By Shri Ramesh N. Thete –Ar(Virtual) Revenue By Shri Ajay D. Kulkarni – Addl.Cit(Dr) Date Of Hearing 06/08/2025 Date Of Pronouncement 08/08/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(A)-1, Gurugram Passed Under Section 250 Of The Income Tax Act, 1961 Dated 24.04.2025 For The A.Y.2011-12 Emanating From The Assessment Order Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961, Dated 05.12.2018. Ita No.1470/Pun/2025 [A] Submission Of Ld.Ar :

Section 143(3)Section 147Section 250Section 44ASection 68

within the knowledge of the AO even at the time of reopening. Mere deposit of cash, without any further tangible material indicating escapement of income, does not constitute "reason to believe" within the meaning of Section 147. Thus, the reopening is bad in law and deserves to be quashed

Daya Shanker Tiwari, Hyderabad vs. Income Tax Officer, Ward-6(1), I T Tower, Hyderabad

In the result, appeal of the assessee is allowed

ITA 827/HYD/2025[2017-18]Status: DisposedITAT Hyderabad08 Aug 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, K A Sai PrasadFor Respondent: Shri Vinod Kannan, Sr. AR
Section 143(3)Section 147Section 148Section 69A

other hand, supporting the order of the learned CIT(A) submitted that, the Assessing Officer has reopened the assessment on the ground of escapement of income on account of under assessment of gift received from Sri Pradeep Tiwari. Although, the assessee claims to have received gift of Rs.11 lakhs ... Assessing Officer has made addition of Rs.5 lakhs in the original assessment, which resulted in escapement of income to the tune of Rs.6 lakhs. The Assessing Officer after considering the relevant facts, has rightly reopened the assessment and, therefore, the argument of Counsel for the Assessee that, it is change

Khajamoinuddin Mahammad, Warangal vs. Income Tax Officer, Ward -1, Warangal

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

ITA 571/HYD/2025[2016-17]Status: DisposedITAT Hyderabad08 Aug 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri K.A. Sai Prasad, C.AFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139Section 147Section 148Section 148ASection 250Section 69Section 69A

source of the time deposit had already been accounted for in the cash deposit item. The Ld. AR, therefore, contended that the only escapement of income, if any, is Rs.32,13,500/-, which is below the monetary threshold of Rs.50,00,000/- specified in section ... single bank account, and denied that the assessee held any other bank accounts. He also submitted that, the correct amount of alleged escapement of income is Rs.32,13,500/-, which is less than the threshold limit of Rs.50 lakhs. Accordingly, the Ld. AR prayed that the notice issued under section

Children Welfare Trust (Regd), Faridabad vs. CIT Exemption, Chandigarh

In the result, Appeal of the Assessee is allowed

ITA 3637/DEL/2024[2016-17]Status: DisposedITAT Delhi08 Aug 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 3637/Del/2024 (A.Y 2016-17) Children Welfare Trust (Regd) Vs National Faceless C/O. Gita Balniketan Senior Assessment Centre, Secondary School, 3-E, Nit, Delhi (Nafac) Faridabad Delhi Pan: Aabtc6957B Appellant Respondent Assessee By Sh. Pavan Ved, Adv, Shri Mohit Gupta, Ca, Sh. Mirza, Ca & Shri Sarthakkh Aggarwal, Ca Revenue By Ms.Pooja Swaroop, Cit(Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 08/08/2025

Section 11(6)Section 139Section 143(3)Section 147Section 148Section 263

payment account nor in ITR under the schedule 'Voluntary Contributions'. 6. basis of forming reason to believe and details of escapement of income:- In view of the above facts, amount of Rs. 1,13,08,822/- is to be added back to the taxable income of the assessee trust

Sh. Sukhbir Singh Badal, Muktsar vs. The Dy. Commissioner of Income Tax, Bathinda

Appeal stand allowed

ITA 411/ASR/2010[2000-01]Status: DisposedITAT Amritsar07 Aug 2025AY 2000-01

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm आयकर अपील सं./ Ita No. 411/Asr/2010 (िनधा"रण वष" / Assessment Year: 2000-01) Shri Sukhbir Singh Badal Dcit-Circle-Ii बनाम/ Vs. S/O Parkash Singh Badal Bhatinda. Vpo Badal, District Muktsar "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abspb-1568-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Shri Ashwani Kumar, Ms. Deepali Aggarwal Ms. Muskan Garg (Cas) –Ld. Ars ""थ"कीओरसे/Respondent By : Sh. Charan Dass (Addl. Cit) – Ld. Sr. Dr

For Appellant: ShriFor Respondent: Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR
Section 143(3)Section 147Section 148Section 2Section 2(22)(e)Section 250(6)Section 69

assessee to the department. Further, certain loans claimed by the assessee were alleged to be non-genuine. Accordingly, the belief of escapement of income was formed by Ld. AO. The Ld. AO rejected assessee’s objections to reopening and proceeded to frame the assessment on the assessee by making certain

Bharat Benefication & Power Pvt. Ltd., Raigarh vs. Pr.Commissioner of Income Tax (Central), Bhopal

ITA 336/RPR/2025[2018-19]Status: DisposedITAT Raipur07 Aug 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 336/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: Shri R. B. Doshi, CAFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 143(3)Section 147Section 263Section 36(1)(va)Section 80G

reopening, as per settled principle of law if any addition / disallowance is made qua the issue on account of which the belief of escapement of income has been formed and the proceedings are initiated u/s 147 of the Act, it would be incumbent upon the Ld. AO to look into