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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

Jamtaram Viraram Purohit, Mumbai vs. Income Tax Officer, WD-20(2)(1), Mumbai

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

ITA 3561/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Jul 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Prakash Jhunjhunwala, ARFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 115BSection 148Section 68

been issued in mechanical manner, on the basis of borrowed satisfaction and in absence of tangible material, without reason to believe of escapement of income; 4.0 On facts and circumstances of the case and in law, Ld. CIT(A) ought to have deleted the addition made u/s.68 r.w.s 11SBBE

Shashwat R Belapurkar, Mumbai vs. Principal Commissioner of Income Tax-42, Mumbai

In the result, appeal is allowed

ITA 2600/MUM/2025[2013-14]Status: DisposedITAT Mumbai31 Jul 2025AY 2013-14

Bench: Shri Saktijit Dey, Vp & Shri Narendra Kumar Billaiya, Am Shashwat R Belapurkar, Pcit-42, C/O Ca Himanshu Gandhi 16Th Floor, Room No.808, Kautilya Bhavan, C- D Wing, Trade World Tower, Kamala Vs. 41 To C-43, Block, Bandra Kurla Mills Compound, Lower Parel (W), Complex, Bandra (East), Mumbai-400013 Mumbai 400051 (Appellant) : (Respondent) Pan No. Aajpb 9995J Appellant By : Shri Himanshu Gandhi Respondent By : Ms. Kavita P. Kaushik, Sr. Dr (Appellant) (Respondent) Date Of Hearing : 31.07.2025 Date Of Pronouncement : 31.07.2025

For Appellant: Shri Himanshu GandhiFor Respondent: Ms. Kavita P. Kaushik, Sr. DR
Section 143(1)Section 147Section 148Section 263

some information, assessment in case of the assessee was reopened u/s. 147 of the Act. The reopening of assessment was because of alleged escapement of income of more than Rs.1,00,000/-, being the amount invested by the assessee towards purchase of the immovable property. In response to notice

Urvi Hitalkumar Patel, Mumbai vs. ITO Ward 33(1)(1), Mumbai, Bkc

In the result, appeal of the assessee is allowed

ITA 2406/MUM/2025[2015-16]Status: DisposedITAT Mumbai31 Jul 2025AY 2015-16

Bench: Shri Amit Shukla & Smt. Renu Jauhriआयकर अपील सुं./Ita No.2406/Mum/2025 (नििाारण वर्ा/Assessment Year: 2015-16) Urvi Hitalkumar Patel V/S. Income Tax Officer, B 1101, Shreenath Tower, बिाम Ward 33(1)(1), Mumbai Shankar Lane, Kandivali Kautilya Bhavan, G Block, West 400067 Bkc, Bandra East 400051. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Cevpp8858L Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Manish Sheth राजस्व की ओर से /Revenue By: Shri Asif Karmali (Sr Dr)

For Appellant: Shri Manish ShethFor Respondent: Shri Asif Karmali (SR DR)
Section 147Section 148Section 148ASection 149(1)(b)Section 250Section 69

valuation was made at Rs. 37,26,000/-. Accordingly, a notice u/s. 148A(b) was issued by the AO on 30.03.2022 for the escapement of income on account of purchase of two immovable properties for Rs. 33,12,500/- and Rs. 37,26,000/- during the period under consideration. Since ... compared with the threshold limit of Rs.50,00,000/- stipulated therein. In the appellant's case, the condition of such likely escapement of income exceeding the threshold limit was very much satisfied.” 4. On merits, Ld. CIT(A) directed the AO to examine the issue afresh after giving opportunity

DCIT-2(1)(1), Mumbai vs. Bp Comtrade Pvt. Ltd., Mumbai

In the result, cross objection filed by the assessee is allowed

ITA 6645/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Jul 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Jay Bhansali, ARFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 147r

already offered the profit/ (loss) in said scrips to tax under business income head; hence, in any case there would be no escapement of income. Hence, it appears that the addition has been made by the Assessing Officer of Rs. 1,79,18,081/- just for sake of making addition ... assessment proceedings. We note that reopening is based on wrong and irrelevant facts, recorded under the reasons for formation of belief for escapement of income without any verification or examination by the ld. AO. Considering the above discussion including a detailed analysis of correct factual position, we are in agreement

DCIT-2(1)(1), Mumbai vs. Bp Comtrade Pvt. Ltd., Mumbai

In the result, cross objection filed by the assessee is allowed

ITA 6644/MUM/2024[2017-18]Status: DisposedITAT Mumbai31 Jul 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Jay Bhansali, ARFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 147r

already offered the profit/ (loss) in said scrips to tax under business income head; hence, in any case there would be no escapement of income. Hence, it appears that the addition has been made by the Assessing Officer of Rs. 1,79,18,081/- just for sake of making addition ... assessment proceedings. We note that reopening is based on wrong and irrelevant facts, recorded under the reasons for formation of belief for escapement of income without any verification or examination by the ld. AO. Considering the above discussion including a detailed analysis of correct factual position, we are in agreement

DCIT-2(1)(1), Mumbai vs. Bp Comtrade Pvt. Ltd., Mumbai

In the result, cross objection filed by the assessee is allowed

ITA 6643/MUM/2024[2016-17]Status: DisposedITAT Mumbai31 Jul 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Jay Bhansali, ARFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 147r

already offered the profit/ (loss) in said scrips to tax under business income head; hence, in any case there would be no escapement of income. Hence, it appears that the addition has been made by the Assessing Officer of Rs. 1,79,18,081/- just for sake of making addition ... assessment proceedings. We note that reopening is based on wrong and irrelevant facts, recorded under the reasons for formation of belief for escapement of income without any verification or examination by the ld. AO. Considering the above discussion including a detailed analysis of correct factual position, we are in agreement

ACIT-2(3)(1), Mumbai vs. Tata Capital Limited (Successor to Tata Cleantech Capital Limited), Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3456/MUM/2024[2016-17]Status: DisposedITAT Mumbai31 Jul 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2016-17

For Appellant: Shri Anish Thacker, CAFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 143(3)Section 147Section 148Section 36(1)(viii)Section 80Section 80I

eligible for claim of Infrastructure Facility” 6.1. Based on the above information, ld. Assessing Officer formed this reason to believe about escapement of income on account of claim of deduction of Rs. 7.5 crores u/s. 36(1)(viii) as noted in para 6 which is reproduces below: 5 Tata Capital

Msg All Trading International Private Limited, East Azad Nagar vs. DCIT, Circle-11(1), Delhi

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

ITA 3195/DEL/2023[2016-17]Status: DisposedITAT Delhi31 Jul 2025AY 2016-17

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2016-17] Msg All Trading International Vs Dcit, Pvt.Ltd., Office No.2, 3Rd Floor, Circle-11(1), 80, East Azad Nagar, Delhi Raghuvarpura, Shahdara, Delhi-110051. Pan-Aajcm6792K Appellant Respondent Appellant By Shri Ved Jain, Adv., Shri Aman Garg, Ca & Ms. Ishika Dua, Ca Respondent By Shri Virender Kumar Singh, Sr.Dr Date Of Hearing 08.05.2025 Date Of Pronouncement 31.07.2025 Order

Section 143(3)Section 147Section 148Section 151Section 250Section 68

submitted that assessee during the course of proceedings before the AO has disclosed all facts relating to deposits and thus there is no escapement of income. 11. Further, the reopening of assessment has to be tested upon the basis of reason recorded at the time of issuing notice under section ... filed, it could not be ascertained where these accounts declared in the return of income therefore, the AO has recorded the satisfaction of escapement of income which in our considered opinion is correct. It is further seen that merely stating that credits in these accounts were not verified

Dalgir Kaur, Ghagga vs. ITO Ward Samana, Patiala

In the result, appeal of the assessee is partly allowed

ITA 131/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh30 Jul 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 131/Chd/2025 "नधा"रण वष" / Assessment Year : 2012-13 Dalgir Kaur, बनाम The Ito, W/O Shri Sadhu Singh, Ward Samana, Vs Atala Road, Ward No.5, Patiala. Vpo – Ghagga. "थायी लेखा सं./Pan /Tan No: Ddwpk1857D अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Rakesh Cajla, Advocate & Shri Armaan Cajla, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr तार"ख/Date Of Hearing : 07.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 30.07.2025

For Appellant: Shri Rakesh Cajla, Advocate and Shri Armaan Cajla, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr.DR
Section 144Section 147Section 151Section 282Section 69A

possessing complete information for formulating a belief that income has escaped assessment. The reasons are based on mere suspicion of escapement of income. For buttressing this contention, he relied upon the following decisions : Sr.No. Nature of Document 1. Sh. Mahavir Parsad Vs. The I.T.O. (ITAT Delhi) 2. Sh. Rajesh Chunara ... assessee that if no specific information is available to the AO, which has a live nexus with the formation of belief exhibiting escapement of income, then ITA 131/CHD/2025 A.Y. 2012-13 6 assessment cannot be reopened, but here is a case where assessee is a non-filer of Income

Adesh Bhujangrao Nagawade, Shrigonda vs. Income Tax Officer, Ward-1, Ahilyanagar

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

ITA 71/PUN/2025[2017-18]Status: DisposedITAT Pune30 Jul 2025AY 2017-18

Bench: Dr. Manish Boradआयकर अपील सं. / Ita No.71/Pun/2025 िनधा"रण वष" / Assessment Year: 2017-2018

For Appellant: Shri Prasad BhandariFor Respondent: Shri Dayanand Jawalikar
Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69A

u/s.44AB of the Act. He further submitted that based on the reply given by the assessee, there remained no scope to believe for escapement of income and therefore the AO ought to have dropped the re-assessment proceedings. 5.(b) So far as merits of the case are concerned

Vikas Dattu Deokar, Pune vs. ITO Ward 14(1), Pune

In the result, appeal of the assessee is partly allowed

ITA 1012/PUN/2025[2016-17]Status: DisposedITAT Pune30 Jul 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1012/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 Vikas Dattu Deokar, V The Income Tax Officer, S.N.126/1, Plat No.18A, S Ward-14(1), Pune. Z Corner, Matoshri Niwas, Manjari Bk, Manjari Budruk, Po: Manjari Farm, Dist: Pune, Maharashtra – 412307. Pan: Aispd7124N Appellant/ Assessee Respondent / Revenue Assessee By Smt. Deepa Khare – Ar Revenue By Shri Eknath Abhang –Addl.Cit(Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 30/07/2025 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)[[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2016-17 Dated 20.02.2025, Emanating From Order U/S.144 Of The Income Tax Act, 1961, Dated 17.05.2023. The Assessee Has Raised Following Grounds Of Appeal :

Section 144Section 147Section 148Section 148ASection 149Section 250

must be adjudicated by this Tribunal. Ld.AR submitted that Assessing Officer has ITA No.1012/PUN/2025 [A] passed an order u/s.148A(d) on 28.06.2022 alleging escapement of income of Rs.10 lakhs for A.Y.2016-17. Thus, the income alleged to have escaped assessment is less than Rs.50 lakhs and the notice u/s.148 was issued ... needs to be offered for taxation in the A.Y. 2016-17". 4.2 Thus, it can be noted that the Assessing Officer has alleged escapement of income of Rs.10 lakhs only for A.Y.2016-17. The order u/s.148A(d) was passed on 28.06.2022 and notice u/s.148 was issued on 29.06.2022. 4.3 The Section

Ashok Dhanraj Chordia, Pune vs. PCIT, Pune-1, Pune

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

ITA 977/PUN/2024[2017-18]Status: DisposedITAT Pune30 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 132Section 143(1)Section 143(2)Section 147Section 148Section 263

surplus funds and the borrowers who are in need of funds. Therefore, after recording due satisfaction and reason to believe with respect to escapement of income and after obtaining the necessary statutory prior approval through ITBA system from Addl. Commissioner of Income Tax, Range-2, Pune, a notice ... received, analysis of information collection/received, enquiries made by the AO, findings of the AO, basis of forming reason to believe and details of escapement of income, applicability of provisions of section 147/151 to the facts of the case etc. Under the heading ‘enquiries made by the Assessing Officer’, the Assessing

M/S. Lookline Vincom Pvt. Ltd., Kolkata vs. ITO, Ward 6(2), Kolkata

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

ITA 461/KOL/2025[2018-19]Status: DisposedITAT Kolkata30 Jul 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Income Tax Officer-6(2), Ward 6(2), M/S Lookline Vincom Pvt. Ltd. Aayakar Bhawan, P-7, 14-C, M.D. Road, 4 Th Floor, Chowringhee Square, Vs. Kolkata-700007 Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aaccl2244C

For Appellant: Shri Monaj Kataruka, ARFor Respondent: Ms. Ranu Biswas, DR
Section 148Section 148ASection 68

also note that in the annexure attached to notice u/s 148A(b) of the Act there has been no whisper about the escapement of income. Thereafter the ld. AO passed the order u/s 148A(d) of the Act dated 06.04.2022, wherein it has been stated that the assessee was given

Narayana Rao Sujatha, Chamarajanagar vs. Income Tax Officer, Ward-1, Chamarajanagar

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

ITA 803/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Jul 2025AY 2017-18

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

For Appellant: Shri R Chandrashekar, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate for Standing
Section 143(2)Section 148Section 234Section 250Section 69A

Appellant's case. c. That there is no tangible material available with the learned assessing officer to substantiate that there is escapement of income in the hands of appellant on the facts and circumstances of the case. d. That there is no sanction accorded under section

Income Tax Officer-12(3)(1), Mumbai vs. Manju Diamonds Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is allowed for statistical purposes whereas the application under Rule 27 of statistical purposes whereas the application under Rule 27

ITA 2766/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jul 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18 Ito-12(3)(1), Manju Diamonds Pvt. Ltd., R.No. 145, 1St Floor, Aayakar 57/59, 1St Floor, Nagdevi Street, Vs. Bhavan, M.K. Road, Maszid Bunder, Mumbai-400020. Mumbai-400 003. Pan No. Aaecm 6609 G Appellant Respondent

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Ms. Dinkle Hariya
Section 133(6)Section 68

escaped assessment. It is not necessary to chargeable to tax has escaped assessment. It is not necessary to establish the escapement of income to a final conclusion at the establish the escapement of income to a final conclusion at the establish the escapement of income to a final conclusion ... recorded reasons based on specific and credible The AO has recorded reasons based on specific and credible information that prima facie indicated escapement of income; information that prima facie indicated escapement of income; information that prima facie indicated escapement of income;  The procedural safeguards envisaged under Section 147 have

Sudhir Bansal, Bhilai, Durg vs. Assistant Commissioner of Income Tax-1(1), Bhilai, Durg

In the result, appeal of the assessee is allowed

ITA 98/RPR/2025[2011-12]Status: DisposedITAT Raipur29 Jul 2025AY 2011-12

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.98/Rpr/2025 "नधा"रण वष" / Assessment Year : 2011-12 Sudhir Bansal 8, Civic Centre, Bhilai, Dist. Durg-490 006 (C.G.) Pan: Adbpb3234H

For Appellant: Shri S.R. Rao, AdvocateFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 147Section 148(2)

reopened u/s. 147/148 of the Act as per information of the Commercial Tax Department, Chhattisgarh i.e. on borrowed satisfaction and no satisfaction regarding escapement of income recorded by the A.O in the “reasons to believe” as per his independent application of mind. It is settled legal position that the reassessment ... there is no whisper about any 6 Sudhir Bansal Vs. ACIT-1(1), Bhilai ITA No.98 /RPR/2025 satisfaction recorded by the assessee regarding escapement of income in respect of the assessee. 7. In such scenario, we find that the Hon’ble High Court of Bombay in the case of Principal

Santoshi Arora, Bemetara vs. Assessing Officer 1(3), Bhilai

ITA 312/RPR/2025[2016-17]Status: DisposedITAT Raipur29 Jul 2025AY 2016-17

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 312/Rpr/2025 (िनधा"रण वष" Assessment Year: 2016-17)

For Appellant: Shri S. R. Rao, AdvFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 147Section 250Section 69A

case of escapement of taxable income which is to be assessed to tax. 6. Basis of forming reason to believe and details of escapement of income In view of the facts, I am of the opinion that the income of the assessee is exceeded the maximum amount which ... deeming provisions of clause (a) of explanation 2 to section 147 is attracted in this case and, it is a fit case of escapement of income for the financial year under consideration. In view of the above, I have reason to believe that the income to the extent

Nine Export LLP, Johari Bazar, Jaipur vs. Income Tax Officer Ward 4(2) Jaipur, Jaipur

In the result, both appeals filed by the assessee are allowed for statistical purposes

ITA 701/JPR/2025[2018-19]Status: DisposedITAT Jaipur29 Jul 2025AY 2018-19

Bench: Dr.Manish Borad

For Appellant: Ms. Twinkle Jain, AdvFor Respondent: Shri Shri Gautam Singh
Section 147Section 250(6)Section 270A

144B of the Income Tax Act, 1961 which is void ab- initio deserves to be quashed as there was no escapement of income. 2. On the facts and in the circumstances of the case and in law, the Learned CIT(A) was wrong and unjust in confirming in making ... levied the Penalty u/s 270A of the IT Act, 1961 which is void ab-initio deserves to be quashed as there was no escapement of income. 2. On the facts and in the circumstances of the case and in law, the Learned CIT(A) was wrong and unjust in confirming

Nine Export LLP, Jaipur vs. Income Tax Officer Ward 4(2) Jaipur, Jaipur

In the result, both appeals filed by the assessee are allowed for statistical purposes

ITA 700/JPR/2025[2018-19]Status: DisposedITAT Jaipur29 Jul 2025AY 2018-19

Bench: Dr.Manish Borad

For Appellant: Ms. Twinkle Jain, AdvFor Respondent: Shri Shri Gautam Singh
Section 147Section 250(6)Section 270A

144B of the Income Tax Act, 1961 which is void ab- initio deserves to be quashed as there was no escapement of income. 2. On the facts and in the circumstances of the case and in law, the Learned CIT(A) was wrong and unjust in confirming in making ... levied the Penalty u/s 270A of the IT Act, 1961 which is void ab-initio deserves to be quashed as there was no escapement of income. 2. On the facts and in the circumstances of the case and in law, the Learned CIT(A) was wrong and unjust in confirming

Amarjit Singh, Ludhiana vs. Income Tax Officer, Ward 6(1) Ludhiana, Ludhiana

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

ITA 1171/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh29 Jul 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 1171 /Chd/2024 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Amarjit Singh बनाम The ITO C/o V V Bhalla & Company Ward 6(1) SCF-39, Rishi Nagar Main Market, Ludhiana Adjoining Subway, Ludhiana-141001, Punjab स्थायी लेखा सं./PAN NO: ABTPS8558B अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से / Assessee by : Shri Pankaj Bhalla, C.A राजस्व की ओर से/ Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr

For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 144ASection 147Section 148Section 151Section 250Section 250(6)Section 270A

proceedings under sections 270A and 272A(1)(d). The Ld. AO had initiated reassessment proceedings under section 148 read with section 144A alleging escapement of income and made the aforesaid addition, which was also followed by initiation of penalty proceedings under the mentioned sections. The assessee objected to the reassessment