← All Phrases

“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

Vrindavan Builders Pvt Ktd, Nagaland vs. ACIT Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 696/COCH/2024[2013-14]Status: DisposedITAT Cochin09 Jun 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

Further it is submitted that the A.O had failed to provide the Assessee with copy of the satisfaction sheet where the Reasons for escapement of income had been recorded by him and also failed to provide the copy of approval granted by the appropriate authority ... under Section 148 on the ground that the Assessing Officer is of the opinion that a contingency may arise in future resulting an escapement of income. That would, in our view, be wholly impermissible and would amount to a rewriting of the statutory provision. Moreover, the reliance which is sought

Vrindavan Builders Pvt Ltd, Nagaland vs. ACIT, Central Circle, Kollam

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

ITA 695/COCH/2024[2012-13]Status: DisposedITAT Cochin09 Jun 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

Further it is submitted that the A.O had failed to provide the Assessee with copy of the satisfaction sheet where the Reasons for escapement of income had been recorded by him and also failed to provide the copy of approval granted by the appropriate authority ... under Section 148 on the ground that the Assessing Officer is of the opinion that a contingency may arise in future resulting an escapement of income. That would, in our view, be wholly impermissible and would amount to a rewriting of the statutory provision. Moreover, the reliance which is sought

Deputy Commissioner of Income Tax, Central Circle, Kollam vs. Allebasi Builders and Developers (P) Ltd, Attingal

In the result, appeal filed by the assessee stands allowed and Revenue’s appeal and assessee’s cross objection stand dismissed

ITA 317/COCH/2024[2015-16]Status: DisposedITAT Cochin09 Jun 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

Further it is submitted that the A.O had failed to provide the Assessee with copy of the satisfaction sheet where the Reasons for escapement of income had been recorded by him and also failed to provide the copy of approval granted by the appropriate authority ... under Section 148 on the ground that the Assessing Officer is of the opinion that a contingency may arise in future resulting an escapement of income. That would, in our view, be wholly impermissible and would amount to a rewriting of the statutory provision. Moreover, the reliance which is sought

Deputy Commissioner of Income Tax, Central Circle, Kollam vs. Moneymuttam Finance, Pathanamthitta

In the result, assessee’s cross objection stands allowed and appeal filed by the Revenue stands dismissed

ITA 315/COCH/2024[2017-18]Status: DisposedITAT Cochin09 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm Assessment Years: 2017-18

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

Further it is submitted that the A.O had failed to provide the Assessee with copy of the satisfaction sheet where the Reasons for escapement of income had been recorded by him and also failed to provide the copy of approval granted by the appropriate authority ... under Section 148 on the ground that the Assessing Officer is of the opinion that a contingency may arise in future resulting an escapement of income. That would, in our view, be wholly impermissible and would amount to a rewriting of the statutory provision. Moreover, the reliance which is sought

Deputy Commissioner of Income Tax, Central Circle, Kollam vs. Arun Raj Pillai, Pathanamthitta

In the result, the cross objection filed by the assessee company stands allowed

ITA 314/COCH/2024[2018-19]Status: DisposedITAT Cochin09 Jun 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)

under Section 148 on the ground that the Assessing Officer is of the opinion that a contingency may arise in future resulting an escapement of income. That would, in our view, be wholly impermissible and would amount to a rewriting of the statutory provision. Moreover, the reliance which is sought

Sreevalsam Hotels and Resorts Private Ltd, Rajavalsam vs. ACIT, Central Circle, Kollam

In the result, assessee’s appeal in ITA No

ITA 115/COCH/2024[2017-2018]Status: DisposedITAT Cochin09 Jun 2025AY 2017-2018

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 143(3)Section 148

Further it is submitted that the A.O had failed to provide the Assessee with copy of the satisfaction sheet where the Reasons for escapement of income had been recorded by him and also failed to provide the copy of approval granted by the appropriate authority ... under Section 148 on the ground that the Assessing Officer is of the opinion that a contingency may arise in future resulting an escapement of income. That would, in our view, be wholly impermissible and would amount to a rewriting of the statutory provision. Moreover, the reliance which is sought

Chinnaswamy Sunder Raju, Bangalore vs. Assistant Commissioner of Income-Tax, Central Circle-2(4), Bengaluru

In the result the appeal of the assessee is partly allowed

ITA 1071/BANG/2024[2017-18]Status: DisposedITAT Bangalore09 Jun 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2017-18

For Appellant: Shri. V Chandra Sekhar, AdvocateFor Respondent: Shri. Shivanand Kalakeri, CIT(DR)(ITAT), Bangalore
Section 127Section 132Section 139(4)Section 143(2)Section 143(3)Section 153A

categorically held that when material which is found in the search of a person is incriminating in nature and indicates escapement of income in the hands of another person, then the AO of that another person can bring the same to tax in the hands of that another person only

Hmg Engineering Private Limited, Mumbai vs. Income-Tax Officer, Ward 1(1)(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3012/MUM/2024[2012-13]Status: DisposedITAT Mumbai09 Jun 2025AY 2012-13

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सुं./Ita No. 3012/Mum/2024 (नििाारण वर्ा / Assessment Year :2012-13) Hmg Engineering Pvt. Ltd. V/S. Ito, Ward (1)(1)(4) 1St Floor, Bandukwala बिाम Income Tax Department, Building, 14 British Hotel 531A 5Th Floor, Aayakar Lane, Off B S Marg, Fort, Bhawan, Maharishi Karve Maharashtra-400023 Road, Maharashtra- 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach3226L Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Krutarth K. Desai राजस्व की ओर से /Revenue By: Shri Hemanshu Joshi

For Appellant: Shri Krutarth K. DesaiFor Respondent: Shri Hemanshu Joshi
Section 143(3)Section 147Section 148Section 41(1)

subject matter. The Supreme Court compared the provision before and after the amendment. Prior to the amendment, there should be escapement of income arising on account of non-filing of return or non-disclosure of material facts or the Assessing Officer should have reason to believe escapement in consequence ... information in his possession. After the amendment, there is only one condition, that there is "reason to believe" escapement of income. 4. Further, it is informed that the notice u/s 148 has been issued after satisfaction of the AO and recording the reasons for the same. The notice

C.I. Finlease Private Limited, Bhopal vs. Deputy Commissioner of Income Tax -1(1), Bhopal

Appeal is allowed

ITA 397/IND/2024[2012-13]Status: DisposedITAT Indore06 Jun 2025AY 2012-13

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

Section 143(3)Section 271(1)(c)

revenue receipt. The assessee had also accounted for the same as income, when the services are actually rendered. Hence, there is no escapement of income on account of service charges received from Hyundai Motor India Limited by the assessee. We uphold the action of Id. CIT(A) in deleting

Gaurav Vinodkumar Dugar Legal Heir of Late Vinodkumar Babulal Dugar, Ahmedabad vs. The ITO, Ward-1(1)(3)(Previously Ward- 1(2)(4)), Ahmedabad

In the result the ITA No

ITA 753/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad03 Jun 2025AY 2012-13

Bench: Dr. Brr Kumar & Ms Suchitra Kambleआयकर अपील सं./Ita Nos. 131 & 132/Ahd/2024 "नधा"रण वष"/Asstt. Years: 2010-2011 & 2011-12

For Appellant: Shri M S Chhajed, ARFor Respondent: Shri Santosh Kumar, Sr. DR
Section 139Section 148Section 151Section 44A

accounts during the Financial Year 2009-10 to the extent of Rs.58,65,362/-. Thus, the AO observed that there is an escapement of income to the extent of Rs.3,22,12,137/- in the AY 2010-11. The reason recorded were supplied to the assessee vide letter dated

Late Vinodkumar Babulal Dugar Though His L/R Gaurav Vinodkumar Dugar, Ahmedabad vs. The Income Tax Officer, Ward-1(2)(4), Ahmedabad

In the result the ITA No

ITA 132/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad03 Jun 2025AY 2011-12

Bench: Dr. Brr Kumar & Ms Suchitra Kambleआयकर अपील सं./Ita Nos. 131 & 132/Ahd/2024 "नधा"रण वष"/Asstt. Years: 2010-2011 & 2011-12

For Appellant: Shri M S Chhajed, ARFor Respondent: Shri Santosh Kumar, Sr. DR
Section 139Section 148Section 151Section 44A

accounts during the Financial Year 2009-10 to the extent of Rs.58,65,362/-. Thus, the AO observed that there is an escapement of income to the extent of Rs.3,22,12,137/- in the AY 2010-11. The reason recorded were supplied to the assessee vide letter dated

Late Vinodkumar Babulal Dugar Though His L/R Gaurav Vinodkumar Dugar, Ahmedabad vs. The Income Tax Officer, Ward-1(2)(4), Ahmedabad

In the result the ITA No

ITA 131/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad03 Jun 2025AY 2010-11

Bench: Dr. Brr Kumar & Ms Suchitra Kambleआयकर अपील सं./Ita Nos. 131 & 132/Ahd/2024 "नधा"रण वष"/Asstt. Years: 2010-2011 & 2011-12

For Appellant: Shri M S Chhajed, ARFor Respondent: Shri Santosh Kumar, Sr. DR
Section 139Section 148Section 151Section 44A

accounts during the Financial Year 2009-10 to the extent of Rs.58,65,362/-. Thus, the AO observed that there is an escapement of income to the extent of Rs.3,22,12,137/- in the AY 2010-11. The reason recorded were supplied to the assessee vide letter dated

Income Tax Officer, Patiala vs. Raj Autos, Patiala

In the result, Cross Objection of the assessee is allowed whereas appeal of the Revenue is dismissed

ITA 829/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh02 Jun 2025AY 2016-17

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 829/Chd/2024 "नधा"रण वष" / Assessment Year: 2016-17 The Ito, Vs Raj Autos, Patiala. Opp. Bhagat Volkswagen Showroom, Sirhind Byepass Road, Patiala. "थायी लेखा सं./Pan No: Aaner8138F अपीलाथ"/Appellant ""यथ"/Respondent C.O. No. 36/Chd/2024 In आयकर अपील सं./ Ita No. 829/Chd/2024 "नधा"रण वष" / Assessment Year: 2016-17 Raj Autos, Vs The Ito, Ward-5, Opp. Bhagat Volkswagen Showroom, Patiala. Sirhind Byepass Road, Patiala. "थायी लेखा सं./Pan No: Aaner8138F अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Ca & Ms. Deepali Aggarwal,Ca Revenue By : Smt. Kusum Bansal, Cit,Dr Date Of Hearing : 23.04.2025 Date Of Pronouncement : 02.06.2025 Hybrid Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, CA and Ms. Deepali Aggarwal,CAFor Respondent: Smt. Kusum Bansal, CIT,DR
Section 147Section 148

return". 7. Considering the factual matrix, statutory provisions and legal principles, the undersigned has reasons to believe there has been an escapement of income to the tune of more that Rs. 19,75,47,805/- chargeable to tax for the A.Y 2016-17 and hence it is fit case

Nalagarh Chemicals Pvt. Ltd., Chandigarh vs. Income Tax Officer, Ward-1(5), Chandigarh

The appeal stand dismissed

ITA 330/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh02 Jun 2025AY 2012-13

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 330/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2012-13) M/S Nalagarh Chemicals Private Ltd. Ito-Ward 1(5) बनाम/ No. 3, Sector 5, Aaykar Bhawan, Sector 17 Vs. Chandigarh-160005 Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacn-4773-A (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Parikshit Aggarwal (Ca) & Ms Shruti Khandelwal (Advocate) – Ld. Ars ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 22-05-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-06-2025 आदेश / O R D E R

For Appellant: Shri Parikshit Aggarwal (CA) and Ms ShrutiFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. DR
Section 143(3)Section 148Section 68

ascertain the fact by evidence or conclusion. What was required at this stage was reason to believe and not established fact of escapement of income. The decision of Hon’ble Apex Court in the case of Rajesh Jhaveri Sock Brokers Pvt. Ltd. (161 Taxman 316) was referred to support this ... that the case was reopened pursuant to receipt of tangible material in the shape of information from DDIT (inv.) which prima facie revealed escapement of income in the hands of the assessee. In our considered opinion, at the stage of reopening, conclusive case of escapement of income was not required

Calance Software Private Limited, New Delhi vs. ACIT, Circle-5(2), New Delhi

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

ITA 1441/DEL/2024[2012-13]Status: DisposedITAT Delhi02 Jun 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2012-13] Calance Software Pvt. Ltd., Vs Acit, 14/34 & 36, Dda Shopping Circle-5(2), Complex, Nangalraya, Delhi New Delhi-110046. Pan-Aaccc5176A Appellant Respondent Appellant By Shri Harish Choudhary, Ca, Shri Mohit Choudhary, Ca & Mitika Choudhary, Adv. Respondent By Ms. Suman Malik, Cit Dr Date Of Hearing 02.06.2025 Date Of Pronouncement 02.06.2025 Order

Section 143(3)Section 147Section 250Section 68Section 69C

failed to appreciate that the assessment order passed u/s 147 is illegal, bad in law and without recording proper satisfaction regarding escapement of income. 3. That on the facts and circumstances of the case and the provisions of the law, the Ld. CIT(A) has failed appreciate that the reason ... relevant. In other words, at the initiation stage, what is required is "reason to believe", but not the established fact of escapement of income. At the stage of issue of notice, the only question is whether there was relevant material on which a reasonable person could have formed a requisite

The Dharmodayam Company, Thrissur vs. ITO, Ward-1(1), Thrissur

In the result, the appeals in ITA No

ITA 791/COCH/2024[2008-09]Status: DisposedITAT Cochin30 May 2025AY 2008-09

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

For Appellant: Ms. Niveditha K. Kammath, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 11Section 12ASection 143(3)Section 148Section 25

information as available at the time of original assessment. No reference was made by the AO to fresh tangible material showing escapement of income from assessment to tax, therefore, it is submitted that the law laid down by the Hon'ble Supreme Court in the case of CIT v. Kelvinator ... mere change of opinion, as evident from the assessment order itself as there was no reference to any fresh tangible material indicating escapement of income to tax. We have carefully perused the assessment order and found that the AO sought to reopen the assessment merely based on the same

The Dharmodayam Company, Thrissur vs. ITO, Ward-1(1), Thrissur

In the result, the appeals in ITA No

ITA 790/COCH/2024[2007-08]Status: DisposedITAT Cochin30 May 2025AY 2007-08

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

For Appellant: Ms. Niveditha K. Kammath, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 11Section 12ASection 143(3)Section 148Section 25

information as available at the time of original assessment. No reference was made by the AO to fresh tangible material showing escapement of income from assessment to tax, therefore, it is submitted that the law laid down by the Hon'ble Supreme Court in the case of CIT v. Kelvinator ... mere change of opinion, as evident from the assessment order itself as there was no reference to any fresh tangible material indicating escapement of income to tax. We have carefully perused the assessment order and found that the AO sought to reopen the assessment merely based on the same

The Dharmodayam Company, Thrissur vs. ITO, Ward-1(1), Thrissur

In the result, the appeals in ITA No

ITA 789/COCH/2024[2006-07]Status: DisposedITAT Cochin30 May 2025AY 2006-07

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

For Appellant: Ms. Niveditha K. Kammath, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 11Section 12ASection 143(3)Section 148Section 25

information as available at the time of original assessment. No reference was made by the AO to fresh tangible material showing escapement of income from assessment to tax, therefore, it is submitted that the law laid down by the Hon'ble Supreme Court in the case of CIT v. Kelvinator ... mere change of opinion, as evident from the assessment order itself as there was no reference to any fresh tangible material indicating escapement of income to tax. We have carefully perused the assessment order and found that the AO sought to reopen the assessment merely based on the same

The Dhamodayam Company, Thrissur vs. ITO, Ward-1(1), Thrissur

In the result, the appeals in ITA No

ITA 788/COCH/2024[2005-06]Status: DisposedITAT Cochin30 May 2025AY 2005-06

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

For Appellant: Ms. Niveditha K. Kammath, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 11Section 12ASection 143(3)Section 148Section 25

information as available at the time of original assessment. No reference was made by the AO to fresh tangible material showing escapement of income from assessment to tax, therefore, it is submitted that the law laid down by the Hon'ble Supreme Court in the case of CIT v. Kelvinator ... mere change of opinion, as evident from the assessment order itself as there was no reference to any fresh tangible material indicating escapement of income to tax. We have carefully perused the assessment order and found that the AO sought to reopen the assessment merely based on the same

Mr. Dhiraj Harish Khialani, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 6(1), Mumbai

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

ITA 5487/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 131Section 133Section 139(1)Section 143(1)Section 143(3)Section 144Section 147Section 148

Basis of forming reason to believe and details of escapement of income: On the basis of the aforesaid tangible material available with me and after conducting own independent enquiry, I have reason to Mr. Dhiraj Harish Khialani believe that income chargeable to tax, as mentioned in the information available, have ... each other. Accordingly, in the reasons recorded, the ld. AO has to only record his primafacie belief and not to establish the exact escapement of income. Mr. Dhiraj Harish Khialani 8. We have heard both the parties and also perused the relevant finding given in the impugned orders. From