“income escaping assessment”

ReassessmentSection 147Section 1471,518 judgments

The decision most relied on for income escaping assessment is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on income escaping assessment

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 income escaping assessment

Palanisamy Srilatha, Salem vs. ITO, Ward-196), Salem

In the result, appeal filed by the assessee is allowed

ITA 2027/CHNY/2025[2015-16]Status: DisposedITAT Chennai07 Jan 2026AY 2015-16

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.S Sridhar, Adv (Erode)For Respondent: Ms. R Anitha, Addl.CIT

Section 144BSection 147Section 148Section 148ASection 151Section 151A

issued a notification dated 29.03.2022 [after laying the same before each House of Parliament] and formulated a Scheme called "the e-Assessment of Income Escaping Assessment Scheme, 2022" (herein after ‘the Scheme’). And that the Scheme provides that (a) the assessment, reassessment or re-computation u/s.147

M/S Jhs Svendgaard Laboratories Ltd., New Delhi vs. DCIT CC-31, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3454/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Jhs Svendgaard Vs. Dcit Laboratories Ltd. B1/E-23, Central Circle-31, New Mohan Cooperative Delhi Tuhglakabad, Badarpur, New Delhi New Delhi Pan: Aabcj5766G Appellant Respondent Assessee By Sh. Gaurav Jain, Adv & Sh. Tarun Chanana, Adv Revenue By Ms.Amisha S. Gupt, Cit (Dr) Date Of Hearing 09/10/2025 Date Of Pronouncement 07/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-30, New Delhi [‘Ld. Cit(A)’

Section 147Section 148Section 151ASection 37

erred in law and on facts in not being able to establish any live link/nexus between the information provided and the allegation of income escaping assessment as there is in effect no information suggesting escapement of income, rendering the entire reassessment proceedings bad in law. 4. That on the facts ... read with Notification No. 18/2022 dated 29.03.2022, which should have been issued by National Faceless Assessment Centre under e-Assessment of Income Escaping Assessment Scheme, 2022. 5. That the CIT(A) has erred on facts and in law in confirming the addition of Rs. 11,05,348/ by estimating

ACIT Circle-28(1), New Delhi vs. Munjal Holdings, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 5834/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 250Section 68

directly co- related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping assessment was less than Rupees one lakh: (a) a reassessment notice could be issued under Section 148 within four years after obtaining the approval ... appropriate authorities specified under Section 151 of the new regime. The effect of Section 151 of the new regime is thus: (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal

Manish Agarwal, Ballygunge vs. ACIT, Central Circle-2, Ranchi

In the result, the appeal of the assessee is allowed

ITA 16/RAN/2024[2011-12]Status: DisposedITAT Ranchi06 Jan 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.16/Ran/2024 Assessment Year: 201-12 Manish Agarwal……….…………….…….…............................……….……Appellant 35A, Tirumala Apartment, Ballygunge Park, Kol- 700019. [Pan: Acdpa1176E] Vs. Acit, Central Circle-1, Ranchi......…..…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Sunit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 28.11.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That A Search & Seizure Operation Under Section 132 Of The Act Was Conducted In The Case Of The Assessee Group On 23.10.2019. Pursuant To The Said Search, The Assessing Officer (Ao) Issued A Notice Under Section 153A Of The Act Calling Upon The Assessee To File Its Return Of Income For Six Assessment Years Preceding The Year Of Search. In Response To The Notice Under Section 153A, The Assessee Filed Its Return Of Income For Assessment Year 2011–12, Declaring A Total Income Of ₹6,95,180/-. During The Course Of Assessment Proceedings, Several Statutory Notices Were Issued To The Assessee, Which

Section 132Section 139Section 143(3)Section 147Section 148Section 149Section 151Section 153Section 153ASection 153C

applicable), assessments can be reopened only up to six years, and in specified cases, up to seven years, subject to the condition that income escaping assessment exceeds ₹50 lakh. The ld. counsel in this respect has referred to section 153A which reads as under: "153A. Assessment in case of search

Preeti Milan Sankhala, Pune vs. ITO Ward 14(3), Pune

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 939/PUN/2025[2017-18]Status: DisposedITAT Pune06 Jan 2026AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.939/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Suhas P. BoraFor Respondent: Shri Manish Sinha

Section 131Section 133ASection 144BSection 147Section 148Section 151ASection 69C

Finance Act, 2021 with regards to National Faceless Assessment Proceeding, Faceless jurisdiction of Income Tax Authorities Scheme, 2022 and Income Escaping Assessment Scheme 2022. 3. The Ld. CIT(A) erred in dismissing the appeal of the appellant without appreciating that the Ld.AO has incorrectly invoked the provisions of Section

Jigna Ashutosh Bhatt, Mumbai vs. Income Tax Officer Ward 33(2)(1), Mumbai

In the result the appeal of the assessee is partly allowed on merits

ITA 3639/MUM/2025[2011-12]Status: HeardITAT Mumbai06 Jan 2026AY 2011-12

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarito Ward-32(2)(1) Jigna Ashutosh Bhatt Kautilya Bhavan, I-1434, Govardhan Nagar Bandra Kurla Bldg. No. 4, Opp. Poinsur Vs. Complex, Bandra (E), Gymkhana, Kandivali Mumbai-400 051 (West), Mumbai-400 067 Pan/Gir No. Aiypb4411G (Applicant) (Respondent) Assessee By Shri Ketan L. Vajani, Ld. Ar Revenue By Shri Aditya Rai, Ld. Dr Date Of Hearing 05.01.2026 Date Of Pronouncement 06.01.2026

Section 132(4)Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68

without bothering to check the statement recorded by the investigation wing. ii. That without prejudice to any other grounds, there cannot be any income escaping assessment on the facts of the case and accordingly the initiation of reassessment without there being any income escaping assessment is without the authority

Naval Seth L/H Late Sh. Ghansham Dass Seth, Delhi vs. ACIT Circle-28(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 6210/DEL/2025[2016-17]Status: DisposedITAT Delhi06 Jan 2026AY 2016-17

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Ms. Mansi Jain, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 147Section 148Section 148ASection 151Section 250

directly co-related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping assessment was less than Rupees one lakh: (a) a reassessment notice could be issued under Section 148 within four years after obtaining the approval ... appropriate authorities specified under Section 151 of the new regime. The effect of Section 151 of the new regime is thus: (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal

Pankaj Jindal Contractor, Mansa vs. The Deputy Commissioner of Income Tax, Circle-I, Bathinda

In the result the appeal of the assessee is allowed

ITA 695/ASR/2024[2014-15]Status: DisposedITAT Amritsar05 Jan 2026AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 695/Asr/2024 Assessment Year: 2014-15 M/S Pankaj Jindal Contractor, Vs. Dcit-Circle-1, Near Vidya Bharti School, Bathinda. Mansa. [Pan:-Aajfp8008L] (Appellant) (Respondent) Appellant By Sh. Sudhir Sehgal, Adv. Respondent By Sh. Charan Dass, Sr. Dr

Section 139(1)Section 143(3)Section 147Section 148Section 148aSection 250Section 282Section 40A(3)Section 68

Baldev Singh Giani vs. Commissioner of Income-tax [2001] 119 Taxman 922 (Punjab & Haryana) Section 148 of the Income-tax Act, 1961 Income escaping assessment Issue of notice Whether recording of reasons under section 148(2) and communicating them to assessee is mandatory and where same were not found

Assistant Commissioner of Income Tax, Tirunelveli vs. Srinivasagam Selvamathan, Tuticorin

In the result, appeal filed by the revenue is dismissed

ITA 2654/CHNY/2025[2013]Status: DisposedITAT Chennai05 Jan 2026

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr. SrinivasagamFor Respondent: Mr.Shiva Srinivas, CIT

Section 144BSection 147Section 148Section 148ASection 151Section 151A

Nagarajan Jaya, Kancheepuram vs. ITO, Ward-1, Kanchipuram

In the result the appeal of the Assessee is allowed

ITA 1815/CHNY/2025[2011-12]Status: DisposedITAT Chennai05 Jan 2026AY 2011-12

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. P. Chidambaram, AdvocateFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T

Section 143(3)Section 147Section 148Section 264

would amount to abating the prescription of the proviso to section 147. The line of distinction between the general cases of income escaping assessment and those provided in the proviso, is that whereas in the general cases there may be any reason for attracting the provisions of section 147 when ... then the reassessment can be done beyond the period of four years from the end of the relevant assessment year only if income escaped assessment due to failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment. In the later situation

Maithan Ceramic Ltd., Kolkata vs. ACIT, Circle 7(1), Kolkata

ITA 1944/KOL/2025[2011-2012]Status: DisposedITAT Kolkata01 Jan 2026AY 2011-2012

For Appellant: Shri P.K.Himmatsinghka, ARFor Respondent: Shri Sandeep Lakra, Sr. DR

Section 142(1)Section 269S

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RAKESH MISHRA, ACCOUNTANT

Vipul Arjanbhai Parmar, Mangrol vs. Income Tax Officer, Ward -1, Junagadh

In the result, appeal filed by the assessee is allowed

ITA 217/RJT/2025[2010-11]Status: DisposedITAT Rajkot31 Dec 2025AY 2010-11

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.217/Rjt/2025 िनधा"रण वष"/Assessment Year : 2010-11 बनाम/ Vipul Arjanbhai Parmar Income Tax Officer Vs C/O. Sarda & Sarda (Ca), Sakar, Ward – 1, Junagadh 1St Floor, Dr. Radha-Krishnan Road, Opp. Rajkumar College, Rajkot, Gujarat - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ditpp9286B (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 143(3)Section 250

shop/land remain unexplained. In view of above facts, the case was reopened u/s 147 of the I.T. Act after recording the reasons regarding income escaping assessment within the meaning of Section 147 of the I.T. Act, 1961 and obtaining the approval of the Pr. Commissioner of Income tax-3, Rajkot

Vikas Jain, Kanpur vs. ACIT-CC 2(1)(1), Kanpur

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

ITA 434/LKW/2024[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2015-16 Vikas Jain, Vs. The Acit, H-2/1, Kidwai Nagar, Kanpur- Circle 2(1)(1), Kanpur 208001 208006 Pan: Abqpj8049R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac On 17.05.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 143(3) For The A.Y. 2015-16 On 27.12.2018. The Grounds Of Appeal Are As Under:- “01. Because There Being No Reason To Believe, Far From There Being Any Material To Form Reasons To Believe, The Proceedings Initiated Right From Issue Of Notice U/S. 148 & The Re-Assessment Framed Thereof Are All Without Jurisdiction Bad In Law, The Order Passed Be Quashed. 02. Because The So-Called Reasons Having Been Recorded Applying Explanation 2(A) To Section 147, Of The Act Which Not Being Applicable, The Very Reason To Believe Being Contrary To The Mandate Of The Section, The Proceedings- Initiated U/S 148, The Reassessment Framed Are All Contrary To The Provisions Of Law, Be Quashed. 03. Because The Approval Given By The Competent Authority U/S 151, Being Mechanical In Nature Without Verification Of Facts, The Notice Issued U/S 148 & The Reassessment Framed Thereafter Be Quashed.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Amit Kumar, DR

Section 143(1)Section 147Section 148Section 151Section 156Section 48Section 50C

previous year exceeded the maximum amount that was not chargeable to tax, then it could be deemed to be a case of income escaping assessment. But in the case of the assessee, it had been recorded by the AO itself, in the assessment order that the assessee had filed ... submitted that the issue could not be covered under section 292B and since it went to the root of the belief of income escaping assessment, which was found to be incorrect, he submitted that it vitiated the notice issued and thereby the entire assessment proceedings. Accordingly, he prayed that

Karnataka Telecom Department Employees Co-Operative Society Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle 1(4), Blr, Bangalore

In the result, appeals of Revenue in ITA Nos

ITA 1080/BANG/2025[2016-17]Status: DisposedITAT Bangalore31 Dec 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Years: 2016-17

For Appellant: Shri PR Suresh, CAFor Respondent: Shri N Balusamy, JCIT-DR

Section 143(3)Section 147Section 148Section 148ASection 149Section 250Section 80(2)(a)

passed on 02.11.2018 wherein returned income was equal to the assessed income. 3.1 Assessee’s case was selected for re-assessment for income escaping assessment. The reason for scrutiny was that the financial statements of the assessee was having associates’ members share capital amounting ... r.w.s.148A, of the Income-tax Act, 1961 and Sec.3 of the Taxation and Other Laws (Relaxation and Amendments of Certain Provisions) Act, 2020 - Income Escaping Assessment Time limit for ITA Nos. 5536, 5537 and 5538/DEL/2024 issuance of notice (reasstt.) -A.Y.2013-14 - Assessee-company filed instant writ on ground that a notice

Assistant Commissioner of Income Tax, Delhi vs. The Indure Private Limited, Delhi

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 4640/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Assistant Commissioner Of Vs. The Indure Private Limited, Income Tax, Indure House, Greater Kailash Part Ii, Delhi South Delhi 1100 48 Pan :Aaact0121C (Appellant) (Respondent)

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 250Section 69C

above extract that the FAO just relied upon the report of the investigation wing. The requirement of provisions for making an assessment of income escaping assessment is that of the satisfaction of the assessing officer. Here is a case where the FAO relied upon the satisfaction of 6 the"internal

Ila Khimjibhai Dulla, Mumbai vs. Ward 41(4)(2), Kautilya Bhavan

In the result, the appeal of the assessee is allowed

ITA 6716/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Dec 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 144Section 147Section 148Section 148ASection 149(1)(b)Section 54

jurisdictional grounds, contending that the notice issued under section 148 is barred by 2 Ila Khimjibhai Dulla limitation inasmuch as the alleged income escaping assessment is admittedly below the statutory threshold of ₹50,00,000/- prescribed under section 149(1)(b) of the Act. It has further been contended that ... procedural but jurisdictional in nature. The Assessing Officer must be in possession of tangible material demonstrating that the income escaping assessment meets the prescribed monetary threshold. In the absence of such satisfaction, the assumption of jurisdiction beyond three years is rendered legally untenable. 9. This position stands fortified

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

ITA 3955/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Dec 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

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

initiated upto 10 years in case of searches conducted on and after April 1, 2017, provided specific conditions are met i.e. if income escaping assessment amounting to Rs. 50 lakhs or more for period beyond 6 years. In appellant case admittedly search was conducted after 1.04.17 and quantum of escapement

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

ITA 3953/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

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

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

ITA 3952/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Dec 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

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

DCIT CC -15, New Delhi vs. Shiva Consultants Pvt. Ltd., New Delhi

ITA 4124/DEL/2025[2015-16]Status: DisposedITAT Delhi30 Dec 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4122/Del/2025 : Asstt. Year : 2010-11 Ita No. 4123/Del/2025 : Asstt. Year : 2013-14 Ita No. 4124/Del/2025 : Asstt. Year : 2015-16 Dcit, Vs Shiva Consultants Pvt. Ltd., Central Circle-15, C-360, Lgf, Defence Colony, Amar New Delhi Colony, South Delhi, New Delhi-110024 (Appellant) (Respondent) Pan No. Aaacs8213J Assessee By : Sh. Gaurav Jain & Sh. Tarun Chanana, Advs. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 18.12.2025 Date Of Pronouncement: 30.12.2025 Order Per Satbeer Singh Godara: These Revenue’S Three Appeals

For Appellant: Sh. Gaurav Jain & Sh. Tarun Chanana, AdvsFor Respondent: Sh. Mahesh Kumar, CIT-DR

Section 153A(1)Section 153CSection 153C(1)

satisfaction, and, for the last assessment year 2015-16, he has wrongly held it as null and void for the reason that income escaping assessment is less than Rs.50,00,000/-; as the case may be. Shiva Consultants Pvt. Ltd. 5. We find no merit in either of the Revenue