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Judicial DoctrinesReopening / 147Reopening / 1471,109 judgments

CHHABI LATA SAHU,ROURKELA vs. INCOME TAX OFFICER, WARD-4, ROURKELA

In the result, the appeal of the assessee is allowed

ITA 626/CTK/2025[2009-10]Status: DisposedITAT Cuttack16 Mar 2026AY 2009-10

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2009-10 Chhabi Lata Sahu Ito, Ward-4, Rourkela

For Appellant: Shri S. K. Sarangi & Bishwa Jyoti Pattnaik, ARsFor Respondent: Shri Shakeer Ahamed, Sr. DR
Section 143Section 148

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. Our view gets support from the changes made to Section 147 of the Act, as quoted hereinabove. Under

DUGGINNIGARI SUBRAMANIYAM NAIDU,TIRUPATI vs. ACIT., CIRCLE - 1(1), TIRUPATI

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

ITA 1443/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Mar 2026AY 2017-18

Bench: the Ld. AO.

Section 133(6)Section 68

which the cash was generated by the assessee and documentary evidences thereof. In absence of such primary documentary evidences which has live link with the generation of the cash out of systemic revenue generating apparatus, the assertion of the assessee that the cash was generated or available with the assessee

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

ITA 2362/PUN/2025[2016-17]Status: DisposedITAT Pune11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250Section 69A

down that the reasons to believe must have rational\nconnection with or relevant bearing on the formation of belief i.e. there\nmust be a live link between material coming the notice of the Assessing\nOfficer and the formation of belief regarding escapement of income. If\nthe aforesaid requirement

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

ITA 2361/PUN/2025[2017-18]Status: DisposedITAT Pune11 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 250Section 69A

down that the reasons to believe must have rational\nconnection with or relevant bearing on the formation of belief i.e. there\nmust be a live link between material coming the notice of the Assessing\nOfficer and the formation of belief regarding escapement of income. If\nthe aforesaid requirement

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

ITA 2360/PUN/2025[2015-16]Status: DisposedITAT Pune11 Mar 2026AY 2015-16
Section 143(3)Section 147Section 148Section 250Section 69A

down that the reasons to believe must have rational\nconnection with or relevant bearing on the formation of belief i.e. there\nmust be a live link between material coming the notice of the Assessing\nOfficer and the formation of belief regarding escapement of income. If\nthe aforesaid requirement

DCIT., CIRCLE-2(1), HYDRABAD vs. KALPTARU INVESTMENTS PRIVATE LIMITED, HYDERABAD

In the result, appeal ITA

ITA 1077/HYD/2025[2013-14]Status: DisposedITAT Hyderabad11 Mar 2026AY 2013-14
For Appellant: Sri P Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 147

dismissed and Order of the\nHon'ble High Court quashing the notice issued u/sec.148 of\nthe Act based on the reasons without disclosing any live link\nor fresh material to connect the transactions entered into by\nthe assessee with the information in possession of the\nAssessing Officer. He has then

EAST DELHI LEASING P.LTD,NEW DELHI vs. ITO, WARD-8(1), NEW DELHI

In the result, appeal filed by the assessee is allowed

ITA 7917/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Mar 2026AY 2010-11
Section 142(1)Section 147Section 148

They are indubitably disparate. The belief recorded by the\nAO suffers from a serious unbridgeable disconnect rendering it redundant,\nsuperfluous and unactionable. Absence of live link between the material on\nrecord and the satisfaction recorded completely mutilates the validity of the\nAO's belief and subsequent action. The Delhi High ... rational connection with or relevant bearing on the\nformation of the belief. Rational connection postulates that there\nmust be a direct nexus or live link between the material coming to\nthe notice of the Income-tax Officer and the formation of his belief\nthat there has been escapement

INFINITY INTERNATIONAL,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. THE ITO, WARD-3(3)(1), AHMEDABAD

In the result, appeal of the assessee is dismissed

ITA 518/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalinfinity International, Nfac, Delhi Vs. H-611, Titanium City Centre, Present Jurisdiction 100 Ft. Anandnagar Road, Ito, Ward 3(3)(1), Satellite, Ahmedabad-380015 Ahmedabad [Pan: Aaefi 2610 J] (Appellant) .. (Respondent) Appellant By: Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ar Respondent By: Shri Alpesh Parmar, Cit-Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 10.03.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147Section 148Section 153(3)Section 250Section 68

quashed. 5. In law and in the facts and circumstances of appellants case, the Ld. CIT(A) erred in holding that there is live link between information and formation of belief is established by the AO when there is no formation of belief by the AO and present proceedings ... nature of transactions, iii. Based on borrowed satisfaction, iv. Lack of independent application of mind, v. Absence of tangible material, vi. Inadequacy of live-link between the information and reasons 8.2 We have examined the reasons recorded by the Assessing Officer which are as under:- “Subject: REASON FOR REOPENING

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 770/RJT/2024[2022-23]Status: DisposedITAT Rajkot09 Mar 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

reference of any name related to the assessee -firm i.e. Accurate Buildcon in the said seized paper. The allegation made without establishing any live link between the noting in the seized document with the assessee -firm is totally misplaced and is based upon suspicion only. The claim that during ... Buildcon during the year under consideration and Ashishbhai Tank is a main partner of M/s Accurate Buildcon. This fact is sufficient enough to establish live link that the unaccounted payment recorded in the seized ledger in the name of Ashishbhai Tank Contractor pertain to no one else but M/s Accurate

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 769/RJT/2024[2021-22]Status: DisposedITAT Rajkot09 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

reference of any name related to the assessee -firm i.e. Accurate Buildcon in the said seized paper. The allegation made without establishing any live link between the noting in the seized document with the assessee -firm is totally misplaced and is based upon suspicion only. The claim that during ... Buildcon during the year under consideration and Ashishbhai Tank is a main partner of M/s Accurate Buildcon. This fact is sufficient enough to establish live link that the unaccounted payment recorded in the seized ledger in the name of Ashishbhai Tank Contractor pertain to no one else but M/s Accurate

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 768/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

reference of any name related to the assessee -firm i.e. Accurate Buildcon in the said seized paper. The allegation made without establishing any live link between the noting in the seized document with the assessee -firm is totally misplaced and is based upon suspicion only. The claim that during ... Buildcon during the year under consideration and Ashishbhai Tank is a main partner of M/s Accurate Buildcon. This fact is sufficient enough to establish live link that the unaccounted payment recorded in the seized ledger in the name of Ashishbhai Tank Contractor pertain to no one else but M/s Accurate

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 767/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

reference of any name related to the assessee -firm i.e. Accurate Buildcon in the said seized paper. The allegation made without establishing any live link between the noting in the seized document with the assessee -firm is totally misplaced and is based upon suspicion only. The claim that during ... Buildcon during the year under consideration and Ashishbhai Tank is a main partner of M/s Accurate Buildcon. This fact is sufficient enough to establish live link that the unaccounted payment recorded in the seized ledger in the name of Ashishbhai Tank Contractor pertain to no one else but M/s Accurate

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 766/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

reference of any name related to the assessee -firm i.e. Accurate Buildcon in the said seized paper. The allegation made without establishing any live link between the noting in the seized document with the assessee -firm is totally misplaced and is based upon suspicion only. The claim that during ... Buildcon during the year under consideration and Ashishbhai Tank is a main partner of M/s Accurate Buildcon. This fact is sufficient enough to establish live link that the unaccounted payment recorded in the seized ledger in the name of Ashishbhai Tank Contractor pertain to no one else but M/s Accurate

INCOME TAX OFFICER, WARD-9(1), KOLKATA, KOLKATA vs. LITTLESTAR SECURITIES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 694/KOL/2025[2012-13]Status: DisposedITAT Kolkata06 Mar 2026AY 2012-13
Section 143(3)Section 144BSection 254Section 68

leap in logic that cannot be countenanced. Furthermore, the\nvaluation of shares is a matter of commercial wisdom. Unless the Revenue proves a\n\"live link\" showing that the funds originated from the assessee's own coffers, the AO\ncannot substitute his judgment for that of the marketplace ... leap in logic that cannot be countenanced.\nFurthermore, the valuation of shares is a matter of commercial wisdom. Unless the\nRevenue proves a \"live link\" showing that the funds originated from the assessee's own\ncofers, the AO cannot substitute his judgment for that of the marketplace.\n13. Upon considering

LAKHMICHAND VASWANI,INDORE vs. ITO WARD 1(4), INDORE, INDORE

In the result ITA No:-653/Ind/2025 and \"Impugned order\"\ntherein is set aside as and by way of remand to Ld

ITA 654/IND/2025[2014-15]Status: DisposedITAT Indore27 Feb 2026AY 2014-15
For Appellant: \nS.No
Section 250Section 69

hands of the appellant.\n9. That the assessment was not reopened based on any new 8 tangible\nmaterial.\n10. That there was no live link between material available on record\nand reasons to believe.\n11. For that the appellant craves leave to add, amend, alter vary and\nOR withdraw

LAKHMICHAND VASWANI,INDORE vs. ITO WARD 1(4), INDORE, INDORE

In the result ITA No:-653/Ind/2025 and “Impugned order”

ITA 653/IND/2025[2014-15]Status: DisposedITAT Indore27 Feb 2026AY 2014-15

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

Section 147Section 246ASection 250Section 253Section 69

hands of the appellant. 9. That the assessment was not reopened based on any new 8 tangible material. 10. That there was no live link between material available on record and reasons to believe. 11. For that the appellant craves leave to add, amend, alter vary and OR withdraw

DCIT CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. CRYSTAL CERAMIC INDUSTRIES LIMITED, AHMEDABAD

In the result, the appeals filed by the Revenue in ITA Nos

ITA 860/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Narendra Prasad

DCIT CENTRAL CIRCLE 1(1) AHMEDABAD, AHMEDABAD vs. CRYSTAL CERAMIC INDUSTRIES LIMITED, AHMEDABAD

In the result, the appeals filed by the Revenue in ITA Nos

ITA 859/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2015-16

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Narendra Prasad

CRYSTAL CERAMICS INDUSTRIES LIMITED,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD

In the result, the appeals filed by the Revenue in ITA Nos

ITA 682/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Narendra Prasad

PRAFULLA KUMAR MALAKAR, INCOME TAX OFFICER, WARD-12(1), KOLKATA, KOLKATA vs. KALAWATI INVESTMENTS & TRADING P LTD., KOLKATA

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

ITA 134/KOL/2025[2015-16]Status: DisposedITAT Kolkata20 Feb 2026AY 2015-16

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 147Section 148Section 250Section 69

each case, by the party alleging so, that this assessee in question was part of this scam. The chain of events and the live link of the assessee's action giving his involvement in the scam should be established. The allegation implies that cash was paid by the assessee

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