← All Phrases

“live link”

Judicial DoctrinesReopening / 147Reopening / 1471,109 judgments

The decision most relied on for live link is ITO v. Lakhmani Mewal Das (103 ITR 437), cited in 721 judgments on BharatTax.

Leading authorities on live link

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.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

PCIT v. RMG Polyvinyl (I) Ltd.
396 ITR 5 · 2017 · High Court
272
citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

CIT v. Foramer France
264 ITR 566 · 2003 · Supreme Court
253
citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

ITO v. Selected Dalurband Coal Co. (P.) Ltd.
217 ITR 597 · 1996 · Supreme Court
180
citing judgments

The Assessing Officer's belief that income has escaped assessment, leading to the reopening of an assessment, is a matter of subjective satisfaction. The materials available at the time of forming this belief do not need to conclusively prove the escapement of income.

153 (Gujarat) 8 Shakti Karnawat v. ITO
296 ITR 90 · 2008 · High Court
171
citing judgments

A live link of third-party information can form the basis for reopening an assessment under Section 148, provided it contains material facts necessary for assessment. The Assessing Officer must demonstrate a "reason to believe" that income has escaped assessment, which can be satisfied by such information even if it pertains to other assessees or relates to accommodation entries.

Kalyanji Mavji & Co. v. CIT
102 ITR 287 · 1976 · Supreme Court
137
citing judgments

The Supreme Court broadly defined 'information' for reassessment under Section 147 to include new facts, external sources, material already on record, or a correct understanding of law from judicial decisions. This definition enables reopening assessments based on subsequent information or mistakes.

Judgments citing live link

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO Ward-1(2), Jaipur

In the result, the appeals of the assessee are allowed

ITA 245/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Oct 2025AY 2015-16
For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT
Section 144Section 147Section 250

between the reasons recorded and the additions made is fatal to the validity of the reassessment. The law requires that there must be a live link or nexus between the reasons which formed the foundation of the belief of escapement of income and the additions ultimately made in assessment ... rational connection with or relevant bearing on the formation of the belief. Rational connection postulates that there must be a direct nexus or live link between the material coming to the notice of the Income-tax Officer and the formation of his belief that there has been escapement

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO, Ward-1(2), Jaipur

In the result, the appeals of the assessee are allowed

ITA 244/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT
Section 144Section 147Section 250

between the reasons recorded and the additions made is fatal to the validity of the reassessment. The law requires that there must be a live link or nexus between the reasons which formed the foundation of the belief of escapement of income and the additions ultimately made in assessment ... rational connection with or relevant bearing on the formation of the belief. Rational connection postulates that there must be a direct nexus or live link between the material coming to the notice of the Income-tax Officer and the formation of his belief that there has been escapement

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO Ward-1(2), Jaipur

In the result, the appeals of the assessee are allowed

ITA 243/JPR/2025[2013-14]Status: DisposedITAT Jaipur13 Oct 2025AY 2013-14
For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT
Section 144Section 147Section 250

between the reasons recorded and the additions made is fatal to the validity of the reassessment. The law requires that there must be a live link or nexus between the reasons which formed the foundation of the belief of escapement of income and the additions ultimately made in assessment ... rational connection with or relevant bearing on the formation of the belief. Rational connection postulates that there must be a direct nexus or live link between the material coming to the notice of the Income-tax Officer and the formation of his belief that there has been escapement

Globus Housing, Bhopal vs. Assessment Unit, NFAC, Delhi

The appeal of the assessee is allowed and the “impugned

ITA 872/IND/2024[2014-15]Status: DisposedITAT Indore10 Oct 2025AY 2014-15

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshi

Section 142(1)Section 147Section 148Section 250Section 253Section 68

erred in issuing notice u/s 148 as the reasons recorded are undated, erroneous and factually incorrect and there is no direct nexus or live link between the reasons recorded and the formation of belief that there has been escapement of any income and therefore reasons as recorded

Sana Md.Saqib Puthawala, Ahmedabad vs. The ITO, Ward-1(1)(1), Ahmedabad

In the result, the appeal of the Assessee is allowed

ITA 624/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 10(38)Section 147Section 148Section 148ASection 250Section 69C

clear that the respondent-Assessing Officer has recorded the reasons only on the basis of the borrowed satisfaction without there being any live link between the information available on the In-sight Portal and the data available on the record of the petitioners-assesses. In such circumstances, the Assessing Officer ... recorded to re-open the assessment to come to the prima. 8. It is found that in the present case also, there was no live link between the information available on the Insight portal and the data available on record in respect of the assessee. The connection of the assessee

Income Tax Officer, Ward-2(1), Guntur vs. Shivani Cotton Industries Private Limited, Guntur

In the result, appeals ITA

ITA 460/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

purpose of making protective assessment because, before reopening of assessment, the Assessing Officer must record ‘reasonable belief of escapement’ which should have a live link between the ‘tangible material’ and the ‘formation of the reason’ to believe that, income had escaped assessment. In the present case, the Assessing Officer

Income Tax Officer, Ward- 1(1), Guntur vs. Potti Kumara Naga Venkata Sai Chakravarthy, Guntur

In the result, appeals ITA

ITA 368/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

purpose of making protective assessment because, before reopening of assessment, the Assessing Officer must record ‘reasonable belief of escapement’ which should have a live link between the ‘tangible material’ and the ‘formation of the reason’ to believe that, income had escaped assessment. In the present case, the Assessing Officer

Income Tax Officer, Guntur vs. Madhusushana Venkata Subba Rao Potti, Guntur

In the result, appeals ITA

ITA 367/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

purpose of making protective assessment because, before reopening of assessment, the Assessing Officer must record ‘reasonable belief of escapement’ which should have a live link between the ‘tangible material’ and the ‘formation of the reason’ to believe that, income had escaped assessment. In the present case, the Assessing Officer

Assistant Commissioner of Income Tax, Guntur vs. Ms.Vijayasai Lakshmi Srinivasa Cotton Mills, Guntur

In the result, appeals ITA

ITA 359/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR
Section 132Section 132(4)Section 147Section 148

purpose of making protective assessment because, before reopening of assessment, the Assessing Officer must record ‘reasonable belief of escapement’ which should have a live link between the ‘tangible material’ and the ‘formation of the reason’ to believe that, income had escaped assessment. In the present case, the Assessing Officer

Jagdish Solanki, Jhabua vs. Income Tax Officer Jhabua, Jhabua

ITA 169/IND/2025[2017-18]Status: DisposedITAT Indore07 Oct 2025AY 2017-18

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

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Income-Tax Officer, Ward-1, Raichur vs. Maralbid Padmavathi, Raichur

In the result, appeal filed by theRevenue is dismissed

ITA 1006/BANG/2025[2016-17]Status: DisposedITAT Bangalore07 Oct 2025AY 2016-17

Bench: Shri.Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2016-17 Ito, Vs. Maralbid Padmavathi, Ward – 1, 4-4-145, Zahirabad Raichur, Raichur. Raichur – 584 101, Karnataka. Pan :Anhpp 8615 N Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Shankar Ganesh D, Addl. Cit(Dr)(Itat), Bangalore. Date Of Hearing : 12.08.2025 Date Of Pronouncement : 07.10.2025

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Shankar Ganesh D, Addl. CIT(DR)(ITAT), Bangalore
Section 139Section 142(1)Section 143(2)Section 147Section 148Section 271(1)(b)

power to reopen, provided there is 'tangible material' to come to conclusion that there is escapement of income from assessment; reasons must have a live link with formation of belief”. In the present case, the JAO was not having any tangible material in his Page 6 of 8 possession

Narendra Kachrulal Abad, Jalna vs. Income-Tax Officer, Ward - 1, Jalna

In the result, appeal of the assessee partly allowed

ITA 866/PUN/2019[2009-10]Status: DisposedITAT Pune06 Oct 2025AY 2009-10

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.866/Pun/2019 निर्धारण वषा / Assessment Year: 2009-10 Shri Narendra Kachrulal Abad, V The Income Tax Officer, Abad House, Nal Galli, S Ward-1, Jalna. Kadrabad, Jalna – 431203. Maharashtra. Pan: Acspa9531C Appellant/ Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Arvind Renge –Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 06/10/2025 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)-1, Aurangabadpassed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2009-10 Dated 30.03.2019, Emanating From Order U/S.143(3) R.W.S 147Of The Income Tax Act, 1961, Dated 03.11.2017. The Assessee Has Raised The Following Concise Grounds Of Appeal :

Section 143(3)Section 148Section 250

borrowed satisfaction, there was no tangible material before the Assessing Officer to arrive at the satisfaction and the Assessing Officer has not established any live link between the information and the satisfaction that the income of Rs.9,54,365/- has escaped assessment. The Notice u/s 148 and the consequential impugned ... shifting out the profit of Rs.5,41,215/-and taking of losses of Rs.4,13,150/-. (iii) The Assessing Officer has not established any live link between the information relied by upon him and the satisfaction/conclusion the income of Rs.9,54,365/- has escaped assessment in the case

Spirit Global Constructions Private Limited, New Delhi vs. ACIT Central Circle-15, New Delhi

In the result, appeal of the assessee is allowed

ITA 3821/DEL/2024[2012-13]Status: DisposedITAT Delhi30 Sept 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] M/S. Spirit Global Vs Acit, Constructions Pvt.Ltd., Central Circle-15, Plot No.1, Lsc, Site No.37- Delhi 38, Morland, Kalkaji, New Delhi-110019. Pan-Aaics2757B Appellant Respondent Appellant By Shri Amitosh Moitra, Ca & Roli Chaubey, Ca Respondent By Shri Dheeraj Kumar Jaiswal, Sr.Dr Date Of Hearing 03.07.2025 Date Of Pronouncement 30.09.2025 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By Assessee Against The Order Dated 24.06.2024 Passed By Ld. Commissioner Of Income Tax (A)- 26, New Delhi [“Ld.Cit(A)”] In Appeal No.10187/2019-20 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 28.03.2014 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2012-13. 2. Brief Facts Of The Case Are That Assessee Is A Private Limited Company, Engaged In The Business Of Real Estate. The Return Of Income Was Filed On 27.09.2012, Declaring Loss Of Inr 2,91,85,777/-. The Assessment Was Completed U/S 143(3) In Terms Of Order Dated 28.03.2014 Passed U/S 143(3) Of The Act Wherein Income So Declared Was Accepted. Thereafter, Case Of The Assessee Was Re-Opened In Terms Of The Notice Issued U/S 148 Of The Act Dated 31.03.2019 & Subsequently, Re-Assessment Order Was Passed On 24.12.2019 By Making Addition Of Inr 3.50 Crores Received From M/S. Anamika Steel Traders Pvt. Ltd. Of Inr 1.75 Crores & M/S. Gajraj Steel Merchants Pvt.Ltd. Of Inr 1.75 Crores Each By Holding The Same As Unexplained Credits.

Section 143(3)Section 147Section 148Section 250

assessment made and confirmed is invalid, bad in law and contrary to the rulings of the courts due to the glaring absence of a live link between the information available with the Investigation Wing and the addition made and confirmed in the hands of the assessee. v. The assessment made

Pramod Gupta, Gurgaon vs. ITO Ward - 46(5), New Delhi

Accordingly the appeal of the assessee succeeds. The same is allowed

ITA 3648/DEL/2019[2010-11]Status: DisposedITAT Delhi30 Sept 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaassessment Year: 2010-11 Pramod Gupta, Vs Ito, B-44, Pinnacle, Sector-43, Ward-46(5), Dlf Phase-05, New Delhi. Gurgaon – 122 009. Pan: Aanpg2866P (Appellant) (Respondent) Assessee By : Shri K. Sampath, Advocate & Shri V. Rajakumar, Advocate Revenue By : Ms Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 30.07.2025 Date Of Pronouncement : 30.09.2025

For Appellant: Shri K. Sampath, Advocate &For Respondent: Ms Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 147Section 148Section 151Section 68Section 69C

merely a borrowed satisfaction on the basis of Investigation Wing report alone. The law is settled that reopening should be on the basis of live link or close nexus which should be there before the AO to form a belief regarding escapement of income. Reliance in this regard

ACIT, Central Circle- 18, New Delhi vs. Jagat Projects Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 2961/DEL/2019[2010-11]Status: DisposedITAT Delhi30 Sept 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: S/Shri. Salil Aggarwal, Sr. Adv., Shailesh GuptaFor Respondent: Ms.RajinderKaur,CIT(DR)
Section 133ASection 143(3)Section 147

settled law that the reasons to believe must have a 'direct Page 7 of 15 ITA No. 2961/ Del /2019 nexus' and a "live link with the formation of an opinion by the AO that taxable income of an Assessee has escaped assessment. It is submitted that the reasons that

Brand India Real Estate Private Limited, Jaipur vs. Income Tax Officer Ward 6(1), Jaipur

In the result, appeal of the assessee is allowed

ITA 514/JPR/2025[2012-2013]Status: DisposedITAT Jaipur29 Sept 2025AY 2012-2013
For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Dharam Singh Meena, JCIT
Section 132Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

rational connection with or relevant bearing on the formation of the belief. Rational connection postulates that there must be a direct nexus or live link between the material coming to the notice of the Income -tax Officer and the formation of his belief that there has been escapement

Raghvender Shankar Finance & Investment Company Private Limted, New Delhi vs. ITO Ward-15(1), New Delhi

The appeals of the assessee are allowed

ITA 8572/DEL/2019[2006-07]Status: DisposedITAT Delhi24 Sept 2025AY 2006-07

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accountnat Member [Assessment Year: 2009-10] M/S Singhal Fasteners Dy. Commissioner Of Income Tax, Company Pvt. Ltd. Circle-24(2), Room No.248, 67-68, Rampuri, Govind Puri, Vs C.R. Building, Kalkaji, New Delhi-110019 New Delhi-110002 Pan-Aaacs1428H Appellant Respondent [Assessment Year: 2009-10] M/S Shankar Radhey Finance Income Tax Officer & Investment Company Ward-23(1), Private Limited, Vs New Delhi-110002 Ag-5, Shalimar Bagh, New Delhi-110088 Pan-Aabcs0968H Appellant Respondent [Assessment Year: 2006-07] M/S Raghvender Shankar Income Tax Officer, Finance & Investment Ward-15(1), Company Private Limited, Vs New Delhi-110002 Ag-5, Shalimar Bagh, New Delhi-110052 Pan-Aabcs0968H Appellant Respondent Assessee By Shri Abhishek Mathur, Ca Revenue By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 27.08.2025 Date Of Pronouncement 24.09.2025

Section 143(1)Section 147Section 148

basis of accommodation entries. However, what was the nature of accommodation entry has not been mentioned. Thus, there appears to be an absence of live link. The ld. AR has sufficiently established that in the reasons recorded, reference of receipt of amount of Rs.15 lakhs on 14.12.2004 and Rs.5 lakhs

Shankar Radhey Finance & Investment Co. Pvt. Ltd., New Delhi vs. ITO Ward 23(1), New Delhi

The appeals of the assessee are allowed

ITA 1067/DEL/2019[2009-10]Status: DisposedITAT Delhi24 Sept 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accountnat Member [Assessment Year: 2009-10] M/S Singhal Fasteners Dy. Commissioner Of Income Tax, Company Pvt. Ltd. Circle-24(2), Room No.248, 67-68, Rampuri, Govind Puri, Vs C.R. Building, Kalkaji, New Delhi-110019 New Delhi-110002 Pan-Aaacs1428H Appellant Respondent [Assessment Year: 2009-10] M/S Shankar Radhey Finance Income Tax Officer & Investment Company Ward-23(1), Private Limited, Vs New Delhi-110002 Ag-5, Shalimar Bagh, New Delhi-110088 Pan-Aabcs0968H Appellant Respondent [Assessment Year: 2006-07] M/S Raghvender Shankar Income Tax Officer, Finance & Investment Ward-15(1), Company Private Limited, Vs New Delhi-110002 Ag-5, Shalimar Bagh, New Delhi-110052 Pan-Aabcs0968H Appellant Respondent Assessee By Shri Abhishek Mathur, Ca Revenue By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 27.08.2025 Date Of Pronouncement 24.09.2025

Section 143(1)Section 147Section 148

basis of accommodation entries. However, what was the nature of accommodation entry has not been mentioned. Thus, there appears to be an absence of live link. The ld. AR has sufficiently established that in the reasons recorded, reference of receipt of amount of Rs.15 lakhs on 14.12.2004 and Rs.5 lakhs

Singhal Fastners Co. P.Ltd, New Delhi vs. ITO, Ward-24(2), New Delhi

The appeals of the assessee are allowed

ITA 1066/DEL/2019[2009-10]Status: DisposedITAT Delhi24 Sept 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accountnat Member [Assessment Year: 2009-10] M/S Singhal Fasteners Dy. Commissioner Of Income Tax, Company Pvt. Ltd. Circle-24(2), Room No.248, 67-68, Rampuri, Govind Puri, Vs C.R. Building, Kalkaji, New Delhi-110019 New Delhi-110002 Pan-Aaacs1428H Appellant Respondent [Assessment Year: 2009-10] M/S Shankar Radhey Finance Income Tax Officer & Investment Company Ward-23(1), Private Limited, Vs New Delhi-110002 Ag-5, Shalimar Bagh, New Delhi-110088 Pan-Aabcs0968H Appellant Respondent [Assessment Year: 2006-07] M/S Raghvender Shankar Income Tax Officer, Finance & Investment Ward-15(1), Company Private Limited, Vs New Delhi-110002 Ag-5, Shalimar Bagh, New Delhi-110052 Pan-Aabcs0968H Appellant Respondent Assessee By Shri Abhishek Mathur, Ca Revenue By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 27.08.2025 Date Of Pronouncement 24.09.2025

Section 143(1)Section 147Section 148

basis of accommodation entries. However, what was the nature of accommodation entry has not been mentioned. Thus, there appears to be an absence of live link. The ld. AR has sufficiently established that in the reasons recorded, reference of receipt of amount of Rs.15 lakhs on 14.12.2004 and Rs.5 lakhs

Nks Holdings P.Ltd, New Delhi vs. ACIT, Central Circle-32, New Delhi

ITA 6690/DEL/2018[2011-12]Status: DisposedITAT Delhi24 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaassessment Year: 2011-12 Nks Holdings Pvt. Ltd., Vs Acit, 3198/15, 4Th Floor, Gali No.1, Central Circle-32, Sangatrashan, New Delhi. Paharganj, New Delhi – 110 055. Pan: Aakcs7827C (Appellant) (Respondent) Assessee By : Shri Amol Sinha, Advocate & Shri Ankit Kumar, Advocate Revenue By : Ms Rajinder Kaur, Cit-Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 24.09.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 10.08.2018 Of The Commissioner Of Income-Tax (Appeals)-30, New Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeal No.317/17-18/2980 Arising Out Of The Appeal Before It Against The Order Dated 28.12.2017 Passed U/S 144/147 Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Acit, Central Circle-32, New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Amol Sinha, Advocate &For Respondent: Ms Rajinder Kaur, CIT-DR
Section 143(1)Section 143(2)Section 144Section 147Section 148Section 68

raised substantial contentions challenging the reasons recorded u/s 148 of the Act to be vitiated for reasons that same are not based on any live link and mere borrowed satisfaction from information received from investigation of SFIO but as to bring home this contention ld. AR has relied the findings