← 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

Deputy Commissioner of Income -Tax, Central Circle-1(2), Ahmedabad vs. Goyal and Co. (Const.) Private Limited., Ahmedabad

ITA 1836/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad06 Aug 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1836/Ahd/2024 िनधा"रण वष" /Asst.Year 2016-17 The Dcit Goyal & Co. (Const.) Private बनाम/ Central Circle-1(2), Limited V/S. Ahmedabad – 380 009 10Th Floor Commerce House Iv Beside Reliance Petrol Pump 100Ft. Road, Satellite Ahmedabad – 380 015 अपीलाथ'/ (Appellant) !( यथ'/ (Respondent) .. & Cross Objection No.42/Ahd/2024 - िनधा"रण वष" /Ay 2016-17 (In Ita No.1836/Ahd/2024 – Ay 2016-17) V/S. Goyal & Co. (Const.) Private The Dcit Limited Central Circle-1(2), 10Th Floor,Commerce House Iv Ahmedabad – 380 009 Beside Reliance Petrol Pump 100Ft. Road, Satellite Ahmedabad – 380 015 Pan: Aabcg 5459 R (Cross Objector) .. (Respondent)

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Kavan Limbasiya, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148Section 69

recorded reasons based on seized material and obtained necessary sanction under section 151. It was held that there was tangible material and live link justifying reopening under section 147. Accordingly, this ground was dismissed by the Ld.CIT(A). 7.3. On merits, the assessee submitted that the alleged cash transactions recorded

ITO 41(3)(1), Mumbai vs. Deepika Anil Agarwal, Mumbai

In the result the appeal filed by the revenue stands

ITA 1885/MUM/2025[2011-12]Status: DisposedITAT Mumbai06 Aug 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawal

Section 10(38)Section 132Section 132(4)Section 143Section 147Section 148Section 263Section 68

Dept has to show that there is a scam and that the assesse is part of the scam. The chain of events and the live link of assesses action giving her involvement in the scam should be established. The Dept cannot rely on alleged modus operandi & human behavior and disregard ... Dept has to show that there is a scam and that the assesse is part of the scam. The chain of events and the live link of assesses action giving her involvement in the scam should be established. The Dept cannot rely on alleged modus operandi & human behavior and disregard

Rajendra Kumar Mundra (HUF), Mumbai vs. National Faceless Assessment Centre (NFAC), Delhi

In the result the appeal filed by the assessee stands allowed

ITA 1000/MUM/2024[2016-17]Status: DisposedITAT Mumbai06 Aug 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawalrajendra Kumar Mundra Vs. Ito, Ward 24(3)(1) (Huf) Piramal Chamber C-28, Ameya Bldg, Behind Lalbaug, Mumbai – Ymca Dn Nagar Andheri (W) 400012. 400053. Pan/Gir No.Aadh6828J (Applicant) (Respondent)

Section 147Section 148Section 2Section 263Section 68Section 69A

Dept has to show that there is a scam and that the assesse is part of the scam. The chain of events and the live link of assesses action giving her involvement in the scam should be established. The Dept cannot rely on alleged modus 23 Rajendra Kumar Mundra

Ultra Modern Exports Pvt. Ltd., New Delhi vs. ITO Ward - 27(1), New Delhi

ITA 527/DEL/2020[2011-12]Status: DisposedITAT Delhi06 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 68

This goes to prove that there is absolutely no tangible material available with the Learned AO which would have a live link to form a belief that income of the assessee had escaped assessment warranting reopening. There is absolutely no basis for the Learned AO to conclude that assessee company

Income Tax Officer Ward-16(3), Delhi ITO vs. Mansarover Exim Pvt. Ltd., Delhi

ITA 1275/DEL/2024[2012-13]Status: DisposedITAT Delhi30 Jul 2025AY 2012-13

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2012-13] Ito, Vs Mansarover Exim Pvt.Ltd., Ward-16(3), 2, First Floor, Pocket-H-34, Delhi Plot No.35, Sector-3, Rohini, New Delhi-110085. Pan-Aaecm9328A Appellant Respondent Revenue By Ms. Amisha S.Gupta, Cit Dr Assessee By Shri Rohit Jain, Adv., Shri Shourya Jain, Ca & Shri Deepesh Jain, Adv. Date Of Hearing 06.05.2025 Date Of Pronouncement 30.07.2025 Order

Section 131Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

record. It may be noted suspicion howsoever strong cannot partake character of tangible proof or evidence beyond a reasonable doubt. There is absence of live link between the evidence available on record and conclusion drawn for additions made of the unexplained cash credit u/s. 68 of the Act. The Legal

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)

must have sufficient cause to believe that it has. 25. In the present case, as may be seen, there is no "close nexus" or "live link" between tangible material and the reason to believe that income has escaped assessment. The information received from the Investigating Unit of the Revenue cannot

Jeet Kaur, Sainik Farm vs. Income Tax Officer Ward 19(3), Delhi

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 5512/DEL/2024[2013-14]Status: DisposedITAT Delhi28 Jul 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishra

Section 143(1)Section 148Section 148ASection 69

circumstances at hand. 4. The impugned reassessment proceedings proceed on a hypothesis or a theory about certain modus operandi of transactions without establishing any live link between the alleged information in the possession of the department and the case of the assessee; thus, the entire proceedings are void ab initio

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

DCIT in ITA Nos. 3284/Del/2019 vide orders dt. 11.05.2022held as under: 9. From the above, we find that there is no live link presented by the AO between the material available with him i.e. the report of the investigation and to reason to belief that the assessee has tried

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 819/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

DCIT in ITA Nos. 3284/Del/2019 vide orders dt. 11.05.2022held as under: 9. From the above, we find that there is no live link presented by the AO between the material available with him i.e. the report of the investigation and to reason to belief that the assessee has tried

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 818/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

DCIT in ITA Nos. 3284/Del/2019 vide orders dt. 11.05.2022 held as under: 9. From the above, we find that there is no live link presented by the AO between the material available with him i.e. the report of the investigation and to reason to belief that the assessee has tried

Ravinder Singh Thakkar, Jaipur vs. Assistant Commssioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 817/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Jul 2025AY 2016-17
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

DCIT in ITA Nos. 3284/Del/2019 vide orders dt. 11.05.2022held as under: 9. From the above, we find that there is no live link presented by the AO between the material available with him i.e. the report of the investigation and to reason to belief that the assessee has tried

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 816/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

DCIT in ITA Nos. 3284/Del/2019 vide orders dt. 11.05.2022held as under: 9. From the above, we find that there is no live link presented by the AO between the material available with him i.e. the report of the investigation and to reason to belief that the assessee has tried

Sylvan Greens Private Limited, Jaipur vs. Deputy Commissioner of Income Tax Circle 6, Jaipur

In the result, the appeal of the assessee is allowed

ITA 414/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Smt. Neelam Bhala, AdvocateFor Respondent: Shri Gorav Avasthi, JCIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 801C

reopen, provided there is 'tangible material' to come to conclusion that there is escapement of income from assessment and reasons must have a live link with the formation of the belief. The Hon'ble Supreme Court in the case of Deputy Commissioner of Income Tax V Pandesara Infrastructure ... reopen, provided there is 'tangible material' to come to conclusion that there is escapement of income from assessment and reasons must have a live link with the formation of the belief. The Assessing Officer must specifically identify what material was not truly and fully disclosed, or what new information came

ACIT, Circle-34, Kolkata vs. Vinod Kumar Lahoti, Kokata

In the result, the appeal of the revenue is dismissed

ITA 2460/KOL/2024[2013-14]Status: DisposedITAT Kolkata25 Jul 2025AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 69C

party statement to be true without examining the veracity of the same. It has further been submitted that the mere information without establishing a live link or direct, the AO has held that here is an escapement of income to the extent

Basant Jain, Delhi vs. DCIT, Central Circle 29, Delhi

In the result, the appeal of the assessee is allowed

ITA 2750/DEL/2023[2013-2014]Status: DisposedITAT Delhi25 Jul 2025AY 2013-2014

Bench: Shri C. N. Prasad & Shri M. Balaganeshbasant Jain, Vs. Dcit, C-119, Shivaji Park, Central Circle-29, Punjabi Bagh, Delhi Delhi (Appellant) (Respondent) Pan: Adbpj2416P

For Appellant: Shri R. S. Singhvi, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133ASection 143(3)Section 147Section 148Section 69

could be safely concluded that the ld AO did not have not tangible material at the time of recording the reasons which had live link to form a belief that the income of the assessee had escaped assessment. The ld AO had formed a belief that income of the assessee

Sonea Dhir, Delhi vs. ACIT Circle-32 (1), New Delhi

Appeal of the assessee is allowed

ITA 3073/DEL/2024[2011-12]Status: DisposedITAT Delhi23 Jul 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 143(1)Section 143(2)Section 147Section 250Section 50C

dated 15:02 2012 the Hon'ble Delhi High Court, which is the jurisdictional High Court held that as long as there is a live link between the material which was placed before the Assessing Officer at the time when reasons for reopening were recorded, proceedings u/s 147 would ... done in a mechanical manner without application of mind, we find there is nothing on record to support such a contention. There is a live link between the information which was available with the Assessing Officer and his formation of belief that income has escaped assessment Sufficiently of such information

DCIT, New Delhi vs. Amit Goel, Delhi

In the result, appeal is allowed

ITA 2965/DEL/2024[2012-13]Status: DisposedITAT Delhi23 Jul 2025AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.2965/Del/2024 िनधा"रणवष"/Assessment Year:2012-13 बनाम Dcit, Amit Goel, Room No.221, 2Nd Floor, Vs. S-33, Panchsheel Park, C.R. Building, I.P. Estate, Hauz Khas, New Delhi. New Delhi. Pan No.Aaapg7084L अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection No.85/Del/2024 (Arising Out Of I.T.A No.2965/Del/2024) िनधा"रणवष"/Assessment Year:2012-13 बनाम Amit Goel, Dcit, Room No.221, 2Nd Floor, S-33, Panchsheel Park, Vs. Hauz Khas, New Delhi. C.R. Building, I.P. Estate, Pan No.Aaapg7084L New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 69C

arising out of such transaction during the F.Y. 2011-12 relevant to the assessment year 2012-13. 8. In the present case, there is live link between the material provided by the Investigation Wing, Delhi and escapement of income exists, I have the reason to believe that amount at least

Nazar Impex Private Limited, Surat vs. Income Tax Officer-1(1)(3), Surat (Current Jurisdiction), Surat

In the result, assessee’s appeal is allowed

ITA 1212/SRT/2024[2012-13]Status: DisposedITAT Surat21 Jul 2025AY 2012-13

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1212/Srt/2024 Assessment Year: (2012-13) (Hybrid Hearing) Nazar Impex Pvt.Ltd. Income Tax Officer बनाम/ 408, Saryu Diamond Complex, Ward-1(1)(3), Surat, Aaykar Vs. Jadda Khadi, Mahidharpura, Bhavan, Majura Gate, Opp. New Surat-395 003 Civil Hospital, Surat-395 001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaccn3603R (अपीलाथ"/Appellant) (प्र"थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Himanshu Gandhi, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 04/06/2025 उद्घोषणा की तारीख/Date Of Pronouncement 21/07/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: This Appeal By The Assessee Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, ‘The Act’), Dated 26.09.2024 By The National Faceless Appeal Centre, Delhi /Commissioner Of Income-Tax (Appeals), [In Short ‘Nfac/Cit(A)’] For The Assessment Year (Ay) 2012-13, Which In Turn Assessment Order Passed By Assessing Officer (In Short, ‘Ao’) U/S 144 R.W.S. 147 Of The Act On 30.12.2019. 2. Grounds Of Appeal Raised By The Assessee For The Appeals Are As Under: “1. Ground 6. On The Facts & Circumstances Of The Case & Law, The Ld. Cit(A) Erred In Confirming Rejection Of Books Of Account Under Section 145(3) Of Income Tax, Act 1961 Without Pointing Out Any Defect In Books Of Account & Even The Return Income On The Basis Of Books Of Account Were Also Not Disputed.

Section 132Section 133ASection 144Section 145(3)Section 148Section 151Section 153CSection 250

assessment provided there is tangible material to come to the conclusion that there is escapement of income and the reasons must have a live link with the formation of belief. Reopening based on mere change of opinion lacks validity and the notice u/s 148 cannot be sustained. In the present

Umang Webtech Pvt. Ltd., Kolkata vs. ITO, Ward 14(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 151/KOL/2025[2014-15]Status: DisposedITAT Kolkata18 Jul 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Umang Webtech Pvt. Ltd. Income Tax Officer, 196/C, C.R. Avenue, Ward 14(1), Aaykar Bhavan Kolkata-700007 110 Shantipally, E.M. Bypass, Vs. West Bengal Kolkata-700107, West Bengal (Respondent) (Appellant) Pan No. Aaacu9656P Assessee By : Shri Amit Agarwal, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 20.05.2025 Date Of Pronouncement: 18.07.2025

For Appellant: Shri Amit Agarwal, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 143(3)Section 147Section 148

apparent from the evidences furnished before us including the bank statement. Therefore, the reopening is made without any substantive basis and live link. We note that despite the assessee repeatedly requesting before the ld. AO that he has not received any such amount and the AO was also not having

Deputy Commissioner of Income Tax, Circle-1(3)(1), Mumbai vs. Tmf Holdings Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 2983/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Jul 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhrideputy Commissioner Of Vs Tmf Holdings Limited 14, 4Th Floor, Sir H C Dinshaw Income Tax, Circle 1(3)(1), Mumbai Building, 16, Horniman Circle, Fort, Room No.535, 5Th Floor, Aaykar Mumbai-400 001 Bhavan, M.K. Road, Mumbai- Pan: Aacct4644A 400 020 Appellant Respondent

For Appellant: Shri Rajan Vora a/w Shri Nikhil TiwariFor Respondent: Shri Ritesh Mishra, CIT DR
Section 115JSection 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

reopen, 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