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“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

Assistant Commissioner of Income Tax, Circle-1(1)(1), Meerut, Meerut (U.P.) vs. Nita Rastogi, Meerut (U.P.)

In the result, appeal of the Revenue is dismissed

ITA 3382/DEL/2025[2013-14]Status: DisposedITAT Delhi26 Nov 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2013-14] Acit Vs Nita Rastogi Circle-1(1)(1) 32-C, Janta Nagar, Garh Road, Meerut-250001. Meerut-250002. Pan-Aanpr7715E Appellant Respondent Revenue By Shri Shyam Manohar Singh, Sr.Dr Assessee By Dr. Kapil Goel, Adv. Date Of Hearing 23.09.2025 Date Of Pronouncement 26.11.2025

Section 139(1)Section 147Section 148Section 250Section 68Section 690

reported in 477 ITR 296 (SC) wherein Hon’ble Supreme Court has held that AO reopened the assessment on borrowed satisfaction without establishing the live link between the information and material on record and dismissed the SLP filed by the Revenue. He also relied on the judgment ... Addl. Commissioner of Income- tax [2024] 166 taxmann.com 72 (Delhi), in which it was held that.... 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

Ajay Gupta, Faridabad vs. Income Tax Officer, Ward-1(1), Faridabad

The appeal of the assessee is allowed

ITA 3011/DEL/2024[2017-18]Status: DisposedITAT Delhi26 Nov 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2017-18 Ajay Gupta, Vs. Ito, 293, Sector-15, Ward-1(1), Faridabad, Faridabad. Haryana – 121006. Pan: Bdppg7239G

For Appellant: Shri Gagan Khandelwal, Advocate; &For Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 10(38)Section 147Section 68

submitting that the AO has duly taken into consideration the information which was received from the Investigation Wing and finding a live link between the information and the material available on record, the reasons were recorded. 3. Justifying the transaction as bonafide, on merits of the transaction, the assessee ... considered to be sacrosanct and without application of any due diligence the information was relied and processed to find a hypothetical live link with regard to escapement of income. 5. After taking into consideration the material on record and the submissions, we are of the considered view that certainly

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

Year Objection No

ITA 2834/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 Nov 2025AY 2016-17
For Appellant: Shri Faroog IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

reopen, provided there is ‘tangible material’ to come to a conclusion that there has been escapement of income from assessment. Reasons must have a ‘live link’ with the formation of the belief. The relevant extract of the judgment of the Hon’ble Supreme Court has been reproduced hereinbelow for ease ... 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

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2830/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

reopen, provided there is ‘tangible material’ to come to a conclusion that there has been escapement of income from assessment. Reasons must have a ‘live link’ with the formation of the belief. The relevant extract of the judgment of the Hon’ble Supreme Court has been reproduced hereinbelow for ease ... 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

DCIT 3.2.1, Mumbai vs. The New India Assurance Co Limited, Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2823/MUM/2024[2019-20]Status: DisposedITAT Mumbai21 Nov 2025AY 2019-20

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

reopen, provided there is ‘tangible material’ to come to a conclusion that there has been escapement of income from assessment. Reasons must have a ‘live link’ with the formation of the belief. The relevant extract of the judgment of the Hon’ble Supreme Court has been reproduced hereinbelow for ease ... 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

The New India Assurance Co Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(2)(2), Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2622/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

reopen, provided there is ‘tangible material’ to come to a conclusion that there has been escapement of income from assessment. Reasons must have a ‘live link’ with the formation of the belief. The relevant extract of the judgment of the Hon’ble Supreme Court has been reproduced hereinbelow for ease ... 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

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle-3(2)(2), Mumbai

Year Objection No

ITA 2620/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 Nov 2025AY 2016-17
For Appellant: Shri Faroog IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

reopen, provided there is ‘tangible material’ to come to a conclusion that there has been escapement of income from assessment. Reasons must have a ‘live link’ with the formation of the belief. The relevant extract of the judgment of the Hon’ble Supreme Court has been reproduced hereinbelow for ease ... 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

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle -3(2)(2), Mumbai

ITA 2618/MUM/2024[2013-14]Status: DisposedITAT Mumbai21 Nov 2025AY 2013-14
Section 115JSection 143(3)Section 147Section 148

reopen, provided there is ‘tangible material’ to come to a conclusion that there has been escapement of income from assessment. Reasons must have a ‘live link’ with the formation of the belief. The relevant extract of the judgment of the Hon’ble Supreme Court has been reproduced hereinbelow for ease

The New India Assurance Co. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(2)(2), Mumbai

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2616/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Nov 2025AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&
Section 115JSection 143(3)Section 147Section 148

reopen, provided there is ‘tangible material’ to come to a conclusion that there has been escapement of income from assessment. Reasons must have a ‘live link’ with the formation of the belief. The relevant extract of the judgment of the Hon’ble Supreme Court has been reproduced hereinbelow for ease ... 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

Saini Co-Operative Tharift and Credit Society Ltd, Delhi vs. ITO Ward-48(1), Delhi

In the result, the appeal is allowed

ITA 4261/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Nov 2025AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. V. Rajakumar, AdvFor Respondent: Sh. Jitender Singh, CIT-DR
Section 80Section 80PSection 80P(2)(a)

from providing credit facilities to its members but also any other income which is attributable to such business. So long as there exists a live link, not necessarily direct, between the income and carrying on of the business of providing credit facilities, the resultant income qualifies for deduction

Saini Co-Operative Tharift and Credit Society Ltd, Delhi vs. ITO Ward-48(1), Delhi

In the result, the appeal is allowed

ITA 4260/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Nov 2025AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. V. Rajakumar, AdvFor Respondent: Sh. Jitender Singh, CIT-DR
Section 80Section 80PSection 80P(2)(a)

from providing credit facilities to its members but also any other income which is attributable to such business. So long as there exists a live link, not necessarily direct, between the income and carrying on of the business of providing credit facilities, the resultant income qualifies for deduction

Income Tax Officer Ward-48(1), Delhi vs. Ravinder Nath Goel, Delhi

In the result, appeal of the Revenue in ITA No

ITA 3437/DEL/2024[2012-13]Status: DisposedITAT Delhi21 Nov 2025AY 2012-13

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Navneet Singal, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 131Section 147Section 148

Trading Co. or for that matter receipt in such account had any direct or proximate relation with the assessee or for that matter any live link between the assessee and the said bank account barring two transactions of receipts by family members of the appellant. The CIT(A) also held

M/S Bajrang Lal Jindal, Kanpur vs. Astt. Commissioner of Income Tax-I, Kanpur

In the result, the appeal of the assessee is allowed

ITA 373/LKW/2017[2008-09]Status: DisposedITAT Lucknow20 Nov 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2008-09 M/S Bajrang Lal Jindal, 140, Vs. Asstt. Commissioner Of Income Anandpuri, Kanpur, U.P. Tax-I, Kanpur Pan: Aanpj5660J (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 27.08.2025 Date Of Pronouncement: 20.11.2025 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)- Kanpur, Confirming The Addition Of Rs. 1,46,11,400/- Made To The Returned Income Of The Assessee As Unexplained Cash Credits By The Assessing Officer In His Order Dated 31.03.2016 For The Assessment Year 2008-09. The Grounds Of Appeal Are As Under: - “1. That The Ld. Cit (A) I, Kanpur Has Erred In Confirming Addition Of Rs. 14611400.00 To The Returned Income Of The Assessee As Unexplained Cash Credits. 2. That The Reasons Recorded For Initiation Of Proceedings U/S 147 By Issue Of Notice U/S 148 Were Based On Improper Premise & Accordingly No Legal & Factual Lengs To Stand & Acordingly All Subsequent Proceedings Are Bad In Law. 3. That The Observation Of The Ld. Cit (A) I, Kanpur Confirming View Of Ld. A O That M/S. Maa Devasar Commodity Is Inexistant Is Factually Incorrect. 4. That Ld. Cit (A) I, Kanpur Has Erred In Not Appreciating The Fact That When The Beneficiary Of The Funds Are Not The Assessee, There Could Be No Addition In His Hands.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. Amit Kumar, DR
Section 147Section 148Section 68

something more was required to be brought on record 9 M/s Bajrang Lal Jindal A.Y. 2008-09 so that there could be a live link between the deposits in the bank account and the belief of escapement of income. He submitted that this had been held repeatedly by various Benches

Assistant Commissioner Income Tax, Central Circle -4(1), Kolkata vs. Victor Tradelink Private Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 2310/KOL/2024[2013]Status: DisposedITAT Kolkata19 Nov 2025

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 139Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 153ASection 153CSection 250Section 68

tangible material per se, when there is no further enquiry having been undertaken thereon by the Assessing Officer and there is no live link between the tangible material 5 Victor Tradelink Pvt. Ltd and the Assessing Officer's reasons recorded for the formation of reason belief of escapement of income

Ramasamy Kandasamy, Karur vs. ITO, Ward-1, Karur

In the result, the appeal of the assessee is allowed

ITA 2023/CHNY/2025[2012-13]Status: DisposedITAT Chennai19 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.2023/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 V. Ramasamy Kandasamy, The Ito, No.4/76, Sf No.927, Sukkaliyur, Ward-1, Karur-639 003. Karur. [Pan: Ajgpk 4945 H]

For Appellant: Mr.H. Yeshwanth KumarFor Respondent: Ms.R. Anitha, Addl.CIT
Section 143(2)Section 143(3)Section 147Section 151

Finlease (P) Ltd (ITA No. 342 of 2011) dated 15.02.2012, the Hon'ble Delhi 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. Sufficiency of such information

Tribhawan vs. ITO Ward-2, Rewari

In the result, both the appeals of the assessee are allowed

ITA 872/DEL/2025[2011-12]Status: DisposedITAT Delhi19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh & Shri Sudhir Kumartribhawan, Vs. Ito, C/O Ipso Legal H-35, 1St Ward-2, Rewari Floor, Jangpura Extension, New Delhi- 110014 (Appellant) (Respondent) Pan: Arlpt6268P Assessee By : Ms. Sumangla Saxena, Adv (Vc) Shri Dishant Sethi, Adv Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Ms. Sumangla Saxena, Adv (VC)For Respondent: Shri Om Prakash, Sr. DR
Section 144Section 147Section 151Section 154

same is liable to be treated as unexplained income of the assessee from undisclosed sources. Furthermore, it is evident that there is a "Live Link" between the material available on record and the escaped Income, as mentioned above. 6. In this case no return of income was filed

Kisan International Trading Fze, New Delhi vs. ACIT, Int. Tax 2(1)(2), Delhi

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

ITA 6152/DEL/2024[2012-13]Status: DisposedITAT Delhi19 Nov 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Kisan International Trading Fze, Vs. Acit, Circle C/O Shri Tarandeep Singh, Advocate Int. Tax 2(1)(2), C – 179, Mansarover Garden, Delhi. New Delhi – 110 015. (Pan :Aaeck0424D) (Appellant) (Respondent) Assessee By : Shri Tarandeep Singh, Advocate Shri Sandeep Yadav, Advocate Revenue By : Shri Vikram Singh Sharma, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 19.11.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Delhi – 43 [“Ld. Cit(A)”, For Short] Dated 06.12.2024 For The Assessment Year 2012-13 Raising Following Grounds Of Appeal :- “1. That On Facts & In Law The Order Dated 06Th December 2024 Passed By The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As The "Cit(A)'} & Order Dated 23Rd December 2019 Passed By The Assessing Officer (Hereinafter Referred To As The "Ao") Are Bad In Law & Void Ab Initio.

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Vikram Singh Sharma, Sr. DR
Section 115A(5)Section 147Section 148Section 195Section 251

Petitioner in the shares of its subsidiary amounted to 'income' which had escaped assessment was flawed. The question of such a transaction forming a live link for reasons to believe that income had escaped assessment is entirely without basis and is rejected as such. 26. For the aforementioned reasons, this

Rajendrasinh Ranjitsinh Jadeja, Khakhadabela, Paddhari vs. ITO WD 2(1)(4), RKT, Rajkot

In the result, appeal filed by the assessee, is allowed, to the extent indicated above

ITA 459/RJT/2025[2012-2013]Status: DisposedITAT Rajkot17 Nov 2025AY 2012-2013

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.459/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) Rajendrasinh Ranjitsinh Jadeja Vs. Ito Ward 2 (1) (4), Khakhadabela, Paddhari, Aayakar Bhawan, Race Course Rajkot - 360110 Ring Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agvpj2529E (Appellant) (Respondent) Appellant By : Shri Gaurang Khakhar, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 01/09/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am ; Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2012-13, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 26/07/2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Dated 25/11/2009 U/S 144 R.W.S 147 Of The Income Tax Act, 1961. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1. That The Reasons Recorded U/S 147 Of The I.T. Act, 1961 By The Ld. A.O. Were Merely Based On The Suspicion & Without Any Tangible Material So As To Suggest Any Escapement Of Income. Hence The Reassessment Proceedings Are Liable To Be Quashed Rajendrasinh Ranjitsinh Jadeja

For Appellant: Shri Gaurang Khakhar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 144Section 147Section 148Section 250

aforesaid view on the above proportion has been reiterated by the Apex Court in A.L.A.Firm vs. CIT 183 ITR 285.Reasons must have a live link with the formation of the belief. This is supported by Circular No.549 dated 31.10.1989 which clarified that the words "reason to believe" did not mean

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. Konark Rajhans Estate Private Limited, Panchkula

In the result, the appeal of the revenue stands dismissed

ITA 805/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh13 Nov 2025AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 805/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2011-12 Acit M/S Konark Rajhans Estate Private Limited Panchkula Circle बनाम/ Vs. Nh 73, Village Kot Extension-Ii, Sector 14, Panchkula. Panchkula. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaeck-2405-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Manav Bansal (Cit) – Ld. Dr ""थ"कीओरसे/Respondent By : Sh. Parikshit Aggarwal (Ca)-Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 20-08-2025 घोषणाकीतारीख /Date Of Pronouncement : 13/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal By The Revenue For Assessment Year (Ay) 2011- 12 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 27-05-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S. 147 Of The Act On 29-12-2018. The Revenue Is Aggrieved By Deletion Of Twin Quantum Additions Of Rs.40.85 Lacs & Rs.707.75 Lacs As Made By Ld. Ao In The Assessment Order. The Grounds Of Appeal Read As Under: -

For Appellant: Sh. Manav Bansal (CIT) – Ld. DRFor Respondent: Sh. Parikshit Aggarwal (CA)-Ld. AR
Section 131oSection 143(3)Section 148Section 40A(3)Section 68Section 68o

that no inference of escapement of income could be drawn against the assessee on these facts. The reasons to believe had no nexus or live link with the escapement of income of the assessee. The assessee had duly filed return of income which fact was contradicted by Ld. AO while

Satish Sawarmal Saraf, Mumbai vs. Assistant Commissioner of Income Tax, CC-4(3), Mumbai

In the result, the appeal filed by the assessee stands

ITA 5540/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Nov 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Section 133(6)Section 250Section 69A

believe that any income has escaped assessment and that the reassessment order passed was illegal and bad in law as: There was no live link between the information received and provided in the reasons recorded with that of the appellant as there was no mention of the appellant