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“reasons recorded”

ReassessmentSection 148Section 14813,127 judgments

The decision most relied on for reasons recorded is Hindustan Lever Ltd. v. R.B. Wadkar (268 ITR 332), cited in 695 judgments on BharatTax.

Leading authorities on reasons recorded

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.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

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

Reassessment proceedings are invalid if initiated based on documents already available on record without fresh tangible material, and if the sanction under section 151 is accorded mechanically, indicating non-application of mind.

M/s Sahara India (Farms) v. CIT & Anr.
300 ITR 403 · 2008 · Supreme Court
268
citing judgments

The requirement of statutory prior approval by a high-ranking authority, even if administrative, serves as an in-built protection against arbitrary exercise of power by the Assessing Officer. While such approval need not record elaborate reasoning, the approving authority has a heavy duty to ensure it is not an empty ritual, fulfilling its purpose of supervisory control.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Pepsi Foods (P.) Ltd. v. Asstt. CIT
367 ITR 112 · 2014 · High Court
225
citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

Judgments citing reasons recorded

ACIT, CC-6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 3995/MUM/2025[2011-12]Status: DisposedITAT Mumbai20 Feb 2026AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

Assessing Officer recorded the reasons for reopening of the assessment and issued notice u/s.148 on 29.03.2016. Statutory compliances of filing return, supplying copy of reasons recorded, filing of objections thereon and disposal of the objections so raised were all met. After considering the submission filed by the assessee

Ravisum Creative Promotions Pvt. Ltd (Formerly Known As Agro Investment Pvt. Ltd, Mumbai vs. ACIT Cen Cir 8 (11(1), Mumbai

In the result, appeal is allowed

ITA 1616/MUM/2022[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarravisun Creative Promotions Pvt. Ltd., Acit, Formerly Known As Ravisun Agro 6Th Floor, Aaykar Bhavan, Investments Pvt. Ltd. New Marine Lines, Vs. 305, Surat Sadan, Surat Street, Churchgate, Masjit Bunder, Mumbai - 400020 Mumbai – 400049 (Appellant) : (Respondent) Pan No. Aabcr 9224M Appellant By : Ms. Radha Halbe Respondent By : Shri Annavaran Kosuri, Sr.- Dr (Appellant) (Respondent) Date Of Hearing : 17.02.2026 Date Of Pronouncement : 20.02.2026

For Appellant: Ms. Radha HalbeFor Respondent: Shri Annavaran Kosuri, Sr.- DR
Section 143(3)Section 147Section 148Section 14ASection 43B

Representative (DR) strongly relied upon the observations of the Departmental Authorities. 7. We have considered rival submissions and perused the materials on record. The reasons recorded by the Assessing Officer for reopening of assessment are as under:- “In this case, the assessment was completed ... Mumbai vide letter dated 10.12.2014. Issue notice u/s 148 of the IT Act, 1961accordingly.” 8. As could be seen from the reasons recorded, the only issue on which the assessment was reopened is alleged non-disallowance of expenditure u/s.14A r.w.r. 8D. It is a fact on record that the original

Yash Kumar Goyal, Gwalior vs. DCIT/ACIT 2(1), Gwalior

In the result, both appeals filed by the assessee are allowed

ITA 519/AGR/2025[2013-14]Status: DisposedITAT Agra19 Feb 2026AY 2013-14

Bench: : Shri S. Rifaur Rahman

Section 143(3)Section 147Section 148Section 153ASection 153CSection 271(1)(c)Section 274Section 50C

that once proceedings under Section 147 are abated due to initiation of Section 153C, the Assessing Officer cannot make additions based on the original reasons recorded under Section 147/148 unless they are supported by incriminating material found during the search. 4. That the penalty proceedings initiated under Section

Yash Kumar Goyal, Gwalior vs. DCIT/ACIT 2(1), Gwalior

In the result, both appeals filed by the assessee are allowed

ITA 518/AGR/2025[2012-13]Status: DisposedITAT Agra19 Feb 2026AY 2012-13

Bench: : Shri S. Rifaur Rahman

Section 143(3)Section 147Section 148Section 153ASection 153CSection 271(1)(c)Section 274Section 50C

that once proceedings under Section 147 are abated due to initiation of Section 153C, the Assessing Officer cannot make additions based on the original reasons recorded under Section 147/148 unless they are supported by incriminating material found during the search. 4. That the penalty proceedings initiated under Section

Smt. Manda Thete, Nagpur vs. Asst. Commissioner of Income Tax, Jabalpur

In the result, the appeal of the assessee stands partly allowed for statistical purposes

ITA 47/JAB/2025[2012-13]Status: DisposedITAT Jabalpur19 Feb 2026AY 2012-13

Bench: Shri Anadee Nath Misshra

Section 143(3)

That the CIT Appeals faceless erred in confirming the action of A.O. us 148 notice dated 30.03.2019 in confirming the reasons recorded for treating the unsecured loans for Rs. 3140045 which has already been proved and accepted by the AO during the course of proceedings for the assessment year

Ramjidas Budhraja Charitable Trust (Sgm), Chhindwara vs. Income Tax Officer Exemption, Jabalpur

In the result, the appeal of the assessee is dismissed

ITA 235/JAB/2025[2015-16]Status: DisposedITAT Jabalpur19 Feb 2026AY 2015-16

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 10Section 11Section 11(2)Section 143(1)Section 143(3)Section 147Section 148

assessment year 2015-2016 by speed post on 14.04.2018. The assessee had also requested the learned Assessing Officer to provide the copy of reasons recorded for reopening of the assessment in view of the Apex Court judgment in the case of G.K.N. Drive Shaft Limited vs. C.I.T. However, no copy ... assessment year 2015-2016 by speed post on 14.04.2018. The assessee had also requested the learned Assessing Officer to provide the copy of reasons recorded for reopening of the assessment in view of the Apex Court judgment in the case of G.K.N. Drive Shaft Limited vs. C.I.T. However, no copy

Trimurti Steels, Bhubaneswar vs. Income Tax Officer, Ward 2(1), Bhubaneswar

In the result, this appeal of the assessee is allowed

ITA 625/CTK/2025[2012-13]Status: HeardITAT Cuttack19 Feb 2026AY 2012-13

Bench: Shri George Mathan & Shri Madhusudan Sawdiatrimurti Steels, I.T.O., Plot No. N-3885, Golap Niwas, Ward- 2(1) Vs. Samantarapur, Bhubaneshwar-751002 Bhubaneshwar. Odisha. Pan No. Aahft 1240 Q Appellant/ Assessee Respondent/ Revenue

Section 143(3)Section 147Section 148Section 184Section 40

reopened by issuance of notice under Section 148 of Trimurti Steels Vs ITO the Act on 29/03/2018. It was the submission that the reasons recorded by the Assessing Officer does not mention that there is failure on the part of the assessee to disclose fully and truly all material facts ... required for the assessment. The ld. AR drew our attention to the reasons recorded which reads as under: 2 Trimurti Steels Vs ITO It was the submission that the reasons only mentioned that the instrument of the firm was not registered with any authority appointed by the State Government

M/S Ras Devcon Private Limited, Sanvid Nagar, Kanadia Road, Indore vs. Assistant Commissioner of Income Tax, Indore, Aaykar Bhawan, Opposite White Church Road

ITA 171/IND/2025[2014- 2015]Status: DisposedITAT Indore19 Feb 2026

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

Section 142(1)Section 143(2)Section 147Section 148Section 246ASection 250Section 253Section 68

duly served upon the assessee. The assessee made written submission along with documents in response of the above notice. Copy of the reasons recorded was also requested by the assessee which was duly provided. Subsequently the assessee made written submission along with other documents. 2.4 That it is recorded ... provision of Section 148 of the Income Tax Act by way of issuing notice under Section 148 of the Act on 30/03/2021. The reason recorded for re-opening are such that in case of present Appellant High Risk CRIU/VRU information on "Insight portal" and also information was received from

Jethabhai Gokulbhai Gol, Banaskatha vs. ITO, Ward 1, Palanpur, Banaskantha

Accordingly, the appeal filed by the assessee is dismissed

ITA 2668/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad19 Feb 2026AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 142(1)Section 144BSection 147Section 148Section 69

that the capital introduced in the partnership firm had already been examined in the firm’s assessment. The CIT(Appeals), after examining the reasons recorded for reopening and the material on record, held that the Assessing Officer had received specific and actionable information regarding substantial cash introduction by the assessee ... learned counsel for the assessee is with regard to the validity of initiation of reassessment proceedings. It is being contended that the reasons recorded by the Assessing Officer were based on a roving enquiry and amounted to borrowed satisfaction on the basis of information received from the DCIT, Gandhinagar Circle

Ramesh Purshottam Modi, Mumbai vs. Income Tax Officer Circle 22(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6577/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Purshottam Ito Circle 22(1) Modi Income Tax 303, Modi House, Linking Vs. Department, Road, Khar West, Piramal Chamber, Mumbai-400 052 Dr. Ss Rao Marg, Parel, Mumbai 0 400 012 Pan/Gir No. Aahpm2793F (Applicant) (Respondent) Assessee By Shri Ashwani Kumar A/W Ms. Deepali Aggarwal, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 12.02.2026 Date Of Pronouncement 19.02.2026

Section 143(3)Section 144BSection 147Section 148Section 250Section 94(7)Section 94(8)

circumstances of the case and in law, the Ld. CIT(A) erred in upholding the action of the Ld. AO that in the reason recorded, the Ld. AO stated that the appellant has claimed fictitious losses of Rs 44,24,42,395/-, whereas Ld. AO completed the Assessment proceedings ... contended that the assumption of jurisdiction under section 147 was bad in law. 14. The learned AR further pointed out that, as per the reasons recorded, the basis for reopening was the alleged short term capital loss of Rs. 44.24 crore, whereas in the reassessment order the addition was ultimately

Society for Advancement in Education, Mussoorie vs. ITO Exemption Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 220/DDN/2025[2011-12]Status: DisposedITAT Dehradun18 Feb 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

have heard both the parties and perused the material available on record. The Assessee has produced the copy of Performa sent along with reasons recorded by the A.O. at Page No. 003 to 005 of the Paper Book. As could be seen from the said documents ... certain reasons recordedAssessee objected to same before AO, that was rejected and assessment was completed u/ss. 143(3) and 147-CIT(A) found that reason recorded by Joint Commissioner of Income Tax, for according sanction, was merely recording ‘I am Satisfied’-Action for sanction was alleged to be without application

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 219/DDN/2025[2010-11]Status: DisposedITAT Dehradun18 Feb 2026AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

have heard both the parties and perused the material available on record. The Assessee has produced the copy of Performa sent along with reasons recorded by the A.O. at Page No. 003 to 005 of the Paper Book. As could be seen from the said documents ... certain reasons recordedAssessee objected to same before AO, that was rejected and assessment was completed u/ss. 143(3) and 147-CIT(A) found that reason recorded by Joint Commissioner of Income Tax, for according sanction, was merely recording ‘I am Satisfied’-Action for sanction was alleged to be without application

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 218/DDN/2025[2009-10]Status: DisposedITAT Dehradun18 Feb 2026AY 2009-10

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

have heard both the parties and perused the material available on record. The Assessee has produced the copy of Performa sent along with reasons recorded by the A.O. at Page No. 003 to 005 of the Paper Book. As could be seen from the said documents ... certain reasons recordedAssessee objected to same before AO, that was rejected and assessment was completed u/ss. 143(3) and 147-CIT(A) found that reason recorded by Joint Commissioner of Income Tax, for according sanction, was merely recording ‘I am Satisfied’-Action for sanction was alleged to be without application

Selestina Tirkey, Bilaspur vs. Income Tax Officer, Ward-2(1), Bilaspur

In the result, appeal of the assessee in ITA

ITA 807/RPR/2025[2014-15]Status: HeardITAT Raipur18 Feb 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.807/Rpr/2025 "नधा"रण वष" /Assessment Year : 2014-15 Selestina Tirkey C/O. Aghya Kerketta, Ganga Nagar, Phase-Ii, Behind 36 Mall, Mangla Chowk, Bilaspur (C.G.)-495 001 Pan: Arapt0339E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-2(1), Bilaspur (C.G.)

For Appellant: Shri Yash Dhariwal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 271(1)(c)Section 69

case of the assesse additional evidences were filed before the Ld. CIT(Appeals) which he had rejected. 13. We have also gone through the reasons recorded in the petition filed by the Ld. Counsel for the assessee as to 7 Selestina Tirkey Vs. ITO, Ward-2(1), Bilaspur

Income-Tax Officer, Ward-1(3)(1), Ahmedabad vs. Parthiv Jawaharbhai Shah, Ahmedabad

The appeal of the asessee is partly allowed for statistical purposes while Revenue’s appeal is dismissed

ITA 1038/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2013-14
For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri Rignesh Das, CIT. DR
Section 147Section 148Section 250Section 68

application of mind/borrowed satisfaction of the AO of escapement of income of the assessee. The assesses case merely rests on the contents of the reason recorded and no reference has been made of the material found by the Investigation wing, which admittedly, was ITA Nos.1030 & 1038/Ahd/2024 [Parthiv Jawaharbhai Shah ... made available to the assessee. We, therefore, find no merit in the contention of the Ld.Counsel for the assessee that the reasons recorded for reopening the case of the assessee were based on borrowed satisfaction and were without any application of mind by the AO, and accordingly reject the same

Parthiv Jawaharbhai Shah, Ahmedabad vs. The ITO, Ward-1(3)(1), Ahmedabad

The appeal of the asessee is partly allowed for statistical purposes while Revenue’s appeal is dismissed

ITA 1030/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2013-14

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri Rignesh Das, CIT. DR
Section 147Section 148Section 250Section 68

application of mind/borrowed satisfaction of the AO of escapement of income of the assessee. The assesses case merely rests on the contents of the reason recorded and no reference has been made of the material found by the Investigation wing, which admittedly, was ITA Nos.1030 & 1038/Ahd/2024 [Parthiv Jawaharbhai Shah ... made available to the assessee. We, therefore, find no merit in the contention of the Ld.Counsel for the assessee that the reasons recorded for reopening the case of the assessee were based on borrowed satisfaction and were without any application of mind by the AO, and accordingly reject the same

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1894/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11 Hyderabad, Dated 11/10/2025 For The A.Y 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 69A

also requested to furnish the reasons for reopening of assessment u/s. 147 of the I.T. Act. The A.O vide letter dated 07.02.2024 provided the reasons recorded for reopening of assessment to the assessee. Thereafter, statutory notices under section 143(2) & 142(1) of the I.T. Act, dated 16.04.2024 & 10.05.2024, respectively ... asset nor any expenditure nor any entry or entries in the books of account. The Assessing Officer has not recorded his satisfaction with the reasons recorded for reopening the assessment regarding fulfilling of the conditions specified u/s 149(1)(b) of the Act. The Assessing Officer has not even quantified

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1884/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

Vilas Polymer P Ltd 9. The learned Counsel for the assessee further referring to the reasons recorded by the A.O submitted that, the A.O invoked explanation (2) clause (i) of section 148 of the Act on the presumption that once a search is initiated under section ... suggest income escaped the assessment for the relevant Asst. Years has simply issued notice under section 148 of the Act on the basis of reasons recorded for reopening of the assessment without there being an iota of discussion in the reasons that the documents found during search suggest escapement

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1876/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

Vilas Polymer P Ltd 9. The learned Counsel for the assessee further referring to the reasons recorded by the A.O submitted that, the A.O invoked explanation (2) clause (i) of section 148 of the Act on the presumption that once a search is initiated under section ... suggest income escaped the assessment for the relevant Asst. Years has simply issued notice under section 148 of the Act on the basis of reasons recorded for reopening of the assessment without there being an iota of discussion in the reasons that the documents found during search suggest escapement

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1874/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

asset nor any expenditure nor any entry or entries in the books of account. The Assessing Officer has not recorded his satisfaction in the reasons recorded for reopening of the assessment regarding fulfilling of the conditions specified u/s 149(1)(b) of the Act. The Assessing Officer has not even ... lakhs or more for each of the A.Ys taken up for initiation of proceedings u/s 147/148 of the Act. He has referred to the reasons recorded for reopening of the assessment and submitted that the Assessing Officer in the reasons recorded has not pointed out which asset is constituting