“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

Ba Continuum India Private Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

ITA 368/HYD/2024[2005-06]Status: DisposedITAT Hyderabad04 Feb 2026AY 2005-06

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 10ASection 142(1)Section 143(2)Section 147Section 40

issued by the AO unless the Joint Commissioner of Income Tax was satisfied on 10 BA Continuum India Private Limited vs. DCIT the reasons recorded by the AO that it is a fit case for issue of such notice. The Ld. AR submitted that as per section ... Assessing Officer, who is below the rank of Assistant Commissioner for Deputy Commissioner), unless the "[Joint] Com-missioner is satisfied on the reasons recorded by such Assessing Officer that it is a fit case for the issue of such notice]: Provided that, after the expiry of four years from

Southern Enterprises, Chennai vs. ACIT Non Corporate Ward 22, Chennai

In the result, appeal filed by the assessee is allowed

ITA 2941/CHNY/2017[2009-10]Status: DisposedITAT Chennai04 Feb 2026AY 2009-10

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Appellant: Ms. S. Sanchitha for Mr. R. SivaramanFor Respondent: Mr. Praveen. S, JCIT

Section 10BSection 142(1)Section 143(2)Section 143(3)Section 147Section 148

relevant assessment year, he (AO) has issued the notice u/s.148 of the Act on 05.12.2014 on the strength of the reasons recorded by him as given below: The assessee, an exporter of garnet sand has shown the closing stock as follows: Total ... Thus the amount of Rs.62,86,250/- which has escaped taxation has to be brought to tax. 5. From a perusal of the aforesaid reasons recorded on 10.11.2014 shows that the AO after going through the financials filed by the assessee for the relevant AY 2009-10, has noted that

Kalpana Ramesh Jain, Mumbai vs. Deputy Commissioner of Income Tax- Central Circle-4(3)(1), Mumbai

In the result all the three appeals of the assessee are allowed

ITA 4597/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Respondent: Shri Mani Jain a/w Shri Prateek

Section 10(38)Section 147Section 148Section 68

application of mind, rendering the assumption of jurisdiction under section 147 unsustainable in law. 4.2 The learned counsel further pointed out that while the reasons recorded allege that the assessee herself was an accommodation entry provider, the assessment order proceeds on an entirely different premise by treating the assessee ... beneficiary—further demonstrates the absence of a valid and coherent belief regarding escapement of income. 4.4 It was submitted that since the reasons recorded themselves suffer from factual inaccuracies and non-application of mind, the sanction obtained for reopening is equally vitiated. A mechanical approval based on erroneous reasons cannot

Kalpana Ramesh Jain, Mumbai vs. Deputy Commissioner of Income Tax- Central Circle-4(3)(1), Mumbai

In the result all the three appeals of the assessee are allowed

ITA 4596/MUM/2025[2016-17]Status: DisposedITAT Mumbai04 Feb 2026AY 2016-17

Section 10(38)Section 147Section 148Section 68

application of mind, rendering the assumption of jurisdiction under section 147 unsustainable in law. 4.2 The learned counsel further pointed out that while the reasons recorded allege that the assessee herself was an accommodation entry provider, the assessment order proceeds on an entirely different premise by treating the assessee ... beneficiary-further demonstrates the absence of a valid and coherent belief regarding escapement of income. 4.4 It was submitted that since the reasons recorded themselves suffer from factual inaccuracies and non-application of mind, the sanction obtained for reopening is equally vitiated. A mechanical approval based on erroneous reasons cannot

Kalpana Ramesh Jain, Mumbai vs. Deputy Commissioner of Income Tax- Central Circle-4(3)(1), Mumbai

In the result all the three appeals of the assessee are allowed

ITA 4595/MUM/2025[2015-16]Status: DisposedITAT Mumbai04 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Respondent: Shri Mani Jain a/w Shri Prateek

Section 10(38)Section 147Section 148Section 68

Shivram S Shetty, Mumbai vs. Income Tax Officer Ward 2(1), Thane

ITA 5653/MUM/2024[2015-16]Status: DisposedITAT Mumbai04 Feb 2026AY 2015-16

Bench: Ms. Kavitha Rajagopal, Jm & Shri Prabhash Shankar, Am

For Appellant: Shri Kumar Kale, AdvFor Respondent: Shri Pravin Salunkhe, SR. DR

Section 133(6)Section 142(1)Section 144Section 144B(1)Section 147Section 148Section 151Section 151ASection 250

relevant assessment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner is satisfied, on the reasons recorded by the Assessing Officer, that it is a fit case for the issue of such notice [Section 151 (1)]. Section 151 (2) stipulates that in any case ... issued under Section 148 by an Assessing Officer, who is below the rank of Joint Commissioner, unless the Joint Commissioner is satisfied, on the reasons recorded by such Assessing Officer, that it is a fit case for the issue of such notice. For the sake of convenience, Section

Shamim Ahmad, Muzaffarnagar vs. Income Tax Officer, Ward 3 (2)(4) Mzr, Muzaffarnagar

In the result, the appeal of the assessee in ITA No

ITA 4241/DEL/2024[2012-13]Status: DisposedITAT Delhi04 Feb 2026AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Shri Manish Gupta, Sr. DR

Section 143(3)Section 147Section 148

live nexus Page 2 of 4 ITA No. 4241/DEL/2024 [A.Y. 2012-13] Shamim Ahmad Vs ITO between the tangible material available on record and reasons recorded to take a view that the assessee is showing low net profit. 7. Furthermore, we find that the CIT(A) had confirmed the addition ... profit shown by the assessee. In view of the factual matrix of the case therefore, we are of the considered view that the reasons recorded for reopening the assessment are not valid and sustainable in law. Accordingly, we quash the notice u/s 148 as also the reassessment order. The grounds

Jvh Technologies Private Limited, Agra vs. ITO Ward 2(1)(1), Agra

In the result, the appeal of the assessee is partly allowed

ITA 395/AGR/2025[2017-18]Status: DisposedITAT Agra03 Feb 2026AY 2017-18

Bench: Shri M. Balaganeshjvh Technologies Pvt. Ltd, Vs. Ito, Shop No. A28, V. S. Ward-2(1)(1), Plaza, Sector-3A, Avas Agra Vikas Colony, Sikandra, Agra (Appellant) (Respondent) Pan: Aadcj3746N Assessee By : Shri Rohit Dua, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 03/02/2026

For Appellant: Shri Rohit Dua, CAFor Respondent: Shri Anil Kumar, Sr. DR

Section 147Section 148Section 148ASection 40A(3)

Supreme Court in the case of Ashish Agarwal, show-cause notice was issued u/s 148A(b) of the Act furnishing the reasons recorded for reopening and an order under section 148A(d) of the Act was passed on 30.07.2022. Thereafter, final notice under section 148 of the Act was issued

Devkrupa International, Bhavnagar vs. The Assistant Commissioner of Income-Tax Circle -1 Bhavnagar, Bhavnagar

In the result, the appeal of the assessee is allowed

ITA 820/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyaldevkrupa International, The Assistant Commissioner Vs. Shop No.1 Navkar Tower, Of Income-Tax Circle-1, Kalubha Road, Bhavnagar Bhavnagar – 364001 [Pan: Aaefd0184G] (Appellant) .. (Respondent) Appellant By: Shri Tushar Hemani, Sr. Advocate Respondent By: Shri Abhijit, Sr. Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 03.02.2026

For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri Abhijit, Sr. DR

Section 143(1)Section 147Section 148Section 250Section 68

documentary evidences such as ledger account, confirmations, ITR acknowledgement and bank statements were furnished before the Revenue Authorities. The Ld. AR argued that the reasons recorded do not disclose the nature, date, or source of alleged transactions, nor any tangible material suggesting escapement of income ... upon the order of the authorities below. 8. We have carefully considered the rival submissions and perused the material available on record. 8.1 The reasons recorded by the Assessing Officer for reopening the assessment read as under:- “1. Brief details of the Assessee: The assessee is a Firm

Mukeshkumar Patel(Individual), Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, all the three appeals of the assessee are hereby allowed

ITA 1463/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Parin Shah, ARFor Respondent: Ms. Ketaki Desai, Sr.DR

Section 132Section 147Section 148Section 44A

also contended that the re-opening of the assessment u/s.147 of the Act was bad in law as the AO had not supplied the reasons recorded for re-opening of the assessment. ITA Nos.1461, 1462 & 1463/Ahd/2024 Mukeshkumar Patel (Individual) Asst. Years : 2015-16, 2016-17 & 2017-18 respectively Further ... account and, therefore, there were no valid reasons to the AO to re-open the assessment. He has further submitted, the AO, in the reasons recorded for reopening of the assessment has mentioned that certain account holders were not traceable and certain accounts were in the name of name lenders/benami

Mukeshkumar Patel(Individual), Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, all the three appeals of the assessee are hereby allowed

ITA 1462/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Parin Shah, ARFor Respondent: Ms. Ketaki Desai, Sr.DR

Section 132Section 147Section 148Section 44A

Mukeshkumar Patel(Individual), Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, all the three appeals of the assessee are hereby allowed

ITA 1461/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2015-16

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Parin Shah, ARFor Respondent: Ms. Ketaki Desai, Sr.DR

Section 132Section 147Section 148Section 44A

Kishorbhai Dattani, Jam Khambhalia vs. Income Tax Officer, Ward -1, Dwarka

In the result, the appeal of the assessee is allowed

ITA 555/RJT/2025[2017-18]Status: DisposedITAT Rajkot02 Feb 2026AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 555/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Kishorbhai Dattani Vs. Income Tax Office, Hospital C/O. Sarda & Sarda (Ca), Sakar 1St Road, Near Rajdhani Hotel, Floor, Dr. Radha-Krishnan Road, Dwarka, Gujarat 361335 Opp. Rajkumar College, Rajkot, Rajkot Gujarat 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakpd7272M (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 03 / 11 /2025 Date Of Pronouncement : 02/ 02 /2026

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. Sr. DR

Section 115BSection 144BSection 147Section 148Section 250Section 69A

13/08/2025 the appeal was dismissed with following observation: “The appellant has objected to the validity of reopening, inter alia, on the ground that the reasons recorded did not constitute a tangible material leading to the formation of belief that income had escaped assessment. However, I find that the information relied

Arpita Jena, Bhubaneswar vs. ITO, Ward 3(1), Bhubaneswar

In the result, the appeal of the assessee is allowed

ITA 585/CTK/2025[2016-17]Status: DisposedITAT Cuttack02 Feb 2026AY 2016-17

Bench: Shri George Mathan & Shri Laxmi Prasad Sahuआयकर अपील सं/Ita No.585/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2016-2017) Arpita Jena, Vs Ito, Ward-3(1), Bhubaneswar A-60, Palashpalli, Bhubaneswar-751020 Dist : Khurda, Odisha Pan No. : Anepj 7345 N (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Miss Sarmila Agarwal, Ca राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 02/02/2026 घोषणा की तारीख/Date Of Pronouncement : 02/02/2026

For Appellant: Miss Sarmila Agarwal, CAFor Respondent: Shri Vijay Singh, Sr. DR

Section 147Section 148

ground that the assessee had sold the immovable property for Rs.75,00,000/- as return had not been filed. The reasons recorded is as follows:- 2 3 4 3. It was the submission that the assessee had responded the same on 17/03/2023 wherein all the details were mentioned which reads ... reopened the assessment and completed the assessment. It was submission that in the assessment no addition has been made on account of the reasons recorded for the purpose of the reopening. It was submission that the addition has been made in respect of the source for the purchase of property

Mr. Ashish Ramesh Ajmera, Dhule vs. ITO, Ward 1, Dhule

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 2506/PUN/2025[2013-14]Status: DisposedITAT Pune02 Feb 2026AY 2013-14

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2506/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Mr.Ashish Ramesh Ajmera, V Income Tax Officer, Plot No.17, Ashish Saraswati S Ward-1, Dhule. Colony, Vidhyanagri, Dhule – 424005 Pan: Aaopa3375J Appellant/ Assessee Respondent /Revenue Assessee By Shri Bhuvanesh Kankani Revenue By Shri Sandeep Sathe – Jcit Date Of Hearing 09/12/2026 Date Of Pronouncement 02/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal), Panaji Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 29.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 147 Of The Act, Dated 14.12.2018. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 147Section 250Section 69A

No.1 that Assessment was reopened as Assessee has not filed return of income and made cash deposits in bank account. Ld.DR read out the reasons recorded for reopening which are at page no.2 of the paper book. Ld.DR further submitted that in the assessment order, Assessing Officer has made addition ... notice u/s.148, Assessee filed Return of Income. Assessee has filed copy of reasons for reopening at page no.2 of the paper book. The reasons recorded are as under: “2. The reason(s) for reopening in your case as requested by you for the AY 2013-14 is as under

Ganapathy Educational and Charitable Trust, Tirupur vs. CIT, Exemptions, Chennai

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

ITA 3550/CHNY/2025[-]Status: DisposedITAT Chennai02 Feb 2026

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.3550/Chny/2025 िनधा"रण वष"/Assessment Year: - Ganapathy Educational & Charitable Vs. The Commissioner Of Trust, 182, East Thottam, Income Tax (Exemption), Mavilamparai, Kalapuram, Udumalpet, Chennai. Tirupur 642 102. [Pan:Aabtg3011A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Paramasivam, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 21.01.2026 घोषणा की तारीख /Date Of Pronouncement 02.02.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi:

For Appellant: Shri Paramasivam, Advocate (Virtual)For Respondent: Shri AR V Sreenivasan, CIT

Section 119(2)(b)Section 80G

activity carried by the assessee for “relief of poor”, “education”, “medical relief”, “Yoga” as well as “preservation of environment”. Therefore, we find the reasons recorded by the ld. CIT(E) on merits in rejecting the belated application, is justified. Thus, 4 I.T.A. Nos.3550/Chny/25 we find no infirmity in the order

Yuvasakthi Welfare Association, Pollachi vs. CIT, Exemptions, Chennai

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

ITA 3549/CHNY/2025[-]Status: DisposedITAT Chennai02 Feb 2026

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. Nos.3548 & 3549/Chny/2025 िनधा"रण वष"/Assessment Year: - Yuvasakthi Welfare Association, Vs. The Commissioner Of Ntpc-Mcet Campus, Udumalpet Income Tax (Exemption), Road, Pollachi 642 003. Chennai. [Pan:Aabay1616J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Paramasivam, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 21.01.2026 घोषणा की तारीख /Date Of Pronouncement 02.02.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against The Order Dated 24.09.2025 Passed By The Ld. Commissioner Of Income Tax (Exemption), Chennai Rejecting The Applications Dated 28.03.2025 In Form No. 10Ab Under Section 12A(1)(Ac)(Iii) Of The Income Tax Act, 1961 [“Act” In Short] Seeking Registration Under Section 12Ab Of The Act As Well As Seeking Approval Under Section 80G Of The Act Respectively.

For Appellant: Shri Paramasivam, Advocate (Virtual)For Respondent: Shri AR V Sreenivasan, CIT

Section 12ASection 12A(1)(ac)Section 3Section 80G

delay before the competent authority has been filed, which is evident from para 4.3 and 4.4 of the impugned order. Therefore, we find the reasons recorded by the ld. CIT(E) in rejecting the belated application, is justified. Thus, we find no infirmity in the order passed ... accordingly, the grounds raised by the assessee are dismissed. I.T.A. No. 3549/Chny/2025 8. The identical facts and circumstances, reasons recorded by the ld. CIT(E) for rejection of application seeking approval under section 80G of the Act are similar to that of seeking registration under section

Yuvasakthi Welfare Association, Pollachi vs. CIT(Exemption), Chennai

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

ITA 3548/CHNY/2025[-]Status: DisposedITAT Chennai02 Feb 2026

For Appellant: Shri Paramasivam, Advocate (Virtual)For Respondent: Shri AR V Sreenivasan, CIT

Section 12ASection 12A(1)(ac)Section 3Section 80G

Aryan Share and Stock Brokers Limited, Chennai vs. ITO, Corporate Ward 1(1) Che, Chennai

In the result, appeal filed by the assessee is allowed

ITA 2756/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Feb 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Praveen Kumar BansalFor Respondent: Mr.Kumar Chandan, JCIT

Section 147Section 148Section 69A

would make him believe that there is in fact an escapement of income. According to him, in the present case, a reading of the reasons recorded would reveal that the AO had only reason to suspect and not reasons to believe escapement of income. Hence, according to him, the essential ... Supreme Court in the case of ITO v. Lakhmani Mewal Das reported in 103 ITR 437. Drawing our attention to the reasons recorded by the AO which is placed at page no.56 of the PB he submitted that a bare reading of the same would reveal that he (AO) received

Mystical Constructions Private Limited, Mumbai vs. DCIT Circle 5(2)(1), Mumbai

In the result, the appeal is Allowed

ITA 5222/MUM/2024[2011-12]Status: DisposedITAT Mumbai02 Feb 2026AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawalι.Τ.Α. No.5222/Mum/2024 A.Y: 2011-12 Mystical Pvt Ltd Constructions A 603, A1 Akbar Bldg, Pe Road, Momin Nagar, Jogeswari (W), Mumbai - 400102 Pan - Aaccn5191N (Appellant) Vs Dcit, Circle 5(2)(1) Aayakar Bhawan, Mumbai. (Respondent) Assessee By Ms. Simran Dhawan A/W Mr. Ravi Gantara Revenue By Shri Umashankar Prasad, Cit Dr Date Of Hearing 04.11.2025 Date Of Pronouncement 02.02.2026 Order Per: Shri. Sandeep Gosain, J.M.: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dt. 06.08.2025 Passed Under Section 250 Of The Income Tax Act, 1961 ('The Act'), By The National Faceless Appeal Centre (Nfac) / Cit(A) For The

Section 132Section 143(3)Section 147Section 148Section 153CSection 250Section 271(1)Section 274

towards sale of TDR, which was adjudged as 'undisclosed income in the received information itself even as the assessee, while objecting to the reasons recorded claimed that it had carried out no transactions with M/s 'ConwoodMahul'. 5. Ld. DR had relied upon the statement of Shri Akshay J Doshi ... towards sale of TDR, which was adjudged as 'undisclosed income in the received information itself even as the assessee, while objecting to the reasons recorded claimed that it had carried out no transactions with M/s 'ConwoodMahul'. 5. Ld. DR had relied upon the statement of Shri Akshay J Doshi