INCOME-TAX OFFICER, WARD-1(2)(3), AHMEDABAD, AAYAKAR BHAWAN, VEJALPUR, AHMEDABAD vs. JASMINE JAYANTIBHAI SANGHAVI, AHMEDABAD
In the result, appeal of the Revenue is dismissed
ITA 1779/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad02 Dec 2025AY 2016-17
Bench: Ms. Suchitra Raghunath Kambleआयकर अपील सं./I.T.A. No. 1779/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2016-17) बनाम/ Income-Tax Officer Jasmine Jayantibhai Ward-1(2)(3), Ahmedabad Sanghavi Vs. 7-F, Swetal Flat, Khanpur Bai Centre, Khanpur, Ahmedabad, Gujarat - 380001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aqcps1433R (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Suresh Chand Meena, Sr. Dr ""यथ" क" ओर से/Respondent By : Shri Sunil Talati, Ar Date Of Hearing 01/12/2025 02/12/2025 Date Of Pronouncement O R D E R The Appeal Is Filed By The Revenue Against The Order Dated 08.08.2025 Passed By The National Faceless Appeal Centre (Nfac), Delhi, For Assessment Year 2016-17. 2. The Grounds Of Appeal Filed By The Revenue Are As Under:
For Appellant: Shri Suresh Chand Meena, Sr. DRFor Respondent: Shri Sunil Talati, AR
Section 133ASection 142(1)Section 147Section 148Section 69ASection 69C
reassessment proceedings initiated vide notice u/s 148 dated 30.03.2021 were based on "borrowed satisfaction" and were hence invalid, without appreciating that the information received from the investigation Wing, which was specific, reliable and based on material unearthed during a survey u/s 133A, constituted sufficient "tangible material" for the formation of a bona fide belief that income had escaped assessment