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Section 147 Reopening Can’t Be Based Only on Cash Deposit Alerts
Case Law Details
- Case Name
- Khazana Stores Private Limited Vs ITO (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Ahmedabad
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Khazana Stores Private Limited Vs ITO (ITAT Ahmedabad)
“Reason to Suspect” Is Not “Reason to Believe”: ITAT Ahmedabad Quashes 147 Reopening Based Only on Cash Deposit Alerts
ITAT Ahmedabad “D” Bench, in Khazana Stores Pvt. Ltd. vs ITO (ITA No. 1506/Ahd/2025, AY 2017-18, order dated 23-12-2025), quashed the reassessment u/s 147 and deleted the addition of ₹59.05 lakh u/s 69A r.w.s. 115BBE, holding that the reopening was without jurisdiction and based on complete non-application of mind.
The AO reopened the assessment solely on Insight Portal / Investigation Wing ...
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