Section 147 Reopening Can’t Be Based Only on Cash Deposit Alerts

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 information alleg...