ITAT Upholds Reassessment Against Sonu Sood in Loan Entry Case

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  • Last Updated on 13 May, 2026

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reassessment against actor Sonu Sood

Case Details: Sonu Pankaj Shakti Sagar Sood vs. Assistant Commissioner of Income-tax, Central - [2026] 186 taxmann.com 322 (Mumbai-Trib.)

Judiciary and Counsel Details

  • Ms Kavitha Rajagopal, Judicial Member & Om Prakash Kant, Accountant Member
  • Tanzil R. Padvekar & Bhavik Chheda, Advs. for the Appellant.
  • Swapnil Choudhari, Sr. AR. for the Respondent.

Facts of the Case

The assessee, an actor engaged in professional acting and brand endorsements, was subjected to reassessment proceedings pursuant to a search conducted under section 132. The Assessing Officer reopened the assessment based on a statement recorded under section 131, alleging that the unsecured loans received by the assessee were accommodation entries routed through conduit entities.

The assessee contended that the issue of unsecured loans had already been examined during the original scrutiny proceedings, and the reopening amounted to a mere change of opinion. It was further submitted that all loans were received and repaid through banking channels, and no incriminating material evidencing cash transactions was found during the search.

The matter then reached the Mumbai Tribunal.

ITAT Held

The Tribunal held that the reopening was made under the deeming provision of Explanation 2(ii) of section 148, which provides for reopening in cases where a search has been conducted. While it is true that a previous assessment concluded the issue, the subsequent search action brought to light the statement of a third party, recorded under section 131.

In the said statement, a specific modus operandi was confessed, implicating the assessee in the procurement of bogus loans in exchange for cash. This constitutes “new tangible material” that was not available to the AO during the original assessment. The discovery of fresh evidence that fundamentally alters the complexion of the facts precludes the application of the “change of opinion” doctrine. Reopening based on new information discovered post-assessment does not constitute a ‘change of opinion’ but rather a discovery of escapement. Accordingly, jurisdictional requirements under sections 147/148 were satisfied.

List of Cases Reviewed

List of Cases Referred to

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied