Facts of the Case Return of Income Tax filed by the petitioner was accepted by virtue of Intimation under Section 143(1) of the Act .Thereafter the Notice u/s 148 was issued to the Assesses for reopening. Issue where assessment is completed by Intimation under Section 143(1) of the Act, there is no requirement for the… Read More »
HELD A number of representations were received against the omission of the words ‘reason to believe’ from section 147 and their substitution by the ‘opinion’ of the Assessing Officer. It was pointed out that the meaning of the expression, ‘reason to believe’ had been explained in a number of court rulings in the past and was well… Read More »
Held while the AO set out the information received from the ED, he failed to examine if that information provided the vital link to form the ‘reason to believe’ that income of the Assessee had escaped assessment for the AY in question. While the AO has referred to the fact that the ED gave information… Read More »