2007 (8) TMI 323 - PUNJAB AND HARYANA HIGH COURT

Assessing Officer had not examined and corroborated the information received from the survey circle before recording his own satisfaction of escaped income and initiating reassessment proceedings - AO has to act on the basis of “reasons to believe” and not on “reasons to suspect” - Tribunal rightly concluded that the Assessing Officer had failed to incorporate the material and his satisfaction for reopening the assessment and, therefore, the issuance of notice under section 148 for reassessment proceedings was not valid - Tribunal is right in law in quashing the assessment order