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2009 (6) TMI 75 - HC - Income TaxReassessment – income escaping assessment – reason to believe – transport subsidy and insurance subsidy earlier sanctioned u/s 80 IC - held that - reason to believe to be valid has to have a rational and logical inter relation with the belief that a taxable income has escaped assessment. The belief necessarily has to be genuine and bona fide and not a charade - notice initiating the proceeding under section 148 of the Act against the petitioner is not in conformity with the legislative prescriptions mandated in section 147 of the Act - As a mere change in opinion cannot be a valid ground for reopening an assessment already made, on an objective evaluation of the return and the supporting materials thereof, the impugned reassessment proceeding is vitiated by want of jurisdiction
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