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2017 (9) TMI 1658 - AT - Income TaxValidity of initiation of proceedings u/s 148 - validity of 'reasons to believe' - deposits in savings bank account - Held that:- It was a mere suspicion of the AO, that prompted him to initiate assessment proceedings u/s 147, which is neither countenanced, nor sustainable in law - AO proceeded on the fallacious assumption that the bank deposits constituted undisclosed income, over-looking the fact that the source of the deposits need not necessarily be the income of the assessee - thus following the judgement in case of BIR BAHADUR SINGH SIJWALI VERSUS INCOME TAX OFFICER WARD 1, HALDWANI [2015 (2) TMI 60 - ITAT DELHI] the reasons recorded are cancelled - Decided in favor of assessee.
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