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2016 (2) TMI 1192 - AT - Income TaxReopening of assessment - formation of belief by AO that certain income chargeable to tax had escaped assessment - information received from the Investigation Wing that assessee made bogus purchases - Held that:- Merely noticing such information, the Assessing Officer proceeds to record a belief that income chargeable to the aforesaid extent had escaped assessment. Reasons recorded by the Assessing Officer do not reflect independent application of mind as to whether the information before him suggested any escapement of income. To that extent, in my view, the reasons recorded do not satisfy the requirement of section 147 of the Act in as much as they do not refer to any documents or statement, etc., which would prima-facie establish a link between the bogus nature of the impugned purchases and consequential escapement of income. - Decided in favour of assessee.
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