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2015 (6) TMI 1175 - AT - Income TaxReopening of assessment - scope of the expression ‘reason’ in the phrase ‘reason to believe’ - addition on gift receipt - Held that:- AO received an information from ACIT, CC-V, Ludhiana that assessee has received gift of ₹ 5 lakhs from Shri Jagdish Duggal, 38G, Sarabha Nagar, Ludhiana from bank account No. 16503 of Shri Jagdish Duggal maintained with Canara Bank, Bharat Nagar Chowk, Ludhiana. AO has also this information that the nature of this entry was an accommodation entry. The above information / material received by the Assessing Officer was relevant and afforded a live link or nexus to the formation of the prima facie belief that income chargeable to tax had escaped assessment in the assessee’s hands. Therefore, there is no merit in the submissions made on behalf of the assessee that reopening of the assessment was invalid. Material before the Assessing Officer was relevant and afforded a live link or nexus to the formation of the prima facie belief that income chargeable to tax had escaped assessment in the assessee’s hands. Thus reopening of the assessment was valid - Decided against assessee
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