TMI Blog2002 (7) TMI 243X X X X Extracts X X X X X X X X Extracts X X X X ..... . 3. The Revenue has raised the sole ground disputing the Dy. CIT(A) s order in cancelling the assessment made under s. 147. The learned Departmental Representative of Revenue has contended that though the income assessed in reassessment was less than Rs. 50,000, but that will not make the information with AO to be for a belief of, escapement of income of less than Rs. 50,000. He has contended t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (a) ITO vs. Smt. Chakka Bai (1985) 23 TTJ (Jp) 334 : (1986) 15 ITD 328 (Jp); (b) Rashes Commission Corpn. vs. Asstt. CIT (2001) 70 TTJ (Mum) 654; (c) ITO vs. Lakhmani Mewal Das 1976 CTR (SC) 220 : (1976) 103 ITR 437 (SC); (d) Indian Oil Corpn. vs. ITO (1986) 58 CTR (SC) 83 : (1986) 159 ITR 956 (SC); (e) Milan Supari Stores vs. Asstt. CIT (1992) 106 CTR (MP) 311 : (1992) 194 ITR 72 (MP); an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e on conjectures and surmises and by making hypothetical calculations, without there being any material. 4. In rejoinder, the learned Departmental Representative of Revenue has contended that supplying of reasons to assessee is not essential. 5. We have considered the rival contentions, the relevant material on record as also the cited decisions. In 15 ITD 328, Jaipur Tribunal has held that at ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to 1026/Jp/93 in the case of Mahesh Kumar Pandya, it has been held that there must be some material/evidence on record to induce AO to entertain belief as such of escapement of income as distinguished and mere suspicion for the same. It has been held therein that when the information, to constitute reason for belief of escapement of income is general and non-specific, the same, in certain circum ..... X X X X Extracts X X X X X X X X Extracts X X X X
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