COURT: | Bombay High Court |
CORAM: | M. S. Sanklecha J, Sandeep K. Shinde J |
SECTION(S): | 147, 148 |
GENRE: | Domestic Tax |
CATCH WORDS: | reasons, Reopening of assessment |
COUNSEL: | Prakul Khurana |
DATE: | July 6, 2018 (Date of pronouncement) |
DATE: | July 19, 2018 (Date of publication) |
AY: | 2010-11 |
FILE: | Click here to view full post with file download link |
CITATION: | |
S. 147/148: If the recorded reasons do not specify, prima-facie, the quantum of tax which has escaped assessment but merely state that it would be at least Rs.1,00,000, and if the reopening is to "verify" suspicious transactions, prima-facie, the reasons do not indicate reasonable belief of the AO and the notice is without jurisdiction |
Further, the reasons also do not specify, prima-facie, the quantum of tax which has escaped assessment but merely states that it would be atleast be Rs.1,00,000/-. Prima-facie, we are of the view that the reasons recorded do not indicate reasonable belief of the Assessing Officer himself to issue the impugned notice
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