Budhiya Agencies P. Ltd. v. Dy.CIT (2020) 77 ITR 72 (SN) (Kol.) (Trib.)

S. 147 : Reassessment-Reason to be believe-Securities premium account–Merely on the basis of information received by another AO based on appraisal report of A group-Reassessment cannot be made. [S. 148]

Tribunal held that the AO is duty bound to make reasonable enquiry to collect material to form reason to believe income has escaped assessment. Merely on the basis of information received by another AO based on appraisal report of a group reassessment is held to be not valid. Reassessment proceedings is quashed. (AY. 2008-09)