Allowing the petition the court held that all that the Assessing Officer desired was examination of certain details pertaining to amount paid by assessee to CCPL. The reasons must be founded on satisfaction of Assessing Officer that income chargeable to tax had escaped assessment. On the facts it was found that there were no reasons to believe but, only reasons to suspect, the notice and order disposing the objection is quashed and set aside. (AY. 2007-08)
Darpan P. Chandaliya v. ITO (2023) 295 Taxman 717 (Bom.)(HC)
S. 147 : Reassessment-After the expiry of four years-Cash deposited in bank-Suspicious of unaccounted money-Reason to suspect and no reason to believe-Notice and order disposing the objection is quashed and set aside. [S. 68, 148, Art. 226]