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]

 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)