Allowing the appeal of the assessee the Tribunal held that ; The information given by DIT (Inv) can only be a basis to ignite/ trigger “reason to suspect”. The AO has to carry out further examination to convert the “reason to suspect” into “reason to believe”. If the AO acts on borrowed satisfaction and without application of mind, the reopening is void . (ITA. No. 2178/Kol/2017, dt. 15.10.2018)(AY. 2010-11)
Devansh Export v. ACIT( 2018) 196 TTJ 665 /( 2019) 176 DTR 17(Kol)(Trib),www.itatonline.org
S. 147: Reassessment – The information given by DIT (Inv) can only be a basis to ignite/ trigger “reason to suspect”. The AO has to carry out further examination to convert the “reason to suspect” into “reason to believe”. If the AO acts on borrowed satisfaction and without application of mind, the reopening is void .[ S. 92, 148 ]