Admitting the petition the Court held that, 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. Interim stay was granted till final hearing .( WP No. 1641 of 2018, dt. 6/07/2018)( AY.2010-11 )
Dulraj U. Jain v. ACIT (Bom)(HC), www.itatonline.org
S. 147: Reassessment-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-Interim stay was granted till final hearing . [ S.148 ]