Hiteshkumar Babulal Ramani v. ACIT (2021) 432 ITR 403 / 279 Taxman 449 (Guj.)(HC)

S. 147 : Reassessment-After the expiry of four years-Assessment without scrutiny-Report of investigation wing-Reassessment was held to be valid. [S. 133, 143(1), 148, Art. 226]

Dismissing the petition the Court held that  Assessing Officer had relied on primary information of undisclosed account and after independent inquiry and upon verification of return of income and other documents, recorded his satisfaction and formed a reasonable belief that income of assessee had escaped assessment. The AO also recorded the statement of the assessee, accordingly notice for reassessment was held to be valid. (AY. 2014-15)