Held, that the Assessing Officer without the reasons to believe and proper verification has passed the order under section 148. Therefore, the notice under section 148 was liable to be quashed. Further, it was held that the addition was made by the Assessing Officer purely on suspicion and there was no effective material available on record to justify it. Therefore, the additions were to be deleted. (AY. 2009-10)
Jagsir Singh v. ITO (2022) 98 ITR 499 (Amritsar) (Trib) Sukhraj Singh v. ITO (2022) 98 ITR 499 (Amritsar) (Trib)
S. 148: Reassessment-Notice-Non filing of ITR-Agriculturist-Deposits of cash in assessee’s bank-Deposit in nature of exchange of agricultural land-Order passed by Assessing Officer without reason to believe and proper verification-Recorded statements not supplied to assessee-Additions made on suspicion-Additions deleted-Reassessment quashed. [S. 147]