The assessee challenged the reassessment notice on the ground that the assessee was not supplied the material forming the reason to believe that income has escaped the assessment. Allowing the petition the Court held that non-supply of material referred to in the reasons to believe would be enough to render the proceedings bad , even though the material for forming the opinion may be sufficient . ( WP No. 13747 of 2021 dt. 4-1-2023 )( AY. 2017 -18 )
Micro Marbles Pvt Ltd v .ITO ( 2023) The Chamber’s Journal- March P. 120 ( Raj )( HC)
S. 148 : Reassessment –Notice – Material for a reason to believe that income has escaped assessment was not supplied – Reassessment notice was quashed [ S.132(4), 147 Art , 226 ]