The Hon’ble tribunal observed that in the absence of nexus between the prima facie inference arrived in the reasons recorded and information vis-a-vis material tangible, credible, cogent and relevant to form a reason to believe, there was no basis to assume jurisdiction, the reasons recorded were highly vague, far-fetched and could not lead to a conclusion of escapement of income. The proceedings initiated were purely based on surmises, conjectures and suspicion and therefore, they were without jurisdiction and deserved to be quashed. (AY. 2011-12)
Milind Madhukar Edke v. ITO (2023)101 ITR 88 (SN) (Pune) (Trib)
S. 147 : Reassessment-With in four years-Income escaping assessment-No fresh material with AO to form opinion that income escaped assessment-Opinion based on incorrect basis-Proceeding on the basis of conjectures-Reassessment without jurisdiction. [S. 148]