Dismissing the appeal of the Revenue the Court held that the recorded reasons of the Assessing Officer clearly showed that the Assessing Officer had himself held that “these sale transaction need to be verified”. This observation of the Assessing Officer itself made the reason to believe actually as a reason to suspect. There could not be a fishing and itinerant enquiry. Order of Tribunal is affirmed. (AY.2010-11)
PCIT v. Maheshwari Devi (2023)455 ITR 755 /146 taxmann.com 550(Jharkhand)(HC)
S. 147 : Reassessment-Sale transaction need to be verified-Reason to suspect-Notice is not valid. [S. 148, 260A]