Radhika Roy v. DCIT (2019) 200 TTJ 665 / 73 ITR 239/ 180 DTR 329 (Delhi)(Trib.), www.itatonline.org Dr. Prannoy Roy v. DCIT (2019) 200 TTJ 665/73 ITR 239 (Delhi) (Trib.), www.itatonline.org

S. 147 : Reassessment-Information from the Dy. DIT(Inv)-Live link between the tangible material and formation of belief and reasons recorded-Mismatch of exempt long term capital gains- Reassessment is held to be valid.[S. 10(38), 45, 148]

On the basis of information received by the Dy. DIT(Inv) on the basis of allegations received by   a Member of Parliament who was Chairman of Standing Committee of Finance. Based on the letter the Dy. DIT(Inv) issues a letter to the AO along with the detailed transactions in the demat account of the assessee and her  husband in respect of capital gains  exemption claimed. AO independently applied his mind to this information and verified from the return of income. After examination of details issued the notice for reassessment. Tribunal held that there is live link between the tangible material and formation of belief and reasons recorded. Mismatch of exempt long term capital gains.  Reassessment is held to be valid. (ITA No. 2020/Del/2017, dt. 14.06.2019) (AY. 2009-10, 2010-11)