Dismissing the petition the Court held that in view of the statutory provisions, there were sufficient reasons given by the Assessing Officer, which according to him constituted “reasons to believe” that income which was chargeable to tax had escaped assessment and which had come to the notice of Department at a later stage in the course of scrutiny. The notice and the reassessment proceedings were not barred by limitation as the proceedings drawn by the Assessing Officer were with sufficient material on record showing income, which was otherwise chargeable to tax, had escaped assessment. (AY.2013-14)
Sanjay Agrawal v. PCIT (2020) 429 ITR 233 (Chhattisgarh)(HC)
S. 147 : Reassessment-Subsequent information from documents impounded during survey of cash transactions- Reassessment proceedings valid. [S. 133A ,148 Art. 226]