It is held that the reassessment u/s. 147 cannot be initiated on mere suspicions of some income having been escaped from assessment. AO acted upon Information received from the investigation wing of the department. It was noted that no independent enquiries were undertaken by the AO. Thus the impugned order was set aside and quashed. (AY. 2011-12 to 2013-14)
Sanjay Singhal (HUF) v. Dy. CIT (2020) 207 TTJ 853 / 194 DTR 209 (Chd.)(Trib.)
S. 147 : Reassessment-Reason to believe-Reassessment proceedings cannot be initiated on basis of a suspicion. [S. 132(4), 148]