Sourav Bakshi v. ITO (2022) 95 ITR 279 (Amritsar)(Trib)

S. 148 : Reassessment-Notice-Validity-Incorrect bank transaction in the form of bank deposits-Wrong facts recorded for formation of belief that income has escaped assessment-Reassessment was quashed [S. 147, 148]

Where wrong facts have been recorded for formation of reason to believe, the assessment proceedings deserve to be quashed. The Tribunal held that it was merely on the basis of incorrect bank transaction in the form of bank deposits, the Assessing Officer had recorded the reasons and thus he had wrongly assumed the jurisdiction. Therefore, the assessment framed for incorrect belief was deserved to be quashed.  (AY.2011-12)