The reassessment proceedings were initiated on the basis of AIR information that the assessee has deposited the sum in savings bank account. The Assessing Officer made addition as cash credits. On appeal the Tribunal held that if adverse information may trigger reason to suspect then the Assessing Officer has to make reasonable inquiry and collect material which would make him believe that there is in fact an element of income. Reason is the link between the information and the conclusion. After information there should be some reason which should warrant the holding of a belief that income chargeable to tax has escaped assessment. The reassessment was quashed. Relied on Ganga Saran & Sons (P) Ltd. v. ITO (1981) 130 ITR 1 (SC). (dt. 7-7-2021) (AY. 2009-10)
Tapan Chakraborty v. ITO (2021) BCAJ-October-P. 53 (Kol.)(Trib.)
S. 147 : Reassessment-With in four years-AIR Information-Cash credits-Cash deposit in the bank-Assessing Officer failed to make reasonable enquiry-Reassessment was quashed. [S. 44AE, 68, 148]
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