Vipul Virendrakumar Patel v. ITO (2020)82 ITR 32 (SN)(Ahd ) (Trib)

S. 147 : Reassessment – Cash deposit in bank in excess of Rs. 10 lakhs – Salary income lower than the threshold limit – Information available with Assessing Officer vague and without any proper identification and quantification of escaped income — Reassessment is held to be not valid [ S.148 ]

The Tribunal held that,  salary income lower than the threshold limit . Information as regards deposit of cash in bank excess of Rs 10 lakhs is vague  hence  information available with Assessing Officer vague and without any proper identification and quantification of  escaped income . Section 147 enables The Assessing Officer can compel the assessee to  file return only in the event of  escapement of  income. Without having cogent reasons for the belief towards escapement, even a person who has not filed the return cannot be forced to file a return by  invoking S. 147 . Accordingly the  reassessment is held to be  not  valid.   ( AY.2010-11)