Reassessment cannot be sustained where the reason to believe is founded on presumptions drawn from a sister concern's records rather than material showing escapement in the assessee's own case. The Court found that alleged on-money receipts were inferred by assuming a cash component in the petitioner's sales merely because another group entity faced allegations of unaccounted receipts, with only a director's profit-sharing interest and an Excel file in his Gmail account as the connecting material. The section 148 notice was quashed.
Reassessment cannot be sustained where the reason to believe is founded on presumptions drawn from a sister concern's records rather than material showing escapement in the assessee's own case. The Court found that alleged on-money receipts were inferred by assuming a cash component in the petitioner's sales merely because another group entity faced allegations of unaccounted receipts, with only a director's profit-sharing interest and an Excel file in his Gmail account as the connecting material. The section 148 notice was quashed.
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