Stamp valuation increases after registration-fee payment led to deletion of property-purchase addition within tolerance and without valuation referral...
Capital Asset Conversion Requires Proven Business Stock Treatment; Paper Consideration in Spousal Flat Transfers Does Not Create Taxable Business Inco...
Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuin...
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Reopening of the assessment u/s 147/148 - The "reason to believe" would mean cause or justification. If the Assessing Officer has cause or justification to know or suppose that income had escaped assessment, he can be said to have reason to believe that an income had escaped assessment. The expression cannot be read to mean that the Assessing Officer should have finally ascertained the fact by legal evidence or conclusion and what is required is "reason to believe", but not the established fact of escapement of income. - At the stage of issue of notice, the only question is whether there was relevant material on which a reasonable person could have formed a requisite belief. - AT
Reopening of the assessment u/s 147/148 - The "reason to believe" would mean cause or justification. If the Assessing Officer has cause or justification to know or suppose that income had escaped assessment, he can be said to have reason to believe that an income had escaped assessment. The expression cannot be read to mean that the Assessing Officer should have finally ascertained the fact by legal evidence or conclusion and what is required is "reason to believe", but not the established fact of escapement of income. - At the stage of issue of notice, the only question is whether there was relevant material on which a reasonable person could have formed a requisite belief. - AT
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