Reopening of assessment u/s 147 - source of funds for investment...

Reopening of assessment u/s 147 - source of funds for investment in property - No doubt the assessee was not a regular tax payer and thus, no return could be consulted by the Assessing Officer while exercising the powers of re-opening. However, the fact remains that it was incumbent on him to at least check the facts recorded in the Sale Deed carefully ascertaining the extent of the assessee's contribution. - The public at large cannot be put to the mercies of careless, casual, arbitrary or whimsical exercise of power. The order deserves to be quashed on this count itself. - AT