Reopening of assessment u/s 147 - ‘reasons to believe’ and ‘re...

Reopening of assessment u/s 147 - ‘reasons to believe’ and ‘reasons to suspect’ - Merely on the basis of suspicion observed that the aforesaid entry might be a bogus entry and that the assessee might have purchased the material from outside. A perusal of the reasons recorded by the Assessing Officer does not show that the Assessing Officer had any credible information or evidence to believe that the aforesaid transaction made by the assessee was bogus, rather, a reading of the whole of the contents of the document containing reasons for reopening of the assessment would reveal that the reopening of the assessment has been made merely on the basis of suspicion - Reopening of the assessment cannot be made - AT