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The High Court quashed the reassessment notice u/s 147, holding that the Assessing Officer failed to form a valid reason to believe that income had escaped assessment. The AO merely brushed aside the assessee's objections without considering them in detail. The AO made vague observations about transactions not reflected in the Demat account but did not address the specific details provided by the assessee in the objections. The Court ruled that the AO cannot validly form a reason to believe without properly examining the assessee's objections, rendering the reassessment notice untenable. The decision was in favor of the assessee.
The High Court quashed the reassessment notice u/s 147, holding that the Assessing Officer failed to form a valid reason to believe that income had escaped assessment. The AO merely brushed aside the assessee's objections without considering them in detail. The AO made vague observations about transactions not reflected in the Demat account but did not address the specific details provided by the assessee in the objections. The Court ruled that the AO cannot validly form a reason to believe without properly examining the assessee's objections, rendering the reassessment notice untenable. The decision was in favor of the assessee.
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