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The High Court held that the reassessment proceedings initiated u/s 148 were invalid. The assessee, a partner in a firm, had disclosed all financial transactions and deposits in the bank account. The Assessing Officer did not have any fresh tangible material to form a reasonable belief that income had escaped assessment, apart from the disclosed information. Merely disclosing financial transactions exceeding taxable limits does not justify reopening the assessment without additional evidence of escaped income. The court concluded that the reassessment notice was untenable and allowed the petition, quashing the reopening proceedings.
The High Court held that the reassessment proceedings initiated u/s 148 were invalid. The assessee, a partner in a firm, had disclosed all financial transactions and deposits in the bank account. The Assessing Officer did not have any fresh tangible material to form a reasonable belief that income had escaped assessment, apart from the disclosed information. Merely disclosing financial transactions exceeding taxable limits does not justify reopening the assessment without additional evidence of escaped income. The court concluded that the reassessment notice was untenable and allowed the petition, quashing the reopening proceedings.
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