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ITAT held that the Assessing Officer (AO) lacks jurisdiction to reopen assessment under section 147. The AO failed to establish a genuine reason to believe income escaped assessment, merely relying on Investigation Wing's report without independent verification. The reasons recorded were generic, mechanical, and lacked substantive evidence of material facts not previously disclosed. The tribunal found no tangible material supporting the AO's belief, emphasizing that receipt of information alone is insufficient to trigger reassessment proceedings. Consequently, the notice under section 148 was quashed, and consequent reassessment proceedings were set aside, decisively ruling in favor of the assessee.
ITAT held that the Assessing Officer (AO) lacks jurisdiction to reopen assessment under section 147. The AO failed to establish a genuine reason to believe income escaped assessment, merely relying on Investigation Wing's report without independent verification. The reasons recorded were generic, mechanical, and lacked substantive evidence of material facts not previously disclosed. The tribunal found no tangible material supporting the AO's belief, emphasizing that receipt of information alone is insufficient to trigger reassessment proceedings. Consequently, the notice under section 148 was quashed, and consequent reassessment proceedings were set aside, decisively ruling in favor of the assessee.
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