Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
Export Support intervention INSIGHT launched to provide non financial capacity building, trade intelligence and pilot support with defined funding and...
Reopening an assessment requires a recorded 'reason to believe' supported by tangible material showing nexus to escapement of income; the AO relied on receipt of funds from a related third party and unsubstantiated suspicion without citing documents or evidence, and failed to undertake reasonable enquiries to convert suspicion into belief. The AO's reasons were scant, vague and based on subjective notions, amounting to a roving enquiry rather than an objective basis for reopening. Consequently, the reassessment notice was invalidated and relief granted to the taxpayer.
Reopening an assessment requires a recorded 'reason to believe' supported by tangible material showing nexus to escapement of income; the AO relied on receipt of funds from a related third party and unsubstantiated suspicion without citing documents or evidence, and failed to undertake reasonable enquiries to convert suspicion into belief. The AO's reasons were scant, vague and based on subjective notions, amounting to a roving enquiry rather than an objective basis for reopening. Consequently, the reassessment notice was invalidated and relief granted to the taxpayer.
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