Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Reassessment jurisdiction was upheld where the Assessing Officer relied on tangible material, including an Investigation Wing report, bank account analysis, field enquiries and a sworn statement, to form an independent belief that income had escaped assessment. The Tribunal found a rational live link between the material and the reopening reasons, noting that the transactions were specifically identified, were not based on mere suspicion, and reflected the officer's own examination rather than borrowed satisfaction. On that basis, the challenge to jurisdiction failed and the reopening was sustained.
Reassessment jurisdiction was upheld where the Assessing Officer relied on tangible material, including an Investigation Wing report, bank account analysis, field enquiries and a sworn statement, to form an independent belief that income had escaped assessment. The Tribunal found a rational live link between the material and the reopening reasons, noting that the transactions were specifically identified, were not based on mere suspicion, and reflected the officer's own examination rather than borrowed satisfaction. On that basis, the challenge to jurisdiction failed and the reopening was sustained.
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