https://www.taxtmi.com/caselaws?id=212653 Reassessment under sections 147 and 148 is valid only where the Assessing Officer has a bona fide belief based on tangible material; it cannot be used for a roving inquiry, suspicion, or a mere change of opinion. On the facts discussed, reasons based on higher profit rate, alleged low wage expenditure, and a need to verify deduction eligibility were found insufficient because they relied on unsupported comparison material. The objection under Rule 46A did not survive independently once the reassessment itself was held unsustainable, and no separate error in the Tribunal's treatment of that issue was found. The Revenue's challenge therefore failed and the reassessment orders were sustained only to the extent not disturbed. en-us Wed, 14 Mar 2012 00:00:00 +0530 Thu, 19 Apr 2012 10:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212653 Reassessment under sections 147 and 148 is valid only where the Assessing Officer has a bona fide belief based on tangible material; it cannot be used for a roving inquiry, suspicion, or a mere change of opinion. On the facts discussed, reasons based on higher profit rate, alleged low wage expenditure, and a need to verify deduction eligibility were found insufficient because they relied on unsupported comparison material. The objection under Rule 46A did not survive independently once the reassessment itself was held unsustainable, and no separate error in the Tribunal's treatment of that issue was found. The Revenue's challenge therefore failed and the reassessment orders were sustained only to the extent not disturbed. Case-Laws Income Tax Wed, 14 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212653