https://www.taxtmi.com/caselaws?id=217204 Information received from a governmental authority under a tax treaty can constitute tangible material for reopening an assessment if it gives rise to a bona fide prima facie belief that income has escaped assessment; at the notice stage, the sufficiency of that material is not justiciable so long as it is more than suspicion or rumour. Here, the Assessing Officer relied on exchange-of-information material indicating an unreported receipt, and the court rejected the arguments of borrowed satisfaction and impermissible improvement of reasons. The notice under section 148 was therefore upheld as valid and within jurisdiction, and the reassessment proceedings were allowed to continue. en-us Wed, 26 Sep 2012 00:00:00 +0530 Sat, 06 Oct 2012 15:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217204 Information received from a governmental authority under a tax treaty can constitute tangible material for reopening an assessment if it gives rise to a bona fide prima facie belief that income has escaped assessment; at the notice stage, the sufficiency of that material is not justiciable so long as it is more than suspicion or rumour. Here, the Assessing Officer relied on exchange-of-information material indicating an unreported receipt, and the court rejected the arguments of borrowed satisfaction and impermissible improvement of reasons. The notice under section 148 was therefore upheld as valid and within jurisdiction, and the reassessment proceedings were allowed to continue. Case-Laws Income Tax Wed, 26 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217204