https://www.taxtmi.com/caselaws?id=191779 Genuine software export receipts supported by STPI certification, invoices and banking remittances were treated as eligible for deduction under section 10B, and could not be taxed as unexplained income under section 68 absent contrary evidence. The Tribunal also held that reassessment under section 147 cannot be founded on a mere change of opinion or suspicion; it requires fresh tangible material and a bona fide reason to believe that income has escaped assessment. On the facts described, the recorded reasons lacked such material, so the reopening was invalid and the consequential assessment was quashed. en-us Fri, 23 Nov 2012 00:00:00 +0530 Fri, 21 Apr 2017 13:14:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191779 Genuine software export receipts supported by STPI certification, invoices and banking remittances were treated as eligible for deduction under section 10B, and could not be taxed as unexplained income under section 68 absent contrary evidence. The Tribunal also held that reassessment under section 147 cannot be founded on a mere change of opinion or suspicion; it requires fresh tangible material and a bona fide reason to believe that income has escaped assessment. On the facts described, the recorded reasons lacked such material, so the reopening was invalid and the consequential assessment was quashed. Case-Laws Income Tax Fri, 23 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191779