https://www.taxtmi.com/caselaws?id=386010 The High Court held that the initiation of proceedings under section 147 was not justified, emphasizing the requirement of a live link between reasons and belief for income escapement. The Court ruled in favor of the assessee, directing the deletion of the added amount of Rs. 1,35,000 from the assessment. It highlighted the distinction between a 'change of opinion' and 'reason to believe' for reassessment, emphasizing the necessity of tangible material post-April 1989. The Court also rejected the seized document as a basis for addition in the assessment year 1988-89 due to lack of specific dates, stressing the need for concrete evidence. en-us Tue, 03 Sep 2019 00:00:00 +0530 Thu, 19 Sep 2019 16:18:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386010 The High Court held that the initiation of proceedings under section 147 was not justified, emphasizing the requirement of a live link between reasons and belief for income escapement. The Court ruled in favor of the assessee, directing the deletion of the added amount of Rs. 1,35,000 from the assessment. It highlighted the distinction between a 'change of opinion' and 'reason to believe' for reassessment, emphasizing the necessity of tangible material post-April 1989. The Court also rejected the seized document as a basis for addition in the assessment year 1988-89 due to lack of specific dates, stressing the need for concrete evidence. Case-Laws Income Tax Tue, 03 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386010