https://www.taxtmi.com/caselaws?id=27364 The court held that the Income Tax Officer (ITO) must have objective reasons to believe that income had escaped assessment before reopening an assessment. The court emphasized that the ITO cannot act arbitrarily and must base the decision on relevant materials. It was noted that just because a transaction was deemed fictitious in a later assessment does not automatically make similar transactions in earlier years fictitious. The court found that the ITO had sufficient grounds to form an objective opinion for reopening the assessment, and therefore, no interference was warranted. The rule was discharged, interim orders were vacated, and no costs were awarded. en-us Wed, 14 Dec 1983 00:00:00 +0530 Fri, 12 Feb 2010 13:28:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27364 The court held that the Income Tax Officer (ITO) must have objective reasons to believe that income had escaped assessment before reopening an assessment. The court emphasized that the ITO cannot act arbitrarily and must base the decision on relevant materials. It was noted that just because a transaction was deemed fictitious in a later assessment does not automatically make similar transactions in earlier years fictitious. The court found that the ITO had sufficient grounds to form an objective opinion for reopening the assessment, and therefore, no interference was warranted. The rule was discharged, interim orders were vacated, and no costs were awarded. Case-Laws Income Tax Wed, 14 Dec 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27364