https://www.taxtmi.com/caselaws?id=447860 ITAT Raipur held that AO lacked valid jurisdiction to initiate proceedings u/s 147 for protective assessment regarding cash deposits in assessee's bank account. The tribunal ruled that reopening is permissible only when AO establishes that ascertainable income escaped assessment in hands of definite assessee. Protective assessment based on future contingency cannot justify assumption of jurisdiction u/s 147, as it requires bonafide belief that chargeable income actually escaped assessment. Since AO believed income belonged to another person and initiated substantive proceedings against that person, simultaneously treating same amount as assessee's escaped income was contradictory. Notice u/s 148 was quashed for invalid jurisdictional assumption. Decision favored assessee. en-us Fri, 26 May 2023 00:00:00 +0530 Sat, 06 Jan 2024 07:37:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447860 ITAT Raipur held that AO lacked valid jurisdiction to initiate proceedings u/s 147 for protective assessment regarding cash deposits in assessee's bank account. The tribunal ruled that reopening is permissible only when AO establishes that ascertainable income escaped assessment in hands of definite assessee. Protective assessment based on future contingency cannot justify assumption of jurisdiction u/s 147, as it requires bonafide belief that chargeable income actually escaped assessment. Since AO believed income belonged to another person and initiated substantive proceedings against that person, simultaneously treating same amount as assessee's escaped income was contradictory. Notice u/s 148 was quashed for invalid jurisdictional assumption. Decision favored assessee. Case-Laws Income Tax Fri, 26 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447860