https://www.taxtmi.com/caselaws?id=450472 The Bombay HC held that reopening of assessment under section 147 requires "reason to believe" rather than merely "reason to suspect" that income has escaped assessment. The AO attempted to reopen based on CIB information regarding huge share transactions but failed to establish that any income had actually escaped assessment. The court found the AO only had reasons to suspect and desired verification through detailed investigation, which is insufficient. Following precedent in Darpan P. Chandaliya case, the HC ruled that mere receipt of CIB information does not entitle reopening without the AO's satisfaction that chargeable income escaped assessment. The impugned notice was quashed, deciding in favor of the assessee. en-us Fri, 01 Mar 2024 00:00:00 +0530 Mon, 23 Jun 2025 11:39:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450472 The Bombay HC held that reopening of assessment under section 147 requires "reason to believe" rather than merely "reason to suspect" that income has escaped assessment. The AO attempted to reopen based on CIB information regarding huge share transactions but failed to establish that any income had actually escaped assessment. The court found the AO only had reasons to suspect and desired verification through detailed investigation, which is insufficient. Following precedent in Darpan P. Chandaliya case, the HC ruled that mere receipt of CIB information does not entitle reopening without the AO's satisfaction that chargeable income escaped assessment. The impugned notice was quashed, deciding in favor of the assessee. Case-Laws Income Tax Fri, 01 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450472