https://www.taxtmi.com/highlights?id=76088 Reopening of assessment u/s 147 - The High Court observed that the reasons provided by the Assessing Officer for reopening the assessment did not establish a live link between the information received and the belief that income had escaped assessment. There was no clear allegation of failure to disclose material facts by the petitioner. The court concluded that the reassessment was merely based on a change of opinion by the Assessing Officer, which did not justify reopening the assessment. It highlighted that a reason to suspect is not the same as a reason to believe, and there must be a rational connection between the material and the belief of income escapement. en-us Wed, 27 Mar 2024 08:30:15 +0530 Wed, 27 Mar 2024 08:30:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=76088 Reopening of assessment u/s 147 - The High Court observed that the reasons provided by the Assessing Officer for reopening the assessment did not establish a live link between the information received and the belief that income had escaped assessment. There was no clear allegation of failure to disclose material facts by the petitioner. The court concluded that the reassessment was merely based on a change of opinion by the Assessing Officer, which did not justify reopening the assessment. It highlighted that a reason to suspect is not the same as a reason to believe, and there must be a rational connection between the material and the belief of income escapement. Highlights Income Tax Wed, 27 Mar 2024 08:30:15 +0530 https://www.taxtmi.com/highlights?id=76088