https://www.taxtmi.com/caselaws?id=458065 ITAT Surat held that reassessment proceedings u/s 147/148 were invalid as the AO recorded reasons based on suspicion rather than "reason to believe" as required by law. The AO mechanically relied on information from Investigation Wing Mumbai regarding bogus purchases and unsecured loans without applying independent mind or establishing live link between received information and assessee's case. Since unsecured loans were not relevant to assessee's matter, the AO failed to satisfy prerequisite condition of having own satisfaction about income escapement. The reassessment was quashed and assessee's appeal was allowed. en-us Thu, 23 Dec 2021 00:00:00 +0530 Fri, 04 Oct 2024 17:46:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458065 ITAT Surat held that reassessment proceedings u/s 147/148 were invalid as the AO recorded reasons based on suspicion rather than "reason to believe" as required by law. The AO mechanically relied on information from Investigation Wing Mumbai regarding bogus purchases and unsecured loans without applying independent mind or establishing live link between received information and assessee's case. Since unsecured loans were not relevant to assessee's matter, the AO failed to satisfy prerequisite condition of having own satisfaction about income escapement. The reassessment was quashed and assessee's appeal was allowed. Case-Laws Income Tax Thu, 23 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458065