https://www.taxtmi.com/caselaws?id=458290 ITAT Kolkata quashed reassessment proceedings initiated under section 147. The AO reopened assessment based solely on investigation wing information without conducting independent inquiry or recording proper reasons. The tribunal held that mere information cannot constitute "reason to believe" required for reopening - AO must possess materials and conduct preliminary inquiry when information only creates "reason to suspect." The recorded reasons contained factual errors regarding commodity trading profits and lacked nexus between investigation wing information and income escapement. The notice under section 148 was issued without satisfying jurisdictional prerequisites, rendering all subsequent proceedings invalid. en-us Wed, 10 Feb 2021 00:00:00 +0530 Fri, 18 Oct 2024 19:52:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458290 ITAT Kolkata quashed reassessment proceedings initiated under section 147. The AO reopened assessment based solely on investigation wing information without conducting independent inquiry or recording proper reasons. The tribunal held that mere information cannot constitute "reason to believe" required for reopening - AO must possess materials and conduct preliminary inquiry when information only creates "reason to suspect." The recorded reasons contained factual errors regarding commodity trading profits and lacked nexus between investigation wing information and income escapement. The notice under section 148 was issued without satisfying jurisdictional prerequisites, rendering all subsequent proceedings invalid. Case-Laws Income Tax Wed, 10 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458290