https://www.taxtmi.com/caselaws?id=59426 Reassessment under sections 147/148 was treated as invalid where the assessee had disclosed the gift transaction in the return, the reopening relied mainly on a retracted third-party statement and general foreign-exchange immunity scheme material, and no independent evidence linked the receipt to an unexplained source. The Assessing Officer's information showed only a broad allegation about gifts routed through NRE accounts on payment of premium, which did not specifically establish that this assessee's remittance fell outside the immunity scheme. As the basic remittance particulars were already furnished and the CBDT circular barred enquiry into covered remittances, mere suspicion did not amount to reason to believe. en-us Thu, 22 Nov 2001 00:00:00 +0530 Thu, 21 Jun 2012 18:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59426 Reassessment under sections 147/148 was treated as invalid where the assessee had disclosed the gift transaction in the return, the reopening relied mainly on a retracted third-party statement and general foreign-exchange immunity scheme material, and no independent evidence linked the receipt to an unexplained source. The Assessing Officer's information showed only a broad allegation about gifts routed through NRE accounts on payment of premium, which did not specifically establish that this assessee's remittance fell outside the immunity scheme. As the basic remittance particulars were already furnished and the CBDT circular barred enquiry into covered remittances, mere suspicion did not amount to reason to believe. Case-Laws Income Tax Thu, 22 Nov 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59426