2007 (7) TMI 367

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....t. yr. 1999-2000 against the order dt. 21st Dec., 2004 of the learned CIT(A). 2. In ground No. 1 of the appeal, the assessee has disputed the legality of initiation of reassessment proceedings. 3. I have heard the learned representatives of the parties and have perused the orders of the authorities below. I observe that the assessee filed his return of income on 16th Feb., 2001 along with th....

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....e assessee remained unexplained and the agricultural income claimed by the assessee was income from other sources. 4. During the course of hearing, the learned representative of the assessee submitted that the AO has initiated reassessment proceedings in respect of the same very fact that had duly been disclosed by the assessee in the original return filed by him. He further submitted that ther....

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....rying out agricultural operation. 6. I, on consideration of the submissions of the learned representatives of the parties, am of the view that the action of the AO in initiating reassessment proceedings by issuing notice under s. 148 of the Act is not justified as the AO has not recorded his satisfaction that he has reasonable belief that the income chargeable to tax has escaped assessment. It ....