High Court Rules Assessment Reopening u/s 147 Needs "Reason to Believe," Not "Reason to Suspect.

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....Income escaping assessment u/s/ 147 - The requirement of law is “reason to believe“ and not “reason to suspect“. In the present case Since the reasons to believe recorded indicate that the Assessing Officer has acted on mere surmise, without any rationale basis, the action of reopening of the Assessment is thus clearly contrary to law and unsustainable - HC....