2016 (4) TMI 257

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....ORDER P. C. 1. This Petition challenges the Notice dated 27th March, 2015 issued under Section 148 of the Income Tax Act, 1961. The impugned notice issued by Assessing Officer seeks to reopen the assessment for A.Y. 2011-12. 2. The reasons in support of the impugned notice read as under: - "In this case, assessment under Section 143(3) of the Income Tax Act was completed on 24.03.2014 assessin....

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....transaction and the claim of revenue expense amounting to Rs. 40,00,00,000/- are seen to be nongenuine in nature. In view of the same, I have reason to believe that income chargeable to tax amounting to Rs. 40,00,00,000/- as aforesaid has escaped assessment for A.Y. 2011-12 in term of Section 147 of the Income Tax Act, 1961, and the same is required to be brought to tax as well as any other inco....

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....Assessing Officer has come to a reasonable belief that the revenue expenses of Rs. 40 lakhs were non genuine resulting in income chargeable to tax escaping assessment. Thus the recorded reasons do indicate the Assessing Officer due application of mind to the information received from him to form a reasonable belief that income chargeable to tax has escaped assessment. Moreover, we do not find that....