Clarifying "Reason to Suspect" vs. "Reason to Believe" in Income Tax: Key for Section 147 and 263 Actions.

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....Revision u/s 263 by CIT - reopening of assessment u/s 147 - "reason to suspect" v/s 'reason to believe' - Information adverse may trigger "reason to suspect" and not 'reason to believe'. When an information adverse like this comes to the notice of the AO then it only triggers 'reason to suspect'. Then what the AO should have done was that he should have made reasonable enquiry and should have collected material which could make him believe that there is in fact escapement of income. - AT....