Reassessment u/s 147 invalidated due to lack of evidence; reliance on a statement without proof deemed insufficient.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of assessment u/s 147 was invalid as statement recorded during survey cannot be solely relied upon without tangible material. Admission of additional income by director was not supported by evidence. Cash appearing in laptop was not proved to belong to assessee company. Reason to believe income escaped assessment must have rational connection with material evidence, which was lacking. Reassessment proceedings quashed as reasons recorded were insufficient and jurisdictional precondition of reason to believe was not met, rendering initiation ab-initio void. Decision in favor of assessee.....