2022 (10) TMI 1298

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....Section 69A read with section 115BBE of the Act. 3. Briefly, the facts are the assessee is a resident individual. For the assessment year under dispute, assessee did not file any return of income under Section 139(1) of the Act. Subsequently, from the information available on record, the Assessing Officer found that in the year under consideration, the assessee had deposited cash amounting to Rs.20,00,000 in his bank account. Noticing this, the Assessing Officer issued a letter to the assessee seeking information on the cash deposits. Since, no response was received from the assessee, the Assessing Officer formed a belief that income has escaped assessment, accordingly, reopened the assessment under Section 147 of the Act. In response to....

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....the Assessing Officer issued a letter to the assessee seeking information, which remained non-complied. Thus, the aforesaid facts reveal, not only the Assessing Officer had tangible material in his possession to form belief regarding escapement of income but there was complete lack of information from assessee's side to explain the source of such cash deposits. In such a scenario, the Assessing Officer was justified in reopening the assessment under Section 147 of the Act as he had enough reason to form a prima facie belief that income had escaped assessment. That being the case, in my considered view, the Assessing Officer was justified in reopening the assessment under Section 147 of the Act. Accordingly, I uphold the validity of reopenin....