1976 (9) TMI 52

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....47 (a) for the assessment year 1959-60. The assessee was originally assessed on a total income of Rs. 4,896. Subsequently, the Income-tax Officer issued a notice under s. 147(a) in response to which the assessee filed a fresh return on 25th February, 1972 showing a total income of Rs. 4,296. It is common ground that the assessment was reopened under s. 147(a). The reasons for reopening the same ar....

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....erial facts necessary for its assessment." 2. The Income-tax officer reassessed the assessee on a total income of Rs. 26,362 including income from undisclosed sources at Rs. 21,000 and interest thereon at Rs. 466. The Appellate Assistant Commissioner upheld the validity of the order and dismissed the appeal on merits as well. 3. It was argued before us by the counsel for the assessee that th....

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....orne out by materials on record. 5. We have considered the rival contentions advanced by both the sides. A careful study of the reasons recorded by the Income-tax Officer for reopening the assessment would at once reveal that the Income-tax Officer did not bring any materials into the report on the basis of which his belief could be sustained. It is not enough that the Income-tax Officer has so....