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The Tax Publishers2020 TaxPub(DT) 2658 (Mum-Trib) INCOME TAX ACT, 1961
Section 147
Receipt of tangible information from investigation wing which suggested possible escapement of income in the hands of assessee was sufficient to form belief as to escapement so as to reopen assessment as original return was processed under section 143(1) and case was rightly reopened within 4 years upon receipt of tangible information.
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Reassessment - Reason to believe - Information from investigation wing as to assessee being beneficiary of providers of bogus loans - Assessee pleading no application of mind by AO
AO received information from investigation wing as to assessee having received bogus loan from certain entry operators. Accordingly, AO reopened assessment so as to make addition. Assessee's case was that reassessment proceedings were initiated merely at the behest of investigation wing without due application of mind by AO. Held: Original return was processed under section 143(1) and case was reopened within 4 years upon receipt of tangible information from investigation wing which suggested possible escapement of income in the hands of assessee. Nothing more was required at that stage since AO had sufficient reasons to form such a belief and therefore, reopening was valid.
REFERRED :
FAVOUR : Against the assessee.
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 68
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