Revenue Must have Tangible Material to initiate income escaping Assessment

Brief of the Case In the case of Coperion Ideal Private Limited v. CIT, Delhi High Court while giving the decision in the favour of the assessee, held that there should be some tangible material available with the Revenue, whenever they want to conclude that Assessee have escaped Assessment. Facts of the case The Assessee filed its return of income for the AY 2002-03 on 31st October 2002 declaring income at Rs.67,91,500. The Assessee showed expenditure of a sum of Rs.20,71,489 under the head “Royalty & Cess”. The, ACIT issued a notice u/s 154 of the Act to the Assessee seeking explanat...