Recording of reasons to believe & not reasons to suspect is pre-condition of section 147

Purnima Komalkant Sharma Vs DCIT (Gujarat High Court) In the given case, the petitioner is an individual and engaged in the business of real estate and transportation and ship breaking. The return of income was accepted without any scrutiny. Thereafter, a search action took place at the premises of the petitioner. Upon conclusion of such proceedings, assessment was framed under section 143(3) read with section 153A(1)(b) of the Act. Thereafter, assessing officer seeks to reopen the assessment of the petitioner for assessment year 2011-12. Upon receipt of the notice, the petitioner requested t...