Section 148: Belief by AO Requires Tangible Evidence, Not Suspicion

Saraswati Petrochem Pvt. Ltd. Vs ITO (Delhi High Court) Delhi High Court quashes notice u/s 148 for AY 2011-12, emphasizing lack of tangible material. Learn key insights on reassessment proceedings. Introduction: The writ petition against proceedings under Section 148 of the Income-tax Act, 1961 involves Saraswati Petrochem Pvt. Ltd. challenging the initiation of assessment/reassessment for AY 2011-12. The AO issued the impugned notice based on a belief that income had escaped assessment. AO’s Obligation to Furnish Material: The AO is obligated to provide material supporting the belief t...