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Prima Facie Belief Required with Tangible Material Showing Income Escaped Assessment- Section 147/148
Case Law Details
- Case Name
- Pareshkumar Punamchand Shah Vs ITO (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2011-12
- Courts
- All ITAT, ITAT Ahmedabad
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Pareshkumar Punamchand Shah Vs ITO (ITAT Ahmedabad)
Prima-facie formation of a belief was required u/s 147/148 based on tangible material having live link/nexus that income escaped assessment
Conclusion: Existence of reasons to belief by way of tangible material and its live link/nexus with formation of belief by AO that income of the assessee had escaped assessment was relevant, and not the sufficiency of material because at the stage of reopening prima-facie belief of the AO based on material on record that income had escaped assessment. AO was having sufficient and tangible...
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