Prima Facie Belief Required with Tangible Material Showing Income Escaped Assessment- Section 147/148

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 incriminating in...