Complemented Assessment cannot be reopened U/s. 147/148 on Borrowed Satisfaction

Hitesh Ashok Vaswani Vs DCIT (ITAT Ahmedabad)

The power to reopen a completed assessment under Section 147 of the Act has been bestowed on the Assessing Officer, if he has reason to believe that any income chargeable to tax has escaped assessment for any assessment year. However, this belief that income has escaped assessment has to be the reasonable belief of the Assessing Officer himself and cannot be an opinion and/or belief of some other authority. On the basis of the information by itself received from another agency, there cannot

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