Mere reason to believe that income has escaped assessment not sufficient to reopen assessments beyond 4 years

Brief of the Case Delhi High Court held In the case of CIT vs. Vishishth Chay Vyapar Ltd. that the legal requirement that “the reason to believe must be predicated on tangible material or information” and that “the belief must be rational and bear a direct nexus to the material on which such a belief is based” was not fulfilled in the present case. In this case, the only reason for forming the ‘reasons to believe’ that income had escaped assessment was the dismissal of the Assessee’s appeal by CIT (A) for AY 1997-98 in which share loss was disallowed for t...