Notice u/s 148 for reassessment cannot be issued based on mere suspicion

Brief of the case

In the beginning of February 2012, elections were to be held for the U.P. State Assembly, the Election Commission had issued instructions that if cash of more than Rs. 2,50,000/- was found with any person, the same may be seized and enquiry made whether this cash was for distribution amongst the voters. Shri A.K. Dhir was stopped by U.P. Police on the border of Delhi and U.P. and as cash of Rs. 5 lakhs was found, this amount was seized. His statement was recorded by DDI (Investigation-

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