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 suff

Please become a Premium member. If you are already a Premium member, login here to access the full content.