Reasons for formation of belief must have rational connection with formation of belief

Milind Madhukar Edke Vs ITO (ITAT Pune) In the present case, ITAT prima-facie find that, the reason to believe that the income of the assessee has escaped assessment is found to have formed on incorrect facts as regards to filing of ITR, further without any enquiry into the transaction reported in AIR and without bringing any cogent material to showcase that the said bank deposits made into saving bank account per se represent the income of the assessee. Further in the absence of any material vis-à-vis findings of the Ld. AO suggesting that, the facts were indeed duly analysed, and  equired...