Reassessment invalid as based on ‘reasons to suspect’ rather than ‘reason to believe’

Vashisht Alloys Vs DCIT (ITAT Chandigarh) ITAT Chandigarh held that reopening of assessment under section 148 of the Income Tax Act merely on the basis of ‘reasons to suspect’ rather than on ‘reason to believe’ is invalid in the eye of law. Held that passive reliance on third-party intelligence would render the reopening invalid as it reflected merely a ‘reason to suspect’. Facts- The assessee is stated to be engaged in manufacturing of metal products. The case of the assessee was reopened and notice u/s. 148 was issued. It was alleged that the income of Rs.80.59 Lacs was receiv...