No reassessment merely for Loan Advancement or Non filing of ITR

Vijay Kumar Agarwal Vs ITO (ITAT Jaipur) Conclusion: Merely saying that `loan had been advanced’ or `ITR had not been filed’, without disclosing the reasons, which led AO to hold such a belief , did not confer valid jurisdiction on the AO to take action under section 147 and 148. Held: AO had received an information from ITO, Jaipur that during the course of assessment proceedings in the case of Smt. Pooja for AY 2011-12 it was found that Shri Vijay had given unsecured loan and as per AST System it had been found that Shri Vijay had not filed his return of income for AY 2010-11 and 2011-12...