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 t

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