Reassessment unsustainable if No Tangible Link Found Between Income Assessment escaped & formation of Belief

Parminder Singh Vs ITO (ITAT Delhi)

ITAT Delhi held that reopening of assessment without any link between the tangible material and formation of belief of AO that income has escaped assessment is unsustainable and bad-in-law and hence liable to be quashed.

Facts- The assessee filed his return of income declaring income of Rs.1,68,680/- under income from business and as agricultural income of Rs.46,000/-. The assessment was reopened by issue of notice u/s 148 as there were

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