Reassessment Valid if AO had ‘reason to believe’ income chargeable to tax escaped assessment

Valmik Thapar Vs ACIT (ITAT Delhi) Conclusion: While recording of the reasons to reopen an assessment, AO was required to form only prima Facie opinions about escapement of income as he was not making an assessment but taking a first baby step for making the assessment by forming a reasonable belief that whether the claim of assessee should be tested in reassessment proceedings or not. Thus, there was no infirmity in the action of AO that reasoned escapement of income by claiming deduction of Rs. 1 crore u/s 54EC. Held: During reassessment proceedings, assessee submitted that he entered into a...