Reassessment not valid if reasons recorded by AO were not sufficient ‘reasons to believe’

HIGH COURT OF BOMBAY Commissioner of Income-tax-3, Mumbai Versus ICICI Bank Ltd. S.J. VAZIFDAR AND M. S. SANKLECHA, JJ. IT Appeal No. 1237 of 2011 JULY  9, 2012 JUDGMENT M.S. Sanklecha, J.  This appeal by the revenue under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the said Act) is directed against the order dated 27/8/2010 of the Income Tax Appellate Tribunal (hereinafter referred to as the “Tribunal”) relating to assessment year 1996-97. 2. Being aggrieved by the Order dated 27/8/2010 the appellant has raised the following substantia...