Reopen proceedings not valid in absence of any tangible material to substantiate escaped income

Brief of the Case ITAT Chandigarh held In the case of M/s Amit Engineers vs. ACIT that it is a trite law that the only condition for the Assessing Officer to reopen the case is that for whatever reasons he has ‘reason to believe’ that income has escaped assessment. The phrase “reason to believe” has been defined in the Landmark judgment of the Hon’ble Apex Court in the case of Sheo Nath Singh Vs. ACIT (1971) 82 ITR 147 in which it was held that “The words “reason to believe” suggest that the belief must be of an honest and reasonable person based upon reasonable grounds and...