Reopening u/s 147 required only “reason to believe” and not the established fact of escapement of income

Brief Facts 1. The assessee has filed return of income declaring income of Rs. 74,850/- The return was processed under section 143(1)of the Act. Subsequently, AO received some information from Joint Sub-Registrar, based on that information notice under sect ion 148 of the Act was issued on 12.12.2008. Information was as under: ”As per information received from the Joint-Registrar, Ambala Cantt. Rs. 15,00,000/- + Registration charges of Rs.l.50 lac on 01.7.2005. in the return of income filed on 20.11.2006 declaring taxable income of Rs. 74,850/-, the transaction of Rs. 5,00,000/- made for pur...