Reopening of assessment u/s. 148 based on reason to suspect is unsustainable-in-law: ITAT Delhi

ITO Vs Surender Dalal (ITAT Delhi) ITAT Delhi held that reopening of assessment under section 148 of the Income Tax Act based on reason to suspect unsustainable as AO failed to demonstrate live link between tangible material and formation of reason to believe that income had escaped assessment. Facts- Vide the present appeal, the appellant mainly challenges the reopening of assessment under section 148 of the Act. Assessee alleges that the assessment was proposed to reopen on the ground that no return of income has been filed by the assessee for the year under consideration when in fact the a...