Reopening Without Cogent Material & on Mere Surmise/Conjecture is Unsustainable: ITAT Delhi

Naz Shazia Vs ITO (ITAT Delhi) ITAT Delhi held that the reopening of assessment had been initiated by mere surmise and conjecture without having any cogent material to form a reasonable belief that income of the assessee had escaped assessment within the meaning of section 147 of the Income Tax Act. Facts- The assessee had filed the return of income for the Asst Year 2014-15 on 24.12.2014 declaring taxable income of Rs 9,34,420/-. This return was duly processed u/s 143(1) of the Act. No scrutiny assessment was framed by the revenue. AO received information from the Kolkata Investigation Wing s...