Reopening notice invalid in absence of any tangible material to establish escapement of income for assessment

ACIT Vs Ravi Parkash Aggarwal (ITAT Delhi)

Primarily, we find that the reasons recorded by the assessee are too sketchy and does not instill any confidence with regard to the reasons recorded for reopening. It is not even clear whether the assessee has received entries pertaining to loans or purchases. The details of the report wherein it was alleged that the assessee has received bogus entries could not be made as a basis for reopening. The existence of belief has to be bonafide and has to be based on material which is relevant hence specific in nature

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