Section 147: AO must act based on ‘reasons to believe’ & not on ‘reasons to suspect’

Kasapu Ramesh Babu Vs ITO (ITAT Visakhapatnam)

Assessing Officer has to act on the basis of “reasons to believe” and not on “reasons to suspect”. In the instant case, the initiation of proceedings u/s 147 of the Act are based upon no evidence and/or un-corroborative material. The Assessing Officer further failed to establish the nexus with the reasons recorded and alleged material available with the AO before initiation of proceedings and Bank Statements later received and got verifi

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