Section 147: Reasons for formation of opinion should have a rational connection with formation of belief

Synfonia Tradelinks Pvt Ltd Vs ITO (Delhi High Court) 1. The reasons which lead to the formation of opinion or belief that the assessee’s income chargeable to tax has escaped assessment should be inextricably connected. In other words, the reasons for the formation of opinion should have a rational connection with the formation of the belief that there has been an escapement of income chargeable to tax. 2. The expression “reason to believe” is stronger than the word ‘satisfied‘. The belief should be based on material that is relevant and cogent. 3. The process of reas...