Sufficiency or correctness of material need not be considered at the stage of issue of Section 148 notice

Saif II Mauritius Company Limited Vs ACIT (Delhi High Court) In the present cases, the issue of dividend income as well as long term capital gain on the sale of shares requires a detailed consideration. Further, in the present cases, Section 148 notices have been issued within four years from the end of the relevant Assessment Years. Also no scrutiny assessment has been taken place in the present cases. Consequently, the test to be applied for re-assessment in the present cases is whether there is ‘reason to believe’ that income chargeable to tax has escaped assessment. In Raymond Woollen ...