Sufficiency/ correctness of material relied by AO for re-opening not to be considered

Pavan Kishanchand Tulsiani Vs Union of India (Gujarat High Court) Gujarat High Court held that when AO has reason to believe and have prima facie material for commencement of re-assessment proceedings, sufficiency/ correctness of the material is not a thing to be considered. Reopening justified. Facts- Petitioner is a Director / Partner in various firms and derives income from various sources. A notice dated 30.3.2018 u/s. 148 was issued for re-assessing the income and called upon the petitioner to file his return of income in the prescribed form for the said assessment year. On 29.8.2018, the...