Tax administration not expected to collect taxes based on ignorances of assessee

Shri Dilpreet Singh Vs ITO (ITAT Chandigarh) Section 148 Conclusive proof as to escapement of income at notice stage not required At the stage of issue of notice under section 148 of Income Tax Act, 1961, the only question to be seen is whether there was relevant material, on the basis of which a reasonable person could have formed  requisite belief. Whether material would conclusively prove escapement of income is not the concern at the stage of issuance of notice under section 148. It was so because formation of belief is within realm of subjective satisfaction of AO, therefore, notice issu...