with
them, kindly provide the same since this would be
"tangible material" for the purpose of sec. 148.
Page 5 of 34
Downloaded ... which is
based on mere general observation nor there is any
tangible material or nexus with the so called
escapement of income and therefore
full and true disclosure. According
to Mr.Soparkar, there was no tangible material before the
Assessing Officer for the purpose of reopening the assessment ... must be self evident, they
must speak for themselves.
(vi) The tangible material which forms the basis for the
belief that income has escaped assessment
with
them, kindly provide the same since this would be
"tangible material" for the purpose of sec. 148.
Page 5 of 34
Downloaded ... which is
based on mere general observation nor there is any
tangible material or nexus with the so called
escapement of income and therefore
link' in respect
of the information received. Therefore, there
was tangible material available with the
Assessing Officer to prima facie form an
opinion/belief ... available on record. Thus, it
is on the basis of tangible material
available with the Assessing Officer, he has
formed a prima facie opinion/belief
link' in respect
of the information received. Therefore, there
was tangible material available with the
Assessing Officer to prima facie form an
opinion/belief ... available on record. Thus, it
is on the basis of tangible material
available with the Assessing Officer, he has
formed a prima facie opinion/belief
must be self evident, they
must speak for themselves.
(vi) The tangible material which forms the basis for the
belief that income has escaped assessment ... investigation. The reasons to believe must
demonstrate some link between the tangible material and
the formation of the belief or the reason to believe that
scrutiny i.e. under
Section 143(1) , even in such cases tangible material is necessary to
reopen the assessment. In this connection, a reference ... Section 143(1) called as the nonÂscrutiny
assessment. Therefore, a tangible material is necessary to reopen even
an assessment made without scrutiny under Section
firm.
7. It is submitted that order of CIT(A) being tangible
material in the hands of the AO of the petitioner-
assessee ... 16304/2019 JUDGMENT
the information received which was the tangible material
was not available at the time of original assessment.
10. It is submitted that
firm.
7. It is submitted that order of CIT(A) being tangible
material in the hands of the AO of the petitioner-
assessee ... 16304/2019 JUDGMENT
the information received which was the tangible material
was not available at the time of original assessment.
10. It is submitted that
deduction under section 80P(2)(d) and is not
based on tangible material and it is only a change of opinion,
which is not permissible ... aside the impugned notice, more
particularly, in absence of tangible material, the Assessing Officer
Page 6 of 32
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