chargeable to tax for the said Assessment Year
had escaped assessment and proposing to re-assess its
income. In response, the petitioner requested ... escapement of income also does not exist in the present
case. The contentions urged by the respondents that the
income has escaped assessment because Section
chargeable to tax has escaped assessment in the
case of the assessee for the three assessment years
immediately preceding the assessment year relevant ... Officer had reason to believe that
certain income has escaped assessment and such
escapement of income was on account of non
filing of the return
inference that income has escaped assessment. His vague feeling that there might have been some escape of income from assessment is not sufficient ... underlying reason for that is that instances of concealed income or other income escaping assessment in a large number of cases come to the notice
cases of concealment of income. Reassessment provision empowers the
Assessing Officer to assess income which has escaped assessment. The object of
the section ... prima facie opinion that the income as escaped assessment which
includes non assessment or under assessment. But, it is not the requirement that
the Assessing
necessarily prove
escapement of income at the stage of recording the reasons,
such reasons must point out to an income escaping assessment
and not merely ... factors which indicate an income
escaping the assessments and the factors which indicate a
legitimate suspicion about income escaping the assessment.
The former category consists
assess or reassess
such income and also any other income chargeable to
tax which has escaped assessment and which comes to
his notice subsequently ... chargeable
to tax has escaped assessment in the case of the
assessee for the three assessment years immediately
preceding the assessment year relevant
chargeable to tax has escaped assessment in the
case of the assessee for the three assessment years
immediately preceding the assessment year relevant ... Officer had reason to believe that
certain income has escaped assessment and such
escapement of income was on account of non
filing of the return
escapes assessment due to oversight or inadvertence or a mistake
committed by Assessment Officer, the jurisdiction to reopen the
original assessment vests in the Assessment ... assess or reassess such
income and also any other income chargeable to tax which
has escaped assessment and which comes to his notice
subsequently
escapement
of income. As per the learned AR, the AO before issuing notice under section 148
of the Act for income escaping assessment ... information received form the investigation wing represent
income of the assessee and such income has escaped assessment. There is no
mention in reason recorded with
above, the learned CIT[A] ought
to have appreciated that there was no bonafide belief that
the income had escaped assessment having regard ... assess or reassess such income
and also any other income chargeable to tax which has
escaped assessment and which comes to his notice
subsequently
