Reopening Tax Assessment Needs Section 148 Notice Based on "Reason to Believe," Not Suspicion or Rumor.

Reopening of assessment u/s 147 - notice under Section 148 - The words "reason to believe" indicate that the belief must be that of a reasonable person based on reasonable grounds emerging from direct or circumstantial evidence and not on mere suspicion, gossip or rumour. - HC .....

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