2018 (7) TMI 2180

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..... transactions as suspicious transactions and called upon the Assessing Officer to verify the transactions as there is a likelihood that income chargeable to tax has escaped assessment. The reasons in support of the impugned notice do not indicate any application of mind and/or further processing of the information to come to a reasonable belief that income chargeable to tax has escaped assessment. .....

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..... n Co., Advocate For the Respondent : Mr. N.C. Mohanty, Advocate ORDER P.C. :- 1. Heard. Rule. 2. This petition challenges notice dated 31 st March, 2017 issued under Section 148 of the Income-Tax Act, 1961 seeking to re-open the assessment for the Assessment Year 2010-11. The assessment was earlier completed by way of intimation under Section 143(1) of the Act. The reaso .....

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..... escaped assessment but merely states that it would be atleast be ₹ 1,00,000/-. Prima-facie, we are of the view that the reasons recorded do not indicate reasonable belief of the Assessing Officer himself to issue the impugned notice. Thus, prima-facie, the impugned notice is without jurisdiction. 3. Accordingly, till the final disposal of this petition, there shall be interim stay of the .....

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