Validity of Reopening of assessment - “tangible material” as may ever give rise to a “reason to believe"...

Validity of Reopening of assessment - “tangible material” as may ever give rise to a “reason to believe" - Reliance on the Report of the Justice M.B. Shah Commission - The High Codurt observed that the assessing authority primarily based its action on the report, which did not provide a definitive finding but only a possibility of under-invoicing. The court held that this did not constitute "tangible material" required to form a "reason to believe". Consequently, the reassessment notice was deemed invalid as it was founded on speculative assumptions rather than hard evidence. .....

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