Sheo Nath Singh vs Appellate Assistant Commissioner Of Income Tax

Authority: Supreme Court Date: 1971-08-12 AY: 1940-41, 1941-42, 1942-43, 1943-44, 1944-45, 1945-46, 1946-47 Section: 147(a), 148 Acts: Income Tax Act 1922, Taxation on Income (Investigation Commission) Act 1947, Constitution of India Result: Assessee Citation: 1973 CTR (SC) 484 (1971) 82 ITR 147 (SC) Justices: K.S. Hegde & A.N. Grover, JJ. Appeal No: Civil Appeal No. 1477 (NT) of 1967
Whether the Income Tax Officer had valid 'reason to believe' under Section 34(1A) of the Income Tax Act 1922 to initiate reassessment proceedings --- Held No, as the recorded reasons were vague, based on mere suspicion, and failed to satisfy statutory requirements.

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