Sec. 147 of Income-tax Act, 1961— Reassessment—Reassessment invalid as there is not valid reason to believe for reopening of assessment.

Facts: Assessee went on appeal and raised the ground that AO has no jurisdiction for starting reassessment proceedings over the petitioner under s. 147 and further that though the demised land was purchased in the name of present petitioner but in fact was purchased in the capacity of trustee/agent for one M/s Vidya Niketan Education Centre.

Held, that we are satisfied with the initiation of the proceedings by the assessing authority and we are further of the opinion that at this stage the petitioner cannot succeed as the material and evidence which are adduced by the petitioner are clearly disclosing that the petitioner has effected the purchase of property in his name. However, without going into the merits of the case we dismiss the writ petition with liberty to the petitioner to raise his grievance before the competent authority. It would be open to the petitioner to adduce whatever evidence or documents as he may rely in support his contention. - CHANDRA MOHAN TIWARI V/s ITO - [2020] 314 CTR 750 (ALL)