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Section 147 & 148 of the Income Tax Act, 1961 — Reassessment — Material which formed the basis for the formation of belief that income chargeable to tax had escaped assessment was the evidence found during the course of search and the appraisal report which revealed that there was sufficient material for the AO to form the belief that income chargeable to tax had escaped assessment, thus, reassessment prcoceedings were valid— Purnima Konalkant Sharma vs. Deputy Commissioner of income tax [2019] 419 ITR 361(Gujarat)