Sec. 147 & 148 of Income Tax Act, 1961—Reassessment—Jurisdiction accorded u/s.147 is invalid as reason to believe was not valid.

Facts: Assessee has challenged the validity of reopening u/s.148 and on addition of Rs. 1,93,066/- on account of bogus purchases.

Held, that there was no merit in the contention that there was a categorical information wherein the assessee’s name was appearing along with details of the parties from whom the assessee has made purchases which were found to be Hawala operator providing accommodation bogus bills. AO after receiving the information has independently applied his mind and recorded his reason to believe as to why such a purchase is not genuine. Thus, the jurisdiction accorded u/s.147 is invalid and the same is dismissed. In the result, the appeal of the assessee is partly allowed. - BELMARKS METAL WORKS V/s ITO - [2020] 80 ITR (TRIB) 699 (ITAT-DELHI)