119 (Gujarat) (HC). 4. Pushpak Bullion (P.) Ltd. v. DCIT

78 Taxmann.com 58High Court2017#3206 most cited

What is 119 (Gujarat) (HC). 4. Pushpak Bullion (P.) Ltd. v. DCIT authority for?

Reassessment proceedings initiated under section 147 require a live link and direct connection between the material that came into the possession of the Assessing Officer subsequently and the belief that income has escaped assessment. Borrowed satisfaction from another officer's belief is not sufficient.

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judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2017 to 2026.

Also referred to as

Pushpak Bullion · section 147 · section 151 · income escaping assessment · fresh tangible material · sanctioning authority · approval under section 151 · borrowed satisfaction · live link · non application of mind

Issues it is cited on

Judgments citing 119 (Gujarat) (HC). 4. Pushpak Bullion (P.) Ltd. v. DCIT