Roshan Di Hatti v. CIT

107 ITR 938Supreme Court of India1977#147 most cited

What is Roshan Di Hatti v. CIT authority for?

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

477

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2026.

Also referred to as

Roshan Di Hatti v. CIT · Section 68 · assessee onus of proof · cash credits · genuineness of transaction · identity of creditor · creditworthiness of creditor · additions to income · unexplained money · Section 143(3) · Section 147

Also reported as

2 SCC 378

Sections most often in play

Section 68Section 143(3)Section 147Section 142(1)Section 115BBESection 69ASection 148Section 144
Read the full judgment

Issues it is cited on

creditworthiness of the creditoronus of proofsource of sourceshare capital and share premiumpreponderance of probabilitysection 31paper companyaddition u/s 68survey under section 133aaddition under section 68share application moneygenuineness of the transaction

Judgments citing Roshan Di Hatti v. CIT

ACIT, Central Circle -1, Ludhiana vs. M/S Oswal Apparels Pvt. Ltd., Ludhiana

In the result, this appeal of the Revenue stands dismissed

ITA 27/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh17 Dec 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

Section 132Section 153A

…P) Ltd.” (supra) is concerned, we note that the Hon’ble Supreme Court in the said case has taken note of the observations made by the Supreme Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laying down the proposition that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must conduct an inquiry, and call for more details before invo…

ACIT, Central Circle -1, Ludhiana vs. M/S Oswal Apparels Pvt. Ltd., Ludhiana

In the result, this appeal of the Revenue stands dismissed

ITA 26/CHANDI/2022[2011-12]Status: DisposedITAT Chandigarh17 Dec 2024AY 2011-12

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

Section 132Section 153A

…P) Ltd.” (supra) is concerned, we note that the Hon’ble Supreme Court in the said case has taken note of the observations made by the Supreme Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laying down the proposition that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must conduct an inquiry, and call for more details before invo…

M/S Oswal Apparels Pvt. Ltd., Ludhiana vs. DCIT, C.C.- 1, Ludhiana

In the result, this appeal of the Revenue stands dismissed

ITA 432/CHANDI/2021[2012-13]Status: DisposedITAT Chandigarh17 Dec 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

Section 132Section 153A

…P) Ltd.” (supra) is concerned, we note that the Hon’ble Supreme Court in the said case has taken note of the observations made by the Supreme Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laying down the proposition that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must conduct an inquiry, and call for more details before invo…

M/S Oswal Trend (P) Ltd., Ludhiana vs. DCIT, C. C.-1, Ludhiana

In the result, this appeal of the Revenue stands dismissed

ITA 429/CHANDI/2021[2012-13]Status: DisposedITAT Chandigarh17 Dec 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

Section 132Section 153A

…P) Ltd.” (supra) is concerned, we note that the Hon’ble Supreme Court in the said case has taken note of the observations made by the Supreme Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laying down the proposition that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must conduct an inquiry, and call for more details before invo…

Deputy Commissioner of Income Tax, Kolkata vs. Salasar Financial Advisory Services Pvt. Ltd., Kolkata

In the result, appeal of the revenue is dismissed

ITA 1926/KOL/2024[2012-13]Status: DisposedITAT Kolkata17 Dec 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. No.1926/Kol/2024 Assessment Year: 2012-13

Section 131Section 250

…d.” (supra) is concerned, we note that the Hon’ble Supreme Court in the said case has taken note of the observations made by the Supreme Court in the “the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laying down the proposition that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must conduct an inquiry, and call for more details before invo…

Yogesh Ginning Mill, Prop. Yogesh Chand Gupta, Govindgarh vs. ACIT, Circle I, Alwar

In the result, the appeals filed by the assessee are allowed

ITA 540/JPR/2024[2018-19]Status: DisposedITAT Jaipur12 Dec 2024AY 2018-19

Bench: This Tribunal Which Were Passed By The Commissioner Of Income Tax (Appeal)- 4, Jaipur [ For Short Cit(A) ] Passed On Dates & F For The Assessment Years Mentioned As Tabulated Here In Below, In Turn Those Orders Were Arises Because The Assessee Has Yogesh Ginning Mill Vs. Acit

For Appellant: Shri Paridhi Jain, AdvFor Respondent: Shri Gajendra Singh (Addl.CIT) a
Section 143(2)Section 143(3)Section 145(3)Section 250Section 68

…the receipt was not income or that if it was, it was not taxable as per the provisions of the Act. In absence of such proof, the Income Tax Officer is entitled to treat it as taxable income. In the case of Roshan Di Hatti v. Commissioner of Income-tax [1977] 107 ITR 938 (SC)[08-03-1977] it is held by the Hon'ble Supreme Court as under- "Now, the law is well settled that the onus of proving the source of a sum of money found to have been received by an assessee is on him. If he disputes the liability for tas, it is for him to show either that the receipt was not income or that if it was, it was exempt from taxat…

Yogesh Ginning Mill, Prop. Yogesh Chand Gupta, Govindgarh vs. ACIT, Alwar

In the result, the appeals filed by the assessee are allowed

ITA 1045/JPR/2024[2017-18]Status: DisposedITAT Jaipur12 Dec 2024AY 2017-18

Bench: This Tribunal Which Were Passed By The Commissioner Of Income Tax (Appeal)- 4, Jaipur [ For Short Cit(A) ] Passed On Dates & F For The Assessment Years Mentioned As Tabulated Here In Below, In Turn Those Orders Were Arises Because The Assessee Has Yogesh Ginning Mill Vs. Acit

For Appellant: Shri Paridhi Jain, AdvFor Respondent: Shri Gajendra Singh (Addl.CIT) a
Section 143(2)Section 143(3)Section 145(3)Section 250Section 68

…the receipt was not income or that if it was, it was not taxable as per the provisions of the Act. In absence of such proof, the Income Tax Officer is entitled to treat it as taxable income. In the case of Roshan Di Hatti v. Commissioner of Income-tax [1977] 107 ITR 938 (SC)[08-03-1977] it is held by the Hon'ble Supreme Court as under- "Now, the law is well settled that the onus of proving the source of a sum of money found to have been received by an assessee is on him. If he disputes the liability for tas, it is for him to show either that the receipt was not income or that if it was, it was exempt from taxat…

ACIT, Circle-2(2)(1), Bangalore vs. Vastimal Bhim Raj Sancheti, Bangalore

In the result, the appeals of the Revenue are dismissed

ITA 441/BANG/2024[2016-17]Status: DisposedITAT Bangalore04 Dec 2024AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K

For Appellant: Shri. Prashanth GS, ARFor Respondent: Shri. Subramanian, JCIT(DR)(ITAT), Bengaluru
Section 68

…, 441/Bang/2024 Page 20 of 22 of the investors. The assessee has provided a clear explanation regarding the source of the credit in its books of account as unsecured loan. 18. It was held by Hon'ble Supreme Court in the case of Roshan Di Hatti v. CIT [1977] 107 ITR 938 that onus of proving the source of sum of money found to have been received by the assessee, is of assessee. Once the assessee has submitted the documents relating to identity, genuineness of transactions and creditworthiness, then ld. AO must conduct enquiry and call for more details before invoking section 68 of the Act. If the assessee is not…

Mohan Lal Ashok Kumar Saraf, Jaipur vs. DCIT Cen Cir 1, Jaipur

In the result, the appeal of the assessee is allowed as indicated hereinabove

ITA 879/JPR/2024[2017-2018]Status: DisposedITAT Jaipur28 Nov 2024AY 2017-2018
For Appellant: Shri Ankit Totuka, AdvocateFor Respondent: Ms. Alka Gautam, CIT-DR
Section 143(3)Section 68

…of the assesse, it is not necessary for the department to locate its exact source (CIT v. M.Ganapathi Mudallar [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC)) In the case of Roshan Di Hatti v. Commissioner of Income-tax [1977] 107 ITR 938 (SC)[08-03-1977) it is held by the Hon'ble Supreme Court as under- 21 MOHAN LAL ASHOK KUMAR SARRAF VS DCIT, CENTRAL CIRCLE-1 JAIPUR "Now, the law is well settled that the onus of proving the source of a sum of money found to have been received by an assessee is on him. If he disputes the liability for tax, it is for him to show either that the…

Sumit Prakashrao Fulzele, Chandrapur vs. ITO Ward 2, Chandrapur

In the result, appeal filed by the assessee is allowed

ITA 35/NAG/2024[2017-18]Status: DisposedITAT Nagpur18 Nov 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Abhay Y. Marathe
Section 115BSection 142(1)Section 144Section 250Section 69A

…said amount came from sale of wearing apparel and traditional silver utensils, since there was no evidence and material to establish sale or inheritance, etc., impugned addition made by authorities below was to be confirmed. 11. Roshan Di Hatti v. CIT [1992] 2 SCC 378 (SC) wherein it was held that the assessee fails to discharge the onus by producing cogent evidence and explanation, the AO would be justified in making the additions back into the income of the assessee. 12. Rakesh Kumar Gupta vs. CIT 115 taxmann.com 38 (Allahabad) (2020) cash deposit claimed it from agricultural income prove cultivation of agricu…

Megapix Vanijya Pvt. Ltd., Kolkata vs. I.T.O., Ward - 9(1), Kolkata

The appeal of the assessee is allowed

ITA 1151/KOL/2024[2012-2013]Status: DisposedITAT Kolkata18 Nov 2024AY 2012-2013

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No.1151/Kol/2024 Assessment Year: 2012-13 Megapix Vanijya Pvt. Ltd……………………………………………..…..……Appellant C/O Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata – 700069. [Pan: Aahcm6624J] Vs. Ito, Ward-9(1), Kolkata............…....….…..….........……........……...…..…..Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri Pradip Biswas, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 27, 2024 Date Of Pronouncing The Order : November 18, 2024 Order Per Sonjoy Sarma: The Present Appeal Is Filed By The Assessee Against The Order Dated 13.05.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Year 2012-13. 2. The Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income On 26.09.2012 By Declaring A Total Loss Of Rs.4,540/-. The Case Of The Assessee Was Selected For Scrutiny Due To Large Share Premium Received By The Assessee During The Relevant Financial Year. Consequently, The Assessing Officer Issued Notices U/S 142(1) & 142(2) Of The Act Requesting For Furnishing Requisite Information. In Response To The Notices, The Ld. Ar Of The Assessee Appeared Before The Assessing Officer & Provided Primary Details Including An Explanation That The Assessee Company Was Engaged In The Business Of Share Trading. Upon

Section 131Section 142(1)Section 143(3)Section 250Section 68

…hon’ble Supreme Court in the case of “PCIT v/s NRA Iron & Steel (P) Ltd.” (supra) has taken note of the observations made by the Supreme Court in the “the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has I.T.A. No.1151/Kol/2024 Assessment Year: 2012-13 Megapix Vanijya Pvt. Ltd. submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must…

Vision Diagnostic India Pvt Ltd, Delhi vs. ACIT Circle 26(2), Delhi

The appeal of the assessee is allowed

ITA 3067/DEL/2024[2017-2018]Status: DisposedITAT Delhi18 Nov 2024AY 2017-2018

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singhassessment Year: 2017-18

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri Amit Katoch, Sr. DR
Section 115BSection 143(3)Section 68

…instant case, appellant has failed to offer any explanation so as to prove the genuineness of said share transactions. Hence, the first limb of section 68 is clearly attracted in this case. The Hon'ble Supreme Court in the case of Roshan Di Hatti V CIT (1977) 107 ITR 938 and Kale Khan Mohammad Hanif V. CIT (1963) 50 ITR 1, held as under: "The law is well-settled that the onus of proving the source of a sum of money found to have been received by an assessee is on him. Where the nature and source of a receipt, whether it be of money or other property, cannot be satisfactorily explained by the assessee, it is open…

Income Tax Officer -19(2)(2), Mumbai vs. Kamlesh Gupta and Sons HUF, Mumbai

In the result, the appeal filed by the Revenue Department stands dismissed, whereas the appeal filed by the Assessee stands allowed for statistical purposes

ITA 4187/MUM/2024[2016-17]Status: DisposedITAT Mumbai30 Oct 2024AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Gagan Goyalassessment Year: 2016-17

For Appellant: Shri Sumit Mantri, A.RFor Respondent: Shri G. Santosh Kumar, Sr. AR
Section 142(1)Section 144Section 250Section 36(1)(iii)Section 68

…nder, (2) the capacity of the lender and (3) the genuineness of the transaction. As the Assessee failed to submit even the basic confirmation and therefore relying on various judgments as recorded in the assessment order such as Roshan Di Hatti vs. CIT (1977) 107 ITR 937 (SC)/Kale Khan Mohammad Hanif vs. CIT (1963) 50 ITR 1 (SC) the unsecured loan amounting to Rs.6,26,53,277/- is treated as non genuine and income from undisclosed sources brought into the books under the garb of unsecured loan and added the same as unexplained cash credit u/s 68 of the Act”. 3.1 The AO also made other addition of Rs.79,14,292/- u…

Kamlesh Gupta and Sons HUF, Mumbai vs. The Income Tax Officer Ward 19(2)(2), Mumbai

In the result, the appeal filed by the Revenue Department stands dismissed, whereas the appeal filed by the Assessee stands allowed for statistical purposes

ITA 4079/MUM/2024[2016-17]Status: DisposedITAT Mumbai30 Oct 2024AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Gagan Goyalassessment Year: 2016-17

For Appellant: Shri Sumit Mantri, A.RFor Respondent: Shri G. Santosh Kumar, Sr. AR
Section 142(1)Section 144Section 250Section 36(1)(iii)Section 68

…nder, (2) the capacity of the lender and (3) the genuineness of the transaction. As the Assessee failed to submit even the basic confirmation and therefore relying on various judgments as recorded in the assessment order such as Roshan Di Hatti vs. CIT (1977) 107 ITR 937 (SC)/Kale Khan Mohammad Hanif vs. CIT (1963) 50 ITR 1 (SC) the unsecured loan amounting to Rs.6,26,53,277/- is treated as non genuine and income from undisclosed sources brought into the books under the garb of unsecured loan and added the same as unexplained cash credit u/s 68 of the Act”. 3.1 The AO also made other addition of Rs.79,14,292/- u…

Heritage Hospitals Ltd, New Delhi vs. DCIT, Circle-11(1), New Delhi

ITA 4090/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Oct 2024AY 2014-15

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Anand Kumar Pandey, AdvFor Respondent: Shri Sandeep Kumar Mishra, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 68

…] 208 ITR 465 (Cal.): ♦ Proof of Identity of the creditors; ♦ Capacity of creditors to advance money; and ♦ Genuineness of transaction This Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must conduct an inquiry, and call for more details before invoking Section 68. I…

Samarth Lifestyle Retailing Pvt. Ltd., Jaipur vs. DCIT, Circle-6, Jaipur

In the result, the appeal of the assessee is allowed

ITA 621/JPR/2024[2011-12]Status: DisposedITAT Jaipur17 Oct 2024AY 2011-12
For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Sanjay Nargas, Addl. CIT
Section 143(1)Section 143(3)Section 147Section 148Section 68

…aspects: • Proof of Identity of the creditors, • Capacity of creditors to advance money, and • Genuineness of transaction 8.4 Hon'ble Supreme Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity. genuineness of the transaction, and credit-worthiness, then the AO must conduct an inquiry. and call for more details before invoking Section 68. I…

Swaroop Narain Shiv Narain, Jaipur, Rajasthan vs. ACIT, Central Circle - 3, Jaipur, Rajasthan

ITA 517/JPR/2024[2018-19]Status: DisposedITAT Jaipur17 Oct 2024AY 2018-19
For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115BSection 127Section 143(2)Section 143(3)Section 69Section 69B

…so taxable. If some credit were received from some unexplained source (to pay for purchases) the same itself is taxable. Be that as it may, the onus is on the assesse to explain and substantiate the source. Roshan Di Hatti v. Commissioner of Income-tax [1977] 107 ITR 938 (SC)[08- 03- 1977], Kale Khan Mohammad Hanif v. Commissioner of Income-tax [1963] 50 ITR 1 (SC)[08-02-1963]] Unexplained stock cannot be presumed to be business income. If the assesse claims so, the assesse is required to prove the same. [Hon'ble Supreme Court in the case of Commissioner of Income-tax v. Devi Prasad Vishwanath [1969] 72 ITR 194 (…

Leading Age Developers Private Limited, Mumbai vs. ACIT CC 2(2), Mumbai

In the result, appeal of the assessee in ITA No

ITA 1114/MUM/2024[2011-12]Status: HeardITAT Mumbai17 Oct 2024AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

For Appellant: Shri Vimal Punmiya, CAFor Respondent: Shri Manoj Kumar Sinha, Sr. DR
Section 143Section 143(3)Section 148Section 153ASection 271(1)(c)Section 68

…/[1994]208 ITR 465 (Cal.): Proof of Identity of the creditors; Capacity of creditors to advance money; and Genuineness of transaction This Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit- worthiness, then the AO must conduct an inquiry, and call for more details before invoking Section 68.…

Leading Age Developers Private Limited, Mumbai vs. Central Circle 2(2), Central Building

In the result, appeal of the assessee in ITA No

ITA 1113/MUM/2024[2011-12]Status: DisposedITAT Mumbai17 Oct 2024AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

For Appellant: Shri Vimal Punmiya, CAFor Respondent: Shri Manoj Kumar Sinha, Sr. DR
Section 143Section 143(3)Section 148Section 153ASection 271(1)(c)Section 68

…/[1994]208 ITR 465 (Cal.): Proof of Identity of the creditors; Capacity of creditors to advance money; and Genuineness of transaction This Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit- worthiness, then the AO must conduct an inquiry, and call for more details before invoking Section 68.…

M/S Arrowspace Tradecom Pvt. Ltd., Kolkata vs. ITO, Ward-10(2), Kolkata

In the result, in light of the discussion made above, this appeal is dismissed

ITA 344/KOL/2024[2016-17]Status: DisposedITAT Kolkata16 Oct 2024AY 2016-17

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 234BSection 234DSection 271(1)(c)

…the Hon'ble Apex Court has dealt with the issue from legal perspective and sum of the passages deserve to be extracted for reference: “This Court in the land mark case of Kale Khan Mohammad Hanif v. CIT [1963] 50 ITR 1 (SC) and, Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and creditworthiness, then the Assessing Officer must conduct an inquiry, and call for more details before invoking…