In the result, appeal of the Assessee is allowed
Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)
reassessment would have to be based on the formation of an opinion that income chargeable to tax has escaped assessment. That primordial condition would clearly not be satisfied on the mere allegation of a delayed digital filing of Form 10. 29. Quite apart from the above, we also bear in mind the underlying intent of Section 11(2