Mere Suspicion cannot be a Ground for Issuance of Notice u/s 148 of the Income Tax Act: ITAT

The ITAT held that a mere suspicion cannot justify the issuance of a notice under Section 148 of the Income Tax Act. It emphasized that there must be tangible material for reopening assessments. The case highlighted the necessity for the Assessing Officer to apply due diligence and have sufficient grounds before initiating reassessment proceedings. This decision underscores the importance of complying with procedural fairness and legal standards in tax matters.