Reassessment notice validity turns on relevant material for bona fide belief, not the sufficiency of evidence in writ review.

Reopening notices under the Income-tax Act are sustainable where the assessing officer has relevant material to form a bona fide belief that income escaped assessment because primary facts were not fully and truly disclosed. The court's role in writ proceedings is limited to checking the existence of such material, not its sufficiency. The document also notes that a delayed writ challenge, coupled with repeated extensions and adjournments sought by the assessee, can weigh against exercise of writ jurisdiction.

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Issues: Whether the notices issued for reopening the assessments under section 34 of the Income-tax Act were without jurisdiction for want of material to believe that income had escaped assessment because of non-disclosure of primary facts, and whether the writ petitions should be entertained despite delay and the petitioner's conduct.

Analysis: The record showed that the assessing officer had scrutinised the books of account in later assessment proceedings, noticed defects in cash records, stock positions, valuation of closing stock, and inflation of expenses, and had reported those matters to the Commissioner before obtaining sanction to issue the notices. These circumstances furnished relevant material for the formation of a bona fide belief that income had escaped assessment through failure to disclose fully and truly all material facts. The court held that it was concerned only with the existence of material supporting the belief, not with the sufficiency of that material. The writ petitions were also filed long after the notices, after the petitioner had sought repeated extensions and adjournments, which weighed against the exercise of writ jurisdiction.

Conclusion: The reopening notices were validly issued within jurisdiction and the challenge failed.

Final Conclusion: The assessee was not entitled to writ relief, and the assessment-reopening proceedings were sustained.

Ratio Decidendi: For reopening under section 34, the Income-tax Officer need only possess some relevant material forming a reasonable belief of non-disclosure of primary facts and escapement of income; the court will not examine the sufficiency of that material in writ proceedings.

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