Parallel reassessment and revision proceedings are not barred where recorded reasons show escapement of income.

Reassessment under Section 148 was valid where the Assessing Officer recorded prima facie escapement of income, including issues such as Section 14A disallowance and incorrect Section 80HHC deduction. Pending revisionary proceedings under Section 263 on similar grounds did not bar action under Section 148, because reassessment and revision operate in different fields and the Act contains no prohibition on parallel proceedings. The challenge to the revision notice was also treated as academic where the reassessment had already addressed the escaped income.

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Issues: Whether the Assessing Officer could validly issue notice under Section 148 of the Income-tax Act, 1961 for reopening an assessment when revisionary proceedings under Section 263 of the Income-tax Act, 1961 were pending on similar grounds, and whether such parallel proceedings were barred.

Analysis: The reasons recorded for reopening showed specific prima facie escapement of income, including under-disallowance under Section 14A, incorrect computation of deduction under Section 80HHC, and other items requiring verification. The statutory scheme of Section 147, as applicable to the relevant assessment year, permitted reassessment where the Assessing Officer had reason to believe that income chargeable to tax had escaped assessment. The existence of pending revision proceedings under Section 263 did not denude the Assessing Officer of jurisdiction to proceed under Section 148, because the two provisions operate in different fields and the Act does not prohibit parallel proceedings. The fact that the reassessment had already taken care of the escaped income also rendered the challenge to the revision notice academic.

Conclusion: The notice under Section 148 was upheld and the challenge to the parallel proceedings failed; the Revenue's position was accepted.

Ratio Decidendi: Where reassessment is initiated on recorded reasons showing escapement of income, pendency of revision proceedings under Section 263 on similar issues does not bar the Assessing Officer from exercising jurisdiction under Section 148.

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