Reassessment notice clarity under income tax law upheld where the statutory references were clear and no real ambiguity existed.

Reassessment notices under section 148 of the Income-tax Act are not invalid merely because they refer to the previous year and corresponding assessment year in the statutory formula, where the meaning is clear on its face and there is no real ambiguity. The Bombay High Court noted that a person familiar with income-tax law would understand the notices, and the assessee's filing of returns pursuant to them further supported clarity. On that basis, the notices were held valid and the reassessment proceedings were not bad in law or void.

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Issues: Whether reassessment proceedings initiated under section 148 of the Income-tax Act, 1961 were bad in law and void on account of ambiguity in the notices.

Analysis: The notices referred to the assessee's previous year and the corresponding assessment year in a manner that was clear to a person familiar with income-tax law. The Court held that there was no real ambiguity in the notices, especially since the assessee had also filed returns pursuant to them.

Conclusion: The notices were not invalid, and the reassessment proceedings were not bad in law or void.

Ratio Decidendi: A notice for reassessment is not invalid merely because it uses the previous year and assessment year in the statutory formula, if the meaning is clear on its face and no real ambiguity exists.

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