Recorded reasons must show a real reason to believe before reassessment; conjectural reopening cannot confer jurisdiction.

Reassessment under sections 147 and 148 is valid only where the Assessing Officer's recorded reasons clearly and unambiguously show a real reason to believe that income chargeable to tax has escaped assessment. Those reasons must stand on their own and cannot be improved, substituted, or supplemented by later explanations or oral submissions. On the facts, the recorded reasons were based on conjecture and did not disclose tangible material establishing escapement of income, so the reopening lacked jurisdiction. The reassessment proceedings were therefore quashed, and the Revenue's appeals failed.

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Issues: Whether the reassessment notices issued under section 148 were valid when the recorded reasons did not disclose a proper reason to believe that income chargeable to tax had escaped assessment.

Analysis: Reopening of an assessment under section 147 must be founded on the Assessing Officer's recorded reasons, which must clearly and unambiguously disclose the jurisdictional basis for the belief that income chargeable to tax has escaped assessment. Those reasons have to be read as recorded, and they cannot be improved upon, substituted, or supplemented by oral submissions or later explanations. On a strict reading, the recorded reasons here proceeded on conjecture and did not show tangible material establishing escapement of income; they also could not be rescued by the Revenue's attempt to treat the wording as a mistake and recast the basis for reopening.

Conclusion: The reassessment proceedings were rightly quashed, and the Revenue's appeals failed.

Ratio Decidendi: Jurisdiction to reopen an assessment under sections 147 and 148 arises only from clear and unambiguous recorded reasons showing a real reason to believe, and such reasons cannot be substituted, supplemented, or read differently to confer jurisdiction.

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