Reassessment jurisdiction fails when reopening rests only on reversed excise findings and no independent material supports the belief.

Reassessment under sections 147 and 148 was invalid because the Assessing Officer relied only on excise anti-evasion findings alleging suppressed sales, and those findings had later been reversed in the assessee's own case. Without independent material on record, the statutory condition of "reason to believe" was not met, as the belief must have a rational nexus with escapement of income. Once the sole foundation for reopening disappeared, the jurisdictional basis for reassessment failed, and the reopening was rightly quashed.

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Issues: Whether reopening of assessment under sections 147 and 148 of the Income-tax Act, 1961 was valid when it was based on findings of the excise authorities that were later reversed and no independent material was brought on record.

Analysis: The reassessment was founded on the Anti-Evasion findings of the Central Excise authorities concerning alleged suppressed sales. Those findings had subsequently been rejected in the assessee's own case by the appellate excise forum. The reopening, therefore, lacked a live and sustainable foundation. For reassessment, the Assessing Officer must have reason to believe that income chargeable to tax has escaped assessment, and such belief must rest on material having a rational nexus with the formation of that belief. Where the sole for reopening disappears and no independent material supports the belief, the jurisdictional condition for reassessment is not satisfied.

Conclusion: The reopening under sections 147 and 148 was invalid and was rightly quashed.

Ratio Decidendi: Reassessment cannot be sustained unless the Assessing Officer's reason to believe is based on independent, relevant material having a direct nexus with escapement of income; if the sole foundation for reopening fails, the reassessment is void.

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