Reassessment validity upheld where survey and search material supported reopening and no contrary evidence was produced.

Reassessment under sections 147 and 148 was upheld where survey and search material, including the director's statement and impounded sales bills, provided the basis for reopening. The assessee failed to appear before the Tribunal and, in the ex parte hearing, produced no material to dislodge the findings of the lower authorities or show that the reopening lacked foundation. On that record, the reassessment proceedings were treated as valid and no interference was called for with the appellate order.

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Issues: Whether the reassessment proceedings under sections 147 and 148 of the Income-tax Act, 1961 were valid and whether the assessee had shown any ground to interfere with the appellate order.

Analysis: The assessee did not appear before the Tribunal and the appeal was heard ex parte under Rule 24 of the Income-Tax (Appellate Tribunal) Rules, 1963. The record showed material gathered during survey and search proceedings, including the director's statement and impounded sales bills, which formed the basis for reopening. The assessee did not bring any material to dislodge the findings of the lower authorities or to establish that the reassessment was without basis.

Conclusion: The reassessment proceedings were held to be valid and no interference was called for.

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