Reassessment jurisdiction requires recorded, bona fide belief based on relevant material; bare assertion is insufficient.

Reassessment under section 34(1)(a) of the Indian Income-tax Act, 1922 could be initiated only where the Income-tax Officer had reason to believe both that income had escaped assessment and that the escapement resulted from the assessee's failure to disclose fully and truly all material facts. That belief had to rest on relevant material, with a rational connection to the recorded reasons; a bare assertion of belief was not enough. Because the officer produced no affidavit and the reasons, report to the Commissioner, and sanction were not shown, the jurisdictional basis for the notices was not established, and the reassessment notices were held without jurisdiction and quashed.

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Issues: Whether the Income-tax Officer had jurisdiction to initiate reassessment proceedings under section 34(1)(a) of the Indian Income-tax Act, 1922 on the basis of a valid belief that income had escaped assessment by reason of the assessee's failure to disclose fully and truly all material facts.

Analysis: The statutory power under section 34(1)(a) could be exercised only if the Income-tax Officer had reason to believe both that income had escaped assessment and that such escapement was attributable to the assessee's omission or failure to disclose material facts. The existence of belief could be challenged, and the court could examine whether the reasons had a rational connection with the formation of that belief and were not extraneous or irrelevant. On the facts, the officer who issued the notices did not file an affidavit, and the record of the reasons recorded, the report to the Commissioner, and the Commissioner's sanction were not produced. In the absence of material showing the basis for the belief, the jurisdictional foundation for the notices was not established.

Conclusion: The reassessment notices were without jurisdiction and were quashed, in favour of the assessee.

Ratio Decidendi: Reassessment under section 34(1)(a) cannot be sustained unless the record shows a bona fide belief founded on relevant material that escaped assessment resulted from non-disclosure of primary facts; mere assertion of belief without support from the record is insufficient to confer jurisdiction.

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