Independent satisfaction for reassessment is mandatory; a mere office note cannot substitute the officer's belief.

Reassessment under section 147 read with section 148 requires the Income-tax Officer to independently form a belief, on relevant material, that income has escaped assessment before issuing notice. An appellate authority's office note asking the officer to examine the possibility of reassessment does not by itself satisfy that statutory precondition, and cannot replace the officer's own recorded satisfaction. As no independent inquiry or proper formation of belief was shown, the reassessment jurisdiction was not validly invoked and the reassessment was annulled.

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Issues: Whether reassessment proceedings under section 147 read with section 148 of the Income-tax Act, 1961 were validly initiated on the basis of the appellate authority's office note without the Income-tax Officer independently satisfying himself that income had escaped assessment.

Analysis: The reopening was founded only on the appellate authority's note asking the Income-tax Officer to examine the possibility of reassessment. The recorded reasons did not show that the Income-tax Officer had independently formed the requisite belief on the basis of material that income had escaped assessment. The note did not amount to a clear direction to reopen, nor could it substitute the statutory requirement that the Income-tax Officer must himself be satisfied before issuing notice. Since no independent inquiry or proper formation of belief was shown, the statutory condition precedent for invoking reassessment jurisdiction was not met.

Conclusion: The reassessment proceedings were invalidly initiated and the annulment of the reassessment was made. The appeal failed.

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