Reassessment notice upheld on material suggesting possible escapement of income; post-amendment Section 148 threshold applied.

A reassessment notice under Section 148 was upheld where the material showed a cash transaction entry linked to the assessee and an admission of a flat purchase from the same group, as this was sufficient at the threshold to indicate possible escapement of income. The Court clarified that, after 01.04.2021, Section 148 does not require recording reasons to believe in the pre-amendment sense or possession of information or evidence in that form. The notice was therefore not void for want of jurisdiction, and the assessee was left to contest the factual nexus and basis of the material before the authority in accordance with law.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 was jurisdiction or otherwise void, and whether the material relied upon by the Assessing Officer was sufficient to justify initiation of reassessment proceedings.

Analysis: The notice was founded on material indicating a cash transaction entry linked to the petitioner, and the petitioner had also admitted purchasing a flat from the same group. The Court held that this material was sufficient to infer escapement of income for the relevant assessment year. It further noted that after 01.04.2021, Section 148 does not require recording of reasons to believe in the pre-amendment sense, nor possession of information or evidence in that form. The petitioner remained at liberty to explain before the authority that the basis was erroneous or that there was no nexus with the amount reflected in the material.

Conclusion: The notice under Section 148 was held to be valid and not void for want of jurisdiction.

Final Conclusion: The writ petition challenging the reassessment notice failed, and the petitioner was left to pursue her objections before the respondents in accordance with law.

Ratio Decidendi: Post-01.04.2021, a reassessment notice under Section 148 of the Income-tax Act, 1961 can be sustained on material indicating possible escapement of income, and the notice will not be invalid merely because the assessee disputes the nexus or sufficiency of that material at the threshold.

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