Pre-reassessment procedure requires the Assessing Officer to...

Pre-reassessment procedure requires the Assessing Officer to issue a show-cause notice, consider the taxpayer's reply and form only a prima facie view that income has escaped assessment. Absence of an oral hearing at that preliminary stage does not by itself invalidate the pre-reassessment order or consequential reassessment notice where a substantive opportunity remains available during reassessment. Information concerning unsecured loans and cash deposits may be considered collectively where intrinsically connected to the alleged escaped income; the genuineness of the loan is to be examined in reassessment. The reassessment must provide a meaningful personal hearing and consider further documents and explanations, with merits left open.