Reopening of assessment under the income tax code was challenged...

Reopening of assessment under the income tax code was challenged on the ground that the reasons recorded relied solely on the claim of interest deduction made without a certificate. The court held that validity of reassessment must be tested only by the reasons recorded; material asserted only in an affidavit cannot supply a basis. The absence of a certificate was not a valid ground where statutes did not require filing it in the assessed facts, and precedent distinguishing cases where expenditure related to taxfree income was disallowable was applied. Consequence: reassessment jurisdiction was invalidated and the appeal by the assessee allowed.