Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
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Reopening an income-tax assessment for the identical bank-deposit transaction already investigated and finally adjudicated is impermissible where the subsequent authority relies on the same material; the doctrine Nemo debet bis vexari pro una et eadem causa bars subjecting the assessee to duplicate adjudication. The court reiterates that a notice under section 148 requires "reasons to believe" grounded in tangible material with a nexus to escaped income and cannot be based on mere suspicion or a change of opinion. The reassessment attempt was self conflicting and set aside; the writ petition was allowed, preventing a second assessment on the same subject matter.
Reopening an income-tax assessment for the identical bank-deposit transaction already investigated and finally adjudicated is impermissible where the subsequent authority relies on the same material; the doctrine Nemo debet bis vexari pro una et eadem causa bars subjecting the assessee to duplicate adjudication. The court reiterates that a notice under section 148 requires "reasons to believe" grounded in tangible material with a nexus to escaped income and cannot be based on mere suspicion or a change of opinion. The reassessment attempt was self conflicting and set aside; the writ petition was allowed, preventing a second assessment on the same subject matter.
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