https://www.taxtmi.com/caselaws?id=63121 Reassessment under section 147(a) may be initiated where the Assessing Officer has a bona fide reason to believe that income escaped assessment because material facts were not fully and truly disclosed; the sufficiency of the recorded reasons is not examined at the initiation stage, and customs material may provide the requisite basis. An addition under section 69A, however, requires affirmative proof that the assessee owned unexplained money, bullion, jewellery or other valuable article. Where the gold was not recovered from the assessee, customs statements were not available for effective cross-examination, the assessee's evidence remained unrebutted, and the customs penalty order had been set aside, ownership was not established and the addition could not survive. en-us Thu, 31 Jan 1985 00:00:00 +0530 Thu, 27 Jan 2011 18:46:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63121 Reassessment under section 147(a) may be initiated where the Assessing Officer has a bona fide reason to believe that income escaped assessment because material facts were not fully and truly disclosed; the sufficiency of the recorded reasons is not examined at the initiation stage, and customs material may provide the requisite basis. An addition under section 69A, however, requires affirmative proof that the assessee owned unexplained money, bullion, jewellery or other valuable article. Where the gold was not recovered from the assessee, customs statements were not available for effective cross-examination, the assessee's evidence remained unrebutted, and the customs penalty order had been set aside, ownership was not established and the addition could not survive. Case-Laws Income Tax Thu, 31 Jan 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63121